/ RECRUITMENT PRIVACY NOTICE

Last Updated: July 2023

Background

This document relates to information that we hold about you, through which you can be identified.

Information of this nature is considered “personal data” under the General Data Protection Regulation (and other data protection legislation). Where we determine the purposes for which, and the manner in which, your personal data are or are to be processed, we act as a “data controller”.

This Privacy Notice lets you know what happens to any personal data that you provide to us, or any that may we collect from you.

This notice applies only to personal information processed by or on behalf of Walden Group and its affiliates with the group of companies.

Changes to this notice

The protection of your data is important to us, and as such we will keep this notice under review. We may, therefore, change this notice from time to time by updating this page in order to reflect changes in the law and/or our privacy practices. We will update the date at the top of the notice accordingly. The up to date version of this will be made available to you. We may also send you an updated copy (depending on whether we are required to do that). The Walden Group GDPR SOP is available on our website and can be consulted for further details on the personal information that we process.

Who are we and how do you contact us and our Data Protection Officer

We are Walden Pharma Group Services Limited of 38 Mount Street Upper, Dublin 2, D02 PR89, Ireland and we are a data controller of your personal data that you provide to us in connection with your application for the role you have applied for. The Walden Group ultimate parent company, EHDH SaS a French company with an office at 31 rue de Fleurus 75006 Paris, also be a data controller of your personal data.

The term personal data means information that is about you or from which we can identify you which will include information that you have provided to us in support of your application for a role in Walden Group. This privacy notice describes how we deal with your personal information. We are the data controller of this information under relevant data protection laws because in the context of our business relationship with you we decide how and why it is processed in the ways explained in this notice. If you have queries about this privacy notice or wish to exercise any of the rights mentioned in it, you can contact us at by emailing GM-Privacy@Walden-Group.com.

When we use terms such as we, us and our in this notice, we mean Walden Pharma Group Services Limited or Walden Group any other entities of the Walden Group. Walden Group means any entity in which EHDH SaS directly or indirectly has at least a 50% shareholding. As at the date of this privacy notice, the members of our Group are identified in the list attached.

What kinds of personal information about you do we process?

This will depend on the nature of our relationship with you. Personal information that we generally process in connection with all of our candidates includes:

Personal contact details such as name, title, addresses, personal email address, telephone numbers, information on work related social media profiles (e.g Linkedin), IP addresses and
Information that you choose to provide to us about you including views and opinions provided to us.
Date of birth.
Tax status information.
Current salary, annual leave, pension and benefits information.
Start date and previous employment dates with previous employers (if appropriate).
Location of current employment or workplace ( if applicable).
Recruitment information (including copies of right to work documentation, education and qualifications, references, referee contact information ( we will ask your consent before contacting) and other information included in a CV or work related social media or cover letter or as part of the application process).
Employment records (including job titles, work history, working hours, training records and professional memberships)
Next of kin information

What is the source of your personal information?

We will generally collect your personal information from you directly through both directly sourcing your profile as a passive candidate and through your direct application to our job advertisements. In event we receive your details from an employment agency, we will ask them for your consent to process information before processing application. We may sometimes collect additional information from third parties including former employers, tax and social security authorities, governmental, competent or regulatory authorities, credit reference agencies or other background check agencies or information in public domain or disclosed in press or media.

We will collect additional personal information in the course of job-related activities throughout the period of you working for us.

What are the legal grounds for our processing of your personal information (including when we share it with others)?

Data protection laws require us to explain what legal grounds justify our processing of your personal information (this includes sharing it with other organisation). For some processing, more than one legal ground may be relevant (except where we rely on a consent). We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

Where we need to perform the contract we have entered into with you.
Where we need to comply with a legal obligation.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

We may also use your personal information in the following situations, which are likely to be rare:

Where we need to protect your interests (or someone else’s interests).
Where it is needed in the public interest.

Situations in which we will use your personal information

We need all the categories of information in the list above primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below.

