AUDAX APPLICANT PRIVACY NOTICE
The Audax Group (“Audax”, “we”, “us” or “our”) is providing this notice to explain how we collect, store, transmit, use and/or share (collectively, “process”) personal information that we obtain about our current and former applicants, part-time and temporary workers and contractors (“you”, “your” or, collectively, the “Applicants”, and this notice, the “Applicant Privacy Notice”), including the California Consumer Privacy Act (the “CCPA”) and similar state privacy laws in the United States, the United Kingdom Data Protection Act 2018 and the General Data Protection Regulation) as it forms part of the law of England, Wales, Scotland and Northern Ireland, as applicable.
Audax may change this Applicant Privacy Notice at any time at its sole discretion. Unless we state otherwise, changes will be effective upon the last updated date at the bottom of this Applicant Privacy Notice. We may notify you of material changes to this Applicant Privacy Notice, which, if we do so, may be by sending an email notification (if you have provided your email address to us) or by other reasonable methods at our sole discretion.
Types of Personal Information We Process
In the course of our recruitment activities, we process certain types of personal information related to individuals who apply for roles with Audax (“Applicant Personal Information”), which may include, but are not limited to:
- Identification information, such as your name, age, gender, citizenship, social security or National Insurance number, driver’s licence or passport details, immigration and right‑to‑work status and identification numbers.
- Contact information, such as your email address, residential address and telephone number(s).
- Professional and employment‑related information, such as your curriculum vitae/résumé, cover letter, previous and current roles/positions/titles and areas of responsibility, professional qualifications and memberships, skills, certifications, references and information about eligibility to work.
- Education information, such as your academic record, degrees, transcripts, training, courses and relevant work placements or internships.
- Recruitment and assessment information, such as information contained in application forms, screening notes, interview notes, meeting and interview scheduling information, assessment and test results (including technical, psychometric or other evaluations) and communications with you about your candidacy.
- Background screening information, where permitted by law and conducted in accordance with applicable legal requirements, such as criminal records checks, credit checks (where relevant to the role), sanctions and adverse media checks and verification of qualifications and employment history.
- Audio, electronic, visual or similar information, such as recordings of interviews (including video interviews) where applicable, CCTV images when you visit our premises and any recordings or transcripts of recruitment‑related calls or video meetings that may be recorded and automatically transcribed and/or summarised.
- Internet or other electronic network activity information related to your use of Audax recruitment portals or applicant tracking systems, such as log data and usage analytics.
- Personal information regarding gender identity, LGBTQ+ affiliation and disability status, and other diversity information, which you may provide to us on a voluntary basis for equal opportunities monitoring where permitted by law.
Some of the Applicant Personal Information we collect may be “Sensitive Personal Information,” which includes government identifiers, information that would provide access to a personal financial account, geolocation, contents of mail or messages, information relating to an individual’s health or mental or physical condition, criminal convictions or offences, their race or ethnicity, their religious or philosophical beliefs, political opinions and/or sexual life or orientation, and whether they are affiliated to any trade union.
We may obtain Applicant Personal Information from the following sources:
- Directly from you, such as information and documents provided through our application processes, portals and forms and during interviews and assessments.
- Through your interactions with our recruitment systems and communications with us, including phone or video calls (which may be recorded and automatically transcribed and/or summarised), emails and other correspondence.
- From third parties, such as recruitment or executive search agencies, background screening providers, referees, former employers, professional networking sites and job boards (in each case to the extent permitted by applicable law).
- From public sources or government bodies where appropriate and lawful (for example, to verify right‑to‑work status or professional licences).
Where Audax requires Applicant Personal Information to comply with its legal or regulatory obligations or to assess your candidacy prior to entering into a contract, the provision of the Applicant Personal Information is mandatory. If such Applicant Personal Information is not provided, we may be unable to process your application or, where applicable, to make an offer of employment. In all other cases, the provision of requested Applicant Personal Information is optional.
