This Recruitment Privacy Notice (this "Notice") governs the collection and use of personal data by Jumeirah International LLC, specifically in relation to all candidates applying to become employees, staff, interns, consultants, contractors or officers at Jumeirah International LLC.
References to "Jumeirah", "our", "us" or "we" within this Notice are related to Jumeirah International LLC.
We are committed to protecting and respecting your privacy. This Notice explains the types of personal data we collect, how we use that personal data, who we share it with, transfers to other countries, how we protect that information, and your legal rights in relation to your personal data. We are committed to abiding by this Notice, as well as the requirements of applicable laws, in the entire recruitment/engagement process.
If and to the extent that other countries’ laws, outside the United Arab Emirates (UAE), United Kingdom(UK) or European Union (i.e. laws other than the General Data Protection Regulation, UK Data Protection Act, UAE Federal Data Privacy Law or equivalents), apply to Jumeirah and its use of your personal data we would supply you with additional privacy notices and explain that the lawful reasons described in them apply in place of those which are listed later in this Notice.
Candidates who are successful in their application and are formally offered employment (or selected for an engagement if an intern or a consultant) with Jumeirah International LLC, will be provided with a different Privacy Notice as part of the on-boarding/engagement process which will supersede this Notice.
We are the data controller of your personal data. We decide how and why your personal data is processed, either alone or jointly with others.
You can access a ‘Data Controller List’ here, which sets out all of our different entities and their contact details. This will enable you to identify the relevant entity that holds, processes, and secures your personal data and is the data controller in relation to your personal data.
In some parts of this Notice we refer to Jumeirah International LLC as being a part of Dubai Holding Corporate LLC and its subsidiaries, as well as referring to Jumeirah International LLC group of companies. Should you wish to learn more, details of Dubai Holding Corporate’s group structure can be found here www.dubaiholding.com
For the purpose of applicable data protection laws, the data controller is Jumeirah International LLC. Contact details are: Corporate Office, Level 5, Building 5, PO Box 73137, Dubai, United Arab Emirates: +971 4 366 5000 privacyoffice@jumeirah.com. We have a Data Protection Officer (DPO) and you can contact our DPO by using these contact details.
Personal data is any information relating to an identified or identifiable living person (for example, name, address, telephone number). When "you" or "your" are used in this Notice, we are referring to the relevant individual who is the subject of the personal data.
In this Notice we refer to "processing your personal data". Processing means anything that is done to or with personal data (including simply collecting, storing or deleting that data).
When you visit our website, we may use cookies and other technologies to automatically collect the following personal data:
- Technical information, including the Internet Protocol (IP) address used to connect your computer to the internet, your login activity, browser type and version, device identifier, location and time zone setting, browser plug-in types and versions, operating system and platform, page response times, and download errors;
- Information about your visit, including the full Uniform Resource Locators (URL) clickstreams to, on and from our websites; and
- Length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouseovers) and methods used to browse away from the page.
IP addresses and other online identifiers (i.e. those listed above) are your personal data. This means that you have the same rights under data protection laws in relation to these as you do with other personal data. For information about the rights see our Cookies Notice.
We may collect personal data at every touch point and interaction we have with you during the recruitment/engagement journey. We collect personal data about you as a candidate from different sources whilst adhering to the data minimization and purpose limitation principles in accordance with the applicable data protection law. As detailed below (some of these may not be relevant to you specifically):
We cannot process your application for employment or engagement without your personal data. Where we do not need your personal data, we will make this clear. For instance, we will explain if any part of an application form you are required to complete is optional or can be left blank.
Information you give us:
- You provide your personal data to us when you respond to a communication from us, when filling in forms on our careers website, over the telephone or through written correspondence with us (e.g. any follow-up queries in relation to your application).
Information we collect about you:
- We collect and create personal data about you ourselves during your application process, for example, our notes of your progress throughout the application process will contain personal data about you.
Information we receive and collect from other sources
- Where permitted by data protection laws, we collect information about candidates from publicly available sources, including publicly available content on social media (depending what your privacy settings are on such services) and publicly available directories such as LinkedIn (if you are on such platforms).
- We also collect personal data about candidates for recruitment purposes from government agencies, and third parties who provide services to candidates or to us in connection with an application, for example, recruitment consultants/agencies, previous employer, or through employment and character references.
- As Jumeirah International LLC forms part of Dubai Holding Corporate LLC and its subsidiaries, to the extent necessary, we will also receive your personal data from other entities within the Jumeirah International LLC group of companies, including Jumeirah International LLC subsidiaries and holding companies.
