Privacy notice – Orange Malone

We are committed to protecting personal information that we receive about our employees, agency staff, consultants and applicants applying to us for a job. We are committed to maintaining transparent practices and explaining how we collect, process, and share that information. Protecting your privacy is very important to us.

This privacy notice explains how and why Orange Malone Ltd (“OM”) collects personal information in relation to our employees and job applicants (“you“), and how we use it.

Who is Orange Malone Ltd?

Orange Malone Ltd is a recruitment company focusing primarily on life insurance and reinsurance, pensions, investment and risk in the UK, Bermuda and Hong Kong.

This Privacy Notice sets out:

What personal information we may collect and hold;
The purposes for which your personal information may be collected, held, used and disclosed;
How we collect and hold your personal information;
What other information we use about you;
How we protect your personal information;
Who we may share your personal information to (including overseas recipients);
How you may access and correct your personal information; and
How you can contact us.

Application of Local Laws

This privacy notice is designed to provide compliance with all relevant applicable laws in the European Economic Area (EEA) and in particular those transposing the General Data Protection Regulation (“GDPR”). OM recognizes that certain laws might be modified to require stricter standards than those described in this privacy notice, in which case we will ensure compliance with those stricter standards.

OM will handle personal information in accordance with local law at the place where the personal information is collected. If applicable law provides for a lower level of protection of personal information than that established by this privacy notice, then this privacy notice shall prevail.

What do we mean by “personal information”?

Personal information means information, or a combination of pieces of information, that could reasonably allow an individual to be identified.

How do we collect personal information?

If you are applying for a position being advertised by OM, we collect your personal information in the following ways (to the extent permissible under local law):

from your application and CV, which you provide directly to us;
by interviewing you and conducting assessments to test your suitability for a role;
from publicly available professional profiles on websites or social media (e.g. LinkedIn); and
from former employers or other referees.

What types of personal information do we collect and process?

To the extent permissible under local law, we may collect the following categories of personal information about you:

personal details (e.g. name, date of birth);
contact details (e.g. phone number, email address, postal address or mobile number);
photographs;
identification documents to verify your identity;
educational and professional background information (e.g. educational history, qualifications, certifications, skills, licenses, professional memberships, compensation history);
information about your marital status, family and dependents;
citizenship or immigration information; and
criminal records.

For what purposes do we use your personal information?

If you are applying for a job we are working on, we use your personal information to:

facilitate the recruitment process and to match your details to job opportunities;
match your experience to role criteria;
communicate with you in relation to your application;
keep you informed of job opportunities which we think may be of interest; and
check whether you have previously applied for a job with us.

What are the legal bases on which we use your personal information?

We are committed to processing your personal information fairly and lawfully and only to the extent necessary to achieve the purposes listed above.

We must have a legal basis to process your personal information. In most cases, our ability to obtain and process your personal information is based on one of the following legal bases:

if you are applying for a job with us, to take the necessary steps prior to entering an employment contract with you;
to comply with our legal obligations, for example obtaining proof of your right to work status to enable us to meet relevant obligations;

On occasion, we may obtain your explicit consent to collect and use certain types of personal information, for example when we are required to do so by law or if candidates ask us to pass their details to a third party for recruitment purposes. If we ask for your consent to process your personal information, you may withdraw your consent at any time by contacting us using the details at the end of this privacy notice.

With whom do we share personal information?

Where necessary we will share your personal information with third parties under the following circumstances:

OM group companies if you are considering roles in OM group locations.

What rights do individuals have in relation to the information we hold?

You have certain rights regarding your personal information, subject to local law. These include the right to:

ask us to confirm whether your personal data is being processed, to access your personal data and for information concerning its processing (right of access);

rectify any inaccurate information we hold about you (right to rectification);

erase your personal information (right to erasure);

In certain circumstances (for example, when the data subject contests the accuracy of their personal data, while their accuracy is being checked),the right to ask for the processing of your personal data to be restricted (right to restriction of processing);

object to our processing of your personal information (right to object);

withdraw your consent in relation to processing your personal information (where we rely on your consent as our lawful basis for processing) (right to withdraw your consent);

receive your personal information in a usable electronic format and transmit it to a third party (right to data portability); and

lodge a complaint with your local data protection authority.

If you would like to discuss or exercise such rights, please contact management by using the contact details below.

How do we protect personal information?

We implement technical and organisational measures to ensure a level of security appropriate to the risk to the personal information we process. These measures are aimed at ensuring the on- going integrity and confidentiality of personal information. We evaluate these measures on a regular basis to ensure the security of the processing.

How long do we retain personal information?

If you are an employee, we will keep your personal information for as long as you remain employed with us. Once our relationship with you has come to an end, we will retain your personal information in accordance with our retention policy for a period of time that enables us to:

Provide you with any continuing benefits such as pension or insurance
Comply with record retention requirements under the law
Defend or bring any existing or potential legal claims
Deal with any queries or complaints you may have
Conduct checks against departing employees that move to certain controlled functions, in accordance with regulations

We will delete your personal information when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.

If you are applying for a job through us, we will retain your personal information in accordance with our retention policy for a period of time that enables us to:

Check our records should you apply for another role with us
Comply with record retention requirements under the law
Deal with any queries or complaints you may have
Offer you other roles you may be suitable for

Contact us

Our United Kingdom postal address is:

Orange Malone Ltd

36 The Avenue, Sunbury on Thames

Middlesex, United Kingdom

Our telephone number is:

+44 771 363 7998

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to your local supervisory authority (i.e. the supervisory in the jurisdiction where you live or work) or the supervisory authority of the jurisdiction where you believe an infringement of data protection laws has occurred. Each supervisory authority may have a difference process for lodging complaints so we encourage you to contact the relevant supervisory authority first to check this.

How do we make changes to this privacy notice?

You may request a copy of this privacy notice from us using the contact details set out above. We may modify or update this privacy notice from time to time. If we make a significant change to this privacy notice, we will notify you and, where appropriate, give you sufficient advance notice so that you have the opportunity to exercise your rights (e.g. to object to the processing).

You will be able to see when we last updated the privacy notice because we will include a revision date, shown below.