Candidate Privacy Policy

Introduction

As part of any recruitment process, Lucid Group Communications Ltd and its global affiliates (“Lucid Group”) collect and process personal data relating to job applicants. This statement contains important information about how your personal data is used by Lucid Group and your associated legal rights. Personal data is defined as information from which an individual may be identified. Lucid Group is committed to complying fully with applicable data protection laws. We respect the privacy rights of our applicants (past and present) and apply appropriate safeguards to protect their personal data.

The data controller and entity responsible for the processing of your personal data collected during the recruitment process is the Lucid Group company to whom you are applying for a job.

The Lucid Group is made up of the following entities:

Lucid Communications Group Limited, Middlesex House, 34-42 Cleveland St, London W1T 4JE, UK

DiD Agency Group LLC, 30 South 15th Street, Suite 1300, Philadelphia, PA 19102

Synetic Life Sciences Limited, Middlesex House, 34-42 Cleveland St, London W1T 4JE, UK

Lighthouse Medical Communications Limited, 30 South 15th Street, Suite 1300, Philadelphia, PA 19102

1. Types of personal data we collect about you

Lucid Group obtains and holds personal data relating to its job applicants as follows: –

• Identity Data includes first name, maiden name, last name, marital status, title, date of birth and gender.
• Contact Data includes address, email address and other contact details.
• Identity Documents includes copies of Passports, Visa and other Identity documents relating to your entitlement to work.
• CV Data includes information about your career history, skills, experience and qualifications
• Health Data includes information about your health, medical conditions, for which we may have to make reasonable adjustments both during recruitment process and potential employment.
• Background Check Data includes information obtained through criminal background checks and/or other pre-employment screening.
• References includes information obtained from references from previous employers or other referees.
• Other Sensitive Data includes Ethnicity.

2. How is your personal data collected?

We collect personal data about you in the following ways:

• Direct interactions. You provide us with your personal data when you submit your application to us, and throughout the job application process.
• Third parties. We will receive personal data about you from various third parties, such as you from recruitment agencies, third parties that carry-out background checks or other pre-employment background screening, referrers, referees and former employers.
• Public sources. We may collect personal data about you from publicly available sources, such as from professional networking websites (e.g. LinkedIn).

3. Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/ActivityType of dataLawful basis for processing including basis of legitimate interestTo manage and administer your application(a) Identity Data

(b) Contact Data

(c) Identity Documents

(d) CV Data

(a) To take steps prior to entering into an employment contract with you.

(b) Necessary for our legitimate interests (to ensure recruitment of the most appropriate applicants).

To assess your suitability for employment (including eligibility to work)(a) Identity Data

(b) Identity Documents

(c) CV Data

(d) References

(a) To take steps prior to entering into an employment contract with you.

(b) Necessary for our legitimate interests (to ensure recruitment of the most appropriate applicants)

(c) Necessary to comply with a legal obligation.

Processing data and monitoring to comply with our obligations regarding discrimination(a) Identity Data

(b) Health Data

(c) Other Sensitive Data

(a) Necessary to comply with a legal obligation

(b) Necessary for our legitimate interests / substantial public interest (to ensure equal treatment of candidates)

(c) Where required by applicable law, with your consent

Carrying out background checks(a) Identity Data

(b) Identity Documents

(c) Criminal Data

(a) Necessary to comply with a legal obligation

(b) Necessary for our legitimate interest / substantial public interest (to prevent and detect unlawful acts).

(c) Where required by applicable law, with your consent.

The Lucid Group may also process your personal data where required by law and/or in its legitimate interests (in protecting its business and reputation) for the purposes of:

• Exercising or fulfilling Lucid Groups’ legal rights and responsibilities, including compliance with statutory and regulatory obligations;
• Managing legal disputes involving applicants, employees and/or third parties; and
• The prevention or detection of fraud, crime or other unlawful or inappropriate conduct.

4. Disclosures of applicant personal data

Where necessary and lawful, your personal data will be disclosed to certain third parties, for example, to: –

• Lucid Group management and employees
• Our professional advisers, such as solicitors or accountants, and consultants
• Government departments and agencies
• Police and law enforcement agencies
• Courts and tribunals
• Insurers
• Partners, suppliers, agents, and service providers
• Third parties to gain references.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

5. International transfers of data

Due to the global nature of Lucid Group’s business, it is necessary for the Lucid Group to transfer some employee applicant data outside the applicant’s country of residence, including to jurisdictions where local legislation does not provide adequate safeguards regarding the protection and security of personal data. This will typically occur when we exchange information with our management team based in other countries or when service providers, for example IT companies that need to access such data, are located outside your country of residence.

Whenever we transfer your personal data outside your country of residence, we ensure a similar degree of protection is afforded to it in the recipient country by ensuring at least one of the following safeguards is implemented:

• We transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; and/or
• We use specific contracts approved for use in your country of residence which give personal data the same protection it has in your country of residence (such as the EU Standard Contractual Clauses and/or UK International Data Transfer Addendum).

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data internationally.

6. Data Retention

We will not retain unsuccessful applicant data for longer than necessary and will delete it once it is no longer required for the purposes set out in the Policy. The longest we will normally hold any applicant personal data is for 1 year after the recruitment process has finished.

7. Your rights

Depending on where you reside, you have several rights under applicable data protection law. These may include the right to:

• Request access to your personal data
• Request correction of your personal data
• Request erasure of your personal data
• Object to the processing of your personal data
• Request restriction of your personal data
• Request transfer of your personal data to another organisation
• Right to withdraw consent

If you wish to exercise any of the above rights, please email our Data Protection Officer: jon.jansen-alder@wearelucidgroup.com

8. Complaints

If you are unhappy about the way your personal data has been handled by the Lucid Group you have the right to complain and may lodge a complaint with our Data Protection Officer or directly with the relevant data protection authority in your country of residence (in the UK, this is the Information Commissioners Office).