Privacy Statement

The commitments in this Privacy Statement apply to all personal data we process during the recruitment process for job applicants. 

1. Introduction

At Cawthron, we take the privacy of our job applicants seriously. When you apply for, or express interest in, a role with us, you may share personal data with us in some manner. The purpose of this Privacy Statement is to be upfront about the data we collect, how we use it, who we share it with, and how you can exercise your privacy rights.

For the purposes of this privacy statement:

• Personal data means any information relating to an identified or identifiable individual, which may be a potential employee including information provided about other individuals such as references or emergency contacts.

2.  Who is responsible for your personal data?

Cawthron are the controllers of all personal data within the scope of this privacy statement.

3. Purposes where we may process your personal data?

3.1 Answering your questions:

If you get in touch with us in relation to a vacancy, we’ll use your personal data in order to reply and answer your question(s). We may also record questions you may have asked, and answers our team have provided, throughout the course of any recruitment process you have engaged in with us for monitoring and record-keeping purposes. For this purpose, we process your name, contact details, your correspondence with us and all other personal data necessary to answer your question.

3.2 Recruitment and selection:

If you’ve shown interest in a position at Cawthron, we store your personal data on our recruitment system and/or associated systems. We use this data to communicate with you and determine whether your qualifications and professional profile meet the requirements of the vacancy you have applied for. We may also use this information to let you know about other opportunities with us or invite you to participate in recruitment activities or events.

Personal data can include your contact details, experience and qualification information (such as your CV/resume, employment history, references, visa status/right to work, education history etc.) and correspondence you’ve had with us about job applications.

We process your personal data on the basis of your consent and/or for the purpose of potentially joining our team. We may also rely on third parties (e.g. recruitment agencies, background checking, your nominated references and immigration agencies) to provide such data and proceed on the basis that they have your consent or another legal basis to collect, process and pass that data to us. If they do not have a legal basis for processing personal data, they must anonymise it.

3.3 Requesting pre-employment checks and employment agreements:

Before you are offered a position at Cawthron as an employee, we’ll use your personal data to initiate employment processes such as requesting pre-employment/engagement checks and, where applicable, assessments and if successful, providing an employment agreement. We’ll tell you which checks are relevant to your role before they are conducted. You can refuse to allow us to conduct checks, but this may affect our ability to offer you a role with Cawthron.

If you are employed or engaged by us, we’ll continue to store your personal data in our People and Capability systems to support employment processes and the management of your employment throughout your time with Cawthron.  Such storage will be in accordance with statutory requirements and our policies.

For this purpose, we process your personal data, which may include contact details, date of birth, gender, nationality, ethnicity, ID card or passport details, employment status, experience and qualification information (such as employment history, education history etc), results of background checks, visa/work permit details, other licensing, availability, tax details, emergency contacts, references, payment and salary details including those related to insurance, and details about your location.

Following your selection, we may provide certain information to immigration and taxation agencies as required by law to monitor our compliance with relevant immigration and taxation laws.

3.4  We also collect and process your personal data based on:

• Cawthron’s legitimate business interests, for example, fraud prevention, maintaining the security of our data and systems, and improving our recruitment services.
• Compliance with mandatory legal obligations, including for example accounting and tax requirements, and procedures required by law.
• Your consent. In these situations, you can withdraw your consent at any time, and when you give your consent, you will be given details on how to notify us when you change your mind.

3.5  How we collect your personal data:

• Through your correspondence with us, such as a note  of a call you make to any of our employees or recruitment team, an email or letter sent, or other records of any contact or correspondence with us (including any correspondence via another third party platform, for example, a job seeker website).
• If you physically visit our premises, we may collect information about you as part of our security measures. We may also collect your name and contact details and, where applicable, car registration for security and health and safety purposes, and your visiting history to our premises.
• From information we obtain from other sources, such as recruitment agencies and other third parties that may relate to your interactions with us. 

4. Who has access to your Personal Data?

4.1 Within Cawthron

• Only those Cawthron staff members or agents acting on our behalf that are involved in the recruitment process(es) you are involved in will have access to your personal data.  Such access will only be to the extent necessary to fulfill their respective tasks. These staff members and agents are, for example, our People and Capability Team, and the relevant hiring managers and interview panels.
• Your personal data may be accessed by other relevant departments such as Technology Support but only to the extent necessary to perform their jobs in relation to onboarding as an employee.

4.2 External parties

• We may use third parties to support our recruitment process. These include but are not limited to recruitment agencies, background checking agencies, and INZ VisaView. These third parties may have access to or request, your personal data when relevant to ensure that we can complete our recruitment process.
• When external parties are given access to your personal data, we will take the required measures to ensure that they agree to process your personal data only to the extent that it is necessary, and in compliance with applicable law.
• We will only provide your personal data to regulatory bodies, tax authorities and/or investigating authorities if obliged to do so by law or regulation, or if you have provided instructions to us to allow this information to be disclosed.
• If you provide us with false information, such as a false visa or qualification, we may choose to share this information with legal/regulatory authorities or the relevant educational institution.

4.3 Transfer of your personal data

We may need to transfer your information to other internal and external service providers, including those in other countries. We will take measures to ensure that your personal data is adequately protected during any transfer and is handled in accordance with this statement. 

4.4 Processing of your personal data by data processors

When an external party processes your personal data following our instructions, solely on our behalf, it acts as a data processor. Examples include a data cloud company that provides a platform for payroll or recruitment-related activities where personal data is processed. We enter into an agreement with data processors concerning the processing of personal data which includes obligations to safeguard your personal data so that it is provided solely to the data processor for the purposes of providing services to us and processed in accordance with this statement.

5. How is your personal data secured?

We make reasonable efforts to secure our systems and ensure your personal data is protected from misuse and loss and from unauthorised access, modification, or disclosure. We may hold your information in either electronic or hard copy form. As our website is linked to the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online. We also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.

6. How long will we retain your personal data?

We will keep your personal data for as long as it is required for the purpose it was provided, taking into account our need to answer queries or resolve problems, provide services, and comply with legal requirements. This means we may retain your personal data for a reasonable period after your last interaction with us. When the personal data that we have is no longer required or is not required to be retained by law, we will destroy, delete or permanently anonymise it.

7. How can you exercise your Privacy Rights?

You have the right to request access to your personal data, and in some circumstances, rectification and/or erasure of personal data. You may also have the right to restrict processing of your personal data, or to object to data processing or portability. If you have given your consent for us to process data for a certain purpose, you can withdraw your consent at any time (although not retrospectively – your withdrawal will be valid from the date of withdrawal rather than from the date of consent was given). It is also important to us that the personal data we hold is accurate, complete and current.

If you’re a registered user of our recruitment system you may log in to your account and update your personal data. If this is not possible you can contact us via https://www.cawthron.org.nz/contact/ to exercise your rights or update your personal data. Please note that we may need to ask for additional information to verify your identity before doing so.