Recruitment Privacy Notice

1. About this Notice

This Recruitment Privacy Notice explains how personal data is processed when you apply for a position within the iLoF Group, are considered or contacted about a potential position, participate in an iLoF recruitment process, or submit a speculative application or ask to be considered for future opportunities.

This Notice currently covers recruitment by ILOF – INTELLIGENT LAB ON FIBER LIMITED (“iLoF UK”) and iLoF – Intelligent Lab on Fiber, Unipessoal Lda (“iLoF Portugal”).

If a position is offered by another iLoF Group company, including the Group’s US subsidiary, the relevant hiring entity will be identified in the job advertisement or recruitment communication. Additional jurisdiction-specific privacy information will be provided where required by applicable law.

2. Who is responsible for your personal data?

The iLoF Group company offering the position for which you apply will normally be the controller responsible for processing your personal data in connection with that recruitment process. The relevant hiring entity should be identified in the job advertisement.

UK positions

Where the hiring entity is ILOF – INTELLIGENT LAB ON FIBER LIMITED, iLoF UK is the controller for the recruitment process.

Recruitment and HR activities are operationally supported from Portugal. Personnel of iLoF – Intelligent Lab on Fiber, Unipessoal Lda may therefore access and process candidate information on behalf of iLoF UK in connection with recruitment administration.

Portuguese positions

Where the hiring entity is iLoF – Intelligent Lab on Fiber, Unipessoal Lda, iLoF Portugal is the controller for the recruitment process.

The fact that a vacancy is advertised through ilof.tech, which is operated by iLoF UK, does not change the identity of the hiring entity or the controller for that recruitment process.

US positions

Where a position is offered by an iLoF Group company in the United States, the relevant US hiring entity identified in the job advertisement or recruitment communication will be the controller for that recruitment process.

Recruitment and HR administration may be operationally supported from Portugal. Additional privacy information will be provided where required by applicable US federal or state law.

3. Personal data we may collect

Depending on the position and stage of the recruitment process, we may collect and process:

• your name and contact details;
• address or location;
• CV or résumé;
• cover letter;
• employment and professional history;
• education and qualifications;
• professional skills and experience;
• publications, patents or other professional outputs where relevant;
• information provided in application questions;
• interview notes and assessments;
• results of technical or professional assessments;
• salary or compensation expectations;
• availability and notice period;
• immigration, visa or right-to-work information;
• references and referee details;
• communications with you;
• information provided by recruitment agencies or professional platforms; and
• information necessary to prepare or administer an employment offer.

Please avoid providing personal information that is not relevant to the recruitment process.

4. Where we obtain candidate information

We may obtain information directly from you, through ilof.tech or another recruitment platform, through LinkedIn or another professional network, from a recruitment agency or recruiter, from referees, from publicly available professional sources, or from another iLoF Group company where this is relevant to a recruitment process.

If we identify or approach you through a professional source rather than receiving an application directly from you, we will provide the applicable privacy information as required by law.

5. Why we use candidate information

We may process candidate information to:

• receive and administer applications;
• assess experience, qualifications and suitability for a position;
• communicate with candidates;
• organise and conduct interviews;
• conduct relevant professional or technical assessments;
• verify information provided during recruitment;
• obtain references where appropriate;
• determine eligibility to work in the relevant jurisdiction;
• make recruitment and compensation decisions;
• prepare and issue employment offers;
• make reasonable adjustments where required;
• maintain recruitment records;
• comply with employment, immigration and other legal obligations;
• establish, exercise or defend legal claims; and
• where separately agreed or otherwise lawfully permitted, consider candidates for future opportunities.

6. Our lawful bases

Steps before entering into a contract

We process information necessary to assess your application and take steps at your request with a view to entering into an employment or other engagement contract.

Legal obligations

We may process information where necessary to comply with applicable employment, immigration, equality, tax or other legal obligations.

Legitimate interests

We may rely on legitimate interests where necessary to identify and assess suitable candidates, organise and manage an effective recruitment process, communicate with candidates, maintain appropriate records, protect the interests of the relevant iLoF Group company, and establish, exercise or defend legal claims.

Consent

Where we specifically ask for consent for a particular processing activity, participation will be voluntary and you may withdraw that consent in accordance with applicable law. We will not rely on consent where another lawful basis is more appropriate.

7. Special-category personal data

In some circumstances, recruitment may involve information subject to enhanced legal protection. This may include, for example, health or disability information required to provide a reasonable adjustment, equality and diversity information, or other special-category information that you choose to provide or that is necessary for a lawful recruitment purpose.

We will only process such information where there is an appropriate legal basis and an applicable condition for processing special-category data. Access to such information will be restricted to those who need it for the relevant purpose.

8. Criminal-record and background information

We will only request criminal-record information or carry out background checks where this is relevant to the position, lawful in the relevant jurisdiction and supported by the appropriate legal basis and safeguards. Where a particular background check requires additional privacy information, that information will be provided separately.

9. Reasonable adjustments

If you request an adjustment to participate in the recruitment process, we may process information necessary to understand and provide the adjustment. Such information will only be used for the relevant purpose and access will be restricted appropriately.

