Privacy notice — job applications
Effective date: [to be added: date]
Version: 1.0
1. Who we are
This Privacy Notice explains how [to be added: Constructive legal company name], a company registered in [to be added: country of registration] under commercial registration number [to be added: CR number], with its registered office at [to be added: registered address] ("Constructive", "we", "us" or "our"), collects, uses, stores and protects the personal data of people who apply for jobs through this careers website or by email ("you").
For the purposes of applicable data protection law, Constructive is the controller of your personal data.
If you have any question about this Notice or about your personal data, please contact us:
- Email: [to be added: privacy contact email]
- Post: [to be added: postal address], marked "Data Protection — Recruitment"
- Data protection officer (where appointed): [to be added: name or role]
2. Scope
This Notice applies to personal data processed in connection with:
- applications submitted through constructiveintl.humanforceai.com/jobs-open;
- CVs and applications sent to our recruitment email address; and
- our recruitment and selection process that follows.
It does not apply to the personal data of employees, which is covered by a separate notice.
3. Personal data we collect
3.1 Data you provide to us
- Identity and contact data: full name, email address, telephone number, and city and country of residence.
- Professional data: CV or résumé and its contents, years of experience, current job title, education, qualifications, certifications, languages, employment history, and any cover note.
- Application data: the position applied for, the date of the application, your answers to screening questions (for example, willingness to relocate or to work remotely), and the reference number we assign.
- Consent records: whether you agreed to be contacted on WhatsApp, and when you accepted this Notice.
3.2 Data collected automatically
- Technical data: the Internet Protocol (IP) address and the date and time of submission. We use these only to protect the application form against spam, fraud and misuse.
- We do not use advertising or tracking cookies on the careers pages.
3.3 Sensitive personal data
We do not ask for sensitive personal data, such as data revealing religion, ethnic origin, health, biometric data, criminal records or political opinions. Please do not include it in your CV or application. If you include it voluntarily, we will process it only as strictly necessary for your application, or delete it.
3.4 Data from third parties
Where permitted by law and relevant to the role, we may receive information about you from referees you name, or from recruitment agencies acting on your behalf.
4. Why we use your personal data and our legal basis
| Purpose | Legal basis |
|---|---|
| Receiving, reviewing and assessing your application for the position you applied for | Your consent, given when you submit the form; and steps taken at your request before entering into an employment contract |
| Considering you for other suitable current or future positions at Constructive | Your consent, which you may withdraw at any time |
| Contacting you about your application by telephone, email or WhatsApp | Your consent |
| Arranging interviews and assessments | Steps taken at your request before entering into a contract |
| Protecting our systems and the application form from spam, fraud and misuse | Our legitimate interest in keeping our services secure, where the applicable law recognises this basis |
| Complying with legal obligations and responding to lawful requests from authorities | Compliance with a legal obligation |
| Establishing, exercising or defending legal claims | Compliance with law and our legitimate interests, as permitted by applicable law |
We will not use your personal data for purposes that are incompatible with those listed above.
5. Automated processing and the use of artificial intelligence
To handle a high volume of applications, we use software, including artificial-intelligence tools, to:
- read CVs;
- extract information such as experience and qualifications;
- match applications to the requirements of our open positions; and
- produce a match score that helps our recruitment team prioritise their review.
No decision to reject, shortlist or hire is taken by automated means alone. A member of our human-resources team reviews applications and makes every decision. You may ask us for information about the logic involved in this processing, ask for a human review of how your application was assessed, and express your point of view, by contacting us at the address in Section 1.
6. Who we share your personal data with
We share your personal data only as necessary for the purposes in Section 4, with:
- our recruitment and hiring personnel, and the managers responsible for the position;
- our service providers acting as processors on our instructions, under written agreements requiring confidentiality and appropriate security. These include:
- our recruitment-software and technology provider ([to be added: Constructive Technology Solutions / provider name]);
- our hosting provider ([to be added: hosting provider name]);
- providers of artificial-intelligence services used to read and match CVs ([to be added: provider name]);
- companies in the Constructive group, where the position or a suitable alternative is with that company; and
- public authorities, courts or regulators, where we are required to do so by law.
We do not sell your personal data and we do not share it for marketing purposes.
7. International transfers
Your personal data may be stored and processed outside your country of residence, including in [to be added: server country] and in the countries where our service providers operate.
Where we transfer personal data across borders, we do so in accordance with applicable law. This includes, where required, obtaining any necessary authorisation, relying on an adequacy decision, or putting in place appropriate safeguards such as contractual clauses that provide an adequate level of protection.
8. How long we keep your personal data
We keep your personal data only for as long as necessary for the purposes in Section 4:
- If you are hired: your application data becomes part of your employee record and is governed by our employee privacy notice.
- If you are not hired: we keep your application for as long as we may reasonably consider you for current or future positions, unless you ask us to delete it sooner, or for any longer period required by law or needed to defend legal claims.
- Technical data used for security is kept for a short period and then deleted or anonymised.
When personal data is no longer needed, we delete it securely or anonymise it.
9. How we protect your personal data
We use appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, misuse, alteration or disclosure. These include:
- encryption in transit;
- access controls limited to authorised personnel;
- activity logging;
- scanning and safe handling of uploaded files; and
- regular backups.
No system is completely secure. If a personal data breach occurs that is likely to affect your rights, we will notify you and the competent authority where required by law.
10. Your rights
Subject to the conditions and exceptions in applicable law, you have the right to:
- be informed about how we process your personal data, as set out in this Notice;
- access your personal data and obtain a copy of it;
- correct inaccurate or incomplete personal data;
- delete your personal data, or request that its processing be restricted;
- withdraw your consent at any time. This includes asking us to stop contacting you on WhatsApp or by any other channel, or to stop considering you for other positions. Withdrawal does not affect processing that took place before it;
- object to processing based on our legitimate interests;
- request a human review of any assessment made with the help of automated tools; and
- lodge a complaint with the competent data protection authority. These include:
- in Egypt, the Personal Data Protection Center;
- in Saudi Arabia, the Saudi Data and Artificial Intelligence Authority (SDAIA);
- in the United Arab Emirates, the UAE Data Office.
To exercise your rights, contact us using the details in Section 1 and quote your application reference number if you have one. We may need to verify your identity before acting on your request. We will respond within the period required by applicable law, and in any case within [to be added: 30] days of receiving your request.
11. Age requirement
Our positions are open only to persons aged 18 or over. We do not knowingly collect personal data from anyone under 18. If we learn that we have done so, we will delete it.
12. Accuracy of the information you provide
By submitting an application, you confirm that the information you provide is accurate and complete to the best of your knowledge. Providing false or misleading information may lead to your application being rejected or, if discovered after hiring, to action in line with applicable law.
13. Changes to this Notice
We may update this Notice from time to time to reflect changes in law or in our practices. The current version, with its effective date, is always available on this page. Where changes are significant, we will take reasonable steps to inform applicants whose applications are still active.
14. Governing language
This Notice may be provided in more than one language. If there is any inconsistency, the [to be added: English] version prevails, to the extent permitted by applicable law.