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Recruitment Privacy Notice

Definitions

In this Privacy Notice, the following expressions have these meanings:

“Personal Data” is broadly defined as any information relating to an identified or identifiable natural person. A natural person can be identified, directly or indirectly, through various identifiers such as a name, an identification number, location data, an online identifier and one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

“Data Protection Officer” refers to Moniepoint Microfinance Bank Limited’s Data Privacy Officer who is responsible for advising on and monitoring compliance with data protection laws.

“Data Subject” is defined as an identified or identifiable living individual. In other words, any person whose personal information is being collected, held, or processed by an organization

Introduction

This Privacy Notice (“Notice”) describes Moniepoint Microfinance Bank Limited’s (“Moniepoint MFB”, “We”, “Our” or “Us”) policies and practices regarding your Personal Data or Data. It explains how your Personal Data is collected, used, and disclosed by Moniepoint for the purpose of managing Our recruitment process. It also tells you how you can access and update your Personal Data and make certain choices about how your Personal Data is used.

If you do not provide necessary Personal Data to Us (We will indicate to you when this is the case, for example, by making this information clear in our sign-up forms), We may not be able to process your job application. This Notice can change from time to time, subject to Moniepoint’s discretion.

This Notice only applies to the Personal Data of job applicants, potential candidates for employment and those who participate in Our recruiting programs and events. This Notice does not apply to the Personal Data of Our employees, partners, clients, vendors or any other person from whom Moniepoint collects Personal Data for other purposes.

  1. Sources of Personal Data

    2. We collect Personal Data from or about you from the following sources:

    • Moniepoint’s Website: Website(s) operated by Us under Our own domain(s)/URL(s) (such as www.moniepoint.com/ng ) and other sites that We run on third party social networks such as LinkedIn.
    • Recruitment forms: Digital recruitment and similar forms that We process in the course of your submitting a job application.
    • Recruitment partners: Data collected by a partner organisation (such as a recruitment agency) working on behalf of Moniepoint.
    • Advertising interactions: Interactions with Our advertisements (e.g., if you interact with one of Our ads on a third-party website, We may receive information about that interaction).
    • Recruitment: Information shared by yourself when applying for a job with Us, information publicly available on social media platforms to identify prospective candidates for a specific function.
    • Data We create: In the course of Our interactions with you, We may create Personal Data about you (e.g. recruitment or interview notes).
  2. Personal Data We Collect

    3. We usually collect Personal Data directly from you when you apply for a role with Us. We use the Personal Data collected in the recruitment process mainly to identify and evaluate candidates for roles at Moniepoint. We also process that Data in order to maintain records in relation to recruitment and hiring and to meet any legal obligations We are subject to.

    • We usually collect Personal Data directly from you when you apply for a role with Us. We use the Personal Data collected in the recruitment process mainly to identify and evaluate candidates for roles at Moniepoint. We also process that Data in order to maintain records in relation to recruitment and hiring and to meet any legal obligations We are subject to.
    • CV / Resume related information: Any information provided in the course of submission of your application, such as employment history (including salary related data), academic qualifications, references, and certifications.
    • Public profiles: We may process information that you have made publicly available such as via LinkedIn or through other recruitment sites.
    • Identity information: Documents such as passport, driving license or national ID cards or similar, that enable Us to identify you and confirm your right to work.
    • Financial information: This includes any information, such as bank details, that is required to process payroll, tax, pensions and similar on your behalf.
    • Record keeping and recordings: Should you be invited to an interview via video call or similar, We may record that interview and any notes associated with that conversation. Interviews, including in person interviews, may be subject to handwritten note taking.
    • Physical and system security: If you attend any Moniepoint location for an interview, you may be captured by CCTV or other security measures in place at that site.
    • Legal claims: Any information relevant (or potentially relevant) to disputes or legal proceedings affecting Moniepoint.
    • Sensitive or special category Data: We may process more sensitive categories of Personal Data where you have provided it to Us for the purposes of making reasonable adjustments during the interview process. We may also ask for more sensitive data where We are permitted to do so by applicable law in order to support Our efforts to create and maintain an inclusive and diverse work place. You are under no obligation to provide this information and anything that is provided will only be used for anonymized reporting purposes and not linked to the application or recruitment process.
  3. Legal Basis For Processing Your Data

