1.0 Introduction
We, Bulletproof (a trading name of Defense.com Cyber Ltd also referred to in this document as “we”, “us”, “controller”) take the protection of your personal data very seriously and strictly adhere to the rules laid out by data protection laws and the General Data Protection Regulation (GDPR-EU and GDPR-UK).
This privacy notice gives you information on how we collect and process your personal data through your use of Teamtailor and any data you may provide if you contact us regarding recruitment and hiring.
We have appointed a data protection officer (DPO) who is responsible for monitoring and providing guidance with our GDPR status. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO/us using the contact information in section 15 of this privacy notice.
2.0 Why we Collect your personal information
We collect your personal data for one of the following purposes:
· To manage the recruitment and hiring process
· To manage the onboarding and employee lifecycle process
3.0 Lawful Basis Of Processing Information
We only collect and use personal information about you when the law allows us to. The lawful basis of the processing of your personal data is consent.
We will request your consent to keep your personal data beyond an initial 6 month retention period (or 30 days for those candidates sourced or referred ).
4.0 What Information we collect and where from
We collect personal information from you, through the Teamtailor website. The categories of personal information that we may collect, store and use about you includes:
- Name, address, telephone number, email.
- Information from Facebook, LinkedIn and other social media accounts
- Your country of birth, nationality.
- Date of birth and gender.
- Passport details, national insurance number.
- Personal information you may provide to us during the course of the recruitment process.
- Racial or ethnic original
- Religious or philosophical beliefs
- Data concerning sex life or sexual orientation.
4.1 Special Category Data
We ask you not to provide any special category data (as described below) when uploading your details on this platform.
To the extent that you may upload this data, we will only process special category data where we have an Article 9 exception allowing us to do so, in this case, this is explicit consent. You will be asked to provide your consent during the application process.
4.2 Third Party Collection of Personal Data
We may also collect your data through Third Parties such as Recruitment agencies., Defense.com Cyber Employees, LinkedIn, social media and recruitment websites.
5.0 How Long we Keep Information For
We pride ourselves on ensuring that your personal data is only retained for the period that we need it for, or in accordance with laws, regulations and professional obligations that we are subject to. All personal information collect has a defined retention period, which is in-line with our retention policy. The information collected in Teamtailor is retained as follows:
Candidate data is initially kept for 6 months if the candidate is classified as an active candidate i.e. they are moving through the recruitment process and haven’t been rejected.
If a candidate is rejected, their personal data will be flagged for deletion after 5 days from the date of rejection and 7 days after being flagged for deletion, the data will be removed.
If a candidate is classified as inactive (e.g. no actions or notes have been added to their profile), their personal data will be flagged for deletion after 30 days from the date of the last activity and 7 days after being flagged as inactive, the data will be removed.
Any candidate that submits a removal request will be flagged for deletion 1 day after the request is made and removed 7 days after being flagged for removal.
Active candidates, or referred/sourced candidates, can opt in for us to keep their personal data for 6 months. If candidates do not respond to a request to extend the retention period beyond 6 months, they will be flagged for deletion after the opt-in message and removed 7 days after this.
Data is backed up however backups are deleted on a 28 day cycle.
6.0 Security of personal information
We take the responsibility for protecting your privacy very seriously and we will ensure your data is secured in accordance with our obligations under the Data Protection laws. We have in place technical and organisational measures to ensure personal information is secured and to prevent your personal data from being accessed in an unauthorised way, altered or disclosed. We have in place a robust access control policy which limits access to your personal data to those employees, contractors and other third parties who only have a business need to know. The processing of your personal data will only take place subject to our instruction.
We have policies and procedures to handle any potential data security breaches and data subjects, third parties and any applicable regulators will be notified where we are legally required to do so.
We have achieved ISO 27001 certification and we are Cyber Essentials and Cyber Essentials Plus certified.
We have ensured that all employees have had information security and data protection training. If you would like more details of the security we have in place, please see "additional information", section 17 of this policy.
7.0 Children's information
We do not knowingly collect information on children. If we have collected personal information on a child, please contact us immediately using the details in section 15, so we can remove this information without any undue delay.
8.0 Your individual rights
In this Section, we have summarised the rights that you have under General Data Protection Regulation. Some of the rights are complex, and not all the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
Your principal rights under General Data Protection Regulation are:
- Right to Restrict Processing
Right to Data Portability
- Processing relies on legitimate interest
- Processing is for scientific or historical research
- Processing includes automated decision making and profiling
- Processing is for direct marketing purposes
The right of access
- You or any third party acting on your behalf with your authority may request a copy of the personal data we hold about you without charge.
- We will ask to verify your identity or request evidence from the third party that they are acting on your behalf before releasing any personal data we hold about you.
The right to be informed
- We are required, to provide clear and transparent information to you about how we process your personal data. This privacy notice addresses this right.
The right of rectification
- If you believe the personal data we hold about you is incorrect or incomplete you have the right to correct this and you may exercise this right along with the right to restrict processing until these corrections are made.
The right to erasure
- If there is no legal basis or legitimate reason for processing your personal data, you may request that we erase it.
