Privacy policy for the Waipā Networks employer branding and recruitment
Privacy policy for Waipā Networks employer branding and recruitment
Date of publication: 9 September 2024
Waipā Networks (‘we’) manage our employer branding and recruitment process through our career site (the ‘Career Site’), and by using a related applicant tracking system.
In this Privacy Policy (the or this ‘Policy’), we explain how we process your personal data if:
- You visit our Career Site (a ‘Visitor’)
- You connect with us via our Career Site, to create a profile with us and receive information about current or future vacancies with us (a ‘Connecting Candidate’)
- You apply for a position with us, via our Career Site or a third-party service (an ‘Applying Candidate’)
- We collect information about you from other parties, sites and services, since we believe your profile is of interest for our current or future vacancies (a ‘Sourced Candidate’)
- We receive information about you from our employees or partners, since they believe your profile is of interest for our current or future vacancies (a ‘Referred Candidate’)
- We receive information about you from a Candidate, who lists you as their reference (a ‘Referee’).
This Policy also describes what rights you have when we process your personal data, and how you can exercise these rights.
When we use the term ‘Candidate’ in this privacy policy, we are referring to each of Connecting Candidates, Applying Candidates, Sourced Candidates and Referred Candidates, unless we state otherwise.
1. About processing of personal information
Personal information means information about an identifiable individual and is any piece of information that relates to a living, identifiable human being. Examples of personal include:
Processing of personal information is any automated use of personal information such as collecting, creating, analysing, sharing, and deleting personal information.
The Privacy Act 2020 and its Information Privacy Principles (‘IPP(s)’) outline how companies may process personal information.
2. What personal information do we process?
All individuals
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Device information - If you visit our Career Site, we will collect information about your device, such as IP address, browser type and version, session behaviour, traffic source, screen resolution, preferred language, geographic location, operating system and device settings/usage.
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Technical and statistical data - If you visit our Career Site, we will collect technical and statistical data about your use of the site, such as information about which URLs you visit, and your activity on the site.
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Communications data - We will collect and store your communication with us, including the information you provided in the communication. This may include the content of emails, video recordings, messages on social media, the information you add to your account with us, surveys, etc.
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Contact details - Such as your name, email address, telephone number and physical address.
Candidates
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Data from interviews, assessments and other information from the recruitment process - Such as notes from interviews with you, assessments and tests made, salary requirements.
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Information in your application - Such as your CV, cover letter, work samples, references, letters of recommendation and education.
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Information in your public profile - Meaning the information we collect about you from public sources related to your professional experience, such as LinkedIn or the website of your current employer.
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Information provided by Referees - Meaning the information we receive from our employees or partners who refer you to us, or by the persons you have listed as your references.
3. Where do we receive your personal information from?
All individuals
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From the Career Site - If you visit our Career Site, we collect technical and statistical information about how you use the Career Site, and information from your device.
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Directly from you - Most of the information we process about you, we receive directly from you, for example when you apply for a position with us or connect with us. You can always choose not to provide us with certain information. However, some personal information is necessary in order for us to process your application or provide you the information you request to get from us.
Referees
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From the person for whom you are a Referee - If a Candidate lists you as their Referee, we will collect your contact details from the Candidate to be able to contact you.
Candidates
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From public sources - We may collect personal information about you from public sources, such as LinkedIn or the website of your current employer.
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From our employees or partners - We may receive information about you from our employees or partners (such as recruitment service providers), when they believe your profile is of interest for our current or future vacancies.
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From your Referees - If you provide us with references, we may collect information about you from them.
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Information we create ourselves or in cooperation with you - Information about your application and profile is usually created by us, or by us in cooperation with you, during the recruitment process. This may for example include notes from interviews with you and any assessments you may undertake during the recruitment process.
4. For what purposes do we process your personal information?
Protect and enforce our rights, interests and the interests of others, for example in connection with legal claims.
