CANDIDATE PRIVACY NOTICE

Enquero Inc. and our affiliated companies worldwide (“Enquero”, “we” or “us”) are a global professional services firm focused on delivering digital transformation for our clients. At Enquero, we are committed to honouring and protecting your privacy. We treat your personal data in accordance with applicable data protection laws and the purpose of this notice is to make sure you are aware of what personal data we collect, obtain your consent (wherever applicable), how we use and take care of it. This Privacy Notice describes our privacy policies and practices regarding the collection and use of your personal data and sets out your privacy rights. If you have any questions or concerns about this privacy policy or your personal data, please contact us at [email protected].

Personal Data we collect 

We, at Enquero, may collect certain personal data directly from you as well as from other available sources to the extent relevant and permitted by applicable local law. The categories of personal data that are typically collected and processed in the recruitment context are: 

  • Name, gender, address, personal and/or business telephone number, personal email address, date of birth and other contact details;
  • Competences, skills (including cognitive abilities and language speaking abilities as a result of any assessments carried out during the recruitment process), experience and education, e.g. your CV or resume, previous employments, educational details and qualifications, third-party references.
  • Languages spoken, Citizenship and Nationality to enable us to check your suitability for a specific role and working location. 
  • Preferences, e.g., areas of interest as well as your preferred ways to be contacted by Enquero);  
  • Your online user identity, e.g. usernames and other such information used in connection with authenticating you to our online recruitment management system. 
  • Technical Information: When you access our services online, our web servers automatically create records of your visit. Please read our website privacy policy by visiting https://enquero.com/privacy-policy/ for more information.
  • Information collected during interviews: As part of our interview process we may maintain audio/screenshots of youin case of telephone interviews or video enabled interviews and subject to your consent) as well as comments noted by our interviewers.
  • Information collected from online assessments proctoring: as part of the recruitment process, we may ask you to take certain tests which are necessary for assessing your suitability for a certain position. Such assessments can also be taken online, without your actual presence at Enquero’s headquarters. In such cases, we may ask for your consent to also collect snapshots during a video enabled interview. No biometric data will be collected of you.   
  • Other information, such as information found from public sources as well as information related to reference checks, depending on the position you are applying for, and where necessary for the recruitment activities. 
  • Additionally, once you have been shortlisted, we may collect additional information such as copy of Government ID, expectation of compensation and remuneration details, information relating to your family members (for benefits administration), passport, visa and work permit (in case of expatriate), background check reports including educational, employment and criminal checks etc. as permitted under applicable laws. Also, in certain cases, we may collect your bank account details, details of the expense incurred and relevant bills to reimburse any expenses incurred by you during the interview processes.

The special categories of personal data (by which we mean either special category personal data or data relating to criminal convictions and offences) collected, as permitted under applicable laws, may include: 

  • Information relating to your health: In certain instances, we may receive information related to health such as Covid-19 vaccination status or certificates, psychological conditions in order to make any necessary accommodations during our interview process. 
  • Data relating to criminal convictions and offenses collected from background checks, as permitted under applicable laws. 
  • Information related to racial, ethnic origin or religious beliefs collected as a result of diversity surveys, as permitted under applicable laws. 

The legal basis for processing sensitive personal data is as defined under the art. 9 para. 2 letter b) of GDPR and as per the applicable laws in India. 

This information will be collected by us in a number of ways through multiple channels during the recruitment process and over time during our relationship with you: 

  • Directly from you (when you apply online or via email or in person); 
  • Through referrals from your friends, family of professional connects who work at/ with Enquero; 
  • From third-parties (through recruitment agencies, recruitment platforms and background verification agencies), which may also include public sources such as professional networking platforms; 

Purposes of processing your personal data and the legal basis for processing  

We, at Enquero, are required to collect and process your personal data for the purposes of Enquero’s recruitment, evaluation of your profile and/ or resourcing activities. The legal basis for processing the personal data is legitimate business interest. When you apply for a role with Enquero, you do so voluntarily and can at any time withdraw your application. Your personal data shall be utilized in the following ways: 

