LiveRamp acts as a data controller with respect to personal data related to job applicants (whether you are applying to us directly for a role as a direct employee, or through a recruitment agency). We are also the controller in regard to data that we process in relation to our employees.
- Data processed by LiveRamp about its employees. Personal data processed about our own employees is handled directly between LiveRamp and the employee data subject.
- Third-party websites, plug-ins, and apps linked to from this website.
2. The Data LiveRamp Processes About You
In the process of recruitment, we may process information about you that has been made available to us by yourself directly and/or by third parties (such as recruitment agencies). Such information may originate from both offline and online sources. LiveRamp does not collect any personal data about children under the age of 13.
Please be aware that as a controller of your personal data, we require recruitment agencies and/or other third parties to acquire your consent prior to sharing your data with us. If you are concerned that your data has been shared with us or others by a recruitment or employment agency and/or other third parties without your knowledge, then please get in touch with the respective agency and/or third party.
3. LiveRamp’s Use Of Your Personal Data
In connection with your application to work for and/or with us, we will collect, store, and use personal data about you provided to us through your:
- Curriculum vitae
- Cover letter
- Application form, including name, telephone number, and personal email address, and which may also include your date of birth, gender, address, employment history and title(s), qualifications, and education background
- Test results as part of your application form(s)
Other form of information that we may process may include
- Information that you have provided to us during your interview(s)
- Information about your current remuneration, including benefit entitlements
- Any other information that you may have decided to share with us during the recruitment process
Please be aware that if you affirmatively consent to LiveRamp’s processing of your sensitive information and provide it as part of the recruitment process, we may process said sensitive personal information about you, such as information about your health, including any medical condition for which we may need to make reasonable adjustments during the recruitment process.
4. Disclosures Of Your Personal Data
As mentioned under Section 3 (LiveRamp’s Use Of Your Personal Data) above, we may share your personal data with certain third parties during the recruitment process solely for use in connection with the recruiting and employment purposes for which you provided it; we will not use or share any such personal data as provided by you for any other purposes (such as marketing).
Sharing personal data within LiveRamp during the recruitment process
We may share your personal data internally via:
- Greenhouse is used by our human resources department as our application tracking system
- Py is used to administer online tests conducted by job applications in relation to certain roles
- We may also share your personal data outside of LiveRamp with applicable recruitment agencies throughout the recruitment stage
Please be aware that LiveRamp employees are only authorised to access any such personal data to the extent that is necessary to perform their jobs. Furthermore, all of our third-party service providers (for example, recruitment agencies) are required to take appropriate security measures to protect your personal data inline with our own policies, and your personal data will only be used in accordance with our instructions.
5. International Transfers Of Personal Data
We may transfer your personal data internationally and outside the EU/EEA. For example, as mentioned under Section 4 (Disclosures Of Your Personal Data) above, LiveRamp shares recruitment data internally via Greenhouse and Py, which are hosted in the U.S. LiveRamp takes measures (such as making such international personal data transfers subject to the EU-US Privacy Shield) designed to ensure that your personal data is adequately protected when transferred to third parties and/or countries outside the EEA.
6. Data Security
LiveRamp takes protection of your data seriously and have implemented appropriate technical, organisational, and physical measures to prevent your personal data from being accidentally lost, altered, disclosed, or used or accessed in an unauthorised way. In addition, we limit our internal access to your personal data to our employees, agents, contractors, and other third parties who have a legitimate business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have also put in place procedures to deal with any suspected personal data breach, and we will notify you and any applicable regulator(s) of a breach where we are legally required to do so.
7. Data Retention
During your recruitment process, LiveRamp may retain your personal data for a period of up to six (6) months from the date that we communicate our decision to you and/or the recruitment agency you have contacted us through about our acceptance and/or rejection of your employment with us you.
We retain your personal information for a period of up to six-month in the event of legal disputes or other legal claims. This will allow us to readily provide evidence regarding any disputes or claims (for example, non-discrimination against candidates on prohibited grounds) and to show that we have conducted the recruitment exercise in a fair and transparent way.
After the six-month period, we will securely destroy your personal data in accordance with our data retention policy. Should we anticipate any reasonable need to retain your personal data beyond the six months, such as on the basis that a future employment opportunity may arise for which we may consider you, we will write to you separately and ask for your explicit consent to retain your personal data on file beyond the initial six months.
Please be aware that we reserve the right to store some information about you to the extent that is required and/or permitted by applicable laws. You have the right to request for your data to be erased by us, or we may erase your data in our discretion prior to any limitation on any timing mentioned above, due to any legal or regulatory obligation. We would, therefore, advise you to retain copies of any information that you have provided us.
8. Your Legal Rights And Choices Regarding Your Data
You have the following rights in regard to your personal data as processed by us in the course of your recruitment and pre-employment process:
- Right of access will allow you to obtain a copy of the personal data that we hold about you.
- Request correction of incomplete or inaccurate personal data that we have processed about you.
- Request erasure of some or all of your personal data where you believe that there is no legitimate reason for us to continue processing it.
- Object and/or restrict processing of some or all of your personal data.
- Request transfer of your personal data that we have possessed to another party as designated by you.
You can exercise these rights by emailing us on HRUK@liveramp.com or via any other method as shown in Section 9 (LiveRamp Contact Details) below. Please note that LiveRamp reserves the right to not share information where it may implicate a third party who does not consent to the sharing of their data.
No Fee Is Usually Required
You will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, we are permitted by law and may charge you a reasonable fee if your request is determined to be clearly unfounded, or if you submit repetitive or excessive requests. Alternatively, we are permitted by law to refuse to comply with your request in these circumstances.
What LiveRamp May Need from You to Act on Your Request
In order to carry out your requests, we may need to request specific information from you to help us confirm your identity and ensure that your access request is applicable to your own personal data (for both access and to exercise any of your other rights). This is a security measure that we implement to help ensure that your personal data is not disclosed to any other person who has no right to receive it. We may also contact you to ask you for further information related to your request to help speed up our response.
LiveRamp’s Time Limit to Respond to Your Request
We try to respond to all legitimate requests within one (1) month. It could, however, occasionally take us longer than a month if your request is particularly complex or if you have made a number of requests. In these situations, we will notify you and keep you updated on the status of your request.
9. LiveRamp Contact Details
Postal address for data protection officer:
- ePrivacy GmbH, Prof. Dr. Christoph Bauer, Große Bleichen 21, 20354 Hamburg
Postal address for LiveRamp:
- LiveRamp UK Limited, 1st Floor, Imperial House, 8 Kean Street, London WC2B 4AS
You have the right to make a complaint at any time by contacting the Information Commissioner’s Office (‘ICO’), who is the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to address your concerns directly with you before you approach the ICO and ask that you please contact us first.
13th May 2019, updated and revised to more clearly address your rights and our obligations under GDPR.