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RECRUITMENT PRIVACY POLICY AND NOTICE

Curtis, Mallet-Prevost, Colt & Mosle LLP (a limited liability partnership organized under the laws of the State of New York, USA) and its associated entities and offices practicing under the Curtis, Mallet-Prevost, Colt & Mosle name in other jurisdictions (including Curtis, Mallet-Prevost, Colt & Mosle LLP, a limited liability partnership established under English law) (collectively, “Curtis” or “we”) are committed to being transparent about how it collects and processes personal data and to meeting its data protection obligations under applicable data protection laws and regulations.  The list of Curtis entities and offices, which are located outside as well as within the European Economic Area (“EEA”), is set out in the Legal Notices section of our website http://www.curtis.com/.  

Personal data” includes any information relating to an individual by which that individual can be identified, directly or indirectly, particularly by reference to an identifier such as the name, identification number, location data or an online identifier of that individual or by reference to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.  Our Privacy Statement on our website at http://www.curtis.com/sitecontent.cfm?pageid=86 (which includes the information required under the General Data Protection Regulation (“GDPR”) and other applicable laws and regulations) applies to the recruitment process at Curtis. Personal data of individuals provided to us or received by us during the course of, or in connection with, an enquiry or an application for a job, summer placement, vacation scheme, internship, or any other position (whether permanent or temporary) (“Recruitment”) at Curtis will be processed by Curtis in accordance with the Privacy Statement at http://www.curtis.com/sitecontent.cfm?pageid=86 in so far as applicable in the context of Recruitment and in accordance with this recruitment privacy policy and notice.

The primary controller of an individual’s personal data in connection with Recruitment in so far as Curtis entities are concerned when processing such data will be the Curtis entity to whom a Recruitment related enquiry or application has been made. 

Types and sources of personal data Curtis may collect and process in connection with Recruitment

Curtis may collect and process in connection with Recruitment personal data such as an individual’s:

(a)  first and last name(s), title, gender, date of birth and contact details (postal address, personal or business email addresses and/or telephone numbers);

(b)  ID documentation such as passport, ID card and/or driving licence;

(c)  immigration status documentation such as work permit, visa or other immigration documents;

(d)  references, diplomas, certificates and other education and/or qualification documentation, results of background checks, including, to the extent permitted by applicable laws and regulations, checks regarding criminal record;

(e)  curriculum vitae (CV), together with supporting documentation and application, including any personal data relating to reasons for the application;

(f)  language skills; and/or

(g)  any special requirements (such as in relation to a disability or any health issue).   

We may collect or receive such personal data via email, online, in hard copy, over the phone, via videoconference and/or in person (such as at interviews or other meetings): directly from an applicant to whom such data relates; or from an intermediary such as a recruitment agency; or from a reference or background screening provider; from the applicant’s referees, current and/or present employers; and/or from other lawful sources.

Personal data Curtis processes in connection with Recruitment may include “special categories of personal data” of an individual, which includes data revealing an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data (such as passport photos and other ID photos) processed for the purpose of uniquely identifying an individual, data concerning health or data concerning an individual’s sex life or sexual orientation. 

In addition, Curtis may, where appropriate, process, in connection with Recruitment, personal data relating to an individual’s criminal offences or confirmation of clean criminal record, if permitted and/or required by applicable laws and/or regulations.

Our lawful bases for processing an applicant’s personal data in connection with Recruitment

Curtis’s lawful bases for processing personal data in connection with Recruitment are:

  1. processing is necessary for Curtis’s legitimate interests in: (a) assessing an applicant’s suitability, qualifications and expertise for a position for which he or she has applied at Curtis (such as a partner, counsel, associate, trainee or consultant position, a summer placement, a vacation scheme placement, an intern role, a business support or administrative role (including a secretarial position) or a services role); (b) managing and fulfilling our recruitment needs for Curtis’s business as a law firm; and/or (c) reviewing Curtis’s recruitment profile in accordance with applicable laws and regulations to ensure equal opportunities and non-discrimination on the grounds of gender, race, ethnic origin, age, religion, disability or any other basis covered by applicable laws and regulation; or
     
  2. processing is necessary for compliance with a legal obligation to which any Curtis entity is subject, including, for example, in order to verify an applicant’s right to work lawfully in the relevant country; or
     
  3. as otherwise permitted by applicable laws and/or regulations. 


