Who we are and this privacy notice
Sunamp is a fast-growing company with great opportunities for talented individuals to do their bit to combat climate change. We are subject to differing data protection regimes in the jurisdictions in which we operate. This notice applies to all Sunamp group companies and reflects our obligations to inform you about the types of personal data we process about you and what we do with your data when you apply for a role at Sunamp. This notice is supplemental to our global privacy notice which you can read here.
Our obligations to you when you apply for a role at Sunamp
In relation to your personal data, we will:
- process it fairly, lawfully and in a clear, transparent way
- collect your data only for reasons that we find proper for the course of the recruitment process and your employment in ways that have been explained to you
- only use it in the way that we have told you about
- ensure it is correct and up to date
- keep your data for only as long as we need it
- process it in a way that ensures it will not be used for anything that you are not aware of or have consented to (as appropriate), lost or destroyed.
Types of data we process
To manage and operate the recruitment process, we will collect the following personal data about you:
- your personal details including your name, address, date of birth, email address, phone numbers
- your photograph
- gender
- marital status
- whether or not you have a disability or some requirements we need to be aware of so we can create equal opportunities for all applicants
- information included on your CV/profile, application message or form including references, education history and employment history
- documentation relating to your right to work in the country where the applicable role is based
- driving licence, passport, residence permit.
How we collect your data
We collect data about you in a variety of ways including the information you would normally include in a CV or a job application cover letter or email, or notes made by our hiring managers during the recruitment process. Further information will be collected directly from you when you complete forms at the start of your employment, for example, your bank and next of kin details. Other details may be collected directly from you in the form of official documentation such as your driving licence, passport or other right to work evidence.
In some cases, we will collect data about you from third parties, such as employment agencies, former employers, credit reference agencies when gathering references or complying with our legal obligations.
Personal data is kept in personnel files or within Sunamp’s HR and IT systems. Access to these systems are limited to those who need it and they are password protected.
Why we process your data
We process your personal data where it is necessary to:
- contact you and respond to your enquiries or job applications to fulfil our contract with you
- perform the employment contract that we are party to
- carry out legally required duties
- carry out our legitimate interests whist balancing your fundamental rights and freedoms
- if we have your consent
- in cases of emergency to protect your life or that of another individual.
All of the processing carried out by us falls into one of the permitted reasons. Generally, we will rely on the first three reasons set out above to process your data.
We need to collect your data to ensure we are complying with legal requirements such as:
- carrying out checks in relation to your right to work in the country in which the role is based, and
- making reasonable adjustments for individuals in accordance with the Equality Act.
We also collect data so that we can carry out activities which are in the legitimate interests of Sunamp. We have set these out below:
- making decisions about who to offer employment to
- making decisions about salary and other benefits
- assessing training needs
- dealing with legal claims made against us or enforcing our legal rights.
If you are unsuccessful in obtaining employment, we will seek your consent to retaining your data in case other suitable job vacancies arise in Sunamp for which we think you may wish to apply. You are free to withhold your consent to this and there will be no consequences for withholding consent.
Special categories of data
Special categories of data are data relating to your:
- health
- sex life
- sexual orientation
- race
- ethnic origin
- political opinion
- religion
- trade union membership, and
- genetic and biometric data.
We must process special categories of data in accordance with more stringent guidelines. In countries where data protection regimes differ significantly, the definition of special or sensitive data may vary. Please see the global privacy notice for more information. Most commonly, we will process special categories of data when the following applies:
- you have given explicit consent to the processing
- we must process the data in order to carry out our legal obligations
- we must process data for reasons of substantial public interest
- you have already genuinely made the special category data public.
We will use your special category data:
- for the purposes of equal opportunities monitoring.
In some jurisdictions, we do not need your consent if we use special categories of personal data in order to carry out our legal obligations or exercise specific rights under employment law. However, we may ask for your consent to allow us to process certain particularly sensitive data. If this occurs, you will be made fully aware of the reasons for the processing. As with all cases of seeking consent from you, you will have full control over your decision to give or withhold consent and there will be no consequences where consent is withheld. Consent, once given, may be withdrawn at any time. There will be no consequences where consent is withdrawn.
Criminal conviction data
We will only collect criminal conviction data where it is appropriate given the nature of your role and where the law permits us. This data will usually be collected at the recruitment stage, however, may also be collected during your employment should you be successful in obtaining employment. We use criminal conviction data in the following ways:
- As it serves as evidence of exactly what you disclose during your interview process.
