Recruitment privacy notice

 1. Introduction

Trafigura recognises the importance of data protection. We understand and value your rights to autonomy and control over how, when and why your Personal Data is used. Given this remains an evolving area, we are firmly committed to ensuring compliance with applicable regulatory and legal requirements, as is reflected in this Notice.

The purpose of this recruitment privacy notice (“Notice”) is to explain how Trafigura (“we”, “us”, “our”) handles Personal Data about our job applicants ( “Application Data”) and our applicants’ rights under data protection law. Trafigura is considered the “Controller” in respect of Application Data that it collects, uses and manages in accordance with this Notice.

This Notice applies to job applications submitted via Trafigura’s careers website or intranet, and those submitted via third parties e.g. recruitment agencies, job boards, online platforms such as LinkedIn and Indeed, etc. employee or third party referrals, or other means e.g. post or email.

Please refer to the Glossary below for an explanation of the defined terms in this Notice.

2. Trafigura 10 Data Protection Principles

We observe 10 Data Protection Principles in relation to Application Data:

Fairness and Transparency Inform people about how we process their Application Data.

Lawful Processing Make sure we always have a good, lawful reason to process Application Data.

Purpose Limitation Only collect Application Data for a specific business need. If we want to reuse Application Data for a new purpose, we must ensure that the two purposes are compatible.

Data Minimization Only process as much Application Data as we need, and no more.

Accuracy Keep Application Data accurate, complete, and up-to-date.

Retention Only keep Application Data for as long as we need it. If we don’t need the
Application Data anymore, we must delete it or fully anonymize it.

Security Protect Trafigura’s Application Data from getting lost or stolen or otherwise processed in an unauthorized manner and make sure our service providers protect this data to the same standard.

Individual Rights Allow certain individuals particular rights in relation to their data, including the right to access, correct or erase their Application Data, or object to it being used for certain purposes.

Application Data Transfers Put in place safeguards before sending Application Data cross- border.

Accountability Trafigura takes steps to make sure our processing of Application Data complies with our  Group Privacy Notice  and these Principles.

3. What Application Data does Trafigura collect?

Trafigura only collects Application Data that is necessary to assess you for the post applied for. This may include one or more of the following categories:

• Information you provide to set up an account on our online recruitment system, e.g. your email address;
• Information you provide to apply for a job vacancy and to tell us who you are, such as your capabilities and suitability for certain positions, your name, contact information, nationality, visa status, professional qualifications, employment and academic history, personal interests, experiences, details of your current compensation and benefit package, résumé and other information submitted in connection with your application;
• Information collected by Trafigura as a result of the recruitment process, e.g. your performance at assessment centres, interview notes or information provided by your referees;
• Information related to your use of our website, e.g. your IP address, which may be collected by using cookie technology. Please see our  Group Privacy Notice  available on our public websites; and
• Special Category Personal Data, such as your race, ethnicity, age or whether you have a disability may be collected with your consent for the purposes of equal opportunities monitoring.

Once we have offered you the role, background checks are processed [with your consent] in order to satisfy ourselves that there is nothing which makes you unsuitable for the role. This is done by a third party pre-employment check provider and will only be requested if permitted by local law. The third party pre-employment check provider collects information to verify your activity, credentials and education, and police records.

We may also collect, use and share aggregated data such as statistical or demographic data for any purpose, including to improve our recruitment practices. Aggregated data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect aggregated data with your Personal Data (or other data) so that it can directly or indirectly identify you, we will treat the combined data as Personal Data which will be processed in accordance with this Notice.

We will indicate where the information we have requested is mandatory or optional.

4. How is your Application Data collected?

We may collect Personal Data about candidates from the following sources:

• You, the candidate;
• Recruitment agencies;
• Government agencies such as the UK Disclosure and Barring Service in respect of criminal convictions;
• Third party pre-employment check providers; and
• Your named referees.

5. What will Trafigura do with your Application Data?

The main purposes for which we use Application Data include:

• Supporting and Processing your Job Application, e.g. so we can assess your ability to meet the job specification, and verify references and professional qualifications;
• Improving our Application Process, e.g. to ensure that our website, intranet and our online recruitment system are user-friendly and contain appropriate and helpful information; and
• Ensuring compliance with our Code of Conduct, e.g. to ensure that we are living up to our values.