Definitions
Affected individuals: The individual(s) affected by the legal issue - this may include persons from all categories of individuals listed above.
Categories of personal data used: All the categories of personal data listed above can be used for this purpose.
Share your personal data with other recipients, for the purposes mentioned in Section 5 below.
Affected individuals: Varies depending on the purpose of the sharing, see Section 5 below.
Categories of personal data used: All the categories of personal data listed above may be used for this purpose.
Collect information about your use of the Career Site, using cookies and other tracking technologies, as described in our Cookie Policy.
Affected individuals: Visitors.
Categories of personal data used: Device information.
Maintain, develop, test, and otherwise ensure the security of the Career Site.
Affected individuals: Visitors.
Categories of personal data used: Device information; Technical and statistical data.
Analyse how the Career Site and its content is being used and is performing, to get statistics and to improve operational performance.
Affected individuals: Visitors.
Categories of personal data used: Device information and technical and statistical data.
Provide you with updates about vacancies with us.
Affected individuals: Connecting Candidates.
Categories of personal data used: Contact details and communications information.
Review profiles and applications sent to us. This also includes communicating with you about your application and profile.
Affected individuals: Connecting Candidates and Applying Candidates.
Categories of personal data used: All the categories of personal information listed above may be used for this purpose.
Collect and evaluate your professional profile at our own initiative. This also includes communicating with you regarding your profile.
Affected individuals: Sourced Candidates and Referred Candidates.
Categories of personal data used: All the categories of personal information listed above may be used for this purpose.
Contact you directly about specific, future vacancies with us.
Affected individuals: Candidates.
Categories of personal data used: All the categories of personal informatoin listed above may be used for this purpose.
Records of interview(s) with you.
Affected individuals: Candidates.
Categories of personal data used: Communications data.
Contact you to ask for your participation in surveys
Affected individuals: Candidates.
Categories of personal data used: All the categories of personal information listed above may be used for this purpose.
Contact you to ask you to provide information about a Candidate, and evaluate the information you provide.
Affected individuals: Referees.
Categories of personal data used: Contact details and Communications data.
5. Whom do we share your personal information with?
Our service providers - We share your personal information with our suppliers who provide services and functionality in our employer branding and recruitment process. For example, this includes recruitment service providers and the supplier of our Career Site and related applicant tracking system.
Companies providing cookies on the Career Site - If you consent to it, cookies are set by companies other than us, who will use the data collected by these cookies in accordance with their own privacy policy. You can find information about which cookies this applies to in our Cookie Policy.
To authorities and other public actors - when we are ordered to do so. We will share your personal information with authorities and other public actors when we have a legal obligation to do so.
To parties involved in legal proceedings - If needed to protect or defend our rights or interests, we share your personal information with public authorities or with other parties involved in a potential or existing legal proceeding. This can for example be in Ministry of Business Innovation and Employment mediation cases, Employment Relations Authority Investigations, Employment Court Cases or Human Rights Commission matters.
Mergers and acquisitions - In connection with a potential merger, sale of company assets, financing, or acquisition of all or part of our business to another company, we may share your personal information with other parties involved in the process.
6. On what legal bases do we process your personal information?
To be able to process your personal information, we need to have a legal reason which complies with the Privacy Act 2020.
When we collect and process your personal information under this Policy;
In accordance with IPP 1: We only collect and process your personal information for the purposes of recruitment, selection and potentially establishing an employment relationship, the information we collect is necessary for these purposes.
In accordance with IPP 2: We collect personal information from you, people you have consented to us collecting information from and information from publically available sources;
In accordance with IPP 4: We collect personal information from you in a way that is lawful, fair and reasonable.
In accordance with IPP 5: We ensure there are safeguards in place that are reasonable to prevent loss, misuse or disclosure of personal information
In accordance with IPP 6: You have a right to ask us for access to the personal information we hold about you and we will provide this to you in most cases. There are some limitations on the information we are required to provide you with, including but not limited to evaluative material.
