Effective December 31st, 2019
As part of our candidate application and recruitment process Sabre GLBL Inc., its parent and its subsidiaries and affiliates (collectively, “Sabre”) collect, process and store Personal Data about you.
The controller of your Personal Data is the hiring Sabre subsidiary or affiliate. References to “Sabre”, “we”, “us” and “our” will means the hiring Sabre affiliate. This means the hiring entity is responsible for deciding how we hold and use Personal Data about you. If you are unsure which Sabre affiliate controls your Personal Data, please contact the Data Protection Officer and the Privacy Team using the details set out below. We process this information for a range of purposes relating to the recruitment process and this may include your application, assessment, pre-employment screening, and your work permissions. This document sets out:
- Why we collect your Personal Data;
- What information is collected; and
- How it is processed within the recruitment process.
Throughout this Privacy Notice we use the term “processing” to cover all activities involving your Personal Data, including collecting, handling, storing, sharing, accessing, using, transferring and disposing of the information.
Why do we collect your Personal Data?
In order to manage your application, we need to process certain Personal Data about you. The purposes for this are set out below. We only process your information as necessary for the purposes of progressing your application or as required by law or regulatory requirements, so not all of the purposes set out below will apply to you all of the time.
Where this is necessary for Sabre to review and assess your application for employment:
- This includes assessing your skills and interest in career opportunities at Sabre, processing your application, analyzing your qualifications, verifying your identity and your eligibility for employment, and communicating with you about your application to respond to your inquiries and schedule interviews.
Where necessary for Sabre’s legitimate interests, as listed below, and where these interests are not overridden by your data protection rights:
- Protecting Sabre’s legal rights. This includes, but is not limited to, use in connection with legal claims, compliance, regulatory, auditing, investigative and disciplinary purposes (including disclosure of such information in connection with legal process or litigation) and other ethics and compliance reporting requirements.
- Maintaining the security and integrity of Sabre’s facilities, equipment and electronic platforms. This includes administering access rights, monitoring compliance with company protocols, and, where permitted by local law and in accordance with relevant policies, for investigations and disciplinary actions.
- To justify processing of your Personal Data based on our legitimate interests, where required, Sabre conducts balancing tests for the data processing it carries out on the basis of its legitimate interests. You can obtain information on our balancing tests by contacting us using the details set out at the end of this Notice.
Where necessary to comply with a legal obligation:
- Disclosures to law enforcement agencies or in connection with legal claims, or regulatory purposes (including disclosure of such information in connection with legal process or litigation).
Where necessary for the purposes of carrying out obligations in the field of employment and social security and social protection law under local law (including, as applicable, under Article 9(2)(b) of the GDPR):
- Information revealing race, ethnic origin, sexual orientation and any disability may be processed in order to facilitate effective equal opportunities monitoring and/or to comply with legal obligations to make reasonable adjustments.
Where you have given consent:
- For example, when required, Sabre shall ask for your permission to conduct a criminal background check, financial background check and personal reference check.
What Personal Data might we process?
Here are the categories of Personal Data we may process.
- Personal details such as contact information, name, address, phone/mobile number, email address, date and place of birth;
- Recruitment information, such as cover letter, resume, areas of interest;
- Work history/job data: previous employers, positions, dates, etc.;
- Compensation: basic salary, benefits, bonuses, etc.;
- Education and work history including professional qualifications and skills;
- Employer feedback / references to include regulated references where necessary;
- Nationality / visa / right to work permit information; (e.g. passport, driving license, Social
- Security or National Insurance numbers);
- Photographs and images from recorded assessments or from onsite CCTV;
- Results of pre-employment screening checks (e.g. credit history, criminal records checks where permitted under local law); and
- Assessment results (e.g. Psychometric assessment results, results video or telephone assessment)
Our processing of the above categories of Personal Data is required to enable Sabre to administer and manage the recruiting process, manage your application, organize interviews, to engage with you about Sabre career opportunities, and for other arrangements required by our hiring and decision-making process.
If you fail to provide us with the necessary information we request to consider your application (such as evidence of qualification and work history), we may not be able to process your application.
We may also process the above categories of Personal Data when we consider it necessary for complying with laws and regulations, including collecting and disclosing Personal Data as required by applicable laws, or to exercise or defend the legal rights of Sabre, protect your or third parties’ property from damage, and protect your safety and that of other parties.
