Nord Anglia Education

Recruitment Privacy Notice
Nord Anglia Education Limited, and its subsidiaries and affiliates ("NAE”, “we”, or “us”) are committed to safeguarding personal data. We define personal data broadly as information that directly identifies an individual or that makes an individual identifiable when combined with other information. 

This Recruitment Privacy Notice (“Privacy Notice") sets out how we will process and protect your personal data in connection with the recruitment process. In case of conflict between this Privacy Notice and applicable law, applicable law will govern. 

This Privacy Notice only applies to the personal data of job applicants, potential candidates for employment or partnership, and those who participate in our recruitment programmes and events. This personal data is submitted directly to NAE through the online application process and follow-up communications and/or through alternative channels (e.g. professional recruitment firms). 

 By providing your personal data to us, you acknowledge that:

• You have read and understood this Privacy Notice and agree to the use of your personal data as set out herein. 
• Your personal data may be transferred and processed worldwide, including in countries that may not be deemed to provide the same level of data protection as your home country, for the purposes and in the manner set out in this Privacy Notice. 
• You are not required to provide any requested information to us, but your failure may lead to us not being able to continue your candidacy for the job for which you have applied. 
• All your representations are true and correct to the best of your knowledge and belief, and you have not knowingly omitted any related information of an adverse nature. Providing inaccurate information may make you ineligible for employment. 
• This Privacy Notice does not form part of any employment contract. 

This Privacy Notice only relates to processing undertaken by or on behalf of NAE. Whilst our websites may contain links to other third-party websites, please note that we do not accept any responsibility or liability for their policies in relation to any Personal Data or their collecting processing of any Personal Data.

Where reasonably necessary or required to do so, we may disclose these details to third parties in relation to law enforcement or regulatory investigation and for the purpose of conducting any pre-employment checks.
 
What personal data do we collect?
The types of personal data that we request from you and the ways that we process it are determined by the requirements of the country in which the role you apply for is located, and not the country in which you reside. Should you apply to more than one location, the types of personal data we request from you and the ways that we process it are determined by the requirements of all the countries in which the positions are located. 

We may collect the following categories of personal data form you:

• Personal identification: Name, title, gender, country, date of birth, nationality and immigration status, including passports / visas as applicable;
• Contact information: Email, phone, address;
• Network traffic and other online data (collected using cookies and similar technologies): Identification numbers, location, IP address, browsing behaviour, device ID, websites visited, language used;
• Account login information: Login ID, other information used to access and/or secure systems and applications including our careers website;
• Personal information regarding qualifications and career development: Any information contained in CVs and additional documents such as professional certificates, assessment and/or test evaluations, interview notes, application details;
• Background information: Employment references and, where permitted, information from background checks;
• Compensation and payroll: Bank account information (for payment), desired salary, current salary, compensation and benefits;
• Any other information that you volunteer: Feedback, opinions, information provided in emails and letters or other conversations; and
• Images and/or videos: Pictures included in your CV, security footage captured during your visit to our office/school.

We may also collect personal data about you online to the extent you have chosen to make this information publicly available. For example, we may find your profile on professional social media websites (such as LinkedIn) and contact you about suitable roles. 

If you receive an offer from us, we will conduct background checks and to the extent permitted by applicable law; we may undertake criminal records checks and where we do so you will be asked to consent to such collection and use before we or our agents undertake the search to assess your suitability for the position.

Special categories of personal data (also referred to as sensitive personal data) is a subset of personal data that includes ethnicity, health, trade union membership, philosophical beliefs, sexual orientation and other categories prescribed by law. We may collect sensitive personal data about a candidate to the extent permitted by applicable laws and to support our efforts to create an inclusive and diverse work environment and for the assessment of your working capacity. Please note that sensitive personal information collected for inclusivity and diversity monitoring is processed in an aggregated and depersonalised form, for reporting purposes.

Why we process your personal data?
We collect and use your personal data for legitimate human resources and business management reasons such as to:

• identify and evaluate candidates for potential, as well as for future roles that may become available;
• maintain records in relation to recruiting and hiring;
• ensure compliance with legal requirements, such as workplace safety and public health
• advance our diversity and inclusion practices;
• carry out background checks to the extent permitted by applicable law, and if you receive an offer from us, criminal background checks; and
• protect our legal rights to the extent permitted by law. 

     
 We may also use your personal data for analytics purposes, including in aggregated/pseudonymized form, to improve our recruitment and hiring process and enhance our ability to attract successful candidates.

