PRIVACY NOTICE AND POLICY FOR JOB APPLICANTS AND SUCCESSFUL CANDIDATES - INDIA

United HealthCare Services, Inc., and its subsidiaries and affiliated companies (collectively, the “Company”) strives to properly address applicable data protection and privacy legal requirements.

The primary data controller with respect to your Candidate Data is the entity with which you are applying for employment.

 

SCOPE

This Privacy Notice and Policy for Job Applicants and Successful Candidates' Data (“Privacy Policy”) provides the individuals who apply for employment with and / or who have been offered employment by one of the Company’s subsidiaries and affiliates in India ("Job Applicants" and "Successful Candidates" respectively) with certain important information about how the Company handles their personal data ("Candidate Data"). This Privacy Policy does not apply to job applicants or successful candidates located outside of India.

 

TYPES OF CANDIDATE DATA COLLECTED

Candidate Data is provided by Job Applicants and Successful Candidates, and includes the following types of data: 

  • Name 
  • Date of Birth
  • Address
  • Email Address
  • Telephone Number (landline and mobile)
  • CV
  • Employment history
  • Education history
  • Reference contacts
  • National Insurance Number/ social security number
  • Gender
  • Nationality
  • Place of Birth
  • Marital Status   

 

PURPOSE OF COLLECTION, USES, AND DISCLOSURES OF CANDIDATE DATA

The Company will use and otherwise process Candidate Data for the following purposes: 

  • recruitment and job placement of Job Applicants including notification of future job opportunities; background screening and on-boarding of Successful Candidates, including
  • enrollment in payroll and applicable employee benefit schemes, preparation of employment contract, and other administrative purposes necessary for the Successful Candidate to commence employment with the Company; 
  • performance of the employment contract between the Company and Successful Candidates; and
  • compliance with Company’s legal obligations, such as government mandated pre-employment health screenings, accounting, and tax requirements.

As necessary, and in connection with these purposes, authorized processors, including, but not limited to, members of the People Team department, the Finance department, the IT department, Compliance and Ethics department, and senior executive Company managers may access and otherwise process Candidate Data in connection with their job responsibilities.

Some of these processors may be employed by the Company at our various global locations outside of India. The Company takes appropriate steps to ensure that such personnel are bound to duties of confidentiality with respect to Candidate Data.

Provision of Candidate Data is necessary to carry out the hiring process, and failure or refusal to provide it would make it impossible for Job Applicants and Successful Candidates to apply for and / or be appointed to a position at the Company.

 

USE OF CANDIDATE DATA FOR BACKGROUND CHECKS AND COLLECTION OF DATA FROM THIRD PARTY SOURCES

Offers of employment with the Company, where permitted by local law, may be subject to and conditioned upon the completion of certain background checks permitted by applicable employment laws, including searches of the following databases: 

  • databases relating to serious and organised crimes, databases managed by regulatory and compliance authorities, web and media databases, and global sanctions and watch lists managed by financial regulatory bodies and law enforcement agencies;
  • standard sanctions databases (UN, EU, U.S. lists, etc.) in compliance with economic sanctions laws throughout the world; and
  • for employees who may work on government programs, including, but not limited to United States Federal or State government programs, United States Federal and/or State debarment or exclusion lists or other such lists required by law or contract. 

Candidate Data provided by the Successful Candidate following an offer of employment may be used to facilitate the conduct of Background Checks.

Successful Candidates may be requested to provide information related to their family members who hold government positions in order for the Company to assess potential conflicts of interest. When providing this information, it is the responsibility of the Successful Candidate to obtain the family member’s permission to disclose such information to the Company.

Due to the nature of the Company's business, the Company will carry out regular and ongoing screenings of the databases listed above during the course of employment to ensure that the Successful Candidate remains suitable for a position with the Company and is permitted without exception to provide services to all of the Company's clients and in particular to organisations that prohibit excluded or debarred individuals from working on their account. Any offer of employment will be strictly conditioned on passing these screenings during the course of employment.

