Candidate Privacy Policy

Privacy is our priority

Welcome!

 

We have two Privacy Policies, to clearly set out the different ways that we collect, manage, use and disclose the information of:

  1. our clients, prospects and individuals who contact us directly; and
  2. candidates who apply for roles with our clients.

 

This Privacy Policy applies to you if you are a candidate applying for a job with one of our clients who use our interview platform. If you are a client of ours (an employer), please review our client-specific Privacy Policy.

 

For candidates who interact with us using our interview platform only, we act as a ‘processor’ of your personal data. The organisation where you’ve applied for a job will remain the ‘controller’ of your personal data. If you have any questions about how that organisation uses your personal data, we recommend you contact them directly to find out more.

 

Though if you have any questions for us, of course we’ll do our best to help. If you reach out to us directly for support, we’ll also become a data ‘controller’ and you should take note of our client-specific Privacy Policy, which will apply to our provision of support to you.

 

Who are you?

Sapia&Co Pty Ltd (“Sapia”, “we”, “our”, or “us”) is a software provider, who offer talent intelligence software to our clients. Our clients have chosen us to provide you with an online interview or questionnaire. Using our artificial intelligence solution, we derive patterns from your free-text answers collected during the interview process.

 

Rather than just matching keywords, our technology reads, deciphers, understands, and makes sense of answers. In addition, we may process video responses and/or demographic information on behalf of our clients. We’ll refer to this technology as our “Platform” throughout the rest of this Privacy Policy. You can find out more about our Platform here.

We are committed to protecting your privacy. If you have any questions about this Privacy Policy, please contact us at privacy@sapia.ai or write to us by mail at PO Box 1405, St Kilda South, Melbourne, 3182 Victoria, Australia.

If you are a United Kingdom (UK) or European Economic Area (EEA) resident, our representative for data protection queries is Prighter, whose details are available here.

What personal data do you need?

When you apply for a job with one of our clients, we need to collect your personal data so our client can offer you an online interview. You might give this information to us directly, or our client may provide it. The data we collect will include your full name, email address, phone number, location, IP address, browser information and any other information requested on the application that the organisation you are applying to has asked us to collect.

When you complete your online interview or questionnaire, we’ll collect your answers and make these available to the organisation where you are applying. In some cases, we may also collect video responses.

In simple terms, your personal data is used to identify you in our Platform (so the organisation knows who you are). If your personal data is not collected, our clients will be unable to assess your suitability for available roles properly.

We may also use anonymised personal data for testing our Artificial Intelligence (AI). This data ensures that candidates are not disadvantaged during the interview regardless of their gender, ethnicity, age, or other protected characteristics. However, we promise that we never use your personal data in our AI algorithms. Hence, it has no impact on assessing your suitability for a role.

To help us develop our Platform and serve you better, we will also collect information using third party services. These third parties may include but are not limited to, Intercom and Hotjar. Data collected may include your IP address, browser details and operating system. We may also collect information about how and when you interact with the Platform (e.g., where you click, scroll your mouse, move in between pages). In this case, we never collect sensitive information such as email addresses, credit card details or passwords. Our Cookie Policy provides more detail on the information we collect. We will never sell your personal data to any third party.

What about my sensitive information?

When completing an interview through Sapia, we may ask questions about your health status, background, racial or ethnic origin, or other genetic information. The personal data we request will differ between our clients, and answering is generally optional.

If you choose to answer the questions, you consent to our collection, use and disclosure of your sensitive personal data as described in this Privacy Policy and as permitted by law.

Our clients may use the personal data we collect to understand better the diversity of their candidates’ and their employees, but only at a general level. They can only view the overall data and not your data specifically. Your personal data is anonymised once collected and before being shared with any of our sub-processors or disclosed outside your region (more on this below).

We may use your anonymised personal data to test our AI to make sure we are not discriminating against candidates.

What do you do with my personal data?