The right to restrict processing
- You may ask us to restrict the processing of your personal data. This means we will still hold it but not process it. This is a conditional right which may only be exercised when:
- We no longer need the personal data, but it is required for a legal process
- You have exercised your right to object to processing and require processing to be halted while a decision on the request to object is made.
- If you are exercising your right to rectification
The right to data portability
- You can request that your personal data is transferred to another controller or processor in a machine-readable format if:
- Processing is based on consent
- Processing is by automated means (i.e. not paper based)
- Processing is necessary for the fulfilment of a contractual obligation
The right to object
You can exercise this right if
o Processing relies on legitimate interest
o Processing is for scientific or historical research
o Processing includes automated decision making and profiling
o Processing is for direct marketing purposes
The right of access
o You or any third party acting on your behalf with your authority may request a copy of the personal data we hold about you without charge.
o We will ask to verify your identity or request evidence from the third party that they are acting on your behalf before releasing any personal data we hold about you.
The right to be informed
o We are required, to provide clear and transparent information to you about how we process your personal data. This privacy notice addresses this right.
The right of rectification
o If you believe the personal data we hold about you is incorrect or incomplete you have the right to correct this and you may exercise this right along with the right to restrict processing until these corrections are made.
The right to erasure
o If there is no legal basis or legitimate reason for processing your personal data, you may request that we erase it.
The right to restrict processing
o You may ask us to restrict the processing of your personal data. This means we will still hold it but not process it. This is a conditional right which may only be exercised when:
o Processing is unlawful
o We no longer need the personal data, but it is required for a legal process
o You have exercised your right to object to processing and require processing to be halted while a decision on the request to object is made.
o If you are exercising your right to rectification
·The right to data portability
o You can request that your personal data is transferred to another controller or processor in a machine-readable format if:
o Processing is based on consent
o Processing is by automated means (i.e. not paper based)
o Processing is necessary for the fulfilment of a contractual obligation
If you have any question about these rights, please see "additional information", section 17 of this policy.
9.0 Consent
Where you have given consent for processing, or explicit consent in relation to the processing of special category data, you have the right to withdraw this consent at any time, but this will not affect the lawfulness of processing based on consent before its withdrawal.
10.0 Failure To Provide Personal Information
Where we need to collect personal data in order to process your application and you fail to provide that data when requested, we may not be able to continue with your application. In this case, we will notify you if this is the case at the time.
11.0 Cookies
Cookies are used on this website. You can control whether you want to accept the use of these cookies via the cookie consent options on the website.
For more information about the cookies used, please see our Cookies Policy.
12.0 Transfers To Third Parties
We may disclose your personal data, listed in section 4 to some third parties to help us deliver our services/products. All third parties are contractually bound to protect the personal data we provide to them. We may use several or all of the following categories of recipients:
- Business partners, suppliers, contractors for the performance of any contract we enter into with them or you
- Companies within our group where necessary for administrative purposes and to provide services to you
- Third parties that support us to provide products and services e.g. IT support, cloud-based software services, providers of telecommunications equipment
- Professional advisors e.g. lawyers, auditors
- Web analytics and search engine provider to ensure the continued improvement and optimisation of our website
13.0 Transfers Outside Of The UK and EEA
In this section, we provide information about the circumstances in which your personal data may be transferred and stored in countries outside the UK or European Economic Area (EEA).
We may share personal information to third parties outside of the UK or European Economic Area (EEA). Any personal information transferred will only be processed on our instruction and we ensure that information security at the highest standard would be used to protect any personal information as required by the Data Protection laws.
Where personal data is transferred outside of the UK or EEA to a country without an adequacy decision, we will ensure appropriate safeguards are in place prior to the transfer. These could include:
Standard Contractual Clauses
Binding Corporate Rules
An exception as defined in Article 49 of the GDPR
For more information about transfers and safeguarding measures, please contact us using the information in section 17.
14.0 Right to complaint
We take any complaints about our collection and use of personal information very seriously.
If you think that our collection or use of personal information is unfair, misleading, or inappropriate, or have any other concern about our data processing, please raise this with us in the first instance.
To make a complaint, please contact us via email on dpo@defense.com.
Alternatively, you can contact us:
By Post: Unit 13, Gateway 1000, Whittle Way, Stevenage SG1 2FP
By Phone: 01438 500096
Alternatively, you can make a complaint to the Information Commissioner’s Office:
By Post:
Information Commissioners Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
By Website: Click Here
By Email: Click Here
By Phone: 0303 123 1113 (Local rate) or 01625 545 745 (National rate)
15.0 European Union Representation
For customers based in the EU, you may contact our representative at eu@defense.com.
If you wish to exercise your rights under the EU GDPR or have any questions regarding data privacy, please contact them on this email address.
16.0 Additional information
Your trust is important to us. That is why we are always available to talk with you at any time and answer any questions concerning how your data is processed. If you have any questions that could not be answered by this privacy policy or if you wish to receive more in-depth information about any topic within it, please contact our DPO and Compliance Team via email on dpo@defense.com.
17.0 Policy Review and Amendments
We keep this Policy under regular review. This Policy was last updated on 22/09/2022
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.