EMPLOYMENT CANDIDATE PRIVACY POLICY


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EMPLOYMENT CANDIDATE PRIVACY POLICY


We take your privacy seriously and are committed to safeguarding your personal information at Emaar Properties PJSC (which term includes all subsidiaries of Emaar Properties PJSC). ("Company", "we" or “us” or “Emaar”) respect your privacy and are committed to protecting it through our compliance with this policy.

Introduction

This policy describes the sources of your personal data that we may collect from you or that you may provide to us and our practices for collecting, using, maintaining, protecting and disclosing that information.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our platforms. By accessing or using our platforms, you agree to this privacy policy.

If you have any questions or concerns about this privacy policy or your personal information, please contact us using the details provided in Section - ‘How do you contact us?’.

What information we collect about you?

The information we collect on or through our platforms in the recruitment context may include:

  • Name, address, telephone number, email address, date of birth and other contact details;

  • Competences, skills, experience and education, e.g. your CV or resume, previous employments, educational details and qualifications, third party references.

  • Languages spoken, Citizenship and Nationality to enable us to check your suitability for a specific role and working location.

  • Preferences, e.g. preferred country of employment, areas of interest as well as your preferred ways to be contacted by us.

  • Your online user identity, e.g. user names and other such information used in connection with authenticating you to our online recruitment management system.

  • Information collected during interviews: As part of our interview process we may maintain audio/ video records of the interview (in case of telephone interviews or video enabled interviews) as well as comments noted by our interviewers.

  • Other information, such as information found from public sources as well as information related to reference checks, depending on the position you are applying for, and where necessary for the recruitment activities.

  • Additionally, once you have been shortlisted, we may collect additional information such as Government ID, expectation of compensation and remuneration details, information relating to your family members (for benefits administration), passport, visa and work permit (in case of expatriate), background check reports including educational, employment and criminal checks etc. where permitted by local law.

    The sensitive personal data (by which we mean either special category personal data or data relating to criminal convictions and offences) collected may include:


  • Information relating to your Health: In certain instances, we may receive information related to health such as disability status to make any necessary accommodations during our interview process.

  • Data relating to criminal convictions and offences collected from background checks Information related to racial, ethnic origin or religious beliefs collected because of diversity surveys.

There is other information we may collect that does not directly reveal your specific identity or does not directly relate to you as an individual. We may automatically collect the following information when you use our service:

  • Your equipment, browsing actions and patterns collected automatically as you navigate through our websites.

  • Usage details, time of requests, Browser types, operating system, IP addresses and information collected through cookies, web beacons and other tracking technologies.

  • Details of your visits to our Website, including traffic data, location data, logs and other communication data and the resources that you access and use on the Website.,

What are the sources of your personal data?

The sources of your personal data collected (collectively referred as “Platforms” in this policy) may include without limitation the following:

  • Emaar websites: These are websites we created for you that are operated by us, they include websites operated by Emaar under our own domains and web addresses (URLs) and our own micro-sites that are part of a third-party social media networks such LinkedIn.

  • Emails, text messaging services, and other electronic messages: These are the electronic text-based interaction between you and Emaar.

  • Career Portal: These includes recruitment portal across Emaar.

  • Third Party Partners: These include through recruitment agencies and background verification agencies, which may also include public sources such as professional networking platforms.

  • Referrals: These include referrals from your friends, family of professional connects who work with us

This policy does not apply to information collected:

  • through any other means, including any other website operated by any third party; or

  • by any third party, including through any application or content (including advertising) that may link to the Website.

Why do we collect and how we use your personal information?

We use personal information for several legitimate interests, including to provide and improve our services, administer our relationship with you and our business.

  • Communicating with you, in context of recruitment activities in accordance with the legitimate business interests of the company:

    • To obtain additional information about your suitability for the role where necessary

    • To inform you of available vacancies;

    • To provide you with information relating to your application and to fulfil your requests.

  • Managing recruitment and resourcing activities, including activities related to organizational planning. During recruitment activities, we may use your information, in accordance with our legitimate business interests:

    • To set up and conduct interviews and assessments;

    • To evaluate, select and recruit applicants;

    • To contact third party referees provided by you to evaluate your previous performances.

