Recruiting Privacy Notice

We collect and process personal information about you when you apply for a job with us. This may include, to the extent permitted by the law of your country:

• • • Information you provide to us: We may collect and store any information you provide us through your application, including: Contact information, such as your name, address, phone, email, and other similar information; Resume or CV, cover letter, previous work experience, education, and transcripts; Desired salary, relevant work experience, type of employment sought, date available, employee referral; Identification, such as your passport number, expatriate status, government identification numbers (e.g. Social Security Number) where permitted, immigration status; race, ethnicity and other sensitive information where permitted (as part of our commitment to equality and diversity in the workplace) and any other information you submit to us, including any correspondences you may have with us during the application process.
    • Information from other sources: We may obtain information about you from other sources, to the extent permitted by applicable law, such as through your contact with or from third parties, including recruiters, employment research firms, identity verification services, the references you provide to us, websites and other publicly accessible information on the Internet. We may also receive information you submit to us through third-party websites, including through LinkedIn. Where permitted by local law and with your consent, we may request background or credit checks from public authorities or financial institutions to evaluate your eligibility for employment or certain Fragomen positions or projects.
    • Information we collect automatically: When you make an application through our online portal, we may collect information sent to us by your computer, mobile phone or other access device. The information sent to us includes, but is not limited to, the following: data about the pages you access, your computer IP address, device identifiers, the type of operating system you are using, your location, mobile network information, standard web log data and other information, including your browser type and traffic to and from our site.

Fragomen may process your personal information for the following purposes:

• • • To assess your skills and interest in career opportunities at Fragomen, process your application, analyze your qualifications and verify your identity and your eligibility for employment;
    • To communicate with you about your application, respond to your inquiries, schedule interviews, appointments and phone calls send and send notices to you about other open positions;
    • To protect the security of Fragomen's premises, assets, systems, and intellectual property, enforce company policies and permit the functionality of our online portal, including to authorize the creation of online accounts, provide customer service and reset passwords; 
    • Where permitted by applicable law and with your consent, we may conduct background checks, which may include verification of skill proficiency, criminal history, financial history and other information that may be necessary for determining your qualifications, preventing fraud, or as requested by Fragomen’s clients;
    • Where permitted by applicable law, and where this information has been provided by you, consider your race, ethnicity and other sensitive information as part of our ongoing commitment to equality and diversity in the workplace;
    • To comply with applicable laws and protect Fragomen's legitimate interests and legal rights, including, but not limited to, use in connection with legal claims, compliance, regulatory, auditing, investigative and disciplinary purposes (including disclosure of such information in connection with legal process or litigation) and other ethics and compliance reporting requirements;
    • To assess qualifications in the event you are employed with Fragomen and subsequently transfer to a different Fragomen entity; and
    • To analyze and improve our application and recruitment process.

Personal information may be shared between Fragomen group companies (Fragomen, Del Rey, Bernsen & Loewy, LLP, Fragomen Global LLP, and any of our related affiliates and subsidiaries worldwide) when necessary for business purposes. 

Personal information may be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the protection of Fragomen's legitimate interests in compliance with applicable laws. 

Personal information may also be shared with third-party service providers, such as the vendors we retain to administer our online and customer services, who process it on behalf of Fragomen for the purposes outlined above. 

We process your personal information because it is necessary to assess your job application. 

The lawful basis we rely on to do this relates to the possibility of entering into a contract of employment with you in the future. When processing your application, we are taking steps at your request, to consider whether you are eligible for the position, to consider you for an interview you and ultimately, if you are the successful candidate, to enter into a contract of employment with you.

On some occasions, we may also rely on your consent to process your personal information.  For example, if we ask your permission to conduct a background check, or we request information regarding your race, ethnicity or other sensitive information for equality and diversity purposes where permitted by local laws.

We also process your personal information where we are required to by law (for example, to comply with record-keeping, auditing, tax or other employment law obligations), or when it is in Fragomen's legitimate interests and when these interests are not overridden by your privacy and data protection rights, such as to protect the security of our facilities. 

We will retain your personal information for as long as we need it to process your application. If your application results in employment with us, the information provided may be retained for purposes of your employment. Unless you indicate otherwise, we will also retain your personal information for a reasonable time to consider your candidacy for other positions that may be of interest to you.

Fragomen takes appropriate technical, administrative, physical and procedural security measures, consistent with local and international information practices, to protect your personal information from misuse, unauthorized access or disclosure, loss, alteration, or destruction.

If you have any questions about our information handling practices or if you wish to access your personal information you should contact our Data Privacy Officer at: [email protected]  

For Applicants within the European Union

You have the right to ask Fragomen for a copy of your personal information, or to correct, delete or restrict processing of your personal information.  In addition, you can object to the processing of your information in some circumstances and, where we have asked for your consent, you may withdraw it at any time. 

These rights may be limited in some circumstances, for example if fulfilling your request would reveal personal information about another person, if we have compelling legitimate interests, or if you ask to delete information which we are required by law to keep. 

If you have unresolved concerns, you have the right to complain to a data protection authority. The data controllers for your personal information are the Fragomen office to which you applied, as well as Fragomen Global LLP. 

Your personal information may be transferred to our affiliates in the United States of America or other countries which we are located and may be processed through global systems and tools for the purposes outlined above.

To see a list of countries please visit: https://www.fragomen.com/locations.

We may also transfer your personal information for these purposes to suppliers in other jurisdictions that may not have equivalent data protection laws to those in your country.  

We have implemented international data transfer agreements, including Standard Contractual Clauses approved by the European Commission, to keep your information safe. You may view a copy of these agreements by contacting us as described in the Your Choices and Rights section above.

This Privacy Notice may be updated periodically to reflect changes in our data practices. We will post a notice on our applicable websites, applications or materials to advise of any significant changes to our Privacy Notice and indicate in the notice when it was most recently updated.