Job Applicant Fair Processing Notice

JOB APPLICANT FAIR PROCESSING NOTICE

Ingevity’s commitment to your privacy

This fair processing notice (“Statement”) is addressed to anyone who applies for, or enquires in relation to, a job opportunity at Ingevity Corporation or any other members of the Ingevity Group (“Ingevity”, “us”, “we”). As your potential employer, we are committed to protecting the privacy and security of your personal data. This Statement gives you information about how we will collect and use your personal data and comply with the applicable data privacy laws, including but not limited General Data Protection Regulation (“GDPR”). It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

Data Protection Principles

We will comply with all applicable data protection law. This states that the personal information we hold about you must be:

Used lawfully, fairly and in a transparent way;
Collected and processed only for specific, explicit and legitimate purposes;
Adequate, relevant and limited to the purposes we have told you about;
Accurate and kept up to date;
Kept only as long as necessary; and
Kept securely.

Information we may collect from you

We may collect the following types of personal data during the application process directly from you or through our third-party contractor, Workday:

Personal contact details such as your name, social name, address, telephone numbers and personal email address and identity details such as your date of birth, gender, marital status and emergency contact information.
Your registration details such as your username and password;
All details included in your CV, covering letter or application, such as your education and employment history.
Details regarding your citizenship status, residency and/or other visa information or eligibility to work in a country.
Your academic and professional information such as your academic history, job titles, salary, school attended, employee files, evaluations, professional references, interviews and certifications.
Any information you or a third party provider provides to us during the recruitment and selection process, including background screening checks and other test results if these form part of the selection process.
The contents of e-mails exchanged between you and us and feedback on your application and any subsequent interview notes.
Preferences related to job location and salary.
Offered terms and conditions of employment.
Working preferences and feedback in relation to Ingevity and our staff.
Preferences in relation to our use of your personal data.
Photographs if provided and CCTV footage from our premises.
Your visa and passport and a copy of each as needed.
Conflicts of interests (including where related to family networks).
Background checks relating to employment history, credit information, social media.
Information about your bank account, and financial status such as your personal income.
Previous and/or offered salary, compensation and other remuneration.
National insurance number and/or other government identification numbers.
Tax codes.

In addition, we may collect, hold and use the following categories of personal data about you that are of a sensitive nature (“Sensitive Personal Data”):

Information about your physical or mental health (including occupational health requirements, accident reports, day-to-day health concerns such as diabetes or epilepsy conditions which we should be aware of, dietary requirements, allergies, drug and alcohol test results and reasons for any short term or long term absence).
Information about your race or ethnicity.
Trade union membership.
Biometric data such as that contained on official identification photographs.
Information relating to actual or suspected criminal convictions and offences or related security measures.

Information that we may collect about you from third parties and other sources

Periodically, we may collect personal data relating to you from the following third parties:

former employers
references
regulatory authorities
pre-employment screening service providers

We may also collect personal data relating to you from the following public sources:

LinkedIn, Indeed, and other public and social media websites.
Public company registries
Criminal or tax records

Why we need your information

This section explains the purposes for which we process your personal information.

We may use your personal information in the following circumstances to:

Assess your skills, qualifications and suitability for a role and make a decision about suitable candidates for available roles within Ingevity, whether through our website or other methods of making recruiting decisions
Carry out background and reference checks
Check you are legally entitled to work
Communicate with you about the recruitment process
Comply with health and safety obligations
Allow for equal opportunities monitoring
Draft employment agreements that will be concluded if you are hired.
Contact you regarding other job vacancies or opportunities that arise within the Ingevity Group.
Monitor the overall level of interest in job vacancies and opportunities and to carry out relevant analysis
Ensure your security whilst you are on our premises and the security of our premises and staff.
Investigate any complaints received from you or from others, about us, our service providers, or the application process

Upon receipt of your CV and/or application, we will process the information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to invite you to interview, we will use the information you provide us at the interview stages to decide whether to offer you a role. If we decide to offer you a role, we will then take up references, which may include a drug test, criminal record check, and a health assessment before confirming your appointment.