  • Communicating with you, in context of recruitment activities in accordance with the legitimate business interests of the company:
    •  To obtain additional information about your suitability for the role where necessary; 
    • To inform you of available vacancies; 
    • To provide you with information relating to your application and to fulfil your requests. 
  • Managing recruitment and resourcing activities, including activities related to organizational planning. In the course of recruitment activities, we may use your information, in accordance with our legitimate business interests: 
    • To set up and conduct interviews and assessments; 
    • To evaluate, select and recruit applicants; 
    • To contact third-party referees provided by you to evaluate your previous performances. 
  • Carrying out online aptitude tests and language assessments. For certain positions, candidates must have a certain set of soft skills and/or language abilities, in addition to the subject-matter expertise. Consequently, we have a legitimate interest to test your cognitive abilities and/or language abilities, so that we can assess your suitability for a certain position within Enquero and ultimately increase the quality of hires, reduce the bias in the recruitment process and improve your overall recruitment experience. Tests have been calibrated and benchmarked by our team of experts, against a significant number of data points, to ensure accuracy and fairness. We will provide you with detailed information on each type of assessment that you may have to take in the email invitation that we send you for before taking the test. 
  • Proctoring of assessments to prevent fraud: When taking online assessments without any supervision (such as online cognitive assessment tests, online language abilities test) we have a legitimate interest to take snapshots and/or video recordings of you during the test, in order to prevent and identify any fraud and ultimately maintain the integrity of the test. An AI algorithm will be used to identify potential fraud within the taken snapshots/video recordings and will highlight them to the responsible recruiter, which shall review them manually in order to reach a decision. The proctoring activity is implemented in the least intrusive manner possible, and all technical and organizational measures have been implemented to ensure minimization, security and confidentiality of the processed personal data. We will inform you in detail of any proctoring carried out and take your consent before any assessment that you may take. 
  • Monitoring and development of our recruitment process We may use your personal data to develop and improve our recruitment processes, websites and other related services. This is in accordance with our legitimate business interests to improve the services we provide. Where feasible, we shall use aggregated anonymous information in the context of such development activities. We may run some analytics on the data collected during the recruitment process to enhance the user experience.  
  • Audit Compliance – We may process personal data as part of our audit processes and engage third-party auditors, from time to time in accordance with the legitimate business interests of the company and/or where necessary in defence or exercise of our legal rights.  
  • Prevention of fraud – We may process your personal data for the purpose of fraud prevention in pursuit of the legitimate interests of the company. 
  • New employment opportunities – If you have expressed an interest in working for us in the future we may retain relevant documents collected during the recruitment process containing your personal data for future employment related opportunities in certain regions and as per the applicable law.  

In the future, if we intend to process your personal data for a purpose other than that mentioned above, we will provide you with any other relevant information and obtain your consent where it is necessary to do so. 

Security 

We have implemented industry standard security measures and reasonable security practices and procedures, to keep your personal data secure and confidential, including and not limited to:

  • Limiting access to your personal data, to Enquero employees strictly on a need-to-know basis, such as to respond to your inquiry or request. 
  • Implemented physical, electronic, administrative, technical and procedural safeguards that comply with all applicable laws and regulations to protect your personal data from unauthorized or inappropriate access, alteration, disclosure and destruction. It is important for you to protect against unauthorized access to your password and to your computer. Be sure to sign off when you are done using a shared computer. 

Enquero takes appropriate action, in any event of misuse of the personal data, in accordance with the law of the land and the policies of the Company.  

Who we may share your personal data with (the recipients or categories of recipients of the personal data)  

  • We may use carefully selected third-parties to carry out certain activities to help us to run our business (such as cloud service providers, IT support vendors), to facilitate abilities tests and language tests (language assessment agencies, online test providers etc.), to carry out background checks (background verification agencies), as permitted by applicable laws, to facilitate your travel and expense (travel and immigration vendors), to facilitate on-boarding at the time of joining Genpact and to facilitate audits (third-party auditors). For information on the third-party vendors partnered with Genpact, please visit https://www.genpact.com/downloadable-content/genpact-list-of-associated-partners-and-suppliers.pdf
  • We have offices and operations in a number of international locations, and we share information between our group companies for business and administrative purposes. Your information could be, shared with our internal staff for screening and interview purposes.  
  • Where required for your role, your CV and business contact details may be shared with clients, as permitted under applicable laws. 
  • Where required or permitted by law, information may be provided to others, such as regulators and law enforcement agencies.   
  • From time to time, we may consider corporate transactions such as a merger, acquisition, reorganisation, asset sale, or similar. In these instances, we may transfer or allow access to information to enable the assessment and undertaking of that transaction. If we buy or sell any business or assets, personal data may be transferred to a third-party involved in the transaction. 

