Twingate Applicant & Candidate Privacy Notice
Last Updated: August 22, 2022
This Applicant & Candidate Privacy Notice (“Notice”) covers the information you share with Twingate Inc. or its affiliated companies (“Twingate”, “we”, “us” or “our”), or which may be acquired or produced by us during the job application or recruitment process.
This Notice explains:
- What information we collect during our application and recruitment process and why we collect it
- How we use that information
- What rights you have with respect to that information
Information We Collect
During the application and recruitment process, we may collect:
- Your name, address, email address, phone number and other contact information
- Your resume or CV, cover letter, previous and/or relevant work experience or other experience, education, transcripts, or other information you provide to us in support of an application and/or the application and recruitment process
- Information from any interviews, phone screenings and other assessments you may have
- Details of the type of employment you are or may be looking for, current and/or desired salary and other terms relating to compensation and benefits packages, willingness to relocate, or other job preferences
- Details of how you heard about the position you are applying for
- Sensitive and/or demographic information, such as gender, information about your nationality, and/or your racial or ethnic origin (which you may voluntarily choose whether to provide)
- Reference information and/or information received from background checks (where applicable), including information provided by third parties
- Information relating to any previous applications you may have made to Twingate and/or any previous employment history with Twingate
- Information about your educational and professional background from publicly available sources, including online, that we believe is relevant to your application or a potential future application (e.g. your LinkedIn profile)
- Information related to any assessment you may take as part of the interview screening process
How Information is Used
Your information will be used by Twingate for the purposes of carrying out our application and recruitment processes, which may include:
- Assessing your skills, qualifications and interests against our career opportunities
- Verifying your information and carrying out reference checks and/or conducting background checks (where applicable) if you are offered a job
- Communications with you about the recruitment process and/or your application(s), including, in appropriate cases, informing you of other potential career opportunities at Twingate
- Creating and submitting reports as required under any local laws or regulations, where applicable
- Where requested by you and agreed by Twingate, assisting you with obtaining an immigration visa or work permit where required
- Making improvements to Twingate’s application and recruitment processes including improving diversity in recruitment practices
- Complying with applicable laws, regulations, legal processes or enforceable governmental requests
- Proactively conducting research about your educational and professional background and skills and contacting you if we think you would be suitable for a role with us
We may also use your information to protect the rights and property of Twingate, our users, applicants, candidates, employees, or the public as required or permitted by law.
If you are offered and accept employment with Twingate, the information collected during the application and recruitment process will become part of your employment record.
Legal basis for processing your information (EU & UK)
If EU or UK data protection law applies to the processing of your information, please be aware that:
- We collect and process your personal data where it is necessary in order to take steps, at your request, prior to our potentially entering into a contract of employment with you.
- We may also seek your consent to process your personal data in specific circumstances, or process it where necessary to comply with a legal obligation or for purposes connected to legal claims.
- If we use your information to improve our application or recruitment process, we do so on the basis that it is in our legitimate interest to ensure we recruit the best possible candidates.
Who Your Information May Be Shared With
- Your information may be shared with our affiliates who are located in the US and other jurisdictions, in relation to the purposes described above.
- If you have been referred for a job at Twingate by a current Twingate employee, we may let that employee know about the outcome of your application.
- In some cases, if it is identified that you have attended the same university/school or shared the same previous employer during the same period as a current Twingate employee we may consult with that employee for feedback on you.
- Twingate may also use service providers acting on our behalf to perform some of the services described above, including for assistance in performing verification or background checks. These service providers may be located outside the country in which you live or the country where the position you have applied for is located.
- Twingate may sometimes be required to disclose your information to external third parties such as to local labor authorities, courts and tribunals, regulatory bodies and/or law enforcement agencies for the purpose of complying with applicable laws and regulations, or in response to legal process.
- We will also share your personal data with other third parties if we have your consent (for example, if you have given us permission to contact your referees), or to detect, prevent or otherwise address fraud, security or technical issues, or to protect against harm to the rights, property or safety of Twingate, our users, applicants, candidates, employees or the public or as otherwise required by law.
- It is your responsibility to obtain consent from referees before providing their personal information to Twingate.
Twingate operates globally, which means your information may be stored and processed outside of the country or region where it was originally collected including in the United States. In some of these countries, you may have fewer rights in respect of your information than you do in your country of residence. Regardless of where your information is processed, we apply the same protections described in this policy. We also comply with certain legal frameworks relating to the transfer of data, such as the European frameworks described below. The European Commission has determined that certain countries outside of the European Economic Area (EEA) adequately protect personal data. You can review current European Commission adequacy decisions on the European Commission website. To transfer data from the EEA to other countries, such as the United States, we comply with legal frameworks that establish an equivalent level of protection with EU law.
- Standard contractual clauses. The European Commission has approved the use of standard contractual clauses as a means of ensuring adequate protection when transferring data outside of the EEA. By incorporating model contract clauses into a contract established between the parties transferring data, personal data is considered protected when transferred outside the EEA or the UK to countries which are not covered by an adequacy decision. We may rely on these standard contract clauses for certain data transfers.
Twingate takes appropriate security measures designed to protect information about you that is collected, processed, and stored as part of the application and recruitment process.
If you apply for a job at Twingate and your application is unsuccessful (or you withdraw from the process or decline our offer), Twingate will retain your information for a limited period after your application. We retain this information for various reasons, including in case we face a legal challenge in respect of a recruitment decision; and based on our legitimate interest to consider and contact you for other current or future job opportunities at Twingate, and to help us better understand, analyze and improve our recruitment processes.
If you do not want us to retain your information for consideration for other roles, or want us to update it, please contact privacy [at] twingate.com. Please note, however, that we may retain some information if required by law or as necessary to protect ourselves from legal claims.
Your Rights in Respect of Your Information
In certain countries, you may have certain rights under data protection law. This may include the right to request access or to update or review your information, request that it be deleted or anonymized, or object to or restrict Twingate using it for certain purposes.
If you wish to exercise a right of access please contact privacy [at] twingate.com. We will respond to any requests in accordance with applicable law, and so there may be circumstances where we are not able to comply with your request.
Alternatively, if you are a resident of the EEA or UK and wish to exercise your rights with respect to your information, you may contact DataRep, which is Twingate’s Data Protection Representative in the EU and the UK. DataRep can be contacted using the following details:
- Web form: https://www.datarep.com/data-request
- Email: email@example.com (you must also quote “Twingate Inc.” in the subject line)
- Mail (Ireland): DataRep, The Cube, Monahan Road, Cork, T12 H1XY, Republic of Ireland
- Mail (UK): DataRep, 107-111 Fleet Street, London, EC4A 2AB, United Kingdom
- Mailing addresses for other EU countries are available upon request to privacy [at] twingate.com
If you are in the EEA or the UK and can’t find the answer to your question in this Notice, you can contact Twingate Privacy Team at privacy [at] twingate.com. Depending on your country of residence, you may also raise any questions or concerns you have regarding your personal information with your local data protection authority.
Changes to this Notice
We may change this Notice from time to time. We will post any changes to this Notice on this page. Each version of this Notice is identified by its “Last Updated” date.