Data protection laws require us to clearly explain the lawful basis to justify our processing of your personal data.
You should be aware that our lawful basis for processing your personal data may be impacted by the legal requirements in the country you work in and by what data protection law(s) apply to the company which is the data controller of the personal data mentioned in this Notice.
We are required under the Kingdom of Saudi Arabia's Personal Data Protection Law to inform you that where the law applies, collecting and processing your personal data is mandatory in order for us to guarantee your rights as a candidate and provide you with a suitable recrutiment/engagement process. Where we are required by applicable laws or professional standards to collect personal data and you fail to provide that data when requested, you may not be able to enter into the recruitment/engagement process.
Where we rely upon Legitimate Interest as a lawful basis, we have balanced your rights and freedoms against our interests, or those of any third parties, and determined your rights are not infringed. Legitimate Interest is where your personal data is processed for either our own interests or the interests of third parties. This can include commercial interests, individual interests, or broader societal benefits. Legitimate Interest will only be used as a lawful basis where the General Data Protection Regulation or UK Data Protection Act applies to you.
Some of the processing described below, will include the processing of sensitive data which we are required to process with more care, in accordance with applicable data protection laws. Where this is the case, we make explicit reference to it.
Your personal data will also sometimes be converted into statistical or aggregated data which cannot be used to re-identify you. This is used to produce statistical research and reports amongst other things. This aggregated data may be shared by us with other companies in the Jumeirah group of companies.
Your personal data is stored by us and/or our Third-Party Service Providers strictly for the time necessary to achieve the purposes for which the information is collected, in accordance with applicable data protection laws. The storage period is outlined in section titled "How do we use your personal data?" below. This means that if you are a candidate we will keep your resume/CV and other personal data about you relating to your application for the length of the recruitment campaign and for 12 months after that (i.e. after we complete the application process relating to the role), in case there are queries from you and to tell you about other roles (if you consent to that). We will only retain your personal data after that if you are the successful candidate and the information will be used to on-board/engage you and form part of your employment/engagement records.
When we no longer need to use your information, we will remove it from our systems and records and/or take steps to properly anonymise it so that you can no longer be identified from it (unless we need to keep your information to comply with legal or regulatory obligations to which we are subject or where we need to retain it for the period during which claims can be brought under the contract).
Jumeirah International LLC forms part of Dubai Holding Corporate LLC and its subsidiaries. To the extent necessary, we will also share your personal data with other entities within the Dubai Holding Corporate LLC group of companies, including to Dubai Holding Corporate LLC subsidiaries and holding companies. Where we do disclose your personal information within the group or to third parties, we will ensure that appropriate safeguards are in place - for example our Intra Group Transfer Agreement, or Controller to Processor Data Processing Agreements.
Our Third-Party Service providers
We also use companies, agents or contractors ("Third-Party Service Providers") to perform services on our behalf or to assist us with the provision of services to support the recruitment process. For example, we engage Third-Party Service Providers to provide psychometric testing, online competency assessment, background checks, security checks, IT services including suppliers of website hosting services and to provide legal, accounting, insurance, audit and other professional services, to host personal data in data storage facilities. We also use recruitment agencies to assist us with the provision of services to support the recruitment/engagement process.
Third parties permitted by law
In certain circumstances, we will be required to disclose or share your personal data in order to comply with a legal or regulatory obligation (for example, we could be required to disclose personal data to the police, counter-terrorist government authorities, or to judicial or administrative authorities).
We will also disclose your personal data to third parties in order to enforce our terms and conditions or other agreements, or to protect the rights, property or safety of Jumeirah or the public, where that is necessary and where data protection laws permit this.
Third parties connected with business transfers
We will sometimes transfer your personal data to third parties in connection with a reorganisation, restructuring, merger, acquisition or transfer of assets, provided that the receiving party agrees to treat your personal data in a manner consistent with this Notice.
Our legal counsel and other professional advisers
We will sometimes share your personal data with firms and companies who provide legal, tax, accountancy and audit related services to us.
Recruitment agencies that are appointed by you or us
Our lawful basis for sharing your personal data with these third parties will be our legitimate interests in being able to provide feedback on the application process to recruitment agencies in order to assist them with sourcing us other appropriate candidates in the future. It is also in the legitimate interests of the agency that it is able to provide a candidate with feedback on their performance in the recruitment process.
Government agencies
We will share your personal data with government agencies that provide us with candidate security checks and related services.