As set out above, we may verify the Application Data you provide and/or collect Personal Data about you from sources other than you to assist with our ‘Pre-Employment Checks’. This may include checking your qualifications, directorships, financial history (e.g. bankruptcy) and if you have a criminal record. If this occurs:

• You will be told in advance by the Trafigura entity you applied to which aspects of your Application Data will be verified and how; and
• the third party provider performing the Pre-Employment Checks will collect information about criminal convictions (if collected) or medical information only where required or permitted by law, through official authorized sources and in accordance with applicable law.
• Where it is necessary and appropriate to the role you have applied for and permitted by local law, you may be required to undertake drug and alcohol testing prior to commencing your employment.

6. The Legal Basis for processing your Application Data

Trafigura will only process your Application Data where we have a legal basis for doing so, i.e. generally because it is necessary for us to decide whether to enter into a contract of employment with you. In certain circumstances we may process your Application Data based on your consent (which you have the right to withdraw), because it is necessary to comply with a legal obligation, or to enable us to pursue our legitimate business interests, e.g. where we consider that it would be beneficial to our business to appoint someone into a particular role, or to enable us to analyze and improve the effectiveness of our recruitment service.

7. Who is your Application Data disclosed to?

(a) Within Trafigura: Trafigura restricts access to Application Data to people within Trafigura who “need to know” that information, e.g. the individuals who will process your job application and manage or are part of the recruitment cycle.

(b) Outside Trafigura: Trafigura shares Application Data with authorized third party pre-employment service providers, in order to manage recruitment, and for the purposes of processing your application as set out above.

Generally, Trafigura will only disclose your Application Data to other third parties:

1. when required to do so by law;
2. in response to a legitimate request for assistance by the police or other law enforcement agency; and
3. to seek legal advice from Trafigura’s external lawyers or in connection with litigation.

8. How long will Trafigura retain your Application data?

We keep your Application Data in accordance with our internal retention policies. Typically, if you are unsuccessful in your job application with us (or if you reject the position), your Application Data will be destroyed within 12 months (this may vary slightly depending on the jurisdiction), in order to comply with our legal obligations. We may keep your application material for a longer period of time if: (i) there is a real possibility you may be suitable for alternative roles in the future, and retaining your application would be useful for such future hire (e.g. to contact you); and (ii) you have consented to this proposal. If you would like more information on this, please contact us.

If you are successful in your application and join Trafigura we will retain your Personal Data in accordance with our internal Data Retention Guidelines and procedures. More information will be provided to you when you start.

9. Where does Trafigura store your Application data?

Applicants should be aware that their Application Data may be transferred to, and stored at, a destination outside their country of residence, which may have less strict, or no data protection laws, when compared to those of their country of residence. It may also be processed by staff outside of their country of residence, whether at Trafigura or at one of our suppliers.

Whenever we transfer your Application Data outside of your country of residence, we will take legally required steps to ensure that suitable safeguards are in place to protect your Application Data and to make sure it is treated securely and in accordance with this Notice. These safeguards apply whether Trafigura is sending Application Data to a third party or another group company, even if the Personal Data will only be accessed remotely from the receiving country. If you are located in the EEA, Switzerland or the UK, you may contact us for more information on the safeguards we have in place to protect your Application Data and your privacy rights in these circumstances using the contact details set out below.

10. Exercising your rights

You may have certain rights in relation to the Application Data that we hold about you. In particular, you may request access to, rectification - if you cannot update such information in our online recruitment system - or erasure of, the Application Data we hold about you, object to or restrict certain types of processing and request a machine-readable copy of the Application Data you have provided. You also have the right to withdraw your consent at any time where we are relying on consent to process your Application Data.

If you notice an error in your application that you would like to correct, or if you want to request to exercise one of these rights, please contact us using the web-based form below.

Any request to exercise one of these rights will be assessed by Trafigura on a case by case basis. In certain circumstances we are not legally required to comply with your request because of the laws in your jurisdiction or because of relevant legal exemptions.

Please submit your request here. 

11. Security

The security of your Personal Data is important to us. We have adopted reasonable security practices and procedures, to help secure the Personal Data that we collect.

12. Contact us

Please contact us here if you would like to find out more about any matters relating to this Notice.

If you have concerns about the way in which Trafigura has handled your Application Data, you have the right to complain to your Data Protection Authority. However, if you have concerns we encourage you to raise this with Trafigura in the first instance.

Glossary

Version 3.0
Last updated: October 2023