Freenome Ltd.
Recruitment Privacy Policy
For UK and EU Job Applicants
VERSION ADOPTED 31 JULY 2023
VERSION ADOPTED 31 JULY 2023
This privacy policy applies to individuals (“you” or “your”) who submit personal data to Freenome Holdings, Inc. or to Freenome, Ltd. (“we,” “our,” or “us”) as a job applicant. This policy aims to give you information on how we collect and process your personal data and how we comply with United Kingdom (“UK”) and European Union (“EU”) data protection requirements.
It is important that you read this privacy policy so that you are fully aware of how and why we are using your data. By consenting to this privacy policy, you are giving us permission to process and transfer your personal data specifically for the purposes identified.
Freenome Holdings, Inc. is based in the United States and is the parent company of Freenome, Ltd., which is based in the UK. Freenome Holdings, Inc. supports Freenome Ltd.’s recruitment and talent acquisition efforts, and as a result, Freenome Holdings, Inc. may process your personal information when you apply for a job position at Freenome Ltd. At times, Freenome Holdings, Inc. may collect your personal information directly from you.
This version was last updated on 31 July, 2023.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been permanently removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
Identity Data includes your first name, maiden name, last name, username or similar online identifier, marital status, title, date of birth, and gender.
Contact Data includes your delivery address, email address and telephone numbers.
Right to Work Data, includes passport details.
Employment Data includes information gathered via the recruitment process such as that entered into a CV or included in a CV cover letter, references from former employers, details on your education and employment history, etc.
Special Categories of Data includes information of any disability you have or other medical information.
We do not collect any information about criminal convictions and offences or personal data relating to children.
Your failure to provide us with data may mean that we are unable to fulfil our requirements for entering into a contract of employment with you. This could include being unable to offer you employment or administer contractual benefits.
You provide several pieces of data to us directly during the recruitment exercise.
In some cases, we will collect data about you from third parties, such as employment agencies and former employers when gathering references.
Should you be successful in your job application, we will gather further information from you, for example, your bank details and next of kin details, once your employment begins.
The law on data protection allows us to process your data for certain reasons only.
The information below categorises the types of data processing we undertake and the lawful basis we rely on.
| Activity requiring your data | Lawful basis |
| Carrying out checks in relation to your right to work in the UK or EU | Legal obligation |
| Making reasonable adjustments for disabled employees | Legal obligation |
| Making recruitment decisions in relation to both initial and subsequent employment, e.g. promotion | Our legitimate interests |
| Making decisions about salary and other benefits | Our legitimate interests |
| Making decisions about contractual benefits to provide to you | Our legitimate interests |
| Assessing training needs | Our legitimate interests |
| Dealing with legal claims made against us | Our legitimate interests |
| Preventing fraud | Our legitimate interests |
| Activity requiring your data | Lawful basis |
| Carrying out checks in relation to your right to work in the UK or EU | Legal obligation |
| Making reasonable adjustments for disabled employees | Legal obligation |
| Making recruitment decisions in relation to both initial and subsequent employment, e.g. promotion | Our legitimate interests |
| Making decisions about salary and other benefits | Our legitimate interests |
| Making decisions about contractual benefits to provide to you | Our legitimate interests |
| Assessing training needs | Our legitimate interests |
| Dealing with legal claims made against us | Our legitimate interests |
| Preventing fraud | Our legitimate interests |
Our employees who have responsibility for recruitment will have access to your data that is relevant to their function. All employees with such responsibility have been trained in ensuring data is processed in line with applicable laws and regulations.
Data is shared with third parties for the following reason: external human resource consultants involved in the recruitment process.
We may also share your data with third parties as part of a company sale or restructure, or for other reasons to comply with a legal obligation upon us. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.
In the event that you do not wish to have your personal data disclosed to the third parties referenced above you should contact us. You may also change your personal preferences to indicate the format, frequency, and subject matter of communications you wish to receive from third parties as a result of this disclosure. Please note that this may prevent us from performing the contract entered into with you and we will notify you if this is the case.
As mentioned in the “Who We Are” section above, Freenome Holdings, Inc. is located in the United States. Freenome, Ltd. may share your personal data with Freenome Holdings as part of our recruitment efforts. Other times, Freenome Holdings may collect your personal data directly from you as part of the recruiting process.
Whenever we transfer your personal data out of the UK or the EU, we ensure a similar degree of protection is afforded to it. By providing us with your personal data, you consent to that data being transferred to the United States.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data in response to our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We only keep your data for as long as we need it for. This time period depends on whether your application is successful, or if you have provided consent to keep your data on file for future job vacancies.
Where you have provided consent to our use of your data, you also have the right to withdraw that consent at any time. This means that we will stop processing your data and there will be no consequences of withdrawing consent.
If your application is successful, your data will be kept and transferred to the systems we administer for employees. We have a separate privacy notice for employees, which will be provided to you at that time.
Under data protection laws, in certain circumstances, you have the right to:
Request access to your personal data (known as a “data subject access request”). enabling you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of any incomplete or inaccurate personal data that we hold about you. We may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. You may ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. You may ask us to suspend the processing of your personal data in the following scenarios:
(a) if you want us to establish the data's accuracy
(b) where our use of the data is unlawful but you do not want us to erase it
(c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims
(d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it
Request the transfer of your personal data to you or to a third party. We will provide your personal data in a structured, commonly used, machine-readable format.
Withdraw consent at any time where we are relying on consent to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may be unable to fulfil our requirements for entering into a contract of employment with you. We will advise you if this is the case.
If you wish to exercise any of the rights set out above, please contact our Data Privacy Manager using the contact details set forth in the “How to Contact Us” section, below.
If you are unhappy with the way in which your personal data has been processed you, have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance using the contact details above so that your concerns may be dealt with via our internal complaints procedure.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, please contact the data privacy manager using the details set out in the “How to Contact Us” section below.
To contact us in the United States:
Freenome Holdings, Inc.
Attn: Legal Department, Privacy
279 East Grand Avenue
5th Floor
South San Francisco CA 94080
Email: privacy@freenome.com
To contact us in the UK:
Freenome Ltd.
Attn: Privacy Manager
MediCity – D6 Building
1 Thane Road, Nottingham, UK NG90 6BH
Email: privacy@freenome.com