BAP Pharma Recruitment Privacy Notice
- At-A-Glance Overview – BAP Pharma Recruitment Privacy Notice
- Full BAP Pharma Recruitment Privacy Notice
- Introduction
- The controller of your Personal Data
- The Personal Data we collect about you
- How we collect your Personal Data
- How we use your Personal Data
- How we use particularly sensitive Personal Data
- Automated decision making
- How long we keep your Personal Data
- The recipients of your Personal Data
- International transfers of your Personal Data
- How we protect your Personal Data
- Your rights regarding your Personal Data
- Our responsibility regarding websites and applications that we do not own or control
- Updates to this Privacy Notice
- Contact Us
At-A-Glance Overview – BAP Pharma Recruitment Privacy Notice
Who Controls Your Data?
BAP Pharma controls your personal data. They comply with data protection laws like GDPR.
What Personal Data is Collected?
- Basic Information: Name, age, gender, contact details.
- Recruitment Information: CV, work experience, qualifications, and interview notes.
- National Identifiers: ID, passport, or work permit.
- Financial Information: Salary details.
- Special Data: Health, ethnicity, or criminal record (only if required).
How is Your Data Collected?
- Your job application or interviews.
- Your interactions with HR or recruitment agencies.
- Background checks or references (if needed for the role).
How is Your Data Used?
- Evaluate application*: Review qualifications, background checks, and references.
- Communicate*: Contact you about the recruitment process.
- Legal Requirements: Check eligibility to work and comply with health or tax laws.
- Equal Opportunities: Where it is in the public interest, or required by law.
- Health and Safety: Monitoring your health and vital interests, if necessary.
* required to enter into a contract with BAP Pharma
Who Has Access to Your Data?
- Hiring manager and HR.
- Government or regulatory authorities when required by law.
- Service providers like payroll processors or pension providers.
International Data Transfers
Your data may be sent to countries outside your own. BAP Pharma ensures your data is protected no matter where it goes, by entering into standard contractual clauses as needed.
How Long is Your Data Kept?
BAP Pharma keeps your data for up to 12 months after your application. This allows them to handle legal claims or invite you to apply for future roles. After this, your data is securely deleted.
Your Data Rights
- Access your data.
- Correct inaccurate information.
- Delete your data in certain cases.
- Limit or object to how your data is used.
- Withdraw consent if you gave it for processing your data.
If you have any concerns or want to exercise your data rights, contact BAP Pharma’s Data Protection Officer (DPO) at [email protected], or you can lodge a complaint with the ICO or the supervisory authority in your country.
Full BAP Pharma Recruitment Privacy Notice
Introduction
Thank you for your interest in BAP Pharma (including BAP Pharma Limited, BAP Pharma GmbH, and BAP US, Inc., referred to as “BAP Pharma”, “We, “Our” or “Us”). We are committed to protecting the privacy and security of your Personal Data.
This Privacy Notice is intended for successful and unsuccessful BAP Pharma recruitment candidates, regardless of location.
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing Personal Data about you, so that you are aware of how and why we are using such information.
You have been directed to or otherwise sent a copy of this privacy notice because you are applying for work with us (whether as an employee, worker or contractor). This notice makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment exercise, and how long it will usually be retained for. It provides you with certain information that must be provided under Data Protection Legislation and explains how your Personal Data will be processed.
Personal Data means any information or piece of information which could identify you either directly (e.g. your name) or indirectly (e.g. a unique ID number).
If anything in this Privacy Notice conflicts with local law in your
jurisdiction, local law prevails.
The controller of your Personal Data
BAP Pharma are the Data Controller for the Personal Data that we process about you during recruitment process.
Where data is processed by a controller or processor established in the European Union or comprises the data of people in the European Union, the Data Protection Legislation means the General Data Protection Regulation (Regulation (EU) 2016/679) (‘EU GDPR’). This includes any replacement legislation coming into effect from time to time. Depending on your location, additional legislation might also apply.