Purposes of Processing Applicant Personal Information
Applicant Personal Information may be processed for the following purposes:
- Where necessary to take steps at your request prior to entering into a contract or to assess and manage your application:
- Receiving, reviewing and processing applications, CVs/résumés and supporting documents.
- Assessing qualifications, experience, skills and suitability for the role, scheduling and conducting interviews and administering assessments and tests.
- Verifying information provided, conducting reference checks and, where permitted by law, background checks and right‑to‑work/immigration verification.
- Communicating with you regarding the recruitment process, including interview scheduling, outcomes and offer management.
- Where necessary to comply with a legal obligation:
- Conducting right‑to‑work, immigration and identity verification and maintaining records required by employment, immigration and equal opportunities laws.
- Disclosures to law enforcement agencies or in connection with legal claims, regulatory, investigative and compliance purposes (including disclosure of such information in connection with legal process or litigation).
- Where necessary for Audax’s legitimate interests, and where our interests are not overridden by your data protection rights:
- Managing and improving our recruitment processes, including analytics, reporting and quality assurance.
- Maintaining a talent pool/database to consider you for current and future opportunities, subject to applicable law.
- Protecting our legitimate business interests and legal rights, including use in connection with legal claims, compliance, regulatory, auditing and investigative purposes and fraud prevention.
- Ensuring the security of our premises, systems, data and personnel, including administering access rights and using CCTV when you visit our offices.
- Where necessary for reasons of substantial public interest or to carry out obligations in the field of employment and social security and social protection law under local law:
- Applicant Personal Information revealing health, race, ethnic origin, sexual orientation and disability may be processed to facilitate effective equal opportunities monitoring and/or to comply with legal obligations relating to reasonable accommodations.
- Where you have given your consent:
- For example, where consent is required by law to conduct certain background checks, to record interviews or to retain your Applicant Personal Information in our talent pool beyond our standard retention period. Where we ask for your consent, you are free to withhold or revoke it.
Disclosure of Applicant Personal Information and Recipients
In order to process Applicant Personal Information for the purposes described in this Applicant Privacy Notice, Applicant Personal Information may be disclosed to any of the following, without limitation, as necessary:
- Employees of Audax involved in the recruitment process, including HR/recruitment personnel and hiring managers.
- Service providers, agents, consultants and advisors of Audax, including recruitment platforms and applicant tracking system providers, background screening providers, assessment and testing vendors, IT and communications service providers and professional advisors.
- Recruitment or executive search agencies and your referees or former employers (to obtain references), in each case subject to applicable law.
- Any governmental, administrative, judicial or regulatory authority, including courts, governmental and non‑governmental regulators, immigration and work authorisation bodies, ombudsmen, law enforcement agencies and fraud prevention agencies.
- Any third party that acquires, or is interested in acquiring, all or part of Audax’s assets or shares, or that succeeds Audax in carrying on all or a part of its business, whether by merger, acquisition, reorganisation or otherwise.
- Third parties as required or permitted by law, including to comply with a subpoena or similar legal process or government request, or when Audax determines in good faith that disclosure is legally required or prudent to further Audax’s commercial purposes, including actual or prospective legal proceedings involving Audax or for the purposes of obtaining legal advice or establishing or defending our legal rights and property.
International Data Transfers
Because the Internet and our operations are global, Applicant Personal Information may be transferred to, processed in, and held in countries (including the United States) other than the one in which you reside. The United Kingdom and the European Union do not consider the United States and many other countries to provide essentially equivalent privacy protections.
We will ensure the application of the same standards of privacy protection as set out in this Applicant Privacy Notice regardless of the international transfer or processing of Applicant Personal Information. To the extent required by, and in accordance with, applicable data protection laws, we rely on appropriate or suitable safeguards in respect of international transfers of personal information, including:
- Using standard contractual clauses approved by relevant authorities as ensuring adequate safeguards (“Model Clauses”).
- Obtaining your consent to transfer Applicant Personal Information about you after first informing you about the possible risks of such a transfer.