We are not able to provide you with information about another person unless you are acting on their behalf and have their written permission.
In accordance with IPP 7: If you believe that we may hold personal information about you that is incorrect, you have the right to ask us to correct it and we will take reasonable steps to do so.
In accordance with IPP 9: We will not keep personal information for longer than it is required for the purposes for which the information may be lawfully used. More information on how long we keep personal information can be found in section 8 below.
In accordance with IPPs 10 and 11: We will only use personal information for the purpose it was collected or a purpose that is directly related to the original purpose of collecting the information. If we wish to use the information in a different way, we will not do so without seeking your permission. The same principles apply in relation to the disclosure of personal information.
In accordance with IPP 12: We ensure any of your personal information disclosed to an organisation outside of New Zealand is protected in a way that is comparable to the protections provided by the Privacy Act 2020. More information on this can be found in section 7 below.
In accordance with IPP 13: We may record and use a unique identifier such as your NHI number or drivers licence number in order to talk to the agencies that issued these numbers about relevant information relating to you.
7. When do we transfer your personal information outside of New Zealand, and how do we protect it then?
We always strive to process your personal information within New Zealand.
However, some of our service providers process your personal data maybe outside of New Zealand. In accordance with IPP 12, we, or one of our suppliers are only able to transfer your personal data outside of New Zealand if we have checked the receiving organisation:
- Is subject to the Privacy Act 2020 because the do business in New Zealand;
- Will adequately protect the information; or
- Is subject to privacy laws that provide comparable safeguards to the Privacy Act 2020.
If none of the above apply, we will only make a cross-border disclosure with the permission of the person concerned, and they will be informed that their information may not be given the same protection as what is afforded by the Privacy Act 2020.
8. How long do we keep your personal information?
All individuals
If we process your personal information for the purpose of being able to protect and enforce our rights, we will keep your personal data until the relevant legal issue has been fully and finally resolved.
Visitors
We keep your personal information for one (1) year for security purposes. The retention periods for cookies are set out in our Cookie Policy. We keep your personal information to analyse the performance of the Career Site for as long as we keep personal information about you for other purposes.
Candidates
If you are a Connecting Candidate (only), we keep your personal data for as long as you remain connected with us.
For other types of Candidates, we keep your personal data to decide if you are a suitable candidate for the relevant vacancy(ies) with us.
If you don’t succeed in the initial recruitment process, we keep your personal information for as long as needed to consider, and potentially contact you, for relevant future job openings.
If we hire you, we will keep your personal information during your employment.
References
We keep your personal information for as long as we keep the personal information of the Candidate for whom you acted as a reference.
9. What rights do you have, and how can you exercise them?
Throughout this Policy, we have informed you about the rights you have in relation to your personal information which we process.
If you want to exercise any of the rights described, we suggest that you:
- Visit the Data & Privacy page on our Career Site, where we offer features to let you exercise your rights;
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Log in to your account with us, where you can use the settings in the account to exercise your rights; or
If you have a concern that you haven’t been able to resolve by speaking with us directly, you may lodge seek the assistance of the Privacy Commissioner in addressing your concerns. More information can be found about this here.
10. Who to contact if you have any questions
If you have any questions, comments or concerns about how we handle your personal information, please contact the People Safety and Sustainability Team by sending an email to pss@wiapanetworks.co.nz in the first instance. If they are unable to answer your questions, they will escalate the matter to our company Privacy Officer.
11. Updates to this Policy
We update this Policy when necessary, for example, if we start processing your personal data in a new way, because we want to make the information even clearer to you, or if it’s necessary to do so in order to comply with the applicable privacy laws of the time.
We encourage you to regularly check this page for any changes. You can always check the top of this page to see when this privacy policy was last updated.
12. Related Documentation
For non-employment related privacy matters. Waipā Networks maintains a general published Privacy Policy available here.
