Application and Recruitment Privacy Notice
Job Applicants and individuals going through Recruitment at Otsuka
Otsuka Pharmaceutical Europe Limited and its affiliates (“Otsuka”) respects your right to privacy.
The data controller of your personal data is Otsuka Pharmaceutical Europe Ltd which is registered with the Information Commissioner’s Office with registration number Z9584844.
Your personal data will be processed according to applicable legislation, including the Data Protection Act 2018 and the UK GDPR. You should read this Notice, so you know what personal data we collect about you, what we do with it and how you can exercise your rights in connection with it. You should also read any other Notices that we give you, that might apply to our use of your personal data in specific circumstances from time to time.
In this Notice, when we talk about personal data, we mean any information that relates to an identified or identifiable person – in this case, you. It applies to job applicants, whose personal data are processed during recruitment and pre-employment screening activities.
Please be aware that we have a separate Notice, which deals with the processing of personal data related to employees in an employment context.
We may collect personal data about you from a variety of sources, including directly from you (for example, when you share your CV with us directly or you apply for a position, which is advertised on social media or other recruitment platforms); and from other sources, such as recruitment agencies or third parties who assist us in pre-screening activities.
Otsuka may collect and use some or all of the following categories of personal data for the purpose(s) described below:
- Basic information – your name (including prefix or title), gender, age or date of birth;
- Contact information – information you provide to us that allows us to contact you, for example your personal or business email, mailing address, telephone number, and profile on a professional social media platform;
- Professional information and experience – information related to your education, work experience, references and referees;
- National identifiers – your national ID/passport, residence and work permit status, social security number, or other taxpayer/government identification number;
- Financial information – your salary, retirement account information, company allowances, bonus, benefits, working time records, and taxpayer reference number (e.g. tax identification number, national insurance number, social security number). We will also collect your bank details if we reimburse you for expenses during the recruitment process.
- Information collected during interviews – comments noted by our interviewers and audio/video recordings of the interview (in case of telephone interviews or video-enabled interviews).
- Background information – education and academic information as well as professional qualifications. If we want to offer you the job, we may need to complete pre-employment screening. We may then also collect additional background information such as credit history, criminal records and occupational health information (if permitted by law).
- Special categories of personal data – information related to your racial or ethnic origin, religious, political or philosophical beliefs, trade union membership, or information about your health, disabilities or sexual orientation. We use this information to make sure we meet relevant laws. If we offer you employment, we may also ask you for information about your health (physical or mental) so we can give health and insurance benefits to you and your dependents. We will also use this information to discuss with you what reasonable adjustments we can make for you. We want to make sure we can provide an inclusive workplace.
Special categories of personal information will only be collected if strictly necessary and legally permitted. If we ask you for special categories of personal information, you can decide whether to share this information. If you decide not to share these with us, please be assured this does not affect your application.
We process the personal data listed above for the following purposes and legal bases, which may vary depending on where you live and where we operate:
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To consider your application, including:
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Consent for processing (Art. 6 (1) a) where you have given us your permission when such permission is obligatory. You can withdraw your permission at any time. Processing is necessary for the performance of a contract (Art. 6 (1) b) for example, before entering an employment contract or perform an employment contract. Compliance with a legal obligation (Art. 6 (1) c) for example, employment, social security and occupational health laws and regulations. Processing is necessary to protect your vital interests or those of others (Art. 6 (1) d). Processing is necessary for purposes of legitimate interests pursued by us (Art. 6 (1) f) for example, it is in our interests in considering you as a candidate for current and future employment opportunities. This does not apply if our legitimate interest is overridden by your interests or fundamental rights and freedoms. |
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For pre-employment screening, including:
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To include you in our talent pool, including:
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To manage and improve our recruitment process, including:
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To achieve other purposes, including:
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We disclose your personal data to the following categories of recipients:
- to our group companies, third party services providers and partners who provide data processing services to us, or who otherwise process personal information for purposes that are described in this Notice or notified to you when we collect your personal data;
- to any competent law enforcement body, regulatory, trade association, government agency, court or other third parties where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights (on the basis of our interest in the defence of our rights), or (iii) to protect your vital interests or those of any other person;
- to a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal data only for the purposes disclosed in this Notice (on the legal basis of our legitimate interest in ensuring the business operation);
- to any other person with your consent to the disclosure.
These recipients of your personal data may be acting on our behalf or as data controllers in their own right.
We use appropriate technical and organisational measures to protect the personal data that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the categories of personal data processed.
We may transfer your personal data to other Otsuka group companies, service providers and partners located outside of the United Kingdom or the European Economic Area (“EEA”) (as appropriate), for example in the USA or Japan. Please note that countries outside of the United Kingdom or the EEA may not provide the same level of protection for your personal data. Where we transfer your personal data outside of the United Kingdom or the EEA, we ensure that appropriate safeguards are put in place and that all transfers of your personal data comply with applicable data protection laws.
The appropriate safeguards that Otsuka uses are based on the model clauses approved by the Information Commissioner’s Office and the European Commission. To find out more about how we safeguard your information in relation to data transfers outside the United Kingdom or the EEA, please contact us using the details in the ‘How to contact us?’ section below.
We retain personal data we collect from you for 6 months after the application and recruitment process has ended for the purposes listed above. In limited circumstances, we may need to retain your personal data for longer because of legal or regulatory requirements.
You have a number of rights which apply to the use of your personal data. The availability of these rights depends upon the lawful basis for processing your personal data and your rights may also be subject to certain conditions and restrictions. These rights are:
- Right to withdraw consent
- Right to information
- Right of access
- Right to rectification
- Right to erasure (also ‘right to be forgotten’)
- Right to restriction of data processing
- Right to data portability
- Right to object
For more information on the rights that you have, please click here or go to https://otsukaprivacy.eu/data-subject-rights.
You also have the right to complain to a data protection authority about our collection and use of personal data. For more information, please contact your local data protection authority. A list of data protection authorities in the European Economic Area is available
We may decide to change this notice. If the change is fundamental or may significantly affect you, we will provide you with the updated notice in advance of the change actually taking effect. We encourage you to review the content of this notice regularly.
Should you have any questions in regards to the protection of your personal data or if you wish to exercise your legal rights, please submit your query
Date of preparation: October 2024 | OPE-NPR-2400071 (v1.0)