DATA PROTECTION POLICY FOR JOB APPLICANTS IN THE UK

This Data Protection Policy (“Policy”) sets out the basis upon which Twist & Shout Communications Ltd. (the “Company”) as well as affiliates and parent entities, such as KnowBe4, Inc., headquartered in the United States of America (“Parent,” and collectively with Company, “KnowBe4,” “we,” “us,” or “our”) may collect, use, disclose, or otherwise process personal data of job applicants in accordance with the Data Protection Act of 1988, and, from 23 May 2018, the Data Protection Act 2018 (“DPA”) as well as local laws (“Privacy Laws”). This Policy applies to personal data in our possession or under our control, including personal data in the possession of organizations which we have engaged to collect, use, disclose, or process personal data for our purposes. We may modify or update this data protection notice from time to time. If we make a material change to this data protection notice, we will notify you of the change.

APPLICATION OF THIS POLICY

  1. This Policy applies to all persons who have applied for any such position with us (“job applicant(s)”), and all references to “employment” in this policy shall apply equally to internships and traineeships (as may be applicable).

PERSONAL DATA

  1. As used in this Policy, “personal data” means data, whether true or not, about an employee or a job applicant who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.
  2. If you are a job applicant, personal data which we may collect includes, without limitation, your:
    1. name or alias, gender, NRIC/FIN or passport number, date of birth, nationality, and country and city of birth;
    2. mailing address, telephone numbers, email address, and other contact details;
    3. resume, educational qualifications, professional qualifications and certifications, and employment references;
    4. other non-traditional identifiers such as personality information or pre-employment testing/quizzes;
    5. employment and training history;
    6. work-related health issues and disabilities; and
    7. photographs.
  3. Other terms used in this Policy shall have the meanings given to them in the DPA (where the context so permits).

COLLECTION, USE, AND DISCLOSURE OF PERSONAL DATA

  1. Collection. We generally collect personal data: 

(a) that you knowingly and voluntarily provide in the course of, or in connection with, your employment or job application with us, or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative,” which may include your job placement agent):

(i) after you (or your authorised representative) have been notified of the purposes for which the personal data is collected, and 

(ii) after you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes; or 

(b) where collection and use of personal data without consent is permitted or required by the DPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).

  1. Use and Disclosure. If you are a job applicant, your personal data will be collected and used by us for the following purposes, and we may disclose your personal data to third parties where necessary for the following purposes:
    1. assessing and evaluating your suitability for employment in any current or prospective position within the Company; and
    2. verifying your identity and the accuracy of your personal details and other information provided
  2. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).

WITHDRAWING CONSENT

  1. The consent that you provide for the collection, use, and disclosure of your personal data will remain valid until such time it has been withdrawn by you in writing. If you are a job applicant, you may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
  2. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process and effect your request within thirty (30) days of receiving it.
  3. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and extent of your request, we may not be in a position to process your job application (as the case may be). We shall, in such circumstances, notify you before completing the processing of your request (as outlined above). Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 8 above.
  4. Please note that withdrawing consent does not affect our right to continue to collect, use, and disclose personal data where such collection, use, and disclosure without consent is permitted or required under applicable laws.

ACCESS TO AND CORRECTION OF PERSONAL DATA

  1. If you wish to make: (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data; or (b) a correction request to correct or update any of your personal data which we hold, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
  2. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
  3. We will respond to your access request as soon as reasonably possible. Should we not be able to respond to your access request within thirty (30) days after receiving your access request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the Privacy Laws).
  4. Please note that depending on the request that is being made, we will only need to provide you with access to the personal data contained in the documents requested, and not to the entire documents themselves. In those cases, it may be appropriate for us to simply provide you with confirmation of the personal data that we have on record, if the record of your personal data forms a negligible part of the document.

PROTECTION OF PERSONAL DATA

  1. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal, or similar risks, we have introduced appropriate administrative, physical, and technical measures such as up-to-date antivirus protection, encryption, and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.
  2. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your personal data and are constantly reviewing and enhancing our information security measures.

ACCURACY OF PERSONAL DATA

18. We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete, and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.

RETENTION OF PERSONAL DATA

  1. We may retain your personal data for as long as it is necessary to fulfill the purposes for which they were collected, or as required or permitted by applicable laws.
  2. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purposes for which the personal data was collected, and are no longer necessary for legal or business purposes.

TRANSFERS OF PERSONAL DATA OUTSIDE OF THE UNITED KINGDOM

  1. Your personal data will be transferred to the Company’s Parent which is based in the United States. We take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the Privacy Laws.
  2. Parent may disclose your personal information to its private equity sponsor, Vista Equity Partners, and its affiliates, including Vista Consulting Group (collectively, “Vista”), for administration, research, database development, workforce analytics and business operation purposes, in line with the terms of this Fair Processing Notice. Vista processes and shares your personal information with its affiliates, including other Vista portfolio companies, on the basis of its legitimate interests in managing, administering and improving its business and overseeing the recruitment process and, if applicable, your employment relationship with Parent. If you have consented to Vista, Parent, and/or Company doing so, we also share your personal information with other Vista portfolio companies for the purpose of being considered for other job opportunities in the pooling system, both inside and outside the UK. Please find a full list of all Vista portfolio companies at: https://www.vistaequitypartners.com/companies/ and Vista’s privacy policy at https://www.vistaequitypartners.com/privacy/. Where this requires us to transfer your personal information outside of the UK, please refer to 21 of this Fair Processing Notice for further details on cross-border transfers. In connection with the recruitment process your personal data may be transferred outside of the UK to iCIMS, Hirebridge, LLC and Criteria Corp., which provide applicant tracking and evaluation services. Hirebridge, LLC and Criteria Corp. have agreed to comply with the UK International Data Transfer Agreement to ensure that your personal information is adequately protected whilst outside of the UK.

DATA PROTECTION OFFICER

  1. You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures; or if you wish to make any request, in the following manner:

Brian Jack, Data Protection Officer
privacymanager@knowbe4.com
33 N. Garden Ave., Ste. 1200, Clearwater, FL 33755

 

EFFECT OF POLICY AND CHANGES TO POLICY

  1. This Policy applies in conjunction with any other policies, notices, contractual clauses, and consent clauses that apply in relation to the collection, use, and disclosure of your personal data by us.
  2. We may revise this Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Policy was last updated. Your continued employment and participation in our recruitment process constitute your acknowledgement and acceptance of such changes.

 

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