In the UK, Data Protection Legislation means the Data Protection Act 2018 (‘DPA 2018’), United Kingdom General Data Protection Regulation (‘UK GDPR’), the Privacy and Electronic Communications (EC Directive) Regulations 2003 (‘PECR’) and any legislation implemented in connection with the legislation mentioned above.
We have appointed a Data Protection Officer (DPO) to help us monitor internal compliance, inform and advise on data protection obligations, and act as a point of contact for data subjects and supervisory authorities. To locate the relevant contact details, please see the Contact Us section below.
The Personal Data we collect about you
| Personal Data Category | Personal Data |
| Basic information | Your name (including prefix or title), gender, civil status, age and date of birth |
| Contact information | Any information you provide to us that allows us to contact you, e.g. your personal or business email address, personal or business mailing address, personal or business telephone numbers, emergency contact information |
| National identifiers | Your national ID, passport details, driving licence details, residency and work permit status, national insurance number, or other taxpayer/government identification number |
| Recruitment information | Information related to your education, work experience, references, and referees. Information relating to education and academic achievements as well as professional qualifications. Information contained in application forms and resumes, such as education, professional qualifications, languages and other relevant skills. Information as a result of background checks (including credit checks and criminal record checks, where applicable). Information relating to interviews, including notes, audiovisual recordings, etc. |
| Financial information | Your salary, pension, stock options, stock grants and other awards, effective date of current compensation, salary reviews, bank details and bank account number, retirement account information, company allowances, bonus, benefits, insurance details |
| Dependant information | Information related to your dependants, e.g. the first and last names, dates of birth, and contact details of your spouse/partner, children, next of kin, and any other dependants |
| Expenses information | Information included in your expense reports and information needed by BAP Pharma to process such reports according to its policies, e.g. places you have been to for business, invoices, car licence plate number |
| Audiovisual recordings | We may collect photographs, video and audio recordings of you, e.g., recording videoconference meetings, or when you upload or share your photographs and videos for recruitment purposes |
| Infrastructure interactions | Information generated by BAP Pharma to enable the use of our IT assets, products, systems, networks and communication channels. Information related to your use of our IT assets, products, systems, network services and communication channels, such as laptops, desktops, tablets and mobiles issued by us, Internet/Website use and access, corporate email, or provided tools or applications |
| Opinions | Information you provide when you participate in our surveys or conversation channels |
| Special Category Personal Data | Information related to your:
|
| Criminal Convictions and Offences Data | Information related to your unspent criminal convictions and offences. |
You can decide whether to give us special categories of information if we ask you for them. If you decide not to share these with us, please be assured this does not affect your application.
You can also choose not to give us the other types of Personal Data when we ask you for them. If you decide not to give us your Personal Data, we may not be able to assess or consider your application.
If you give us the Personal Data of another person, e.g. your spouse/partner or referees, we assume you have their permission to share their data with us.
How we collect your Personal Data
We collect your Personal Data when you:
- Apply for a job at BAP Pharma and participate in our recruitment process;
- Interact with our Human Resources team;
- Sign up to receive open job posts;
- Otherwise provide it to us.
We will also collect your information through:
- Recruitment agencies;
- Background checks, credit checks, and other pre-employment check providers;
- Credit reference agencies;
- Your named referees; and,
- Social media platforms (such as LinkedIn) or other publicly available sources.