Our lawful bases for processing your personal information

We will rely on one or more of the following lawful bases for processing your personal information:

it is necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract with you;
it is necessary for compliance with a legal obligation to which we are subject; and/or
it is necessary for the purpose of our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Our legitimate interests include, making informed recruitment decisions and selecting suitable candidates for available roles, facilitating the interview process, checking you are legally entitled to work, communicating offers of employment and in ensuring the security of our premises and staff. You can obtain further information about these legitimate interests and how we have made sure that these legitimate interests do not override your rights and interests by contacting us at the contact address below.

We may also use your personal information with your consent when contacting you about other job vacancies.

How we use Sensitive Personal Data

We may use your Sensitive Personal Data in the following circumstances:

to ascertain your fitness to work;
to run a criminal background check;
to comply with health and safety obligations;
to conduct equal opportunities monitoring;
to ensure racial and ethnic diversity at senior levels;
to prevent fraud and other unlawful acts;
to gather evidence for possible grievance hearings;
to deal with legal disputes involving you, our employees, workers and contractors, including accidents at our premises; and/or

We will rely on one or more of the following Article 6 GDPR lawful bases for processing your Sensitive Personal Data:

it is necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract with you;
it is necessary for compliance with a legal obligation to which we are subject; and/or
it is necessary for the purpose of our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Our legitimate interests include our interest in, having employees that are suitable for the job, and defending and exercising our legal rights. You can obtain further information about these legitimate interests and how we have made sure that these legitimate interests do not override your rights and interests by contacting us at the contact address below.

Furthermore, we will rely on one or more of the following Article 9 GDPR lawful bases for processing your Sensitive Personal Data:

your explicit consent;
for the purposes of carrying out our obligations and exercising our specific rights under EU employment law;
it is necessary for the establishment, exercise or defense of legal claims;
it is necessary for reasons of substantial public interest; and/or
it is necessary for assessing whether you are fit to work.

We may also rely on the following UK-specific legal bases, where applicable:

it is necessary for performing or exercising obligations or rights imposed on or granted to us by employment laws;
it is necessary for equal opportunities purposes; and/or
it is necessary for promoting or maintaining diversity in senior positions at Ingevity; and/or
to prevent or detect an unlawful act.

If you fail to provide personal information

If you fail to provide certain information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we may not be able to process your application successfully. For example, if we require a criminal record check or references for a role and you fail to provide us with relevant details, we will not be able to take your application further.

Disclosure of personal data

We may also share your personal data with the following third parties:

Other companies within Ingevity for purposes connected with your employment or the management of Ingevity’s business.

We may disclose your personal data to these parties in their capacity as our service providers. These parties are under contract to Ingevity and are bound by terms of confidentiality and we will, as required by applicable law, ensure that your privacy rights are adequately protected by appropriate technical, organisation, contractual or other lawful means. We do not allow service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

In some contexts, we may disclose the personal data to the following controllers who will be directly responsible under data protection law for using your personal data lawfully.

Third party service providers, consultants and websites in the recruitment field;
Our legal adviser for the purpose of providing legal advice to us;
Our internal and external auditor for the purpose of providing audit services to us;

We may need to share your personal data with a regulator or to otherwise comply with the law.

International transfers of personal data

The personal data that we process about you may be transferred to one or more countries outside the European Economic Area ("EEA") which have not yet been deemed by the European Commission to offer adequate data protection ("Third Countries"). Specifically, your application and any additional information you provide to us will be added to our international recruitment database located in the United States. This recruitment database will be accessible to selected Ingevity employees relevant to the recruitment process and will be shared with third parties acting on behalf of Ingevity who may be located in Third Countries.

We have an intra-group data transfer agreement in place between members of the Ingevity Group to ensure that any transfers of personal data being transferred out of a member of an Ingevity Group member that is based in the EEA is adequately protected in line with EU law. This agreement incorporates standard contractual clauses approved by the European Commission that require members of the Ingevity Group that are based outside of the EEA to treat your personal data in line with EU law. If you wish to obtain a copy of the intra-group data transfer agreement, please contact us using the contact details below.

