GDPR Job Candidate Privacy Notice
AST & Science, LLC and its affiliated companies take your data protection rights and our legal obligations seriously. The information that you provide to us in the course of your application for employment with us as well as other information that relates to you or other identified or identifiable individuals (“Personal Data”) will be treated in a secure and confidential manner as set out in this Privacy Notice (“Notice”).
The AST group company that posts a job opening for which you are applying (either AST SpaceMobile UK Limited, AST & Science Iberia, S.L., or AST & Science Israel, Ltd.) together with AST & Science, LLC in the United States (both, the “Company” “AST”, “we”, “our” or “us”) are the controllers of your Personal Data, determining why Personal Data is processed, and how it is processed. In addition, where processing of Personal Data is undertaken by affiliates of the Company for their own independent purposes, these affiliates may be controllers or joint controllers of your Personal Data and a separate privacy notice will be provided to you.
Throughout this Notice we use the term “processing” to refer to all activities involving your Personal Data, including collecting, handling, storing, sharing, accessing, using, transferring, erasing and disposing of Personal Data.
This Notice is provided to you in compliance with data protection laws. This Notice does not constitute or form part of any contract nor is it an offer to contract. This Notice does not confer any contractual right on you, or place any contractual obligation on us.
1. Personal Data
We may collect various types of Personal Data about you for the purposes described in this Notice:
- Data about you: forename and surname, gender, nationality, civil/marital status, date of birth, age, home contact details (e.g., address, telephone number, e-mail), national ID number, immigration and eligibility to work data, next-of-kin/dependent contact information, salary/wage expectations.
- Data about your employment history and qualifications: education and training, qualifications, references.
- Data about your application: CV and application, interview data.
You may give us the Personal Data described above during the recruitment process, whether through your application, further communications, on the telephone or during interviews.
We may also receive Personal Data about you from third parties: recruiters; references from a previous employer; business partners; sub-contractors providing recruiting or technical services; analytics providers; , as well as from publicly available sources such as social media where such Personal Data is proportionate to the position for which you are applying. We may also retain that Personal Data after you have been employed (where this is relevant and to the extent permitted by applicable law).
We may also receive information (which may include your Personal Data) from our hiring manager, from our Human Resources staff, and, from time to time, from our other employees (for instance, in the course of conducting an interview).
2. Why We Process Your Personal Data; Legal Bases
The Personal Data requested from you during the recruitment process is required by us in order to assess your application for employment with the Company. If you do not provide some or all of this Personal Data it may affect our ability to process your application and therefore to enter into an employment agreement with you. In some cases, it may mean that we are unable to continue with your application for employment as the Company will not have the Personal Data we believe to be necessary for the effective and efficient management of the recruitment process.
We collect the Personal Data described in Section 1 above for the purposes of managing the Company’s recruitment related activities, namely: verification of qualifications and employment eligibility; the evaluation and selection of candidates; setting up and conducting interviews and tests; and conducting evaluations, assessments and otherwise as needed in the recruitment process, including if relevant, issuing employment offers; bringing successful candidates into the Company; dealing with queries or complaints relating to the recruitment process; and, where appropriate, retaining information relating to unsuccessful candidates for consideration in future relevant vacancies.
We process your Personal Data for the purposes described above on the following legal bases (subject to applicable laws):
- Legal obligations: the processing is necessary for compliance with an EEA or UK legal obligation to which the Company is subject (purposes of processing: verifying eligibility for employment or complying with obligations regarding non-discrimination); or
- Contractual obligations / Pre-contratual steps: the processing is necessary to comply with the terms of our recruitment scheme, as disclosed to you prior or during the recruitment process or in order to take steps at your request prior to entering into an employment contract with you (purposes of processing: communicating with you about your application, ); or
- Legitimate interests: the processing is necessary for the legitimate interests pursued by the Company in hiring qualified and appropriate persons (purposes of processing: setting up and conducting interviews and tests; conducting evaluations and assessments; verifying your academic, work and other qualifications; verifying references; evaluating and selecting candidates for further consideration; to issue an employment offer; to deal with queries or complaints; and to consider unsuccessful candidates for future vacancies), except if in light of particular circumstances our interests are overridden by your interests or fundamental rights and freedoms that require protection of Personal Data; or
- For positions at AST & Science Israel, Ltd.: Consent: the processing is conducted with your consent (including if you consent to allow us to retain your application so that we can consider you for future job positions). You hereby acknowledge that all Personal Data hereunder is provided at your volition and that you are not legally required to provide any Personal Data to the Company.
3. With Whom Do We Share Your Personal Data?
As part of a multinational with affiliates in several countries, the Company may hire for its sites, and use resources, located outside the country where you live. Your Personal Data may be shared with affiliated companies where it is reasonable and necessary to do so, such as to ensure a consistent application of standards for candidate recruitment. Within the Company, your Personal Data can be accessed by or may be disclosed internally on a need-to-know basis to persons responsible for managing or making hiring decisions, Human Resources staff, system administrators and other support teams (such as IT and Finance).
Your Personal Data may also be accessed by third parties who provide us with services relevant to your recruitment, namely recruiters; companies that host, support and/or maintain the IT systems supporting our recruitment system; and companies that verify your references, undertake background checks solely to the extent permitted subject to applicable law or conduct vetting on our behalf.