Making a decision about your recruitment or appointment.
Transfer of your employment from a previous employer.
Determining the terms on which you work for us.
Checking you are legally entitled to work in the country where your job is located (i.e. Europe or Morocco)
Assessing mandatory tax and social security withholdings applicable to role.
Discussing the following benefits with you:
Healthcare plan/voluntary health insurance,
Paid Leave,
Life Assurance and disability cover,
Educational Assistance ( if applicable)
Bonus or incentive pay( if applicable),
Share/stock purchase options ( if applicable),
Company mobile phone ( if applicable)
Company car ( if applicable).
Any other benefits that the company may from time to time add to benefits plan,
Liaising with your / our pension provider.
Making decisions as to whether to make awards to you under the group employee incentive arrangements operated by Walden Group
Liaising with and providing data to the administrator of any group employee incentive arrangements operated by Walden Group
Administering the contract offer for successful candidates (if applicable).
Business management and planning, including accounting and auditing.
Making decisions about salary and compensation.
Assessing qualifications for a particular job or task, including decisions about promotions.
Making decisions about your employment or engagement.
Education, training and development requirements.
Dealing with legal disputes involving you, or other employees, workers and contractors.
Ascertaining your fitness to work.
Complying with health and safety obligations.
To prevent fraud.
To set up access to use of our information and communication systems and monitor your use of our information and communication systems to ensure compliance with our IT policies if applicable.
To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution, if applicable.
Equal opportunities monitoring.

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

”Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:

Where we need to carry out our legal obligations and in line with this notice.

2.Where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards.

We will use your particularly sensitive personal information in the following ways:

We will use information relating to leaves of absence, which may include sickness absence or family related leaves, to comply with employment and other laws.
We will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits.
We will use information about your physical or mental health, or disability status if you cease employment by reason of total and permanent disability and may be entitled to retain some or all of any employee incentive awards granted to you by Walden Group
We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so. We will use information about criminal convictions and offences in the following ways:

To assist recruitment decisions, including any restrictions in your ability to carry out a role.

We are allowed to use your personal information in this way to carry out our obligations in protecting our employees and company property or proprietary information and to comply with our legal obligations.

How and when can you withdraw your consent?

As is set out above, most of what we do with your personal information is not based on your consent, and is instead based on other legal grounds. For processing that is based on your consent, you have the right to take back that consent for future processing at any time. You can do this by contacting us responding to this email or emailing GM-Privacy@Walden-Group.com where your request will be actioned.

If you have been introduced by an employment agency, we will tell the employment agency or other intermediary who introduced you to us that you have withdrawn your consent only if it is our data processor (this means an organisation who is processing personal information on our behalf) or if we are required to do when you exercise certain rights under data protection laws. You should make sure to contact them directly to withdraw your consent for what they do with your personal information as a data controller in their own right.

If you withdraw any consent to processing data in connection with the group employee incentive arrangements operated by Walden Group, it may prejudice your ability to participate in these arrangements.

Is your personal information transferred outside Ireland or the EEA?

We are based in Ireland but sometimes your personal information may be transferred outside Ireland or the European Economic Area. If your personal information is processed within Europe or other parts of the European Economic Area (EEA), then it is protected by European data protection standards. Some countries outside the EEA do also have adequate protection for personal information under laws that apply to us. We will make sure that suitable safeguards are in place before we transfer your personal information to countries outside the EEA that do not have adequate protection under laws that apply to us, except in cases where what are called ‘derogations’ apply. Your personal information may be transferred to countries in which Walden group operates including but not limited to Morocco.

Walden Group have inter-company standard contractual clauses in place to cover international transfers of information within the group of companies.

For more information about suitable safeguards and (as relevant) how to obtain a copy of them or to find out where they have been made available you can contact us using the details above.

What should you do if your personal information changes?

It is important that the personal information we hold about you is accurate and current. You should tell us without delay about any changes to your personal information so that we can update our records. The contact details for this purpose are: your local HR manager or HR generalist or by responding to this email .

Do you have to provide your personal information to us?

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).

Do we do any monitoring involving processing of your personal information?

In this section, monitoring means any listening to, recording of, viewing of, intercepting of, or taking and keeping records (as the case may be) of calls, email, text messages, social media messages, in person face to face meetings and other communications.

We may monitor where permitted by law and we will do this where the law requires it. In particular, where we are required by applicable law record certain telephone lines or in person meetings (as relevant) we will do so.

