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Effective from November 2021……
UBA RECRUITMENT DATA POLICY
UBA understands that your privacy is important to you. We may process your personal data in our capacity as data controllers. We take data protection very seriously and understand the importance of protecting your privacy and Personal Information (as defined below).
Please do not submit such Personal Information to us if you do not wish us to collect it.
This Recruitment Privacy Notice (RPN) describes how we handle and protect your personal data in line with UBA’s recruiting processes and programs.
This RPN only applies to the personal data of job applicants and potential candidates for employment. However, it does not apply to our employees, contractors or clients.
“Personal data”/ ”Personal Information” means information that identifies job applicants and potential candidates for employment with us, either submitted as part of the online application and/or through alternative channels (e.g., via professional recruiting firms).
We will process your personal data in accordance with this RPN, unless such processing conflicts with the requirements of applicable law, in which case, applicable law will prevail.
By submitting your personal data to us, you acknowledge that:
You have read and understood this RPN and agree to the use of your Personal data as stated therein.
You are not obligated to provide any requested information to us, however, failing to do so may affect our ability to assess your application for the job.
All of Personal Information provided by you as well as your representations are true and correct to the best of your knowledge and belief, and you have not knowingly omitted any related information of an adverse nature. Providing any inaccurate information may make you ineligible for employment.
This RPN does not form part of any contract of employment offered to hired candidates.
What Personal Information do we collect?
Personal Information we collect about you may include the following:
General identification and contact information: your name; address; email; telephone details; gender; marital status; family status; date and place of birth; physical attributes including photos.
Other sensitive information: religious beliefs, ethical origin, and criminal record.
Information enabling us to provide products and services: age, location.
Publicly available information in relation to professional history: educational background; employment history; skills and experience; professional licenses and affiliations; educational and professional qualifications.
We collect personal data about you from third parties, such as professional recruiting firms, your references, prior employers and employment background check providers, to the extent this is permitted by applicable law.
We may also collect personal data about you online to the extent that you have made this information publicly available. For example, we may find your profile on professional social media websites (such as LinkedIn through our recruiter’s license) and contact you about suitable roles.
What legal basis do we rely on to process your Personal Information?
Consent
UBA in applicable circumstances will process your data with your consent. For example, we rely on consent when we send promotional material or when you link your candidate account to your Social Network account. You have the right to withdraw consent at any time. Where consent is the only legal basis for processing, we will cease to process data after consent is withdrawn.
The processing is necessary to fulfil a contract
Legitimate Interest
UBA also processes your data when it is necessary to protect your interest or the interest of any other persons.
Such legitimate interests include:
Ensuring the security and integrity of our services and ensuring that our Websites and Apps operate effectively;
operating our business and protecting UBA and its employees, clients, and third parties;
to manage our relationship with you, and to evaluate and maintain the efficacy of our recruiting process more generally;
to verify the Personal Information you provide to us;
to assess and confirm your suitability for employment and decide to whom to offer a job.
To respond and defend against legal claims.
The processing is necessary for compliance with a legal obligation
UBA may process your data to comply with our legal and regulatory obligations, e.g. preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies.
Who do we share your Personal Information with?
Our service providers