Our lawful bases for processing special categories of personal data in connection with Recruitment

Our lawful bases for processing special categories of personal data of an individual in connection with Recruitment are:

  1. processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity;
     
  2. processing relates to personal data which is manifestly made public by the individual to whom the data relates;
     
  3. on the basis of explicit consent of the individual to whom the data relates provided to Curtis in the context or in connection with Recruitment relating to him or her, which would include consent to Curtis conducting criminal background and other checks relating to the individual; or
     
  4. as otherwise permitted by applicable laws and/or regulations.

Please do not provide to Curtis any special categories of personal data of any individual in connection with Recruitment, until that individual has explicitly consented in writing to such special categories of personal data relating to him or her being processed by Curtis as set out in this recruitment privacy policy and notice, and such explicit consent has been provided to Curtis.

Cross-border transfers of personal data and recipients of data in connection with Recruitment

Processing of personal data (which includes, or may include, special categories of personal data and/or information regarding an individual’s criminal record or alleged criminal activities) by any office(s) of the Curtis entities within the European Economic Area (“EEA”) involves transfer of such personal data to the offices of the Curtis entities outside the EEA.  Such transfers are made on the legal bases described in the Privacy Statement on our website at http://www.curtis.com/sitecontent.cfm?pageid=86.  Such data may also be transferred by a Curtis entity to a third party which may be within or outside the EEA.  The categories of recipients of personal data processed by Curtis and legal bases for transfers of such data to recipients outside the EEA are set out in the Privacy Statement on our website at http://www.curtis.com/sitecontent.cfm?pageid=86

Failure to provide information

Where personal data of an individual is needed by Curtis for the purposes of, or in connection with, any aspect of the Recruitment process and such personal data is not provided to us, Curtis may stop or not proceed with the Recruitment process.

Data security

Curtis has implemented appropriate personal data security policies and technical measures to protect personal data under its control, including personal data which Curtis processes in connection with Recruitment, from unauthorised access, improper use, unauthorised modification, unauthorised disclosure or accidental loss. The Curtis entities have put in place procedures to deal with any personal data breach in accordance with their respective legal obligations in this regard under applicable laws and regulations.

Retention of personal data in connection with Recruitment

Personal data processed by Curtis in connection with Recruitment is retained by Curtis: (i) in relation to successful Recruitment applications which result in the individual to whom the application relates commencing work at Curtis, for the period specified in the relevant job offer documentation; and (ii) in relation to Recruitment applications which are unsuccessful or which do not ultimately result in the individual to whom the application relates commencing work at Curtis, typically, for the period of up to one year, in each case, except where one or more Curtis entities believe that such personal data is or may be otherwise required to be retained for a longer period by any applicable laws or regulations and/or professional or regulatory rules and/or standards to which one or more Curtis entities are subject, in which case such personal data will be retained for such longer period.

Individuals’ rights under the GDPR

Individuals have, or may have, rights under the GDPR, including in respect of their personal data processed by Curtis in connection with Recruitment.  For the description of such rights and how individuals may exercise one or more of their rights under the GDPR in connection with their personal data processed by Curtis, please see the Privacy Statement on our website at http://www.curtis.com/sitecontent.cfm?pageid=86.

Changes

This recruitment privacy policy and notice may change from time to time.  Any updates to this recruitment privacy policy and notice will be included on the Curtis website at http://www.curtis.com/sitecontent.cfm?pageid=99.

If you need further information on how Curtis processes individuals’ personal data, please click the following link to our Privacy Statement: http://www.curtis.com/sitecontent.cfm?pageid=86 or contact privacy@curtis.com.

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