Personal data may be transferred to the following Third Countries:

The United States;
China;
Japan;
South Korea;
Thailand;
India; and
Brazil

Automated decision-making

An initial automated decision may be taken if an applicant:

is not yet 18 years of age,
is unable to provide proof of lawful eligibility to live and work in the country where employment is offered;
is unwilling to agree in the application process to complete a drug screen test if an offer of employment is made that is contingent on passing a drug screen test;

We do not envisage that any decisions other than those detailed above will be taken about you using automated means. In the event that this position changes, we will notify you in writing.

Failure to Provide Personal Information

Retention of personal data

We will keep your personal data only for so long as is necessary and for the purposes for which it was originally collected and in line with our Corporate Company Retention Guidelines. If you are successful in your application your personal information will be retained until termination of your employment and then in accordance with our Corporate Company Retention Guidelines. If you are unsuccessful, we will retain your personal information for 24 months after communicating this fact to you. We will only keep personal information for longer periods where we need to do so to comply with legal or regulatory obligations or where we anticipate we will need to keep it to defend against legal claims or exercise our legal rights.

Your rights under UK and EU data protection law

In certain circumstances, under UK and EU data protection law you will have the right to:

Request access to your personal data.
Request rectification of your personal data if it is inaccurate or incomplete.
Request deletion of your personal data if there is no reason for its continued processing.
Restrict the processing of your personal data (for example, if you want us to establish its accuracy or the reason for processing it).
Object to the processing of your personal data being processed.
Request the transfer of your personal data to another party.
Withdraw your consent to processing, in the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose. Once we have received notification that you have withdrawn your consent, they will no longer process your information for the purpose or purposes you originally agreed to, unless they have another legitimate basis for doing so in law. Please note that the withdrawal of your consent will not affect the lawfulness of any processing of personal data based on your consent before its withdrawal.

If you want to exercise any of the above rights, please contact us using the contact details given below.

Contact

If you have any questions concerning this Statement or the policies or procedures referred to above, please contact Ingevity's Privacy Office at [email protected].

If you are dissatisfied with any aspect of our handling of your personal data, you have a right to lodge a complaint with your local EU data protection authority. You can find the contact details of your local EU data protection authority at https://edpb.europa.eu/about-edpb/board/members_en. If you are in the UK, the relevant data protection authority is the Information Commissioner's Office (https://ico.org.uk/make-a-complaint/).

Our Affiliates

We are controllers in respect of the personal data we collect about you for the purposes of applicable data privacy law, including but not limited to the UK and EU. This means that we are responsible for deciding the purpose for, and the means by which we process your personal data. For the purpose of this Statement, our affiliates identified at the bottom of this Statement are also joint controllers in respect of the personal data (in that they jointly determine the purpose for which the personal data is processed and the means by which the personal data is processed) and the Statement is also issued by us on behalf of these affiliates.

When our affiliates, Ingevity Holdings Sprl and Ingevity UK Ltd (each being a "European Ingevity affiliate") assess your suitability for certain positions in their company, they will share your application with Ingevity Corporation. The European Ingevity affiliate and Ingevity Corporation will be joint controllers of your personal information as both companies will use that information to form a joint decision on whether or not to hire you. In general, the European Ingevity affiliate and Ingevity Corporation will be separately responsible for treating your personal information in line with applicable European data privacy law (including the obligation to keep it secure). However, it is up to the European Ingevity Affiliate to make this privacy notice available to you and to make sure that the personal information they provide to Ingevity Corporation is accurate. Also, both the European Ingevity Affiliate and Ingevity Corporation will be jointly responsible for responding to any request you make about exercising your rights in relation to your personal information.

For the purposes of this Statement, the following companies within the Ingevity Group will be joint controllers of the personal data:

Ingevity affiliate	Contact details
Ingevity Holdings Sprl	www.ingevity.com - T: +32 2 775 97 30
Ingevity UK Ltd	www.ingevity.com - T: +44 0 1925 591111

Updates to this Statement

We reserve the right to update this Statement and any other relevant policies or procedures at any time. Any substantial changes that we may make to this Statement in the future will be posted on this page. We may also notify you in other ways from time to time about the processing of your personal data.