What legal basis do we have for using your personal data?
Under data protection law, there are various legitimate and lawful grounds we can rely on when processing your personal information. In some contexts, more than one of the stated grounds will apply to the processing we carry out. We have summarised these grounds under four headings:

• contractual and precontractual measures relating to our potential employment relationship with you;
• legal obligations to comply with applicable law necessary to satisfy our legal and regulatory obligations, including with regard to public health and workplace safety;
• legitimate interests in evaluating your application to manage our relationship with you, to ensure we recruit appropriate employees, evaluate our recruitment process, and protecting our business, students, families, staff and third parties; and
• consent, when we request a reference from a former employer. 

If we process special category personal information, as well as ensuring that one of the grounds for processing mentioned above, we will also make sure that one or more of the additional grounds for processing this type of personal information applies. The grounds include:

•  processing being necessary for the purposes of your or our obligations and rights in relation to employment insofar as it is authorised by law or collective agreement;
• processing relating to data about you that you have manifestly made public;
• processing being necessary for the purpose of establishing, making or defending legal claims;
• processing being necessary for provision of health care or treatment, medical diagnosis, and assessment of your working capacity;
• processing for equality and diversity purposes, to the extent permitted by local law; and
• processing for which you have given us your explicit consent.

How we share your information?
Internally
Your personal information will be seen internally by members of the relevant NAE Recruitment teams, and other HR team members, hiring managers, associates and partners involved in recruitment and, in some circumstances (if you are interviewing or you join us), other prospective colleagues on a need-to-know basis only. We may also disclose your data to other employees of the firm where it is necessary for decision-making regarding your application. This will depend on the type of role you are applying for.

Externally 
We share your personal data with third party providers to carry out reference checks, and other pre-employment checks  and on-boarding activities in the event you accept an offer of employment or engagement from us. We also share it with organisations that process data on our behalf, such as our payroll service, insurers and other benefits providers, our bank and organisations that host our IT systems and data. This would normally occur if you accepted an offer from us and would be carried out as part of the onboarding process. We also use a third-party applicant tracking system (ATS), which securely stores your personal information for us once you have made an application in order to enable the relevant hiring managers and recruiters to consider your application.

When do we send your personal data abroad?
The global nature of our business means that your personal information may be disclosed to other NAE entities, or to third party suppliers or partners, located outside the United Kingdom or the country in which the role you apply for is located (for a full list of our school locations please visit Our Schools). These jurisdictions may not offer a level of protection of privacy equivalent to the level. Where we transfer your personal information outside the United Kingdom, the firm will ensure that adequate safeguards have been provided by the entity receiving the information. 

In respect of internal transfers within NAE, we commit to ensure your data receives a level of protection which is at least in line with the requirements of data privacy legislation applicable in the United Kingdom.

In respect of transfers of your personal information to third party suppliers outside the United Kingdom, we will take steps to ensure that your personal information receives an adequate level of protection, including by, for example, entering into appropriate data transfer agreements.
 
How long do we keep your personal data for?
Our general approach is to retain your personal information only for as long as is required to satisfy the purpose for which it was collected by us or provided by you. If you become employed by us, we will keep your personal information for the duration of your employment and for a period afterwards.

The length of time for which we keep data collected during the recruitment process may depend on the type of role or opportunity you are applying for. Generally, if your application is unsuccessful, we will remove your details after 12 months of inactivity on this applicant tracking platform.  Deletion of files may be suspended where required by law or in order to maintain evidence if we consider a complaint or dispute to be likely.
 
What are your rights in relation to the personal data we collect?

You have a variety of rights that enable you to exercise control over your personal information, including rights of access, erasure and objection. These rights are subject to certain exemptions which we may apply and certain rights (such as erasure) only apply in limited circumstances. For more detailed information about your rights, please refer to the ‘Rights Relating to Personal Data’ section of our Privacy Policy. 
 
Automated decision making
We do not currently use any automatic decision making as part of our recruitment processes, although we may use filtering questions in order to assist us with the administration and progression of your application throughout some stages of the application process.

Recruitment enquiries
If you have any general question about your application or the recruitment process, please contact  recruitment@nordanglia.com.

Data Protection Contact details and complaints
If you have any questions or concerns about this Privacy Notice or how NAE is processing your personal information, please contact the Group Data Protection Officer (“GDPO") at Compliance@nordanglia.com 

Certain schools (e.g., EU schools) have a local designated Data Protection Officer whose details can be found on the School websites or by contacting the GDPO. 

We hope that the GDPO can resolve any query or concern you raise. If you feel we have not handled your query or concern to your satisfaction you can contact the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. They can be contacted by telephone on 0303 123 1113, or via the ICO’s live chat facility, which you can access via your browser by clicking here.

Status of this notice
This Privacy Notice does not form part of any contract of employment you might enter into and does not create contractual rights or obligations. It may be amended by us at any time. Nothing in this Privacy Notice is intended to create an employment relationship between NAE and any non-employee.

Last updated: May 2023