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Candidate Data Privacy Notice

This Candidate Data Privacy Notice (this Notice) is intended to ensure that you are aware of what personal data Spaulding Ridge LLC (Spaulding Ridge, we, us, our) with a registered address at 203 North LaSalle Street, Chicago, Illinois, 60601, U.S.A. holds in relation to you, and how we use that data as data controller.

For the purposes of this Notice, Affiliate Company means a company which is a subsidiary of Spaulding Ridge.

Please read the following carefully to understand our use of your personal data.


This Notice applies to you because you are applying to work with us (whether as an employee, agency worker, consultant, individual contractor or partner).  It also applies to third parties whose information you provide to us in connection with our relationship with you (for example, in respect of references).  Please ensure that you provide a copy of this Notice to any third parties whose personal data you provide to us.

This Notice does not form part of any offer of employment or any contract of employment and does not confer any contractual right on you, or place any contractual obligation on us.

It applies to all personal data collected, maintained, transmitted, stored, retained, or otherwise used (i.e. processed) by us regardless of the media on which that personal data is stored. We may update this Notice at any time and will notify you in writing of any changes.

What is Personal Data?

‘Personal Data’ is defined as any data relating to a living individual who can be identified directly from that data or indirectly in conjunction with other information. We hold some or all of the types of personal data set out in Appendix 1, in relation to you.

Purpose and Basis for Processing

We will hold, process and may disclose personal data, listed at the Annex 1 of this Notice, provided by you for the following purposes:

Purpose (a)

  • Recruitment/appointment including assessing your job application
    • Providing you with building and IT access;
    • Payroll and finance including reimbursing any applicable expenses associated with the recruitment process e.g. travel expenses

Basis (a)

  • This processing of your data is necessary to process job applications submitted by, or on your behalf) and to assist in our determination as to whether to enter into a contract of employment (or engagement) with you.
    • in circumstances where you are interviewing for a senior role, we may record the presentation round of your interview for the purposes of enabling our interviewers to ask specific questions relating to your specific presentation in the following interview round(s) and also to assist in our determination as to whether to enter into a contract of employment (or engagement) with you.

Purpose (b)

  • Monitoring and promotion of equal opportunities including the review of gender breakdown and recruitment;

Basis (b)

  • This processing of your data is necessary for our legitimate business interest in managing our business including legal, personnel, administrative and management purposes and for the prevention and detection of crime, provided our interest is not overridden by your interest. Please note that you have a right to object to processing of your personal data where that processing is carried on for our legitimate interest.

Purpose (c)

  • Managing health and safety at work and incident reporting;
    • Exercising our right to defend, respond or conduct legal proceedings;

Basis (c)

  • This processing of your data is necessary in order for us to comply with any legal or regulatory obligations.
Special Categories of Personal Data 

Certain categories of your personal data are regarded as ‘special’ including information relating to an individual’s:

  • Physical or mental health;
    • Religious, philosophical or political beliefs;
    • Trade union membership;
    • Ethnic or racial origin;
    • Biometric or genetic data; and
    • Sexual orientation.

We only process such data where necessary for the purpose of carrying out the obligations, and exercising specific rights, of Spaulding Ridge or of a prospective employee under employment law or for the assessment of your working capacity. See Appendix 1.

We will only process data relating to your criminal convictions or involvement in criminal proceedings when permitted by law, or where provided voluntarily by you.


In principle, we do not rely on your consent for data use. We may, however, from time to time, (i) ask for your consent to use your personal data for a specific purpose; and/or (ii) process your personal data (including “special data”) in order to protect your vital interests or the interests of another. If we do so, we will provide you with full details of the data that we would like and the reason we need it. We will also inform you about the fact that you can revoke your consent at any time and how you should do that.  Once we have received notification that you have withdrawn your consent, we will no longer process your application and, subject to our retention policy, we will dispose of your personal data securely.

Where you do not provide us with your Personal Data

If you do not provide us with your personal data we may not be able to process your job application, or assess your suitability for a particular role, comply with our legal obligations or manage our business. We will tell you when we ask for information which is a statutory or contractual requirement or needed to comply with our legal obligations.

Security and Storage of Personal Data

We securely store your personal data in a centralized database, with controlled access to such database. Access to personal data (including special data) in both electronic and paper form is restricted to members of the HR Department and employees who have a legitimate and justifiable reason to view such data.

Recipients of Your Personal Data

We may disclose your personal data to an Affiliate Company including, without limitation, for the following reasons: in order to run global processes, carry out group wide reporting, or take decisions about hiring or promotion.

It may be necessary from time to time for us to disclose personal data to third parties or agents, including without limitation to the following:

  • Third parties to assist in the administration, processing and management of certain activities pertaining to prospective employees;
    • Individuals or companies employed by Spaulding Ridge to carry out specific services, functions or consultancy work including external reference agencies and other financial institutions;
    • Relatives or legal representatives of prospective employees;
    • Regulatory bodies to whom we are obliged or required to disclose information including Workplace Relations Commission, Courts and Court-appointed persons;
    • Legal and medical practitioners;
    • Potential purchasers or bidders;
    • Relevant Government departments and agencies; and
    • Other support service providers necessary to assist Spaulding Ridge with the above.