- When the transfer is necessary for the performance of a contract between you and us, or if the transfer is necessary for the performance of a contract between us and a third party, and the contract was entered into in your interest.
- When the transfer is necessary to establish, exercise or defend legal claims.
You can request further details in relation to international transfers, including a copy of the Model Clauses, by using the contact details provided below.
Retention
Audax will retain Applicant Personal Information that we process pursuant to this Applicant Privacy Notice for the duration of time necessary to fulfil the purposes for which we collected Applicant Personal Information, including to satisfy any legal, accounting or reporting requirements and to establish or defend legal claims. When deciding how long to retain Applicant Personal Information, Audax also takes into account the amount, nature and sensitivity of the Applicant Personal Information, the purposes for processing and whether it can achieve those purposes through other means. Audax may also retain Applicant Personal Information to investigate or defend against potential legal claims in accordance with the limitation periods of countries where legal action may be brought.
Security
Audax has safeguards in place designed to help protect Applicant Personal Information that it processes from loss, misuse and unauthorised access, disclosure, alteration and destruction. However, no such measures can guarantee security and Audax cannot promise that your Applicant Personal Information will remain absolutely secure in all circumstances.
Your Privacy Rights
Your Rights under United Kingdom and European Union Law
You may be entitled to ask Audax for a copy of your Applicant Personal Information, to correct, delete or restrict processing of it and to obtain the Applicant Personal Information you provide in a structured, machine‑readable format and ask us to share this Applicant Personal Information with other organisations. You may also have the right to object to processing of your Applicant Personal Information in some circumstances. Where we have asked for your consent, you may withdraw consent at any time. If you ask to withdraw your consent to Audax processing your Applicant Personal Information, this will not affect any processing which has already taken place at that time.
These rights may be limited, such as where fulfilling your request would reveal personal information about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete Applicant Personal Information that we are required by law to keep or have compelling legitimate interests in keeping. We will inform you of relevant exemptions we rely upon when responding to any request you make. If you wish to exercise these rights, please contact us as set out below.
If you have unresolved concerns you have the right to complain to a data protection authority in the United Kingdom or the European Union.
Your Rights under California Law
Applicants who are residents of California may have certain rights regarding their Applicant Personal Information. Those rights include:
- The right to know what Applicant Personal Information we collect, including: (i) the right to request information regarding the categories of Applicant Personal Information we collect along with other information such as the categories of sources from which the information is collected and third parties with whom it is shared; and (ii) the right to request a copy of the specific pieces of Applicant Personal Information we collect.
- The right to delete Applicant Personal Information that we collect from you, subject to certain exceptions.
- The right to correct inaccurate Applicant Personal Information that we maintain about you.
- The right to opt-out of the sale or sharing of Applicant Personal Information. However, since we do not sell or share Applicant Personal Information, as those terms are defined under the CCPA, you are already opted out;
- The right to limit the use of sensitive personal information in some circumstances.
- The right not to be retaliated or discriminated against for exercising any of these rights in good faith. However, we reserve all rights we may have under law with respect to requests made in bad faith or that are manifestly unfounded or excessive.
Exercising Your Rights
If you want to exercise any of these rights, please submit a request by emailing compliance@audaxgroup.com. We will review your request and respond accordingly. The rights described above are not absolute and we reserve all our rights available to us at law in this regard. If you make a request with respect to your Applicant Personal Information, you may be required to validate your identification as a security precaution. If it is necessary to collect additional information, we will use the information only for verification purposes and will delete it as soon as practicable after complying with the request. If you make a request through an authorised agent, we will require written proof that the agent is authorised to act on your behalf. We will process your request within the time provided by applicable law.
Enquiries, Requests or Concerns
The data controller for your Applicant Personal Information is the Audax entity to which you are applying or providing services.
All enquiries, requests or concerns regarding this Applicant Privacy Notice or relating to the processing of Applicant Personal Information should be sent to compliance@audaxgroup.com.