    4. Our processing of your Personal Data for the purposes mentioned above is based:

    • in part, on Our performance of a contract or steps preparatory to entering a contract relating to Our potential employment relationship with you.
    • in part, on Our compliance with applicable law, with regard to Personal Data necessary to satisfy Our legal and regulatory obligations, including with regard to verifying your identity and eligibility to work in Nigeria and conducting background checks;
    • in part, on your consent, if We collect sensitive Personal Data for legally permitted purposes other than compliance with Our legal obligations; and
    • in part, on Our legitimate business interests in evaluating your application to manage Our relationship with you, to ensure that we recruit appropriate employees, maintain a talent pool for a reasonable period (not more than 365 days) after an unsuccessful application, based on Our operational needs to efficiently fill future vacancies, and to evaluate and maintain the efficacy of Our recruitment process more generally.
  4. Background Screening

    5. If you receive an offer from Us, We may conduct a background check on you or instruct a third party to do so on Our behalf. A background check may include criminal background data to the extent permitted by law. If a background screening is required, you may be contacted by a third-party background screening service provider who would provide you with further information about the process and what Personal Data it might involve.

  5. Disclosure Of Your Personal Data

    6. Your Personal Data may be accessed by recruiters and interviewers across Moniepoint. Individuals performing administrative functions and IT personnel within Moniepoint may also have access to your Personal Data to the extent necessary to perform their jobs.

    We use Greenhouse as a third-party service provider to provide a recruiting applicant tracking software system. Except to the extent necessary to accomplish the uses and purposes described in this Notice, We do not disclose your Personal Data to third parties. We also require Our service providers to use your Personal Data solely for purposes related to their engagement with Moniepoint and not for their own independent use. We do not otherwise share or sell your Personal Data to third parties.

    In addition, We may disclose or transfer your Personal Data in the event of a re-organization, merger, sale, joint venture, assignment, or other transfer or disposition of all or any portion of Our business.

  6. Transfer of Your Personal Data

    7. Your Personal Data may be disclosed to other entities affiliated with Moniepoint and within the same group as Moniepoint, or to third party partners, located outside the country. These jurisdictions may offer different levels of protection for Personal Data. When We transfer your Personal Data across borders, We will ensure that appropriate safeguards and standards have been provided by the entity receiving the information.

  7. Data Retention

    8. If you accept an offer of employment with Us, any relevant Personal Data collected during your pre-employment period will become part of your personnel records and will be retained in accordance with the privacy notice applicable to Moniepoint’s employees, which shall be made available to you upon commencement of your employment.

    We may want to remain in contact with you and consider you for future employment opportunities. In such an event, We will seek your consent to include you in one of Our recruiting programs that provides you with ways to further stay in touch with Moniepoint, either prior to or after you formally apply for a job opportunity. Participation in these recruiting programs is entirely optional. If you join a recruiting program, we retain your Personal Data for a period of time specific to that program (in each case, not more than 365 days), but if you wish to withdraw from the program at any time, please contact Us at [email protected] and copy [email protected].

  8. Security

    9. We use generally accepted standards of technical and operational security to secure your Personal Data. Only authorized personnel of Moniepoint and of Our third-party service providers are permitted to access your Personal Data, and these employees and third-party service providers are required to treat this information as confidential. Despite these precautions, We cannot guarantee that unauthorized persons will not obtain access to your Personal Data. Should any unauthorized access to your Personal Data become apparent, Moniepoint will abide by statutory reporting obligations under the Nigerian Data Protection Act, 2023 (NDPA).

  9. Your Rights

    10. Your Personal Data is protected by legal rights enshrined in the NDPA. These rights include:

    • Right to be informed about the processing of your Personal Data;
    • Right to access your Personal Data held by Us;
    • Right to rectify inaccurate or incomplete personal information;
    • Right to request erasure of Personal Data from Moniepoint’s systems and records, subject to applicable legal and regulatory requirements;
    • Right to withdraw consent for processing Personal Data at any time, in cases where consent has previously been given, to the extent Our processing relies on your consent as the lawful basis for processing. This right may not apply if there are other legal justifications to continue processing or We need to retain certain Personal Data where required or permitted under applicable law;
    • Right to object to the processing of your Personal Data, for example, direct marketing;
    • Right to object to any decisions based on the automated processing of your Personal Data, including profiling;
    • Right to data portability i.e., the right to request that Personal Data be sent to a third party;
    • Right to lodge a complaint with the Nigeria Data Protection Commission (NDPC).

    If you would like to submit a request in relation to your data subject rights, you can fill out Our data subject access request (DSAR) Form, specifying the right you wish to exercise.

    If you have unresolved concerns, you also have the right to complain to the NDPC through their website on https://ndpc.gov.ng/.

    To ask questions or make comments on this Notice and Our privacy practices or to make a complaint about Our compliance with applicable privacy laws, please contact Us at [email protected].

  10. Changes To This Notice

    11. Moniepoint reserves the right to modify this Notice. We will publish any changes to this Notice on this page. Please check this page regularly to keep up-to-date.