1. UK Candidate Privacy Policy – Recruitment and offer of employment process

Data Controller: Zenobe Energy Limited (Zenobē)

Data Protection Manager: Anne Darnell – Head of HR anne.darnell@zenobe.com

As part of our recruitment and employment offer of employment process, Zenobē collects and processes personal data relating to job applicants. We are committed to being transparent about how we collect and use that data and how we meet our data protection obligations.

What information does Zenobē as a recruiter and potential employer collect?

Zenobē collects a range of information about you during the recruitment and employment offer process. This includes:

• your name, gender, address and contact details, including email address and telephone numbers;
• other information you have stated on your CV including details of your qualifications, skills, experience and employment history;
• information about your current level of remuneration, including benefit entitlement;
• whether or not you have a disability which Zenobē needs to make reasonable adjustments during the recruitment process;
• information about your entitlement to work in the UK; and
• reports from candidate tests as part of the selection process

We may collect this information in a variety of ways. For example, data might be contained in your CVs, obtained from your passport or other identity documents, collected by recruitment companies or online networking sites, or collected through interviews or other forms of assessment including online tests.

We also collect personal data about you from third parties, such as references supplied by former employers and in some cases information from employment background check providers. We will only seek information from third parties only once a job offer to you has been made and will inform you that we are doing this. Data will be stored in a range of different places, including on your application record, in HR management systems and on other internal IT systems (including email, SharePoint and on our applicant tracking system).

Why does the Zenobē process personal data?

We need to process data to enable us to assess your application and, where relevant, to prepare to enter into a contract of employment with you. We need to process data to ensure that we are complying with our legal obligations. For example, we are required to check successful applicant’s eligibility to work in the UK before employment starts. Zenobē has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows us to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. We may also need to process data from job applicants to respond to and defend against legal claims.

After acceptance of an offer of employment, we also collect information about whether or not applicants are disabled to make reasonable adjustments for candidates who have a disability. We process such information to carry out our obligations and exercise specific rights in relation to employment.

Who has access to data?

Your information may be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy, the Founder Directors and IT staff if access to the data is necessary for the performance of their roles. Zenobē will not share your data with third parties, unless your application for employment is successful and it makes you an offer of employment. Zenobē will then share your data with former employers to obtain references for you, and if needed employment background check providers to obtain necessary background checks. We will not transfer your data outside the European Economic Area.

2. How does Zenobē Energy protect data?

Zenobē takes the security of your data seriously. It has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties. For example, our IT systems are password protected and access to confidential data is restricted and monitored.

How long does Zenobē keep data for?

If your application for employment is unsuccessful, Zenobē will hold your data on file for up to 24 months after the end of the relevant recruitment process. We do this in case other vacancies arise which might be suitable for you, and in case we need to defend any legal claims. After this period, our policy is, in most circumstances, to delete your personal data from our system. This is subject to any legal or regulatory obligation to keep personal data for a longer period of time (for example if it is subject to our obligations as a Skilled Hire Sponsor). We will also hold your personal data for a longer period if it is required in connection with legal proceedings. If we would like to retain your data for longer than this we will ask for your consent which you will be able to withdraw at any time. If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your HR file and retained during your employment. The periods for which your data will be held will be after any employment with Zenobē ending is 10 years and this is documented in the Employee Privacy Policy which is issued as part of the onboarding process.

Your rights

As a data subject, you have a number of rights. You can:

• access and obtain a copy of your data on request;
• require Zenobē to change incorrect or incomplete data;
• request that Zenobē delete your data where there is no good reason for its continuing to process that data;
• ask us to suspend the processing of your data, for example if you want us to establish its accuracy or the reason for processing it; and
• object to the processing of your data where Zenobē is relying on its legitimate interests as the legal ground for processing and there is something about your particular situation which makes you want to object to processing on this ground.

If you would like to exercise any of these rights, please contact olivia.tonks@zenobe.com.

If you believe that Zenobē has not complied with your data protection rights, you can complain to the Information Commissioner.

3. What if you do not provide personal data?

You are under no statutory or contractual obligation to provide data to Zenobē Energy during the recruitment process. However, if you do not provide the information, Zenobē Energy may not be able to process your application properly or at all.

4. Automated decision-making

Recruitment processes are not based solely on automated decision-making.