If your application for employment with the Company is successful and you accept a job offer from us, your Personal Data may also be shared as described in our employee privacy notice, and notably with Human Resources management, payroll and benefits systems, and the Personal Data contained in such systems may be accessible by providers of those systems, their affiliated companies and sub-contractors; tax authorities; regulatory authorities; and our lawyers, auditors, investors, consultants and other professional advisors.
The Company may also share your Personal Data if it becomes involved in a reorganization, merger, consolidation, acquisition, or any form of sale of some or all of its assets, with any type of entity, whether public, private, foreign or local.
The Company expects all third parties to process any Personal Data disclosed to them in accordance with applicable law and contract terms, including with respect to Personal Data confidentiality and security. Where these third parties act as a “processor” (for example, by verifying your references at our request), they carry out their tasks on our behalf and upon our instructions for the above-mentioned purposes. In this case, your Personal Data will only be disclosed to these parties to the extent necessary to provide the required services.
4. Security of Personal Data
We implement what we determine to be reasonable physical, technical and administrative security standards designed to protect your Personal Data from loss, misuse, alteration, destruction or damage.
Where we have given you (or where you have chosen) a password that enables you to access certain parts of our recruitment portal, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. The transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our recruitment portal; any transmission is at your own risk. Once we have received your Personal Data, we will use strict procedures and security features to try to prevent unauthorized access.
5. Where we Process and Store your Personal Data
From time to time your Personal Data will be transferred outside your country for the purposes described in this Notice. For example, your Personal Data may be transferred, among other purposes, to conduct the review of your application, the processing of your details and the provision of support services.
We may share your Personal Data (i) with colleagues within the Company; (ii) with colleagues at AST group entities in the United States, which has not received a decision of the European Commission confirming that it provides adequate protection to Personal Data; and with third parties as described in this Notice.
Transfers outside the EEA or UK may be made pursuant to legally acceptable mechanisms that ensure an adequate level of protection. Where applicable, you are entitled, upon request, to receive a copy of the relevant contract (Standard Contractual Clauses or Binding Corporate Rules) showing that appropriate safeguards have been taken to protect your Personal Data in connection with such transfer.
6. Retention of your Personal Data
We will retain candidate Personal Data for a period of up to one year following the closure of the recruitment process relating to the role for which you applied in the event other job opportunities arise within the Company or an affiliate. In all cases, we will retain your Personal Data for a period of time corresponding to the applicable statute of limitations for any kind of claims that we may bring or that may be raised against us, or legal or regulatory obligations.
7. Your Rights
Subject to conditions set forth in applicable data protection legislation, you have the following rights:
- Right to Access – You have the right to request access to any Personal Data concerning you, subject to limited exceptions that may be prescribed by applicable law.
- Right to Correct (Rectification) – The Company aims to ensure that all of your Personal Data is correct. You are entitled to have any inadequate, incomplete or incorrect Personal Data corrected (that is, rectified).
- Right to Withdraw Consent – In the (rare) event your Personal Data is processed on the basis of your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
- Right to Data Portability – Where we rely upon your consent as the legal basis for processing, which shall be exceptional, or the fact that the processing is necessary to perform a contract to which you are party or to take steps at your request prior to entering a contract, and the Personal Data is processed by automated means, you have the right to receive all such Personal Data which you have provided to us in a structured, commonly used and machine-readable format, and also to require us to transmit it to another controller where this is technically feasible.
- Right to Erasure – You are entitled to have your Personal Data erased under specific circumstances, such as where you have withdrawn your consent, where you object to processing based on legitimate interests and we have no overriding legitimate grounds or where Personal Data is unlawfully processed.
- Right to Restriction of Processing – You have the right to restrict our processing of your Personal Data (that is, allow only its storage) where:
- you contest the accuracy of the Personal Data, until we have taken sufficient steps to correct or verify its accuracy;
- where the processing is unlawful but you do not want us to erase the Personal Data;
- where we no longer need your Personal Data for the purposes of the processing, but you require such Personal Data for the establishment, exercise or defense of legal claims; or
- where you have objected to processing justified on legitimate interest grounds (see below), pending verification as to whether we have compelling legitimate grounds to continue processing.
Where your Personal Data is subject to restriction we will only process it with your consent or for the establishment, exercise or defense of legal claims.
Right to object to processing justified on legitimate interest grounds – where we are relying upon legitimate interest to process Personal Data, you have the right to object to that processing based on grounds related to your particular situation. If you object, we must stop that processing unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or we need to process the Personal Data for the establishment, exercise or defense of legal claims. Where we rely upon legitimate interest as a basis for processing, we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis.
· Right to lodge a complaint – You may lodge a complaint with the supervisory authority of your habitual residence, place of work or place of alleged infringement (in the case of Spain: Agencia Española de Protección de Datos – www.aepd.es ).
8. How to Contact Us; How to Exercise Your Rights
To obtain further information regarding your rights, to exercise any of your rights (other than to lodge a complaint), or to ask any questions regarding the processing of your Personal Data, please contact firstname.lastname@example.org. To lodge a complaint, please contact the relevant Data Protection Supervisory Authority.
9. Changes to this Notice
Any changes or updates we may make to this Notice will be posted on this page in advance. For other changes, please check back frequently to see any updates or changes to this Notice.
Updated: September 14, 2022