Ozone Project Recruitment Privacy Notice
Ozone Project Limited (“Ozone” or “we”) is an AdTech company headquartered in the UK that provides advertising systems on behalf of Publishers. We take privacy seriously and are committed to ensuring we process your data fairly and lawfully. This Privacy Notice explains how we process your personal information that we receive or collect.
This Privacy Notice sets out, in line with GDPR, the types of data that we collect and process on you as a job applicant. It also sets out how we use the information, how long we keep it for, and other relevant information about your data.
Where we collect your data from
Ozone collects and processes data:
Provided directly from you
From a professional third party whom we have engaged to help us look for suitable candidates (this might be via a recruitment firm, or headhunter for example)
From a friend, acquaintance or colleague (referral)
We may use a Credit Reference Agency to help confirm your identification
We will also collect your personal data from named referees
Processing your data
As part of processing your data lawfully, we need to tell you the reason we are processing your data and all of the following:
The lawful basis we use, which allows us to process your data.
What types of data we process (within categories of personal data)
How long we process your data (retention period), or how we determine this period.
Where we process your data, and whom we share your data
The Purposes
To assess your suitability for a job you have applied for
Ozone collects and processes your personal data when you apply for, or we receive your application for a job with us.
For this purpose, we process some or all of the data detailed under ‘categories of personal data'
Lawful basis
Ozone relies on the lawful basis of “processing necessary to perform a contract or to take steps at your request, before entering a contract
Retention Period
Ozone retains your data for this purpose for a period of 6 months from the date of an appointment for the role you apply for.
Legal Obligations placed upon Ozone as an Employer
Ozone is required by the following laws to collect information about your entitlement to work in the UK, as well as data necessary for ensuring we recruit staff fairly.
Equality Act 2010
Health and Safety at Work Act 1974
Employment Rights Act 1996
The immigration, Asylum and Nationality Act 2006
For this purpose, we process some or all of the data detailed under ‘data concerning health’ and ‘data relating to your right to work in the UK’ under Categories of personal data.
Lawful basis
Ozone relies on legal obligation for this purpose, and a further condition for special category data (see below).
Retention Period
We retain your data for this purpose for 6 months from the date of receipt of your application.
Categories of personal data
Your contact details
Your name, address and contact details, including email address and telephone number;
Details of your employment history (your CV)
Previous employers, dates of employment, qualifications and training, name, address, email and telephone numbers, and general work history, or any information you provide on your CV.
Data concerning health
We process data about your health, for example, to understand if you have a disability which Ozone needs to make reasonable adjustments for during the recruitment process.
Data relating to your right to work in the UK
Ozone processes information about your entitlement to work in the UK, for example, your passport details, identification card details, VISA details, or any other form of id which may be suitable, including details of your racial and ethnic origin and date of birth. We also process data for equal opportunities monitoring.
Special Category Condition
In addition to having a lawful basis of ‘Legal Obligation to process some of your data, Ozone also has to satisfy a further condition, where it is necessary to process special category data (sensitive data), and this condition is in article 9 (b) and 9 (h) GDPR. The data that we may process under this category is ethnicity and racial origin as well details about your health.
“processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law in so far as it is authorized by Union or Member State law”
“Processing is necessary for the assessment of the working capacity of the employee”
Ozone also processes your data under the UK DPA 2018 – schedules Schedule 1: parts 1 and schedule 1, part 2 (b), which relates to processing for employment, and the assessment of your working capacity.
Who we share your data with?
Ozone uses a number of service providers or categories of service providers to help us fulfill our business interests as well as our legal obligations as an employer. Where these service providers are Controllers in their own right, we call this sharing your data. This means that when we share your data with them, they have their own purposes and obligations, and you should therefore refer to their Privacy Policy for details on how they process your data.
Runway East (our office provider) when accessing our offices in London
Referees, which whom you have given permission to contact
Law enforcement or regulatory bodies, courts and public authorities, if we were required to share by law.
Information Commissioners Office – www.ico.org.uk If required for an investigation.
To see more detail on who we share data with, please see our main privacy policy here.
Where is your data processed?
Ozone stores personal data in Google data centers in Europe.
Your Rights
Your right of access.
If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
Your right to rectification.
If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
Your right to erasure.
You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
The right to erasure, sometimes knows as the right to be forgotten, is not an absolute right. This means, that although we may be able to delete your personal information for a specific purpose, we may still have to process your data under a legal obligation. The lawful basis used to process your data, is often the measure that will dictate to what extent we can delete all or some of your data.
Your right to restrict processing.
You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
Your right to data portability.
You have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine-readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
Your right to object.
You can ask us to stop processing your personal information, and we will do so, if we are:
relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
processing your personal information for direct marketing
Your rights in relation to automated decision-making and profiling.
You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.
Your right to withdraw consent.
If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time. To withdraw your consent, please email privacy@ve.com or contact your HR department.
Your right to lodge a complaint with the supervisory authority.
If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the UK Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.
Confidentiality and security of your personal information
We are committed to keeping secure your personal information and we will take reasonable precautions to protect your personal information from loss, misuse or alteration.
Changes to this Privacy Notice
We may make changes to this Privacy Policy from time to time.
To ensure that you are always aware of how we use your personal information we will update this Privacy Policy from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We will notify you by e-mail of any significant changes. However, we encourage you to review this Privacy Policy periodically to be informed of how we use your personal information.