    • In the event your profile is shortlisted, we may collect additional personal data (as mentioned in the previous section), to carry out background checks (in accordance with local law), facilitate travel for face to face interviews and to roll-out an employment offer letter.

  • Monitoring and development of our recruitment process - We may use your personal data to develop and improve our recruitment processes, websites and other related services. This is in accordance with our legitimate business interests to improve the services we provide. Where feasible, we shall use aggregated anonymous information in the context of such development activities.

  • Audit Compliance - We may process personal data as part of our audit processes and engage third party auditors, from time to time in accordance with the legitimate business interests of the company and/or where necessary in defence or exercise of our legal rights.

  • Accommodation for disabilities - In certain instances we may receive or request for information related to health such as disability status to make any necessary accommodations during our interview process. We shall process such information only based on your explicit consent.

  • Prevention of fraud – We may process your personal data for fraud prevention in pursuit of the legitimate interests of the company.

  • New employment opportunities - If you have expressed an interest in working for us in the future we may retain relevant documents collected during the recruitment process containing your personal data for future employment related opportunities

In the future, if we intend to process your personal data for a purpose other than that mentioned above, we will provide you with any other relevant information and obtain your consent where it is necessary to do so.

How to opt out?

    • Email: You can click on the unsubscribe link provided in the email you receive from us.

    • SMS: you can follow the instruction provided in the messages you receive from us

    • Applications: You may use the “opt out” option provided within the career portals

    • Contact us: You may contact us using the details provided in Section - ‘How do you contact us?’.

Who might we share this information with?

We may disclose personal information that we collect, or you provide as described in this privacy policy:

  • We may use carefully selected third parties to carry out certain activities to help us to run our business (such as cloud service providers, IT support vendors), to facilitate language tests (language assessment agencies), to carry out background checks (background verification agencies) to facilitate your travel and expense (travel and immigration vendors) and to facilitate audits (third party auditors).

  • We may share your personal information with any member of the Emaar group, including subsidiaries affiliates and holding companies, to conduct the activities described in this Privacy Policy. Such group companies are located outside the European Economic Area ("EEA"). Please visit here to see a list of the locations within our corporate group. Your information could be shared with our internal staff for screening and interview purposes.

  • Where required or permitted by law, personal information may be provided to others, such as regulators and law enforcement agencies.

  • We may share to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all the Company's assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by the Company about our Website users is among the assets transferred.

  • We may share with government or regulatory request to comply with any court order, law or legal process

The personal information that we collect from you may be transferred to, and stored at, a destination outside the EEA (for example, in Dubai). It may also be processed by staff operating outside the EEA who works for us or for one of our third-party vendors. We will take all steps that are reasonably necessary to ensure that your personal information is treated securely and in accordance with this privacy policy and applicable data protection laws, including, where relevant, entering EU standard contractual clauses (or equivalent measures) with the party outside the EEA receiving the personal information. We carry out such transfers to facilitate the performance of our contract and in pursuit of our legitimate business interests of helping us serve you better. We have implemented adequate safeguards to protect and secure the information involved in such transfers. Where we transfer personal information outside of EU, we either transfer personal information to countries that provide an adequate level of protection (as determined by the European Commission) or we have appropriate safeguards in place. Appropriate safeguards to cover these transfers are in the form of standard contractual/data protection clauses adopted by the European Commission.

If you would like more information on protection measures and transfer mechanisms, please contact us using the details provided in Section - ‘How do you contact us?’.

How long do we keep information about you?

We will only keep your personal information for as long as is reasonably necessary taking into consideration our need to screen CV’s, shortlist candidate profiles, facilitate interview discussions, any other purpose outlined above or to comply with legal requirements under applicable law(s). This means that we may retain your personal information for a reasonable period, for example, we may retain CV of potential candidates, that may not have been selected, for a period of 6 months to check for any suitable positions that may arise in the future and to keep you appraised on any potential opportunities. In certain cases, we may retain your personal information for a longer period where extended retention periods are required by law or regulation and to establish, exercise or defend our legal rights. We will ensure that it is disposed in a secure manner when it’s no longer needed.

You may choose to opt-out from receiving information about future career opportunities by contacting us using the options given in section - ‘How to opt out?’ of this policy. Once you opt-out Emaar will stop processing your personal data and delete it from our systems and hard copy documents.

