Catalina Holdings Bermuda Ltd. and its subsidiaries including Catalina Services (Bermuda) Ltd. (CSBL) is committed to protecting the privacy and security of your personal information.

CSBL is a “data controller”. This means that we are responsible for how we hold and use personal information about you.

You are required to read this privacy notice because you are applying for a vacancy that has been advertised by CSBL. It provides you with certain information that must be provided under the Bermuda Personal Information Protection Act 2016 (PIPA).

This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time.

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

PERSONAL INFORMATION PROTECTION PRINCIPLES

We will comply with PIPA. This says that the personal information we hold about you must be:

  • Used lawfully, fairly and in a transparent way.
  • Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  • Relevant to the purposes we have told you about and limited only to those purposes.
  • Accurate and kept up to date to the best of our knowledge.
  • Kept only as long as necessary for the purposes we have told you about.
  • Kept securely.

PERSONAL INFORMATION WE COLLECT

The types and categories of information we hold about you
“Personal information” means any information that relates to an identified or identifiable individual and examples include names, dates of birth, photographs, video footage, email addresses, and telephone number. “Sensitive personal information” is a defined term in PIPA that includes information relating to such aspects as place of origin, race, colour, sex, sexual life, health, disabilities, religious beliefs, and biometric and genetic information.

In connection with your application for work with us, we may collect, store, and use the following categories of personal information about you:

  • The information you have provided to us in your CV/Resume or application form and any other supporting documentation or additional forms. (e.g. monitoring forms).
  • Any information you provide to us during an interview, including the results of tests and psychometric testing and assessments.

This personal information may include:

  • Contact detail (e.g. name, address, telephone numbers or personal email address)
  • Date of birth
  • Employment history (e.g. job application, employment references or secondary employment)
  • Education history (e.g. qualifications)
  • Training history and development needs
  • Copies of passports or other photo ID
  • Details of any criminal convictions (e.g. Police checks)
  • Security clearance details (e.g. basic checks and higher security clearance)
  • Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process)

We may also collect, store and use the following sensitive personal information relating to you as part of the recruitment process:

  • Place of origin
  • National or ethnic origin
  • Sex
  • Marital status
  • Physical or mental disability
  • Physical or mental health (e.g. Sick leave forms or fit notes (e.g. Statement of Fitness for Work from a GP or hospital) and Accident at work records).
  • Family status

How is your personal information collected?
We typically collect personal information through the application and recruitment process, either directly from candidates or sometimes from an employment agency or background check provider. We may sometimes collect additional information from third parties including former employers, former educational institutions, credit reference agencies or other background check agencies.

How will we use information about you?

1. We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

  • Where we need to communicate with you about the recruitment process and keep records related to our recruitment processes.
  • Where we need to assess your skills, qualifications and carry out background and reference checks, where applicable during the recruitment and appointment process.

2. We may also use your personal information in the following situations, which are likely to be rare:

  • Where we need to protect your interests (or someone else’s interests).
  • Where it is needed in the public interest or for official purposes.

Situations in which we will use your personal information
We need all the categories of information in the list above primarily to allow us to perform our recruitment process with you and to enable us to comply with legal obligations. In some cases, we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The types of situations in which we will process your personal information are listed below.

  • Making a decision about your recruitment or appointment.
  • Determining the terms on which you work for us.
  • Assessing your qualifications for a particular role.
  • Ascertaining your fitness to work.

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

If you fail to provide personal information
If you fail to provide certain information when requested that is necessary for us to consider your application (such as your qualifications or work history), this may delay/halt the process of your application.

Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

OUR DUTY

How we use sensitive personal information
Sensitive personal information requires higher levels of protection. We shall not use your sensitive personal information without lawful authority to discriminate against any person contrary to any provision of Part II of the Human Rights Act 1981.

  • We will use your Sensitive personal information with lawful authority if and only to the extent that it is used:
  • With your written explicit consent.
  • In accordance with an order made by either the court or the Commissioner
  • For the purpose of any criminal or civil proceedings; or
  • In the context of recruitment or employment where the nature of the role justifies

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

Our obligations as an employer
We will use your sensitive personal information in the following ways:

  • We will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments.
  • We will use information about your race, colour or national or ethnic origin, religious beliefs, or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.

Do we need your consent?
We do not need your consent if we use your sensitive personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your employment application with us that you agree to any request for consent from us.

Information about criminal convictions
We will only collect information about criminal convictions if it is appropriate given the nature of the role you are applying for and where we are legally able to do so. Where appropriate, we will collect information about criminal convictions as part of the recruitment process.

We will use information about criminal convictions and offences in the following ways:

  • To assess you are suitable to perform the duties of the role you are applying for.

We are allowed to use your personal information in this way to perform the recruitment process we have entered with you.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

DATA SHARING

We may have to share your data with third parties, including third-party service providers and other entities in the group. We require third parties to respect the security of your data and to treat it in accordance with the law.

We may transfer your personal information outside of Bermuda and if we do, you can expect a similar degree of protection in respect of your personal information.

Why might you share my personal information with third parties?
We may share your personal information with third parties where required by law, where it is necessary to administer the recruitment process with you or where we have another legitimate interest in doing so.

Which third-party service providers process my personal information?
“Third parties” includes third-party service providers (including contractors and designated agents) and other entities within our group. The following activities are carried out by third-party service providers in the recruitment process: Recruitment.

How secure is my information with third-party service providers and other entities in our group?
All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

Transferring information outside of Bermuda
We may transfer the personal information we collect about you to other Catalina companies based in USA and UK in the ordinary course of our business administration and IT back-up archiving. The personal information will remain within our custody and control and always with equivalent levels of security present to meet Bermuda Privacy standards. The IntraGroup Sharing Agreement covers all data transfers between USA, UK and Bermuda.

Data Security
We have put in place measures to protect the security of your information. Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

DATA RETENTION

How long will you use my information for?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer going through the recruitment process and no longer considering or being considered for the role, we will securely destroy your personal information in accordance with our Data Retention Policy.

YOUR RIGHTS

Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your recruitment relationship with us.

  • Under certain circumstances, by law, you have the right to:
  • Request access to your personal information. This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information we hold about you. This enables you to have any incomplete or inaccurate information corrected.
  • Request the erasure of your personal information. This enables you to ask us to delete or remove personal information without good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing.
  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please make a written request to dataprotection@catalinare.com. If you make a request, we will respond without undue delay and within 45 days of receipt.

Access Fee
You will not have to pay a fee to access your personal information or to exercise any of the other rights. However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

Security Measures
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information or to exercise any of your other rights. This is another appropriate security measure to ensure that personal information is not disclosed to anyone with no right to receive it.

Withdrawal of Consent
In the limited circumstances where you may have provided your consent to collecting, processing and transferring your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Bermuda Human Resource Partner sakinadarrell@catalinare.com. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

HOW TO COMPLAIN

We have appointed a Privacy Officer (PO) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the PO.

If you have any concerns about our use of your personal information, you can make a complaint to us at:

The Privacy OfficerDorchester House, 2nd Floor
7 Church Street
Hamilton HM11 Bermuda
privacyofficer@catalinare.com

You have the right to make a complaint at any time to the Privacy Commissioner’s Office (PrivCom), the Bermuda supervisory authority for data protection issues if you are unhappy with how we have used your data.

The PrivCom’s address:
Maxwell Roberts Building
4th Floor
1 Church Street
Hamilton, HM11
Bermuda 1-441-543-7748
privcom@privacy.bm
PrivCom website: https://www.privacy.bm/

CHANGES TO THIS PRIVACY NOTICE

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information. If you have any questions about this, please contact Human Resources.