For selected roles we use data processors who use artificial intelligence and machine learning during the recruitment process. Our processors incorporate artificial intelligence, machine learning and psychology into their platforms, providing Jumeirah with an automated candidate view or profile. This allows us to predict areas such as natural abilities, cultural values, cultural needs, competencies, behaviour, thinking styles, working styles, motivators, and integrity.
Profiling
These processors, as well as those who provide online recruitment questionnaires rely on profiling. This means any form of automated processing of your personal data to evaluate certain personal aspects about you, such as to analyse or predict aspects concerning your economic situation, personal preferences, etc. This type of profiling does not have a legal or other significant effect on you. We will seek your consent before the start of this type of personal data processing.
We sometimes use a questionnaire that automatically ranks candidates, however, no candidates are automatically accepted or rejected, instead they are ranked according to their responses. This is profiling. The answers to the questionnaire do amount to a profile of you. We will seek your consent before the start of this type of Personal Data processing.
The majority of personal data processed by us and our recruitment system provider is stored in the United Arab Emirates, where the appropriate data protection measures are in place.
When processing your personal data, we may transfer this to third parties based in other countries, to the extent necessary to fulfil the purposes described in this Notice. Jumeirah International LLC forms part of Dubai Holding Corporate LLC and its subsidiaries. Your personal data may be transferred within this group of companies, as well as to Jumeirah International LLC subsidiaries and holding companies.
Where data transfers take place, such transfers shall always be done in compliance with relevant data protection laws.
For transfers of personal data from the UK and European Economic Area (“EEA”) we transfer personal data to entities outside the EEA, under the EU Standard Data Protection Clauses.
Further information about transfers can be obtained by contacting us using the following email address privacyoffice@jumeirah.com.
To the extent required, we will also transfer your personal data to third parties in connection with a reorganization, restructuring, merger, acquisition or transfer of assets, provided that the receiving party agrees to treat your personal data in a manner consistent with applicable laws and requirements.
We have implemented technology and operational security measures in order to protect personal data from loss, misuse, alteration or destruction. Only authorised persons are provided access to personal data; such individuals have agreed to maintain the confidentiality of this personal data.
Our websites may contain links to and from third party websites. Please note that if you follow a link to any of these websites, these websites will have their own terms of use and privacy policies and that we do not accept any responsibility of liability for these policies. Please check these policies before you submit any personal data to these websites.
You may have certain rights relating to your personal data. However, these rights can differ depending upon the country in which you are located. That country’s law will determine which rights apply and in what instances.
Right to Withdraw Consent: Where you have provided your consent to us, you will always have the right to withdraw this at any time. You can do this by either following the information provided at the time you provided your consent, or by contacting us using the following email address privacyoffice@jumeirah.com. The withdrawal of consent will not affect any processing that was based on consent before its withdrawal.
Right to Request Correction of Your Personal Data: You will always have the right to request that we correct or update any personal data that we process about you that is inaccurate or incomplete. You can do this by contacting us at privacyoffice@jumeirah.com.
Right to Restrict the Processing of Your Personal Data: You have the right to ask us to restrict, suspend, or stop the processing of your data. You can do this by contacting us at privacyoffice@jumeirah.com.
Right to Request Deletion of Your Personal Data: You have the right to request your personal data to be deleted. You can do this by contacting us at privacyoffice@jumeirah.com.
Right to Object to the Processing of Your Personal Data: You have the right to object to our processing of your personal data. You can do this by contacting us at privacyoffice@jumeirah.com.
Right to Obtain a Copy of Your Personal Data: You have the right to obtain a copy of your personal data in a commonly used and machine-readable format. You can do this by contacting us at privacyoffice@jumeirah.com.
Right to Lodge a Complaint: You have the right to lodge a complaint with the supervisory authority in your country of residence, place of work, or the country in which an alleged infringement of data protection law has occurred.
It is important to understand that these rights are not absolute (e.g., their application may depend upon the lawful basis we rely upon to process your personal data) and that we may require further information from you (e.g., to confirm your identity) in order to action your request.
If you want to exercise any of the rights set out above or have any questions or concerns about how we treat your personal data, please contact us at privacyoffice@jumeirah.com or by writing to us at: Jumeirah International LLC Corporate Office, Level 5, Building 5, PO Box 73137, Dubai, UAE, Phone: +971 4 3665000. Please include your reply address when you write to us.
We will update this Notice if we need to do that in response to changing legal, regulatory, or operational requirements. We will notify you of any such changes (including when they will take effect) if we are required to do so by data protection laws.