For candidates who have accepted employment positions, we shall retain the personal data in line with our Data Retention policies available on our Emaar intranet portal and any legal or regulatory requirements.

For more information on where and how long your personal information is stored, and for more information on your rights of erasure and portability, please contact us using the details provided in Section - ‘How do you contact us?’.

How secure is your information?

Your personal data security is an important concern to us. We have implemented appropriate technical and organizational security measures, policies and procedures to protect your personal information from the accidental loss, unauthorized access, use, alteration and disclosure. All information you provide to us is stored on our secure servers behind firewalls: Measures we take includes:

  • Limiting access to your personal data, to our employees strictly on a need to know basis, such as to respond to your inquiry or request.

  • Implemented physical, electronic, administrative, technical and procedural safeguards that comply with all applicable laws and regulations to protect your personal data from unauthorized or inappropriate access, alteration, disclosure and destruction. It is important for you to protect against unauthorized access to your password and to your computer. Be sure to sign off when you are done using a shared computer.

  • Our employees who misuse personal data are subject to strict disciplinary action, as it is a violation of the Integrity Policy of Emaar.

  • Destroying or anonymizing personal information if it is no longer needed for the purposes for which it was collected; and

The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Existence of Automated Profiling and Decision Making

We use automated profiling, in limited circumstances as explained below:

  • In certain instances, while hiring individuals for senior leadership roles, we utilize an Emaar managed tool that aggregates publicly available data about the individual, analyses the text content, detects communication style, makes personality assumptions, and provides personality predictions, based on the person's writing style. This information shall be utilized by the recruitment team pursuant to our legitimate business interest to tailor our interview processes and communicate better with the candidate.

  • While hiring individuals for entry level positions, we utilize an Emaar managed web-based tool to facilitate the interview & recruitment process. The tool maintains video records of the interview process to create a Big Five psychology profile of candidate through voice & movement & vocabulary analysis. The Big Five psychology profile provides the analysis under 5 key personality traits such as ‘openness to experience’, ‘conscientiousness’, ‘extraversion’, ‘agreeableness’, and ‘neuroticism’. These insights of the profiling are utilized by the recruitment team pursuant to our legitimate business interest to help us take informed decisions while shortlisting our candidates.

We do not carry out any processing activities that involve automated decisions.

What are your rights?

If you are subject to laws that provide you with such rights, you may have certain rights in relation to your personal information given below.

If you wish to access any of these rights, we may ask you for additional information to confirm your identity and for security purposes, before disclosing personal information to you. We reserve the right to charge a fee where permitted by law, for example, if your request is manifestly unfounded or excessive.

If you would like to access the below rights, you may contact us by completing a form on our website or by mailing us at candidate. privacy@emaar.ae or sending us a communication to Data Privacy Office, PO Box 9440, Dubai, United Arab Emirates . We shall aim to comply with all requests within reasonable time in-line with applicable laws. We may not always be able to fully address your request, for example,

  • if it would impact the confidentiality we owe to others, or

  • if we are legally entitled to deal with the request in a different way. or

  • if your request involves deletion of information that are required to comply with the legal requirements.

We will make every reasonable effort to honour your request in-line with applicable laws. In the event we require additional time due to the complexity of the request, we shall promptly inform you of the same.

You have a right to:

  • Request access to your personal data and request details of the processing activities conducted by us.

  • Request that your personal data is rectified if it is inaccurate or incomplete

  • Request erasure of your personal data in certain circumstances.

  • Request restriction of the processing of your personal data by us in certain circumstances.

  • Object to the processing of your personal data in certain circumstances.

  • Receive your personal data in a structured, commonly used and machine-readable format in certain circumstances.

  • Lodge a complaint with the relevant supervisory authority.

  • Object to, and not to be subject to a decision based solely on, automated processing (including profiling), which produces legal effects or significantly affects you.

  • Withdraw any consent you have provided to us at any time by contacting us.

This policy may change from time to time. Your continued use of our platforms after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

How do you contact us?

In case of any queries related to this policy, you can contact our Data Privacy Office in one of the following ways.

  • Email us at candidate.privacy@emaar.ae

  • Call us at 800-EMAAR (36227)

  • Send us a communication to the Data Privacy Office, Emaar Group LLC, P.O. Box 9440, Dubai, United Arab Emirates.