RMS Data Privacy Notice

1. Introduction

Seamless Technologies (“us”, “we”, or “our”) understands the criticality of privacy in handling your (“Data subject”) personal data. Hence, we want you to engage with us knowing that we value your Personal Data and that we protect it. Here you will find details of how we process your Personal Data through Seamless Technologies RMS, our recruitment management system for receiving, managing, assessing, and communicating with applicants throughout the recruitment process, the purposes for which we process it, your rights regarding the data we process and how you can contact us.

2. Definitions

Personal Data: Any information relating to an identified or identifiable living individual, including information that can directly or indirectly identify an applicant.

Applicant/Candidate: Any person who applies, is considered, or is assessed for employment, internship, consultancy, or any similar opportunity with Seamless Technologies.

Seamless Technologies RMS: The recruitment management system used by Seamless Technologies to collect, store, review, assess, and manage applicant information throughout the recruitment process.

Sensitive Personal Data: Personal Data revealing or relating to matters such as health information, biometric data, race or ethnic origin, religious beliefs, criminal records, or other categories treated as sensitive under applicable data protection laws.

3. Collectable Personal Data

Through our Recruitment Management System, we may collect the following categories of personal data:

Contact information: This includes any information you provide to Seamless Technologies that would allow us to contact you personally, such as your name, address, e-mail, phone number, social media profiles, and residential address.

Demographic information & interests: Any information that describes your demographic or behavioral characteristics. Examples include your date of birth, age or age range, gender, geographic location (e.g., postcode/zip code), hobbies and interests, and/or lifestyle information.

Professional and Educational Data: This includes any information such as Curriculum vitae, academic records, certifications, cover letter, employment history, references.

Assessment Data: This includes information such as interview notes or videos, test results, answers to screening questions, skills assessments, any other information you provide to us in support of and during the recruitment process;

Sensitive Personal Data: We do not seek to collect or otherwise process sensitive personal data in the ordinary course of our business. Sensitive information includes data relating to race, ethnicity, political opinions, religious or other similar beliefs, trade union membership, physical or mental health, sexual tendencies, or criminal record. Where it becomes necessary to process your sensitive personal data for reasons dealing and associated with or relating to Seamless Technologies’ recruitment process, we rely on your prior express consent for any such processing, which is voluntarily given. Where we seek to process your sensitive personal data for any other reason except where mandated otherwise by local law(s), local law enforcement or any regulatory authority, your express written consent will be required beforehand. We may enhance personal information we collect from you with information we obtain from third parties that are entitled to share that information; for example, information from other agencies, search information providers or public sources (e.g., for due Seamless Technologies diligence purposes), but in each case as permitted by applicable laws.

4. Condition for Processing Personal Data

We shall only process your personal data if at least one of these conditions are met:

Consent: This refers to any freely given, specific, informed, and unambiguous indication through a statement or a clear affirmative action that signifies your agreement to the processing of your Personal Data by Seamless Technologies RMS.

Contractual Necessity: Processing is necessary to process your application and to take the steps necessary before entering into an employment contract. This includes processing your job application, assessing your suitability for a role, and communicating with you throughout the recruitment process.

Legal obligation: Processing is necessary for compliance with a legal obligation to which Seamless Technologies is subject.

Legitimate interests: To manage and improve recruitment processes, provided such interests do not override the rights of the data subjects.

Public interest: processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in Seamless Technologies.

Proper motives: Seamless Technologies shall not seek consent that may engender direct or indirect propagation of atrocities, hate, child rights violations, criminal acts, and anti-social conduct.

5. How We Use Your Personal Data

Your personal data is used strictly for recruitment and hiring purposes, including:

• Managing job applications and candidate databases
• CV screening and assessing qualifications
• Interview coordination
• Conducting Assessments and communicating hiring decisions
• Offer letters and onboarding successful applicants

6. User Rights

You have rights when it comes to our handling of your Personal Data. Those rights include:

• the right to request access to your Personal Data where those requests are reasonable and permitted by law or regulation. Seamless Technologies shall provide reasonable and accessible means for Individuals to submit their requests, which do not have to take any specific form and can be submitted by any method, this process is handled and managed by the Data Protection Office in Seamless Technologies
• the right to request that Seamless Technologies erase your Personal Data in accordance with applicable data protection laws.
• the right to rectify or amend inaccurate or incomplete Personal Data,
• the right to withdraw your Consent at any time. This can be initiated by contacting the Data Protection Office of Seamless Technologies,
• the right to object to Seamless Technologies’ processing of your Personal Data if there are compelling legitimate grounds to do so and to the extent permitted by law or regulation,
• individuals have the right to object to Seamless Technologies’ processing of their Personal Data for direct marketing purposes,
• the right to receive your Personal Data in a commonly used and machine-readable format and,
• the right not to be subject to automated processing which will affect your legitimate interests.
• The right to lodge a complaint with the Nigeria Data Protection Commission (NDPC) where you believe our processing of your data violates the requirements of the Nigeria Data Protection Act 2023(NDPA), Office of the Data Protection Commissioner for KDPR ; for GDPR, you can lay a complaint with the Information Commissioner’s Office (ICO).