We will inform you in advance if we intend to further process or disclose your personal data for a purpose other than the purposes set out above. We take all reasonable steps, as required by law, to ensure the safety, privacy and integrity of such data and information and, where appropriate, enter into contracts with such third parties to protect the privacy and integrity of such data and any information supplied.

Transfer of Personal Data outside the EEA

The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA), for the purposes described above. Due to the global nature of our business, your personal data may be disclosed to Affiliate Companies outside the EEA, including in particular Affiliate Companies in the USA. It may also be processed by personnel operating outside the EEA who work for us or for one of our suppliers who act on our behalf. We will ensure suitable safeguards are in place to protect the privacy and integrity of your personal data in such circumstances.


Spaulding Ridge has implemented generally accepted standards of technology and operational security in order to protect your personal information from loss, misuse or destruction.

In particular, Spaulding Ridge has put in place appropriate technical and organizational security measures to prevent any unauthorized or unlawful disclosure or processing of personal information and the accidental loss or destruction of or damage to personal information.

Data Retention

Data will be stored for as long as required to satisfy the purpose for which the data was collected and used, unless a longer period is necessary for our legal obligations or for the exercise or defense of legal claims. Usually, we retain your data for a period of 1 year after the job application process is finalized.

Our retention practices are reviewed and updated from time to time in line with legal requirements and best practice. Further information can be obtained from our compliance and privacy office at [email protected]

Your Data Rights 

You have several rights in relation to your personal data. You have a right to:

• access a copy of your personal data held by Spaulding Ridge;
• request rectification of your personal data if it is inaccurate or incomplete;
• request erasure of your personal data in certain circumstances;
• restrict our use of your personal data in certain circumstances;
• move (or port) personal data which is automated in certain circumstances;
• object to the processing of your data where our legal basis for processing your data is our legitimate interests;
• not to be subject to a decision based on automated processing, including profiling which has legal or similar significant effects;
• withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal; and
• lodge a complaint with the Office of the Data Protection Commission (if you are unhappy with how your personal data is being handled).

However, these rights may not be exercised in certain circumstances, such as when the processing of your data is necessary to comply with a legal obligation or for the exercise or defense of legal claims.

If you wish to exercise any of your rights in this regard please contact the our recruiting department at [email protected]

We will respond to your request as soon as practicable. We may request proof of identification to verify your request.

Further Information
If you require any further clarification regarding this Notice, please contact the Company’s Compliance and Privacy office [email protected]

Appendix 1

General Personal Data

• CV/Resumé
• Application form
• Name format type
• Prefix (Mr./Mrs/etc.)
• First name
• Preferred Name
• Middle name
• Last name (Family Name)
• Former Last Name (Maiden Name)
• Suffix
• Telephone number
• E-mail address
• National ID Type
• National ID
• Social Security Number (US employees)
• Employee ID, other than Social Security Number for non-US employees e.g. PPS number
• Country (that has issued the National Identification document)
• Regulatory Region
• Citizenship Status
• Citizenship Country (names a country as opposed to the status above).
• Nationality
• Date of Birth
• Gender
• Father’s Name
• Language Skills
• Passport Issue Country
• Passport Issue City
• Passport Issue State
• Passport Expiry Date
• Visa/Permit Status
• Country – for Visa/Permit (Country Name for which visa is applied/granted)
• Visa/Permit Effective Date
• Visa/Permit Type (Work Permit/Business/etc.)
• Visa/Permit Contract
• Visa/Permit Expiry Date
• Home Address
• Employment Action (Hire/Rehire)
• Reason for Employment Action (Hire/Rehire)
• Employee Classification
• Employment Status
• Type of Contract
• Contractual starting date
• Contractual end date
• Probation Period
• Continuous Service Date
• Job classification
• Full time/ Part time status
• Part time percentage
• Job Title and Job Title Code
• Department
• Sub-Department
• Region
• Market
• Interview recording

To the extent that data is not captured by the above, the Company will also process personal data relating to the following matters:

  • Professional– including previous employment background, references from previous employers, record of interview/interview notes, selection and verification records, educational details, professional and/or academic transcripts, professional certifications, special skills including (driver) licenses, language skills, memberships of committees or other bodies;
  • Premises and IT access – including information required to access company systems and applications such as email account and system passwords, login and access records, download and print records, call recordings, record of email and internet usage in accordance with our email and internet policy, CCTV images captured during the legitimate use of CCTV within Spaulding Ridge.
  • General correspondence/meetings – relating to the recruitment process.
Special Categories of Personal Data
  • Physical or mental health data– such as information about your physical or mental health or condition; for example, we will use information about disability status to consider whether we need to provide for appropriate adjustments during the recruitment process.
  • Other special categories of personal data– such as racial or ethnic origin; religious or similar beliefs; membership of a trade union; the commission or alleged commission of any offence; and any proceedings for any offence committed or alleged to have been committed, the disposal of those proceedings or the sentence of any court in those proceedings.

Special categories of personal data will only be collected and used in so far as such is necessary for the purposes of carrying out an obligation in the field of employment/social security/social protection law, or exercising specific rights or when the use is authorized by law or for the assessment of working capacity.