Conduct of the Background Checks may involve the collection of additional information about the Successful Candidate from educational institutions, government agencies, previous employers, credit reporting agencies, information in the public domain and law enforcement agencies at the international, national or local level as permitted by applicable law. If a Successful Candidate's prior employers and/or other references are contacted, the report may include information obtained through personal interviews.

As permitted under applicable local law, the information collected may include, but is not limited to, educational and professional achievement / qualifications, employment references, information freely available in the public domain, and criminal history records including enhanced disclosure where required by law for a particular position (the "Background Check Data"). If Job Applicants and Successful Candidates provide the Company with data of third parties (such as former employers, references, etc.) the Job Applicants and Successful Candidates must ensure that the communication of such data to the Company and further processing by the Company according to this Privacy Policy is lawful.

 

TRANSFER TO THIRD PARTIES

The Company uses third-party vendors for certain services, including: 

  • the online recruitment portal in which Job Applicants enter and submit their application; and
  • the conduct of the Background Checks described above.

When Company retains a third-party vendor, that vendor will be carefully selected and required to use appropriate measures to protect the confidentiality and security of personal data.

Some of these third parties are located outside India, including in countries that may not provide the same level of data protection as your home country, such as the United States of America. To the extent required by applicable law, the Company will address any applicable requirement to assure an adequate level of data protection before transferring Candidate Data and Background Check Data.

 

RETENTION OF CANDIDATE DATA AND BACKGROUND CHECK DATA

Candidate Data and Background Check Data will be retained only for so long as reasonably necessary for the purposes set out above, in accordance with applicable laws.

When a Successful Candidate enters employment with the Company, his or her Candidate Data and relevant Background Check Data may be transferred to an employee personnel file and may be processed and retained in accordance with applicable law or the Company's Data Protection Policy from time to time in force, a copy of which is available on the Company intranet.

 

DATA SECURITY AND DATA INTEGRITY

The Company maintains reasonable security measures to safeguard Candidate Data from loss, interference, misuse, unauthorized access, disclosure, alteration or destruction. The Company also maintains reasonable procedures to help ensure that such data is reliable for its intended use and is accurate, complete and current.

 

RIGHTS

Job Applicants and Successful Candidates are entitled to request access to, rectification or erasure of their own Candidate Data, or withdrawal of consent and other rights in accordance with applicable law or Company policy. Requests should be submitted to the People Team department using the information below in the “Contact Information” section.

If a Job Applicant or Successful Candidate is aware of changes or inaccuracies in his or her Candidate Data of which the Company is not aware, he / she should inform the local People Team department of such changes so that the Candidate Data may be updated or corrected.

Candidate Data from Job Applicants will be retained on file, to be used for future employment opportunities, subject to applicable law on retention of personal data. If Job Applicants wish to have their application information removed from the recruitment database at any point before an employment offer, they should send a written request to the local People Team department with the subject line "Please remove me from your Recruitment database". Notwithstanding such a request, certain information may be retained as required by applicable law.

Job Applicants and Successful Candidates may lodge a complaint with the relevant data privacy government regulator(s) should the Company violate applicable data privacy law(s) in its processing of your Candidate Data.

 

DISCLOSURES REQUIRED OR PERMITTED BY LAW

Regardless of any other provisions in this Privacy Policy, the Company may disclose or otherwise process Candidate Data in the context of any sale or transaction involving all or a portion of the business, or as may be required or permitted by law or required for the purposes of any regulatory audit to which the Company may be subject from time to time.

 

CONTACT INFORMATION

Job Applicants and Successful Candidates can raise any issues regarding their Candidate Data with their local Human Resources department or our Data Protection Officer by contacting:

Human Resources

Submit an online request at https://hrdirect.uhg.com/hrportal or via phone at 001 866 295 5066

Data Protection Officer

UHG_Privacy_Office@uhg.com