If you want to request that any of these rights, be actioned in relation to your personal data, please complete this form or send an email to dpo@Seamlesstech.com.

7. Data Collection Methods

• Web Forms: We collect your personal details provided via our online recruitment portal. This typically includes information such as your name, contact details, employment history, and educational background. These details are processed for the purposes of candidate evaluation, communication, and talent acquisition, and are kept in a secure manner.
• Electronic Medium: We collect personal details via electronic media (such as email, complaint forms, etc.) in a secure manner while maintaining accuracy. These communications may include CV submissions, queries, feedback, or interview scheduling. All electronic records are maintained securely, and, when necessitated by legal or vital obligations, we archive these communications.

8. Transfer of Personal Data

The following describes the various scenarios for which we may share your Personal Data with third parties.

• Transfer for Service Provision: we employ other companies and individuals to perform functions on our behalf as service providers. Service providers, and their selected staff, are only allowed to access and use your Personal Data on our behalf for the specific tasks that they have been requested to carry out, based on our instructions, and are required to keep your Personal Data confidential and secure.
• Transfer as a legal requirement: we may share your information with other parties when required by law or as necessary to protect our service. We may also share your information in connection with a transfer of assets, or if we are otherwise involved in a merger or transfer.
• Intra-Company transfers: your Personal Data may be transferred to or accessible by other entities within the Seamless Technologies Group. However, these entities will be bound by the terms of this Policy.
• Out of Country Transfer: Your Personal Data may be transferred to a foreign country for storage or processing where it is necessary to do so in line with the permissible conditions defined by the NDPA-GAID, KDPR and GDPR. We will ensure that appropriate safeguards are in place to ensure the protection of your Personal Data being stored or processed out of the country.

9. How We Ensure Protection of Your Personal Data

We use appropriate measures (including physical access controls and secure software and operating environments) to keep your Personal Data confidential and secure. Seamless Technologies is in compliance with these data protection regulations: NDPA-GAID, KDPR and GDPR, and this assures that your personal data is collected, managed, processed and stored according to the requirements stated in these regulations. Please note, however, that these protections do not apply to information you choose to share in public areas such as third-party social networks.

• Data Retention Policy: Where your application is unsuccessful, we retain your personal data for a period of up to 24 months, for the legitimate purpose of considering you for future suitable roles. At the end of the retention period, we will contact you regarding continued retention of your data for this purpose.
• Personal Data Breach Notification: Seamless Technologies will inform relevant authorities and if necessary, affected individuals of personal data breach within 72 hours of being aware of the breach where Personal Breach refers to a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data. This includes breaches that are the result of both accidental and deliberate causes.

10. Changes to This Notice

If we change the way we handle your Personal Data, we will update this Notice and keep you informed via a public notice. We reserve the right to make changes to our practices and this Notice at any time, please also check back frequently to see any updates or changes to our Notice.

11. Data Controller and Contact

The following are Seamless Technologies’ respective entities which will make use of and ensure the full security of any collected data for the purpose of recruitment management:

• SeamlessHR.Com Limited, at No 8, Metal Box Road, Plot 9, Block “C” Ogba Industrial Scheme, Ikeja, Lagos State Nigeria;
• The Seamless Ltd, at House Number FC 302, East Legon, Nii Osabu Kle Ave, Ghana; and
• Seamless Human Resources Management Technology Ltd at 36, Othaya Road, Kileleshwa, Nairobi.

Any question regarding this policy can be addressed to the DPO at: dpo@seamlesstech.com.

12. Summary

• Yes, we do collect personal data that you give us. (e.g. your email).
• No, we won’t email you unless we think it’s really important, e.g. to share some relevant updates and information with you.
• Yes, you can opt-out from any communication.
• Yes, we have to share some of that data with some of our service providers to make the solution work (e.g. our support platform).
• No, we won’t sell your data or hand it to anyone that will sell or abuse it.