This Privacy Statement applies to all personal data about prospective employees (including contractors, temporary, part-time, secondees or similar) (“you”) that is collected, maintained or used by directors, officers, managers and employees of any Prosus Group company (“we/us”) as part of current or prospective recruitment activities.

Personal data collected, maintained or used outside of the recruitment activities, such as personal data arising from your use of our consumer products or commercial offerings by the Prosus Group, is not covered by this Policy.

Nothing in this Policy is intended to form a contract of employment or otherwise. At our discretion and as necessary, we may amend this Policy from time to time. We will notify you appropriately when updates are made.

This Privacy Statement does not cover the processing of personal data of employees of the Prosus Group as this is covered in the HR Privacy Policy that is communicated separately to employees.
 

We generally process the following personal data about you over the course of recruitment:

• Your biographical information, including your name, gender, date of birth, previous job history in the context of a CV/resume, education details, languages, professional certifications, qualifications or memberships and nationality;
• Your contact information, including your home and postal address, telephone number, email address, country of residence;
• Your identification numbers, including government-issued identification number or passport information, if required for completion of background checks, offers of employment and visa and work permit processes;
• Feedback from interviews and other engagements in the course of recruitment;
• Information from references that you share us with;
• Salary expectations, family situation and property details, if relevant for relocation discussions;
• If mandated by local laws, for instance in South-Africa, we may collect information about your racial or ethnic origin, to comply with diversity regulations. In such case, we will endeavour to collect only the minimum amount of personal data required to comply with such laws.

We collect personal data about you directly from you, or from the recruitment agency that has obtained your permission to provide us with your personal data. We may also contact you through publicly available sources (e.g. career networks such as LinkedIn). In any event, we will ask for your specific permission for us to process your personal data, regardless of the source of your information.

We may also use other sources, subject to restrictions under applicable law, to assist in obtaining relevant personal data about you, in particular in the context of pre-employment screening as described in Section 4 below.
 

Prosus is committed to the reliability and professionalism of its employees. Therefore, in the final phase of the recruitment process, Prosus engages a third party, such as HireRight to complete pre-employment background checks (screening). You will be specifically informed about the scope and background checks and you will be requested to provide your specific permission to complete such pre-employment screening activities.

The background checks will comprise at the minimum the verification of academic and professional qualifications, previous employment, ID document, running checks against global watchlists and where permitted, completion of an international criminal records verification. For executive positions, we may run additional checks related to directorship positions, registration with financial supervisory authorities and limited adverse media verification. The third party completing the background checks retains your personal data for a limited period of time necessary to complete the checks and we receive information on successful completion of the pre-screening or limited information necessary to clarify any issues detected.
 

Generally, Prosus Group companies process your personal data because it is necessary to initiate and complete the recruitment between you and the company, and where our legal duties as a prospective employer require it.

We will seek your explicit consent for keeping your personal data in our recruitment database, either in the context of on-going recruitment activities or for creation of talent pools for prospective recruitment. In such case, you may revoke your consent at any time, by using the functionality of our Applicant Tracking System or by contacting your global recruitment contact person.

In limited circumstances, we may process your personal data where it is necessary for us to defend, prosecute or make a claim in a court of law. We may also process personal data for something called “legitimate interests” under European law, in particular in the context of protection of security of our IT assets, our premises and our members of staff. In practice, this means that we must put in place appropriate privacy safeguards to ensure that we are respecting your interests, as well as your fundamental rights.
 

Your personal data may be used for the following recruitment-related purposes:

• To contact you and manage the recruitment process, schedule, complete and appraise interviews and other engagements with you;
• To assess your legal eligibility for work and complete background-checks;
• To store emails and documents generated in the context of the recruitment activities in our secure Applicant Tracking System;
• To prepare and discuss any potential offer of employment and prepare the required employment contract documentation;
• To manage the Prosus Group recruitment activities, in particular in the context of ensuring diversity, benchmarking remuneration, ensuring proper succession planning and HR strategy;
• To comply with our legal obligations in the context of recruitment, in particular regarding monitoring and ensuring equal employment opportunities, in respect of gender, ethnicity and racial origin.
• For statistical analysis and research purposes in the context of recruitment, including predictive modelling and people planning.

Your personal data will be shared within our Group for the purposes described in Section 6 above to the extent necessary to carry out these purposes, and as permitted by law.

We are a global Group with a global footprint. Note that your personal data may be processed either in the jurisdiction of the Prosus Group company involved in your recruitment, or in any other jurisdiction where we or our approved third-party service providers operate, worldwide, depending on the needs of the business over the course of the recruitment process, to the extent necessary and as permitted by law. Should your personal data move outside the European Economic Area or another jurisdiction that restricts the international transfer of personal data, we use GDPR- and locally-compliant mechanisms to require that the same level of data protection be applied in the jurisdiction where the data is being processed.

Your personal data will only be shared outside our Group with third parties under the following circumstances: (1) where a third-party service provider retained by us is under contract to assist in administering our recruitment and/or IT activities, subject to appropriate confidentiality obligations and data processing agreements, compatible with this Privacy Statement; (2) with government authorities only when we have determined that we are required to do so under applicable laws; (3) to anticipate or defend legal claims; or (4) where you have given us your prior permission to do so.

We use a third party Applicant Tracking System (Lever) to manage your personal data securely in the context of the recruitment activities, subject to appropriate confidentiality and data processing requirements.
 

• SUBJECT ACCESS: You have the right to access your personal data in many circumstances, generally within 1 month of your request


• RECTIFICATION: You can ask us to have inaccurate personal data amended


• WITHDRAWAL OF CONSENT: You can withdraw any consents to processing that you have given us and prevent further processing if there is no other legitimate ground upon which Prosus can process your personal data


• ERASURE: You can ask us to erase personal data in certain circumstances, recognising that Prosus must in any case respect its data retention legal obligations in the field of recruitment


• RESTRICTION: You can require certain personal data to be marked as restricted for processing in certain circumstances
• RAISE A COMPLAINT: You can raise a complaint about our processing with the data protection regulator in your jurisdiction, or with our Data Protection Office (see Section 10 below).

Pursuant to the permission you have given us, we will store your personal data in our Applicant Tracking System for the duration of the recruitment activities. Unless you are starting your employment with the Prosus Group, with your consent, we will store your personal data for a duration of initial 12 months after the completion of the recruitment process or for inclusion in a talent pool. We will then contact you via e-mail to provide you with the opportunity to update your personal data or revoke your consent. In such case your personal details will be deleted as soon as possible.

In any event, we will not store your personal data beyond the subsequent 12 months period, unless you provide us with an explicit permission or you take part in an on-going recruitment process.
 

The controller of your personal data is Prosus Services B.V. located at Gustav Mahlerplein 5, 1082 MS Amsterdam. The Prosus Group's supervisory authority is the Dutch data protection authority (Autoriteit Persoonsgegevens (Autoriteit Persoonsgegevens – https://autoriteitpersoonsgegevens.nl

To exercise your data subject rights, or if you have questions about this Privacy Statement, please send an email to our Data Protection Office at: [email protected]

If there are any updates or changes to this Privacy Statement, we will notify you appropriately.