The purpose of this Notice is to explain how Trafigura handles Personal Data about our job applicants (the “Application Data”) and our applicants’ rights under data protection law.
This Notice applies to applications submitted via our online recruitment system, LinkedIn, Trafigura’s website or intranet, and those submitted via third parties e.g. recruitment agencies and job boards, or other means e.g. post and email.
2. Trafigura 10 Data Protection Principles
We observe 10 Data Protection Principles in relation to Application Data:
Fairness and Transparency Inform people about how we process their Application Data.
Lawful Processing Make sure we have a good, lawful reason to process Application Data.
Purpose Limitation Only collect Application Data for a specific business need. If we want to reuse Application Data for a new purpose, we must ensure the two are compatible.
Data Minimisation Only process as much Application Data as we need, and no more.
Accuracy Keep Application Data accurate, complete, and up-to-date.
Retention Only keep Application Data for as long as we need it. If we don’t need the Application Data anymore, we must delete it or anonymise it.
Security Protect Trafigura’s Application Data from getting lost or stolen or otherwise processed in an unauthorised manner and make sure our service providers protect this data to the same standard.
Individual Rights Allow certain individuals particular rights in relation to their data, including the right to access, correct or erase their Application Data, or object to it being used for certain purposes.
Application Data Transfers Put in place safeguards before sending Application Data cross-border.
Accountability Trafigura takes steps to make sure our processing of Application Data complies with our Global Data Protection Policy and these Principles.
3. What Application Data does Trafigura collect?
Trafigura generally only collects Application Data that is necessary to assess you for the post applied for. This may include:
- Information you provide to set up an account on our online recruitment system, e.g. your email address;
- Information you provide to apply for a job vacancy and tell us who you are, your capabilities and suitability for certain positions, name, contact information, nationality, professional qualifications, employment history, personal interests, experiences, résumé;
- Information collected by Trafigura as a result of the recruitment process, e.g. your performance at assessment centres, interview or information provided by your referees;
Personal Data about criminal convictions, medical information will only be sought where necessary for the role you have applied for, and permitted by local law. Other Sensitive Data e.g. ethnicity, race and gender will only be requested where required by law for the purpose of the assessment of your application. We will indicate where the information we have requested is mandatory or optional.
4. What will Trafigura do with your Application Data?
The main purposes for which we use Application Data include:
- Supporting and Processing your Job Application, e.g so we can assess your ability to meet the job specification, and verify references and professional qualifications;
- Improving our Application Process, e.g. to ensure that our website, intranet and our online recruitment system are user-friendly and contain appropriate and helpful information; and
- Ensuring compliance with our Code of Conduct, e.g. to ensure that we are living up to our values.
We may verify the Application Data you provide and/or collect Personal Data about you from sources other than you to assist with our ‘Pre-Employment Checks’. This may include checking your qualifications, directorships, financial history (e.g. bankruptcy) and if you have a criminal record (where necessary for the role you have applied for). If this occurs:
- You will be told in advance by the Trafigura entity performing the Pre-Employment Checks check which aspects of your Application Data will be verified and how; and
- the Trafigura entity performing the Pre-Employment Checks will collect information about criminal convictions (if collected) or medical information only where necessary, through official authorised sources and in accordance with applicable law.
- Where it is necessary and appropriate to the role you have applied for and permitted by local law, you may be required to undertake drug and alcohol testing prior to commencing your employment.
Trafigura will only process your Application Data where we have a legal basis for doing so, i.e. generally because it is necessary for us to decide whether to enter into a contract of employment with you, but also based on your consent (which you have the right to withdraw), because it is necessary to comply with a legal obligation or to enable us to pursue our legitimate business interests, e.g. so we can deliver an effective recruitment service.
5. Who is your Application Data disclosed to?
Within Trafigura Trafigura restricts access to Application Data to people within Trafigura who have a “need to know” that information, e.g. the individuals who will process your job application and manage the recruitment cycle.
Outside Trafigura Trafigura shares Application Data with authorised third party service providers, in order to manage recruitment, notably to conduct screening and verification of your application and the information you provide, e.g. academic/professional qualifications.
Generally, Trafigura will only disclose your Application Data to other third parties:
- when required to do so by law;
- in response to a legitimate request for assistance by the police or other law enforcement agency; and
- to seek legal advice from Trafigura’s external lawyers or in connection with litigation.
6. How long will Trafigura retain your Application data?
We keep your Application Data in accordance with our internal retention policies. Typically, if you are unsuccessful in your job application with us (or if you reject the position), your Application Data will be destroyed within 7 months (this may vary slightly depending on the jurisdiction), in order to comply with our legal obligations and so that we may contact you again if another suitable position arises. We may keep your application material for a longer period of time (up to a maximum of 18 months) if: (i) there is a real possibility you may be suitable for alternative roles in the future, and retaining your application would be useful for such future hire (e.g. to contact you); and (ii) you have consented to this proposal. If you would like more information, please contact us.
If you are successful in your application and join Trafigura we will retain your Personal Data in accordance with our internal Data Retention Guidelines and procedures. More information will be provided when you start.
7. Where does Trafigura store your Application data?
Applicants should be aware that their Application Data may be transferred to, and stored at, a destination outside their country of residence, which may have less strict, or no data protection laws, when compared to those of their country of residence. It may also be processed by staff outside of their country of residence, whether at Trafigura or at one of our suppliers.
Whenever we transfer your Application Data outside of your country of residence, we will take legally required steps to ensure that adequate safeguards are in place to protect your Application Data and make sure it is treated securely and in accordance with this Notice. These restrictions apply whether Trafigura is sending Personal data to a third party or another group company, even if the Personal data will only be accessed remotely from the receiving country.
8. Exercising your rights
You may have certain rights in relation to the Application Data that we hold about you. In particular, you may request access to, rectification - if you cannot up-date such information in our online recruitment system - or erasure of, the Application Data we hold about you, object to or restrict certain types of processing and request a machine-readable copy of the Application Data you have provided.
Any request to exercise one of these rights will be assessed by Trafigura on a case by case basis. In certain circumstances we are not legally required to comply with your request because of the laws in your jurisdiction or because of relevant legal exemptions.
The security of your Personal Data is important to us. We have adopted reasonable security practices and procedures to help secure the Personal Data that we collect.
10. Contact us
Please submit your request here and select “Personal data and privacy rights” if you would like to find out more about any matters relating to this Notice or to exercise your rights.
If you have concerns about the way in which Trafigura has handled your Application Data, you have the right to complain to your Data Protection Authority. However, if you have concerns we encourage you to raise this with Trafigura in the first instance.
Last updated: 04.05.2018