During the process we also capture some sensitive personal data about you (e.g. disability information). We do this to make reasonable adjustments to enable our candidates to apply for jobs with us, to be able to take online/telephone assessments, to attend interviews/assessment and to ensure that we comply with regulatory obligations placed on us with regard to our hiring.
What are the sources of the Personal Data you receive about me?
Sabre may process the following types of Personal Data when you apply for a position with us:
- Data you provide to us: Sabre collects and stores any data you provide us through your application, including your contact details; your application materials (CV, resume, cover letter, previous work experience, education, and transcripts, and our notes from any interviews with you); your desired location, type of employment sought and date available; your identification documents (passport number, government identification numbers where permitted, immigration status); and any other data you submit to us, including any correspondences you may have with us during the application process.
- Data from other sources: Sabre may obtain data about you from other sources, including recruiters, employment research firms, identity verification services, the references you provide to us, websites and other publicly accessible data on the Internet. We will also receive data you submit to us through third-party websites. In certain countries, where permitted, we collect details of professional registrations, sanctions with professional bodies, financial checks or criminal convictions where you have consented to background checks.
- Information we collect automatically: When you make an application through Sabre’s careers page, Sabre may collect information sent to us by your device. For example, this includes the pages you access, your computer IP address, device identifiers, the type of operating system you are using, your location, mobile network information, cookies, standard web log data and other information, your browser type, and traffic to and from our site.
With whom do we share your Personal Data?
Sabre may need to share your Personal Data internally (both in the country where you may work and in other countries in which we have central operations) and may require sharing it with some external parties or associates of Sabre. Some of these third parties and associates may be located outside the European Economic Area (“EEA”), or your home jurisdiction. As a result, Personal Data may be collected, used, processed, stored or disclosed in the United States of America, and in some cases, other countries. Personal Data is only transferred to another country if this is permitted under the applicable privacy legislation. If you are resident in the EEA, we will only transfer your Personal Data to countries with a standard of data protection deemed adequate by the European Commission, or pursuant to appropriate safeguards, such as standard data protection clauses adopted by the European Commission. If you are a resident of another country with cross border transfer restrictions, we will transfer the data in accordance with applicable law.
If you wish to enquire further about the safeguards used, please contact us using the details set out at the end of this Notice. Your information will only be shared if it is necessary or required (for example to carry out Pre-employment screening).
The recruitment process will involve:
- Assessing and progressing your application;
- Assessing your suitability (skills, strengths, behaviors for the role); and
- Activities needed to complete the on-boarding and screening process should your application be successful.
To enable these processes your Personal Data may be shared internally, but the information shared is limited to what is required by each individual to perform their role in the recruitment process.
Your Personal Data may be shared internally with the following people:
- Those employees who would have managerial responsibility for you or are acting on their behalf;
- Employees in HR who have responsibility for certain HR processes (for example recruitment, assessment, pre-employment screening);
- Employees in Legal, Compliance Audit and HR with responsibility for investigating issues of non-compliance with laws and regulations, policies and contractual requirements;
- Employees in IT and system owners who manage user access; and/or
- Security managers for facilities / premises.
Sabre may also need to share your information with certain external third parties including:
- Companies who provide candidate interview and assessment services to Sabre;
- Suppliers who undertake background screening on behalf of Sabre (employment and criminal checking bureaus, etc.);
- Academic institutions (Universities, colleges, etc.) in validating information you’ve provided; and/or
- Other third-party suppliers (or potential suppliers), who provide services on our behalf.
How do we protect your information?
Our HR and recruitment systems use physical, technical and procedural safeguards that are appropriate to the sensitivity of the Personal Data. These safeguards are designed to protect your Personal Data from accidental or unlawful destruction, loss, access, use, modification or damage.
Sabre endeavors to use Personal Data that is up-to-date and accurate. Where Sabre is made aware that the applicant Personal Data it maintains is inaccurate, reasonable measures are taken to rectify the data.
Where we share information with other parties located outside your country, as a minimum, Sabre will require that such Personal Data is protected as required by the laws of the country where you work. Sabre also requires its third-party suppliers or recipients of Personal Data to guarantee the level of protection required by applicable law.