How we use your Personal Data
| Personal Data Category | Lawful Basis | Purpose |
|
Our Legitimate Interest in recruiting talent
GDPR, Article 6(1)(f) |
Recruitment
For recruitment purposes, including, but not limited to: suitability reviews (applications, CVs, interviews); maintaining recruitment records; screening, background checks, credit checks, and criminal record checks; and, sourcing references, where applicable. |
|
Contractual Obligation
GDPR, Article 6(1)(b) |
Successful Recruitment
For successful recruitment purposes, including, but not limited to: verification of identification documentation; collecting personal, financial, and health information to prepare for your forthcoming employment. |
|
Contractual Obligation
GDPR, Article 6(1)(b) |
Communication
Communicating with you and facilitate your communication with others. |
|
Legal Obligation
GDPR, Article 6(1)(c) |
Legal Obligations
For the purposes of complying with legal, regulatory and other requirements, including, but not limited to: checking Right to Work documentation; reviewing vehicular insurance and associated documentation; complying with local employment, social security and occupational health laws and regulations; record-keeping and reporting obligations; and, complying with government inspections and other requests from government or other public authorities. |
|
Vital Interest
GDPR, Article 6(1)(d) |
Vital Interest
Monitor your health in order to safeguard and protect you, or to act in your vital interest, or the vital interest of a third party. |
|
Our Legitimate Interest in maintaining a candidate pool
GDPR, Article 6(1)(f) |
Retaining Unsuccessful Candidate Data
Retaining your candidate information in order to potentially invite you to apply for a similar role in the future. |
|
Legal Obligation
GDPR, Article 6(1)(c) |
Equal Opportunity Monitoring (Germany)
Where you are applying to BAP Pharma GmbH, we are obligated to request that you provide us with information about your health (specifically, about your disability status) in order to comply with our obligations to employ severely disabled persons. You are under no obligation to provide this information. |
|
Public Interest
GDPR, Article 6(1)(e) |
Equal Opportunity Monitoring (UK; US)
Where you are applying to BAP Pharma Limited or BAP US, Inc., we may use information about your ethnicity, religious or philosophical beliefs, health data (including any disabilities), or sexual orientation, for equal opportunity monitoring and reporting purposes. You can opt out of equal opportunity monitoring at any time by using the contact details provided in the Contact Us section below. |
If you fail to provide information when requested, which is necessary for us to consider your application, we will not be able to process your application successfully. For example, if we require references for this role and you fail to provide us with relevant details, we will not be able to take your application further.
How we use particularly sensitive Personal Data
Special Category Personal Data
| Special Category Personal Data | Condition for Processing | Purpose |
|
Employment Law GDPR, Article 9(2)(b) |
Reasonable Adjustments
We may use information about your health or disability status to consider whether we need to provide reasonable adjustments to your recruitment or interview process (e.g., if you are disabled). |
|
Vital Interest GDPR, Article 9(2)(c) |
Vital Interest
To act in your vital interest, or the vital interest of a third party. |
|
Employment Law GDPR, Article 9(2)(b)Bundesdatenschutzgesetz / Federal Data Protection Act (BDSG), Part 2, Chapter 1, Sub-chapter 2, Section 26(3)Sozialgesetzbuch Neuntes Buch – Rehabilitation und Teilhabe von Menschen mit Behinderungen / Ninth Book of the Code of Social Law – Rehabilitation and Participation of Persons with Disabilities (SGB IX), Part 3, Chapter 2, Section 154 |
Equal Opportunity Monitoring (Germany)
We may request to process information about your health data (specifically, about your disability status) in order to comply with our obligations to employ severely disabled persons. You are under no obligation to provide this information. You can opt out of equal opportunity monitoring at any time by using the contact details provided in the Contact Us section below. |
|
Substantial Public Interest GDPR, Article 9(2)(g)Equality of opportunity or treatment Data Protection Act 2018 Schedule 1, Paragraph 8 |
Equal Opportunity Monitoring (UK)
We may use information about your ethnicity, religious or philosophical beliefs, health data (including any disabilities), or sexual orientation, for equal opportunity monitoring and reporting purposes, in accordance with applicable law or best practice. You can opt out of equal opportunity monitoring at any time by using the contact details provided in the Contact Us section below. |
Criminal convictions and offences data
Depending on the jurisdiction in which you operate and on your specific role, we may collect information about your criminal convictions and offences if we offer you a position with us and you accept (conditional on checks and any other conditions, such as references, being satisfactory). We do this to satisfy ourselves that there is nothing in your criminal convictions and offences history which makes you unsuitable for the role. Our roles require a high degree of trust and integrity, and it is therefore best practice to undertake such checks and a pre-requisite in some instances. Should you not agree to undertake or complete this check, or BAP Pharma subsequently receives results which would indicate that it may not be appropriate to continue your application or employment, BAP reserves the right to withdraw any employment offer or end your employment, as applicable.