We rely on the lawful basis of consent to process this data.
If you do not provide your data to us
One of the reasons for processing your data is to allow us to carry out an effective recruitment process. Whilst you are under no obligation to provide us with your data, we may not able to process, or continue with (as appropriate), your job application.
Sharing and protecting your data
Your data will be shared with colleagues within Sunamp where it is necessary for them to undertake their duties about recruitment. This includes, for example, the HR department, personnel who are responsible for screening your application and interviewing you, the IT department where you require access to our systems to undertake any assessments requiring IT equipment.
In some cases, we will collect data about you from third parties, such as employment agencies.
Your data will be shared with third parties if you are successful in your job application. In these circumstances, we will share your data in order to obtain information such as references as part of the recruitment process and/or obtain a criminal records check etc.
Where we share your data with third parties, we provide written instructions to them to ensure that your data are held securely and in line with data protection requirements. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.
For more information about sharing and protecting your data please read the global privacy notice or (where available) the specific country privacy notice on our website.
How long we keep your data
In line with data protection principles, we only keep your data for as long as it is necessary and this will depend on whether or not you are successful in obtaining employment with us.
If your application is not successful and we have not sought consent or you have not provided consent upon our request to keep your data for the purpose of future suitable job opportunities at Sunamp, we will keep your data for one month once the recruitment exercise ends.
If we have sought your consent to keep your data on file for future roles at Sunamp, and you have provided consent, we will keep your data for 6 years in line with our HR Data Retention Policy and once the recruitment exercise ends. At the end of this period, we will delete your data, unless you have already withdrawn your consent to our processing of your data in which case it will be deleted upon your withdrawal of consent.
If your application is successful, your data will be kept and transferred to the systems we administer for employees. We have a separate privacy notice for employees, which will be provided to you.
Automated decision making
Depending on the role, we may make some decisions about you based on automated decision making (where a decision is taken about you using an electronic system without human involvement). This may include AI software or psychometric testing at screening stages, for the basis of proving technical abilities. Where appropriate and if required by applicable law, we will always inform you prior to making any decisions using automated decision making.
Your rights in relation to your data
The data protection laws in the country in which you reside may entitle you to specific rights in relation to your personal data and this notice does not take away those rights nor establish rights or obligations which are additional to those prescribed in the applicable local data protection law.
For more information about your rights please read the global privacy notice or (where available) the specific country privacy notice on our website.
In the UK and the European Union, the law on data protection gives you certain rights in relation to the data we hold on you. These are:
- the right to be informed. This means that we must tell you how we use your data, and this is the purpose of this privacy notice
- the right of access. You have the right to access the data that we hold on you. To do so, you should make a subject access request
- the right for any inaccuracies to be corrected. If any data that we hold about you is incomplete or inaccurate, you are able to require us to correct it
- the right to have information deleted. If you would like us to stop processing your data, you have the right to ask us to delete it from our systems where you believe there is no reason for us to continue processing it
- the right to restrict the processing of the data. For example, if you believe the data we hold is incorrect, we will stop processing the data (whilst still holding it) until we have ensured that the data is correct
- the right to portability. In some situations, you may transfer the data that we hold on you for your own purposes
- the right to object to the inclusion of any information. You have the right to object to the way we use your data where we are using it for our legitimate interests
- the right to regulate any automated decision-making and profiling of personal data. You have a right not to be subject to automated decision making in way that adversely affects your legal rights.
Where you have provided consent to our use of your data, you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. We will let you know if withdrawing your consent to process your data means we are not able to continue the recruitment process with you.
If you wish to exercise any of the rights explained above, please email [email protected]
Contacting us and additional information for some countries
If you wish to raise a complaint on how we have handled your personal data, you can contact [email protected] and we will investigate the matter.
In some jurisdictions you have the right to make a complaint to an external regulator.
For more information please read the global privacy notice or (where available) the specific country privacy notice on our website.
Changes to this notice
To ensure we reflect what we do with your personal data or any change to our legal obligations, we will review and may change this notice from time to time. Any changes we make will be posted on our website and, if appropriate and possible, notified to you. Please check back frequently to see any updates or changes.
Version Date: 11 February 2025
