Prime Microfinance Limited

Recruitment Privacy Notice

Overview

This recruitment privacy notice ("Privacy Notice") relates to the collection, storage, use and disclosure of your personal data by Prime Microfinance Limited (referred to in this Privacy Notice as PRIME, we or us) throughout the recruitment process including through the careers website https://www.primemicrofltd.com/careers ("Careers Site"). PRIME MICROFINANCE acts as controller for personal data collected for recruitment purposes.

We take our data protection obligations seriously and it is important to us that you understand how we use your personal data. This Privacy Notice sets out in detail the purposes for which we process your personal data, who we share it with, what rights you have in relation to that data and everything else that we think it is important for you to know.

This Privacy Notice only applies to the personal data of job applicants, potential candidates for employment, and our optional recruiting programs and events (referred to as you in this Privacy Notice). It does not apply to our employees, contractors or clients, or other personal data that PRIME MICROFINANCE collects for other purposes.

This Privacy Notice is supplemental the general terms and conditions and privacy policy of the PRIME MICROFINANCE website which are available at https://www.primemicrofltd.com/terms (the “General Terms and Conditions”). You should read the General Terms and Conditions as they contain important terms applying to your use of our website, in particular how we may bar your access to the our website and/or the Careers Site.

This Privacy Notice covers, among other things, the following:

  • What information do we collect?
  • How do we collect information about you?
  • How do we use your information?
  • What is the legal basis that permits us to use your information?
  • How do we share your information?
  • How long do we keep your information?
  • How do we keep your information secure?
  • Your rights in relation to your information
  • Complaints

From time to time we may change the way we use your personal data. If we make any substantial changes in the way we use your personally identifiable information, we will notify you by posting a prominent announcement on the Careers Site and/or the Site as applicable.

Contact details

PRIME's contact details are as follows:

Address: PRIME MICROFINANCE, No 20 Morocco Lane, Indepence Avenue, Accra, Ghana
Telephone: +233 209280693

We have appointed a Data Protection Officer whom you can contact using the following details:

DPO@primemicrofltd.com

What information we collect

The information we collect will include your personal data, which means information that can be used to identify you, which may include but not be limited to your contact information, such as your home address and contact details (including your mobile telephone number), your date of birth; your educational and professional qualifications, your right to work, visa status, employment status; and any other information about you that you disclose to us during the application process.

The personal data that we collect about you may also include special categories of personal data, such as information about your racial or ethnic origin, criminal or alleged criminal offences, sexual orientation or your health and lifestyle where applicable to the recruitment process including where necessary to accommodate any disability needs. PRIME MICROFINANCE will seek your express consent to process your special categories of personal data.

If you fail to provide us with this information, or you object to us processing such information (see the below for more information about your rights in relation to your information) the consequences are that we may be prevented from progressing your application.

How do we collect personal data?

We collect your personal data when you submit a job application to us via email or if you choose to submit a job application or CV to us in any other way.

In considering your application we may also obtain information from third party sources, including any referees that you specify, educational institutions and publicly available sources including [LinkedIn, Facebook and Google+] (“Social Network Sites”) when you choose to provide us with a link to your profile on any Social Network Site as part of your job application.

We may also obtain your contact details from publicly available sources, including content that you have made public on other Social Network Sites or similar sites for professional purposes to make initial contact with you for recruitment purposes. If we contact you in this way you will be given the opportunity to opt out of receiving any further information about career opportunities with PRIME MICROFINANCE and you can subsequently opt out at any time by contacting bacbhr@primemicrofltd.com.

Your personal data may be provided to PRIME MICROFINANCE by recruitment agencies with who you have registered an interest in working for PRIME MICROFINANCE. If you are a recruitment agency you should, in particular, make sure that all of the information in this Privacy Notice is communicated to the applicant.

If you give us information about other individuals - for example, referees - or you are providing information about applicants to us in your capacity as a recruitment agency, you must first make sure that the individual knows that you might disclose information about them (either specifically to us or, at least, to potential employers).

How we use your information

The information we collect and process will be used in order to:

  • to consider and process any application that you make for any particular job with PRIME MICROFINANCE including to identify and contact you;
  • to determine whether you have the professional skills, expertise and experience for the position applied for;
  • if you are offered a position with PRIME MICROFINANCE, to verify the personal data provided including your identity, address, right to work, employment history and academic background and other background screening purposes including, where allowed by law, criminal record checks, searches with a credit reference agency and sanctions screening checks;
  • to assist in the administration of PRIME's recruitment programme, recruitment campaign planning, and compliance with related internal policies;
  • to provide you with information about other job vacancies if you would like PRIME MICROFINANCE to send you such notifications; and
  • for statistical purposes.

