Candidate Privacy Policy

Thank you for your interest in joining Nomupay. This privacy policy explains how we collect, use, and protect your personal information during and after the recruitment process. It is designed to ensure you understand your rights and how we comply with privacy laws in the regions where we operate, including the UK, Lithuania, UAE, Malaysia, Hong Kong, Philippines, Thailand, Singapore, Australia, and New Zealand. While our data processing aligns with the standards of the EU General Data Protection Regulation (GDPR), we also adhere to applicable local data protection laws in each country where we operate.

We thought it would be helpful for you to understand a little bit about our organisation and how we look after your information when you submit it. The job advert should generally provide you with the recruiting process but this policy will also form part of your contractual documentation.

Nomupay is a “data controller” for job applications. This means that we are responsible for deciding how we hold and use personal information about you. You are being sent a copy of this privacy policy because you are applying to work with us. It makes you aware of how and why your personal data will be used, namely for the purposes of recruitment, and how long it will be retained for.

Having received your application for a position, we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role.

• If you do, we will decide whether your application is strong enough to invite you for an interview.
• If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the role.
• If we decide to offer you the role, we will then take up references and, where required, carry out background checks before confirming your appointment.

If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications, work history and right to work documentation), we will not be able to process your application successfully. For example, if we require references for this role and you fail to provide us with relevant details, we will not be able to take your application further.

We will collect, store and use the following categories of personal information about you in connection with your application for work:

• The information you have provided to us in your on-line application and/or curriculum vitae and any supporting covering letter including name, title, address, telephone number, personal email address, date of birth, gender, employment history, qualifications;
• Right to work documentation e.g. type of visa;
• Any information you provide to us during an interview, interview notes;
• References from former employees or contacts;
• Background check results (if applicable);

We may also collect, store and use the following special categories/sensitive personal information:

• Information about your race or ethnicity (optional)
• Banking information about you so we can pay you
• Emergency contact details (Next of Kin)
• Information about your health, including any medical condition, health and sickness records (to provide appropriate adjustments if needed); and
• Information about criminal convictions and offences (if relevant to the role).

We will use the personal information we collect about you to:

• Assess your skills, qualifications, and suitability for the role that you have applied for;
• Carry out background and reference checks, where applicable;
• Communicate with you about the recruitment process;
• Keep records related to our hiring processes;
• Comply with legal or regulatory requirements.

We will use the sensitive personal information about you in the following ways:

• We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made in preparation for you starting to work with us if your appointment is confirmed.

• We may collect information about your criminal convictions history if we would like to offer you the role.
• For some roles we are required to carry out background checks in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role.
• We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.

• It is in our legitimate interests to decide whether to appoint you to work within the company since it would be beneficial to our business to appoint someone to that role;
• We need to process your personal information to decide whether to enter into a contract of employment with you.
• To meet regulatory obligations (e.g., verifying your right to work).

The people team will only share relevant personal information with trusted third parties for the purposes of processing your application:

• Background check providers
• Referees
• Internal Nomupay teams involved in the hiring process

All third parties are contractually obligated to handle your data securely and in compliance with applicable laws.

The confidentiality and security of your information is importance to us. We take the utmost care when handling your personal and confidential information and ensure that we have appropriate organisational and technical security measures in place to prevent unauthorised access, accidental damage, destruction or loss. Access to your information is on a need to know basis.

We use computer safeguards such as firewalls and data encryption and enforce physical access controls to our buildings and records to keep information safe and expect those who are employed or who work in partnership with us have regular training and follow our policies and procedures.

We retain your data only as long as necessary for the recruitment process or as required by law. If you’d like us to delete your data, you can contact us at any time.

You can ask for this data to be deleted at any time by contacting data.privacy@nomupay.com

You have several rights including:

1. A right to access and to obtain information regarding your Personal Data that we process;
2. A right to correct data if you believe that any information we hold about you is incorrect or incomplete;
3. A right to deletion of your data if applicable;
4. Object to the processing of your Personal Data;
5. Restrict the processing of your Personal Data; and/or
6. Withdraw your consent where Nomupay obtained your consent to process Personal Data.

Please note that the above rights may not apply in all circumstances.

If you have any questions or concerns about the information we hold on you, please contact our Data Protection Officer – data.privacy@nomupay.com or write to us: Nomupay, 111 Piccadilly, Manchester, M1 2HY

We will update this privacy policy from time to time to reflect any changes to our ways of working. Please contact our Data Protection Officer if you would like more information.

Last update: January 2025