International and group company transfers of personal data 

We are part of an international group of companies and, as such, transfer personal data concerning you to countries outside the European Union (EU). We transfer personal data between our group companies and data centres for the purposes described above. We may also transfer personal data to our third-party vendors outside of the EU as described above. Your personal data may be stored in databases located outside of the EU including in India. The database is controlled by our administrative staff located outside of the EU including in India and can be accessed electronically. 

Where we transfer personal data outside of EU,  we either transfer personal data to countries that provide an adequate level of protection as determined by the European Commission or we have appropriate safeguards in place. Appropriate safeguards to cover these transfers are in the form of standard contractual /data protection clauses adopted by the European Commission. Please visit https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2010:039:0005:0018:EN:PDF to know more about standard contractual/data protection clauses.   

Where we transfer personal data between our group companies, we have covered these transfers by entering into standard contractual clauses adopted by the European Commission. If you would like more information on the any of the data transfer mechanisms on which we rely please contact our Data Protection Officer, details available in the contact section below. 

Period for which the personal data will be stored  

Your personal data will be retained for as long as necessary in order to achieve the purpose for which the information was collected namely to enable us to contact you in future about potential employment opportunities at Enquero, if any, in line with our Data Retention policies and any legal or regulatory requirements. You may choose to opt-out by writing to us at [email protected]enquero.com. Once you opt-out Enquero will stop processing your personal data and delete it from our systems and hard copy documents, in which case Enquero will no longer be able to provide you any services like informing you about possible vacancies. 

Your rights 

If you are a resident of the EEA, you may have certain rights relating to your personal data provided under the GDPR. These include the right to: 

  • Request access to your personal data and request details of the processing activities conducted by Enquero and by third parties, within a reasonable time and at a prescribed fee, if any. 
  • Request that your personal data is rectified if it is inaccurate or incomplete, irrelevant, excessive, out of date, misleading or obtained unlawfully. 
  • Request erasure of your personal data in certain circumstances. 
  • Request restriction of the processing of your personal data by Enquero in certain circumstances. 
  • Object to the processing of your personal data in certain circumstances. 
  • Receive your personal data in a structured, commonly used and machine-readable format in certain circumstances.  
  • Object to, and not to be subject to a decision based solely on, automated processing (including profiling), which produces legal effects or significantly affects you. 
  • Withdraw any consent you have provided to us at any time by contacting us. 

Enquero endeavors to extend the rights to all candidates as applicable per the respective data privacy laws of the country where it operates from. These rights may be limited in some situations for all the countries, including India– for example, where we can demonstrate that Enquero has a legal requirement to process your data. In some instances, this may mean that we are able to retain data even if you withdraw your consent. 

Where Enquero requires personal data to comply with legal or contractual obligations, then provision of such data is necessary: if such data is not provided, then we will not be able to manage our contractual relationship, or to meet obligations placed on us.  In all other cases, provision of requested personal data is optional.

In the event you have unresolved concerns, you also have the right to lodge a complaint with the data protection authority where you work, normally live or where the alleged infringement of data protection laws has occurred. We hope this will not be necessary and would like to assure you we will do our best to resolve any dissatisfaction you may have. 

Enquero extends following rights to the candidates who are based in India, under the Information Technology Act, 2000 and the Rules made therein-  

  1. Request access to your personal data to review; 
  2. Request that your personal data is rectified if it is inaccurate or incomplete; and
  3. Opt-out or withdraw any consent you have provided to us at any time by contacting us.

To exercise the rights outlined above with respect to your personal data, you may write to us at [email protected].  

Changes to our privacy policy 

This privacy policy was last updated in March 2022 and we will notify you of changes we may make to this privacy policy where required, however we would recommend that you look back at this notice from time to time to check for any updates. 

Contact 

Enquero is the controller of data for the purposes of GDPR. 

If you have any concerns as to how your data is processed, you can contact our Data Protection Officer by writing to [email protected]