Recruitment Privacy policy

Protecting your personal data is a priority for us at SGR Compliance SA, as Data Controller.

We want to ensure that you are informed about our policy regarding the processing of your personal data, should you submit to our recruiting process.

This Recruitment Privacy Policy contains information on what personal data we collect, what we do with that information, and your rights regarding it.

If you are interested in applying for a job position or submitting a spontaneous job application, please feel free to contact us at hr@sgrcompliance.com

If you require further information or have any questions about our Recruitment Privacy Policy, please do not hesitate to contact us at the following address: privacy@sgrcompliance.com.

SGR reserves the right to amend this Privacy Policy partly or fully, or simply to update its content (e.g., as a result of changes in applicable laws). Any amendment or update to this Privacy Policy will be available on this page. Please check this page regularly to keep up to date.


What personal data we collect

For prospective candidates, we collect basic identification information, such as your name, title, photograph, gender, date of birth, educational and professional history, and contact details.

If you actively apply for a role with SGR, we will usually also collect other information directly from you:

  • physical and electronic address and other contact details (e.g., private telephone number, private email and/or postal address);
  • education and employment information (e.g., contact details for your current/former employer, information about your educational background, your work experience and other experience/interests, previous employment details including current salary and benefits package);
  • information collected as part of the interview process (e.g., notes taken from your interview and/or assessment day);
  • electronic communication information, including but not limited to e-mails including attachments, chat or other instant messaging, and other communication data;
  • any other information that you voluntarily decide to share during the recruitment process.

We may also collect information from professional social media websites if you have chosen to make such information publicly available.

If your application is successful, we will usually also collect:

  • identification information (e.g., date of birth, ID card and other national ID numbers as required, immigration status);
  • family information (e.g., marital status);
  • where permitted by, or necessary to comply with, applicable laws, special categories of data such data about racial and ethnic origin, and data about criminal records.

How we use your personal data

We process your personal data solely for human resources purposes.

Recruiting and application handling

We process your personal data to undertake recruitment activities, such as determining the suitability of a candidate’s qualifications and managing the status of your application. We also use this information to prepare for and enter into a contractual employment relationship.

Staff Administration

The processing of your personal data may be necessary to manage our human resources records (e.g., keeping your application data on file) and to communicate with you about any actual or potential job vacancy.

Onboarding

During the onboarding phase, we need to process your personal data to create your internal profile and communicate with third parties such as authorities, insurance companies, and pension funds, where we are required to do so by applicable law or regulation.

Basis for the processing of Personal Data

Depending on the purpose of the processing activity, the legal basis for the processing of your personal data will be one of the following:

  • necessary to perform our contractual obligations towards you or to take pre-contractual steps at your request;
  • necessary for the legitimate interests of SGR, and does not unduly affect your interests or fundamental rights and freedoms (e.g., to determine whether a candidate or potential candidate’s skills, qualities and experience are suitable for a role within SGR);
  • we have obtained prior explicit consent (such as when we ask you the consent to retain your data for future job positions that may become available).

To the extent that we process any special categories of data relating to you, we will do so because:

  • the processing is necessary to comply with our legal or regulatory obligations (e.g., obligations under employment, social security or social protection law);
  • the processing is necessary for the establishment, exercise or defence of a legal claim;
  • where legally permissible, you have given your explicit consent to us.

You are under no obligation to provide data to us during the recruitment process. However, if you do not provide the information, we may not be able to process your application properly or at all.

How we protect your personal data

We use generally accepted standards of technical and operational security to secure your personal data. Only our authorised personnel are permitted to access personal data and is required to treat this information as confidential.

Who we share your personal data with

Your personal data are processed by:

  • human resources department;
  • managers working in the department where the position for which you are applying is open;
  • third parties such as authorities, insurance companies, and pension funds, as required by applicable law or regulation.

We may also wish to communicate with the authors of your references. In this case, we will ask for your explicit consent first.

Retention period

We will only retain your personal data as long as necessary to fulfil the purpose(s) for which they were collected, or to comply with legal, regulatory or internal policy requirements, whichever is longer.

In general,

  • personal data relating to unsuccessful candidates are kept for 12 months after the date on which we notify you that your most recent application has been unsuccessful; after that period and for a maximum of 36 months, we nevertheless continue to retain a minimal amount of your information (e.g., name, job title) as part of human resources history activities;
  • with their consent, personal data relating to unsuccessful candidates suitable for future opportunities within SGR are kept for 36 months from the date of our last recorded communication;
  • personal data relating to successful candidates will become part of your personnel dossier and will be retained in accordance with our employee’s privacy policy, which will be provided during the on-boarding process. If your application is successful, your application will be retained as part of your personnel dossier.

However, if you wish to have your personal data removed from our systems, you can make a request as described in section below (“Exercising your rights”).

Transfer of data abroad

The personal data we collect will be processed in Switzerland and could be transferred also to other countries with a legislation that guarantees an adequate level of data protection or, in the absence of such legislation, based on appropriate safeguards (e.g., standard contractual clauses adopted by the European Commission, binding corporate rules, and certifications).

Exercising your rights

To exercise your rights, please contact us at privacy@sgrcompliance.com.

As a data subject, you have the right to access and to obtain a copy of your personal data as processed by SGR, and to request the correction and erasure of your personal data.

You are also entitled to object to the processing of your personal data, based on grounds relating to your particular situation, to request the restriction of the processing, and to withdraw your consent at any time if you previously provided it.

We will process such requests in accordance with applicable data protection laws. However, please note that the rights listed above are not absolute and may not always apply; exemptions could be applicable depending on the situation.

In response to a request, we will usually ask you to verify your identity and provide information that helps us to better understand your request.

If we do not comply with your request, we will explain why.

We are committed to respecting your personal data. However, if you believe that the processing of your personal data is being carried out in violation of applicable data protection laws, you have the right to lodge a complaint with the Federal Data Protection and Information Commissioner or file a legal action in Lugano Court.

(April 2024)