We process the personal data we collect and share it with certain sub-processors on our behalf to evaluate your capabilities. As a result, we generate a personality and behavioural profile that our client can then utilise to make hiring decisions and coach and improve performance once employed.

As mentioned above, we also process your anonymised personal data to improve our Platform through machine learning and testing for adverse impact. In addition, we use behavioural information to improve our Platform and provide you with a better experience.

Do you share my personal data with anyone?

It might sound obvious, but we will pass your interview responses to our clients when you apply for a job with them. We are not responsible for how they then use or process your personal data. You should review their applicable privacy policy for information on how they use your personal data.

Like most organisations, we may share your data with several third-party services and tools to run our Platform. These are known as sub-processors. Think about it. Suppose you were applying for a loan from a bank. In that case, they would likely need to share your personal data with credit reference agencies before they make a lending decision. In our case, we use sub-processors to help provide us computing power, communicate with you and analyse your data. By disclosing your personal data, including sensitive information to us on the Platform, you consent to this information being provided to third parties to run the Platform and provide services to you and our clients. These third parties may include parties based in the United States of America. Ask us for more details.

We might also need to share your personal data with relevant authorities or organisations if we are under a duty to disclose or share your personal data to comply with any legal obligation, or to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of our clients or others. We may exchange information with other companies and organisations for fraud protection.

We may also share personal data with prospective buyers of our business under our legitimate interest to ensure the buyer can continue our business.

Do you transfer personal data internationally?

We store and process the data we collect from you in the same geographic region of our client (the company you are applying to work with). For example, suppose you live in Australia but apply to work with an American organisation. In that case, your data will likely be stored and processed in the USA.

Sapia is a global organisation with clients and employees across the world. To provide you with our services, we need to transfer personal data between our teams for the purposes described in this Privacy Policy. This Privacy Policy continues to apply even when we transfer personal data outside of your country of residence.

Whenever we transfer your personal data outside of the UK and the EU, we ensure it receives additional protection as required by law. We haven’t set out these specific circumstances to keep this Privacy Policy as short and easy to understand as possible. However, you can contact us for more information.

How long will you keep my personal data?

As a data ‘processor’, we will retain your personal data for a period set by our client (the ‘controller’). You should review their applicable privacy policy for information on how they use your personal data and how long they store it.

If our client does not define a retention policy, we will retain your personal data for as long as they remain a client of Sapia unless they (or you) ask us to delete it. If you ask us to delete your personal data, we will either permanently de-identify or delete it unless we require it for legal reasons.

In some circumstances, we carefully anonymise your personal data so that it can no longer be associated with you, and we may use this anonymised information indefinitely without notifying you. We use this to test our AI solution for any adverse impact.

How do I access or control the personal data you have?

You have various rights under applicable data protection and privacy laws, including the right to:

  • access your personal data (also known as a “subject access request”);
  • correct incomplete or inaccurate data we hold about you;
  • ask us to erase the personal data we hold about you;
  • ask us to restrict our handling of your personal data;
  • ask us to transfer your personal data to a third party;
  • object to how we are using your personal data; and
  • withdraw your consent to us handling your personal data.

 

To exercise any of your data privacy rights, you should contact the organisation you’ve applied for a role with in the first instance.However, if you wish to contact us (privacy@sapia.ai), we will do our best to help you.

You also have the right to complain about us collecting and using your personal data with your relevant supervisory authority. Contact details are freely available, but we have included links to some common supervisory authorities below:
Australia
European Union
United Kingdom

What if I have any questions?

We’ve worked hard to create a Privacy Policy that’s easy to read and clear. However, if you would like any more information, please contact our Data Protection Officer at privacy@sapia.ai. You can also reach us by mail at PO Box 1405, St Kilda South, Melbourne, 3182 Victoria, Australia.

If you are a United Kingdom (UK) or European Economic Area (EEA) resident, our representative for data protection queries is Prighter, whose contact details are available here.