This includes external third-party service providers, such as medical partners for pre-employment medical screening, background check, recruiting firms, auditors, IT systems, support and hosting service providers; data storage and cloud providers and similar third-party vendors and outsourced service providers that assist us in carrying out business activities.
UBA may share Personal Information with governmental or other public authorities (including, but not limited to, Central Bank, credit bureau, law enforcement, and criminal investigations agencies); and other advisors and representatives as we believe to be necessary or appropriate: (a) to comply with applicable law; (b) to comply with legal process; (c) to respond to requests from public and government authorities; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety or property, you or others; and (g) to allow us to pursue available remedies or limit our damages.
UBA may share your Personal Information with its subsidiaries and affiliate companies.
Other third parties
Occasionally, we may share Personal Information with other third parties, including background check service providers. We will always do this under contract and in accordance with your instructions.
How we use Personal Information?
We collect and use your personal data for legitimate human resources and business management reasons including:
Identifying and evaluating candidates for potential employment, as well as for future roles that may become available;
Recordkeeping in relation to recruiting and hiring;
Conducting background and criminal history checks as permitted by applicable law;
Protecting our legal rights to the extent authorized or permitted by law; or
Emergency situations where the health or safety of one or more individuals may be endangered.
We may also analyze your personal data or aggregated data to improve our recruitment and hiring process and augment our ability to attract successful candidates.
Data retention
If you accept an offer of employment by us, any relevant personal data collected during your pre-employment period will become part of your personnel records. If we do not employ you, we may nevertheless continue to retain and use your personal data for a period of time for system administration purposes, to consider you for potential future roles, and to perform research. Thereafter, we retain a minimal amount of your personal data to record your recruiting activity with us to enable us to understand whether you have previously applied for a role (or roles).
Your personal data will be retained for such period as is required to meet any legal and/or regulatory requirement as well as UBA’s operational polices.
Security
We have implemented generally accepted standards of technical and operational security to protect personal data from loss, misuse, alteration, or destruction. Only authorized personnel of UBA and of our third party service providers are provided access to Personal data, and these employees and third party service providers are required to treat this information as confidential. Despite these precautions, we cannot guarantee that unauthorized persons will not obtain access to your personal data.
Your rights
We take reasonable steps that are designed to keep your personal data accurate, complete, and up-to-date for the purposes for which it is collected and used. We also have implemented measures that are designed to ensure that our processing of your personal data complies with this RPN and applicable law.
In accordance with applicable law, you have;
A right to request a copy of the personal data we hold about you and details of how we use that information;
A right to amend or rectify your personal data if any of the information held about you is incorrect or out of date;
A right to erase your personal data, to demand that we cease the processing of your personal data, to restrict the processing of your personal data, and/or to withdraw your consent to the processing of your personal data. This may not apply if there are other legal justifications to continue processing and we may need to retain certain Personal data where required or permitted under applicable law, and; 
A right to provide us with instructions as to the processing of your Personal data in case of death.

In addition, and where granted by applicable law, you may have the right to lodge a complaint with a competent data protection authority.
If you would like to make a request to access, review, correct, delete or port the personal data we have collected about you, or to discuss how we process your personal data, please contact our data protection officer, Romaric Sia at [email protected]
To help protect your privacy and security, we will take reasonable steps to verify your identity before granting you access to your Personal data. We will make reasonable attempts to promptly investigate, comply with, or otherwise respond to your requests as may be required by applicable law. Depending upon the circumstances and the request, we may not be permitted to provide access to Personal data or otherwise fully comply with your request; for example, where producing your information may reveal the identity of someone else. We reserve the right to charge an appropriate fee for complying with your request where allowed by applicable law, and/or to deny your requests where, in the Bank’s discretion, they may be unfounded, excessive, or otherwise unacceptable under applicable law.
Social Media Tools
Our application process allows you to pull relevant information from social media websites (such as LinkedIn, Google Drive and Facebook) into your application form. If you choose to feed any Personal data from such social media tools, it will be used in accordance with this RPN.
Cookies and other tracking technologies
We may use first party and third-party cookies, web beacons, pixels, clear gifs, and other similar technologies (collectively “Cookies and Other Tracking Technologies”) to identify you and your interests, to remember your preferences, and to track your use of our websites. We also use Cookies and Other Tracking Technologies to control access to certain content on our websites, to protect the websites, and to process any requests that you make of us.
Changes to Privacy Policy
We review this RPN regularly and reserve the right to make changes at any time to take account of changes in our business and legal requirements. We will place updates on our website.
Please view the “Effective from” date at the top of these terms to see when it was last revised.


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