As part of the selection process, Sabre performs a number of screening checks, where permitted by local law. These checks are only performed on candidates who have been selected for a role. Your consent will be requested before screening checks are performed.
Criminal records checks
Given the nature of our business, we have legal and regulatory obligations to ensure that the people we employ can be relied upon to handle client money and information responsibly. We therefore may ask questions about any prior civil or criminal proceedings you may have been subject to and may also conduct criminal record checks where permitted and in accordance with applicable law.
In order to comply with our legal and regulatory obligations in relation to anti-money laundering and sanctions restrictions, we will screen your name against global sanctions lists. The screening will simply involve searching our internal and third-party databases to ensure you are not on a sanctioned list. We are not able to employ anyone on a sanctions list. In addition, in order to comply with our legal obligations relating to anti-bribery and corruption, we will also perform searches and ask questions to assess whether there is a potential bribery or corruption risk to the role based on your personal and political associations. If there is a risk, we will look to assess what additional internal controls we need to put in place to reduce that risk.
In addition to using Personal Data for the position for which you have applied, if you request, Sabre may retain and use your Personal Data to consider you for other positions. Unless required for tax or other legal purposes or in connection with employment as specified above, your Personal Data will be retained for:
- A maximum of two years for United States applicants;
- For 30 days after the position for which you applied is filled in EEA; and
- Otherwise as required by law.
If you are selected for, and accept employment with us, we will retain your Personal Data throughout your employment in accordance with our policy that you will have access to upon your acceptance of employment.
European Union, Switzerland or United Kingdom Data Subject Rights
This section applies only if you use the website or are applying for a job from within the European Union, Switzerland or the United Kingdom, and supplements the information in this Privacy Notice. Depending on where you live, you may have the following rights in respect of your Personal Data that we hold:
- Right of access. You may request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you and check that we are lawfully processing it.
- Right to rectification. The right to obtain rectification of your Personal Data without undue delay where that Personal Data is inaccurate or incomplete.
- Right to erasure. The right to obtain the erasure of your Personal Data without undue delay in certain circumstances, such as where the Personal Data is no longer necessary in relation to the purposes for which it was collected or processed.
- Right to portability. The right to request we send your Personal Data to a third party.
- Right to restriction. The right to obtain the restriction of the processing undertaken by us on your Personal Data in certain circumstances, such as where the accuracy of the Personal Data is contested by you, for a period enabling us to verify the accuracy of that Personal Data.
- Right to object to processing of your Personal Data where we are relaying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to such processing.
When making a rights request, please note that Sabre may request specific information to confirm your identity and your right to access this information, as well as to search for and provide the Personal Data that Sabre maintains.
If you wish to exercise one of these rights, or have questions or comments about this privacy statement and our privacy practices, please direct such inquiries or requests to Sabre’s Data Protection Officer and/or the Privacy Office at: email@example.com.
There may be instances where applicable law, regulatory requirements or other policies allow or require Sabre to refuse to provide some or all of the Personal Data that it maintains. We will inform you if we are unable to comply with your request to access, rectify or erase any of your Personal Data, or your request to restrict the processing of your Personal Data, and the reasons why we are unable to comply.
If you are If you are dissatisfied, we ask that you contact us first to see if we can resolve the issue. However, if you are an individual in Europe or certain other jurisdictions, you may have the right to lodge a complaint with the supervisory authority in the country in which you live, in which you work, or in the place of the alleged infringement of your privacy rights. If you reside in Europe, further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
For California Residents
Sabre does not Sell your Personal Data, as defined under the California Consumer Privacy Act of 2018 and its amendments (“CCPA”). The categories of Personal Data Sabre may collect about you, the purpose(s) for which the information was collected, and the categories of third parties with whom the business shares Personal Data are listed above in the “What Personal Data might we process” section.
To request this Privacy Notice in another format, please contact our Data Privacy Team at firstname.lastname@example.org.
Changes to this Notice
Sabre reserves the right to modify this Notice by posting changes to relevant Sabre websites. If required by law, we will notify you of the change. If you submit additional Personal Data or request to be considered for a Sabre position following the effective date of a modified Notice, your information will be handled in accordance with the Notice in effect at that time.