TravelClick Job Applicant Privacy Notice
Last updated: March 2019
This privacy notice sets out how TravelClick, Inc. and any of our related affiliates and subsidiaries worldwide (collectively, “TravelClick” or “we“) use and protect your personal data in accordance with current data protection law.
Data We Collect
If you apply for a job with us, we will collect, use and store personal data about you. To the extent permitted by law, this may include:
Data you provide to us:
- contact details (name, address, phone numbers, email, etc.);
- qualification details (such as resume, CV, cover letter, work experience, education, transcripts);
- application information (such as expected income, type of job wanted, availability, references);
- identification details (such as passport number, nationality and residence, government ID numbers (e.g. Social Security Number), immigration status; and
- any other data you submit to us, including any correspondence between you and TravelClick exchanged during the application process.
Data from other sources: we may also obtain data about you from other sources, such as recruiters, market research companies, identity verification providers and information accessible on the Internet and third-party websites, including LinkedIn. If you have consented to background checks and/or where permitted by law, we may also collect details of professional registrations, sanctions with professional bodies, financial checks or criminal convictions.
Purposes and Legal Basis
TravelClick may access, use and store your personal data for the reasons set out below:
- Where this is necessary for TravelClick to review and assess your application for employment including:
- assessing your skills and interest in career opportunities at TravelClick;
- processing your application,
- analysing your qualifications,
- verifying your identity and your eligibility for employment; and
- communicating with you about your application, to respond to your inquiries and schedule interviews.
- Where necessary for TravelClick’s legitimate interests, as listed below, and where our interests are not overridden by your data protection rights, including:
- protecting our legitimate business interests and legal rights, such as use in connection with legal claims, compliance, regulatory, auditing, investigative and disciplinary purposes (including disclosure of such information in connection with legal process or litigation) and other ethics and compliance reporting requirements; and
- maintaining the security and integrity of our facilities, equipment and electronic platforms, such as administering access rights, monitoring compliance with company protocols, and where permitted by local law and in accordance with relevant policies, for investigations and disciplinary actions.
- Where necessary to comply with a legal obligation.
- Disclosures to law enforcement agencies or in connection with legal claims, or regulatory purposes (including disclosure of such information in connection with legal process or litigation).
- Where you have given consent.
- For example, we may ask for your permission to conduct a criminal background check.
Disclosure to Third Parties
Where necessary for business purposes, we may share personal data between TravelClick group companies and employees in additional locations (locations including in the United States, European Union, Singapore and Australia).
Personal information may be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the protection of TravelClick’s legitimate interests in compliance with applicable laws.
Personal data may also be shared with third party service providers who will process it on behalf of TravelClick for the purposes above.
In the event that TravelClick is sold or integrated with another business, your details may be disclosed to TravelClick advisers and any prospective purchaser and their advisers and will be passed to the new owners of the business.
Retention of Your Data
We will retain your personal data in a form that identifies you for no longer than is necessary for the purposes needed for the application, except where required by law. If your application is successful, the information provided may be retained for purposes of your employment. If it is not successful, we will retain your personal information for a reasonable time so that we can consider you for other positions that may be of interest to you, unless you indicated that you do not wish for this to happen (and there is no legal obligation to retain such personal information). Applications and Personal Information will be retained in accordance with the policies and requirements of the position’s jurisdiction. For example, applications and information of EU persons applying for a position in the U.S. will be subject to U.S. data retention policies.
Your Choices and Rights
For Applicants within the European Union
If you wish to access your personal data you should contact Karen Sanchez, HR & Recruiting Compliance Specialist at GDPRrequests@travelclick.com. You have the right to ask TravelClick to rectify, block or restrict access to, complete and delete your personal data. You can also ‘port’ your personal data (that is, to ask us to provide it to you in a structured, commonly used and machine-readable format and to transmit it directly to another organisation). You have the right to request further information about the handling of your personal data. In some circumstances you can also object to us processing of your data and, where we have asked for consent to process your data, you may be able to withdraw this consent.
All requests will be dealt with at the earliest opportunity and any delay will be kept to a minimum. In any event, we will not exceed the statutory time limit.
However, there are exceptions to these rights. For example, access to personal data may be denied in some circumstances if making the information available would reveal personal information about another person or if TravelClick are legally prevented from disclosing such information. In addition, TravelClick may be able to retain data even if you withdraw your consent, where TravelClick can demonstrate that it has a legal requirement to process your data. We will inform you of relevant exemptions we rely upon when responding to any request you make.
If you have unresolved concerns, you have the right to complain to a data protection authority in the country where you live, where you work or where you consider that a breach of data protection has occurred.
We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests. You can obtain information on any of our balancing tests by contacting us using the contact details set out below.
Transfer outside EEA
We operate globally, so we do need to transfer your personal data internationally. In particular, your personal data will be transferred to and processed in the United States and Spain.
When transferring personal data to countries outside the EEA, we comply with European Union law by using Standard Contractual Clauses approved by the European Commission or by adopting other adequate safeguards (including where relevant transfers to a recipient with an appropriate Privacy Shield certification). A copy of the relevant transfer mechanism can be provided for your review on request to the GDPRrequests@travelclick.com.
Updates to this Privacy Notice
This privacy notice may be updated periodically to reflect changes in our data practices. We will post a notice on our applicable websites, applications or materials to advise of any significant changes to our Privacy Notice and indicate in the notice when it was most recently updated.
The data controller for your personal data is TravelClick, Inc. If you have a privacy question, concern or request, please contact us using the contact details below: GDPRrequests@travelclick.com.