We may only use information relating to criminal convictions where the law allows us to do so. Where we are required to collect your consent prior to undertaking this check, we will request your consent. In other cases, we may not require your consent; this will usually be where such processing is necessary to carry out our obligations and provided we do so in line with our Data Protection Policy.
We have in place appropriate policies and safeguards which we are required by law to maintain when processing such data.
Automated decision making
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
How long we keep your Personal Data
We will retain your Personal Data for no longer than twelve (12) months after we have communicated to you our decision about whether to appoint you. We retain your Personal Data for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way.
We may also review your records during this period to determine whether we would like to invite you to apply for any future, similar roles. If you object to this processing, please contact us using the contact details in the Contact Us section below.
After this period, we will securely destroy your Personal Data in accordance with our data retention policy and relevant Data Protection Legislation.
The recipients of your Personal Data
We will only share your Personal Data with the following third parties for the purposes of processing your application: recruitment agencies, our HR management and recruitment system and parties involved with pre-employment checks, VISA applications and so on. All our third-party service providers are required to take appropriate security measures to protect your Personal Data in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
International transfers of your Personal Data
BAP Pharma uses service providers in multiple countries. Therefore, we may need to transfer and use your Personal Data outside of the country where we collect it from you. In some cases, an adequacy decision is in place, which means the country of the third party receiving the data has been deemed to have adequate protections in place by the European Commission and/or UK government, and data can flow freely without any additional measures in place. In other cases, BAP Pharma implement appropriate measures to protect your Personal Data when we transfer your Personal Data outside of your home country. This includes having appropriate agreements in place to protect your data, such as data transfer agreements that incorporate standard data protection clauses. You can request a copy of the standard contractual clauses we use from our DPO using the contact details in the Contact Us section below.
How we protect your Personal Data
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your Personal Data on our instructions, and they are subject to a duty of confidentiality. If you would like additional assurances regarding how we process data securely, please contact us as set out below.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Your rights regarding your Personal Data
You have rights we need to make you aware of. You may have the right to:
- Ask us for copies of your Personal Data. There are some exceptions, which means you may not always receive all the information we process;
- Ask us to correct information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete;
- Ask us to delete your Personal Data, in certain circumstances;
- Ask us to restrict the processing of your information;
- Object to our processing of your Personal Data;
- Ask that we transfer information you have given us from one organisation to another, or to give it to you;
- Withdraw your consent, where you have previously provided it to us; and
- Complain to your local data protection authority.
To exercise any of these rights, you can contact us using the information in the Contact Us section below.
For your protection, and to protect the privacy of others, we may need to verify your identity before complying with your Request.
If you object to us using your Personal Data or withdraw consent for us to use your Personal Data, after initially giving it to us, we will respect your choice in line with the applicable law. However, by objecting or withdrawing your consent, we may not be able to complete the recruitment and pre-employment screening activities described above.
If you are in the UK, you have the right to make lodge a complaint at any time to the Information Commissioner’s Office (ICO) https://ico.org.uk, the UK supervisory authority for data protection.
If you are in the EU or EEA, you also have the right to lodge a complaint at any time with the relevant supervisory authority responsible for data protection. For a list of the relevant supervisory authorities, please see https://www.edpb.europa.eu/about-edpb/about-edpb/members_en
Our responsibility regarding websites and applications that we do not own or control
Our careers portal and recruitment pathway may contain links to websites or mobile applications we do not own or control. Our Privacy Notice does not cover this processing. Please read the privacy notices on those websites and mobile applications if you would like to find out how they collect, use and share your Personal Data.
Updates to this Privacy Notice
We may change this privacy notice from time to time, for example, if the law changes. We recommend that you check this notice regularly to keep up-to-date.
Contact Us
If you would like to exercise one of your rights as set out above, or you have a question or a complaint about this notice or the way your Personal Data is processed, please contact us by one of the following means:
Our Data Protection Officer (DPO): The DPO Centre Ltd, [email protected]
Thank you for taking the time to read our privacy notice
2025-02-21 – V1.5;