10. Sharing candidate information within the iLoF Group

Recruitment activities may involve personnel from more than one iLoF Group company. Candidate information may therefore be accessed by recruitment and HR personnel, relevant hiring managers, interviewers, managers involved in the hiring decision, and other personnel whose involvement is reasonably necessary for the recruitment process.

For UK vacancies, recruitment administration may be carried out by personnel of iLoF Portugal on behalf of iLoF UK. This does not mean that every iLoF Group company becomes a controller of your application.

Where candidate information is subsequently used by another Group company for a separate recruitment process, that company may become a controller in relation to that new purpose.

11. Other recipients

Where necessary, candidate information may also be shared with:

• recruitment agencies and recruiters;
• applicant-management or recruitment platforms;
• professional networking platforms;
• IT and communications providers;
• assessment or testing providers;
• background-screening providers, where applicable and lawful;
• immigration or mobility advisers;
• professional advisers;
• referees; and
• competent courts, regulators or public authorities where required.

Candidate information is not shared with third parties for unrelated marketing purposes.

12. International processing and transfers

Because recruitment for iLoF UK is operationally supported from Portugal, candidate information relating to UK positions may be accessed and processed in Portugal. Personal data may therefore be transferred between the United Kingdom and the European Economic Area.

Where an international transfer requires a specific safeguard under applicable data protection law, an appropriate transfer mechanism will be used. Transfers from the European Economic Area to the United Kingdom may rely on the applicable European Commission adequacy decision. If recruitment activities in the future require transfers to another country, the relevant safeguards and any additional information required by law will be addressed at that time.

13. How long we keep recruitment information

UK recruitment

Where an application to iLoF UK is unsuccessful, candidate information will normally be retained for up to six months after the recruitment process has ended, unless a longer period is necessary in connection with an actual or anticipated legal claim, another legal obligation requires longer retention, or you have separately agreed to be considered for future opportunities.

Portuguese recruitment

For recruitment processes carried out by iLoF Portugal, the records required by Article 32 of the Portuguese Labour Code will be retained for five years, as required by law.

This statutory recruitment record is distinct from the complete candidate file. Personal information that is not required for that statutory record will not be retained merely because the five-year record-keeping obligation applies.

Other candidate information will normally be retained for up to six months after the relevant recruitment process has ended, unless a longer period is required by law, necessary in connection with a legal claim, or you have agreed to be considered for future opportunities.

Successful candidates

Where you accept an offer, relevant information collected during recruitment may become part of your employment record and will then be processed in accordance with the privacy arrangements applicable to personnel of the relevant hiring entity. Information that is not required for the employment relationship will not be retained solely because you have become an employee.

14. Speculative applications and future opportunities

A speculative application or an application for a particular vacancy does not automatically mean that your complete application will be retained indefinitely for other opportunities.

Where we wish to retain your information for future opportunities beyond the ordinary recruitment retention period, we may ask whether you would like us to do so. Where you agree, we will normally retain the relevant candidate information for up to 12 months for this purpose.

You may ask us at any time to stop considering you for future opportunities. If your information is subsequently passed to another iLoF Group company for consideration for a specific position, that company may become the controller for the resulting recruitment process.

15. Recruitment decisions

Recruitment decisions are made by the personnel responsible for the relevant hiring process based on the information available during recruitment.

We do not currently make recruitment decisions that produce legal or similarly significant effects on candidates solely by automated means. If automated decision-making of this kind is introduced, candidates will be provided with the information and safeguards required by applicable law.

16. Is providing personal data mandatory?

You are not generally legally required to apply for a position or provide candidate information. However, some information is necessary for us to assess your application, communicate with you or determine whether you are legally eligible for the relevant role. If you do not provide information that is reasonably necessary for those purposes, we may be unable to progress your application.

17. Your rights

Depending on the law applicable to the recruitment process, you may have rights including the right to request access to your personal data, correct inaccurate or incomplete information, request deletion in certain circumstances, request restriction of processing, object to processing based on legitimate interests, withdraw consent where processing is based on consent, and request portability of certain information where the relevant legal conditions are met.

These rights are subject to applicable legal conditions and exceptions.

Where iLoF UK is the controller, you may lodge a complaint with the Information Commissioner’s Office (ICO). Where iLoF Portugal is the controller, you may lodge a complaint with the Comissão Nacional de Proteção de Dados (CNPD).

18. Security

We use appropriate technical and organisational measures designed to protect candidate information against unauthorised access, disclosure, alteration, loss or destruction. Access to recruitment information is restricted according to business need.

19. Changes to this Notice

We may update this Recruitment Privacy Notice to reflect changes to our recruitment processes, Group structure or legal obligations. The current version will be available through the Careers section of ilof.tech and the “Last updated” date will be amended accordingly.

20. Contact

For questions or requests concerning recruitment privacy, please contact:

Email:
privacy@ilof.tech
info@ilof.tech

Please identify your message as a Recruitment Privacy enquiry and, where applicable, identify the vacancy to which your request relates.