Some of our monitoring may be to comply with regulatory rules, self-regulatory practices or procedures relevant to our business, to prevent or detect crime, in the interests of protecting the security of our communications systems and procedures, to have a record of what we have discussed with you and actions agreed with you, to protect you and to provide security for you and for quality control and staff training purposes.

Some of our monitoring may check for obscene or profane content in communications.

Telephone calls and/or in person meetings between us and you in connection with your application and employment with us may be recorded to make sure that we have a record of what has been discussed. We may also record these types of calls for the quality control and staff training purposes.

What about profiling and other automated decision making?

This section is relevant where we make decisions about you using only technology, and where none of our employees or any other individuals have been involved in the process.

We can do this activity based on our legitimate interests (and they are listed in the section about legal grounds above) only where the profiling and other automated decision making does not have a legal or other significant effect on you. In all other cases, we can do this activity only where it is necessary for entering into or performing the relevant contract, is authorised by laws that apply to us, or is based on your explicit consent. In those cases you have the right to obtain human intervention to contest the decision. Profiling for direct marketing can mean there is a separate right to object.

For how long is your personal information retained by us?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer an employee, worker or contractor of the company (and do not hold any awards under any employee incentive arrangements) we will retain and securely destroy your personal information in accordance with applicable laws and regulations. In event that you are not considered successful for the role, we will keep your information for the minimum amount of time necessary after decision unless you agree otherwise for us to hold your details on file for future roles in the Walden Group or wish to revoke consent at any stage in future

Your Personal Data will not be stored for longer than necessary for the purposes for which they were collected or as required under applicable retention policies and/or in accordance with applicable law. Our retention practices reflect local statute of limitation periods and national statutory obligations of Walden Group. This retention period may be extended if Walden Group is required to preserve your personal data in connection with litigation, investigations and proceedings, or if a longer retention period is required by applicable law.

What are your rights under data protection laws?

Here is a list of the rights that all individuals have under data protection laws. They do not apply in all circumstances. If you wish to exercise any of them we will explain at that time if they are engaged or not. The right of data portability is only relevant from May 2018.

The right to be informed about your processing of your personal information;
The right to have your personal information corrected if it is inaccurate and to have incomplete personal information completed;
The right to object to processing of your personal information;
The right to restrict processing of your personal information;
The right to have your personal information erased (the “right to be forgotten”);
The right to request access to your personal information and to obtain information about how we process it (see below for further details);
The right to move, copy or transfer your personal information (“data portability”);
Rights in relation to automated decision making which has a legal effect or otherwise significantly affects you.

You have the right to complain to the Irish Data Protection Commission’s Office which enforces data protection laws: https://www.dataprotection.ie/docs/Contact-us/b/11.htm

You may exercise these rights free of charge. However, Walden Group may charge a reasonable fee or refuse to act on a request if it is manifestly unfounded or excessive, in particular because of its repetitive character. In some situations, the Walden Group may refuse to act or may impose limitations on your rights if, for instance, your request is likely to adversely affect the rights and freedoms of others, prejudice the execution or enforcement of the law, interfere with pending or future litigation, or infringe applicable law. In addition, prior to acting upon any of rights, the Walden Group takes reasonable steps to verify your identity. In all cases, you have a right to file a complaint with a Supervisory Authority.

What about data anonymisation and use of aggregated information?

Your personal information may be converted into statistical or aggregated data which cannot be used to re-identify you. It may then be used to produce statistical research and reports. This aggregated data may be shared and used in all the ways described in this privacy notice.

What about data privacy notices from other organisations?

We have mentioned that we may share your personal information with governmental, competent or regulatory authorities, credit reference agencies or other background check agencies. They require us to pass on to you information about how they will use your personal information to perform their services or functions as data controllers in their own right. These notices are separate to our own.

How do we secure your personal data?

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from GM-Privacy@Walden-Group.com .

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

How do you request access to your personal data?

In the first instance, you should make any request for access to GM-Privacy@Walden-Group.com.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, and in exceptional circumstances only, we may refuse to comply with the request in such circumstances.

ANNEX I – Walden Group entities