If successful in the employment process any information provided through the recruitment process may form the basis of your personnel record with PRIME MICROFINANCE and may be used for the purposes of administering your employment, benefits and training with the PRIME MICROFINANCE, ensuring your health and safety and to fulfil PRIME's responsibilities as an employer. You will receive further information about such processing as applicable.

What is the legal basis that permits us to use your information?

We have described the purposes for which we may use your information. We are permitted to process your information in this way, in compliance with applicable data protection legislation, by relying on one or more of the following lawful grounds:

  • you have explicitly agreed to us processing your information for a specific reason;
  • the processing is necessary to perform an agreement we already have with you, or to take steps to enter into an agreement with you (e.g. contract of employment);
  • the processing is necessary for compliance with a legal obligation we have; or
  • the processing is necessary for the purposes of a legitimate interest pursued by us, which might be to protect our business interests; or to evaluate, develop or improve our services.

In relation to special categories of personal data, we will generally rely on your specific consent in order to process such information (including data relating to health or criminal offences); although it may be necessary for us to use certain information in order to comply with our legal obligations.

Sharing your information

In order to consider any application that you make to PRIME MICROFINANCE, we may transfer your personal information to our representative offices in countries outside the European Economic Area (“EEA”) and to third party service providers.

You should be aware that in territories outside the EEA, data privacy laws and practices are likely to be different and may be less stringent than those within the EEA. In such cases, we will ensure that there are adequate safeguards in place to protect your personal data that comply with our legal obligations.

We may also share your personal information with:

  • law enforcement agencies, other governmental agencies or third parties if we are required by law to do so; and
  • other business entities should we plan to merge with or be acquired by that business entity, or if we undergo a re-organisation with that entity.

The Bank takes all reasonable steps to keep Staff personal data confidential. PRIME's staff will only have access to your personal data to the extent necessary in order to fulfil their legal obligations or for the proper administration of PRIME MICROFINANCE. The following categories of the PRIME's staff may process your personal data:

  • PRIME's Human Resources team;
  • PRIME's management team.

Monitoring demographics

PRIME MICROFINANCE may keep a record of your race, ethnic origin, sexual orientation, religion, sex or disability for equal opportunity monitoring purposes. We may publish this information but only as an aggregate statistic and not in any way that could identify you individually (unless you specifically consent).

Automated decision-making and profiling

We do not carry out automated decision making or profiling in relation to recruitment

How long we retain your personal data

If your application for employment is unsuccessful then we may continue to hold information and opinions about you and your applications after any application process is complete, in case we need to consult it in the future if you make another application or become a PRIME MICROFINANCE employee, if a dispute arises about an application that you have made or in order to contact you if potentially suitable job opportunities become available in the future.

We will delete or anonymise your information after 6 years or sooner if we no longer need it, although we may continue to hold purely statistical information which does not identify you.

How we protect your information

We take all reasonable steps to keep your information secure and confidential including by monitoring appropriate technical security measures.

We will not usually disclose personal data about you to any person outside PRIME MICROFINANCE, other than or otherwise in a way that is inherent to the nature of our business.

Your rights in relation to your information

You should note that you have the right to access, modify or delete any information concerning your personal profile in compliance with applicable data protection legislation. To access or correct any inaccuracies in your personal details you may do so by contacting bacbhr@primemicrofltd.com.

Where you have consented to our processing of your personal data (including special categories of personal data) you may withdraw your consent at any time, by contacting bacbhr@primemicrofltd.com copying in DPO@primemicrofltd.com to request that we stop using your personal data.

Please note that in certain circumstances it may be still lawful for us to continue processing your personal data even where you have withdrawn your consent if such processing is required and is in accordance with one of the other legal bases described above.

If at any stage you would like to withdraw an application or remove your CV and please let us know by sending an email to bacbhr@primemicrofltd.com.

Complaints

If you have any complaints about the way we use your personal data please contact our Data Protection Officer at DPO@primemicrofltd.com who will try to resolve the issue. If we cannot resolve your complaint, you have the right to complain to the data protection authority the Information Commissioner which regulates and supervises the use of personal data in the UK, via their helpline on +233 209280693.