Privacy Policy Introduction This Privacy Policy describes how we collect and use personal information. It applies to all candidates for jobs at Starlizard, and sports professionals about whom we hold Personal Data. We are required under data protection law to notify you of the information contained in this policy. Starlizard is committed to protecting the privacy and security of your personal information, so we take great care to ensure your personal information is held in the strictest confidence and in accordance with the Data Protection Principles set out in Article 5 of the General Data Protection Regulation. This policy may apply to you if you are one of the following data subjects: Individuals involved in our recruitment process; or Sports professionals about whom we collect data; What information do we collect? We collect a range of personal information for various business purposes as set out below: Recruitment: When you apply to us for a job: your name and contact details; your CV; If you are invited for an interview and during the interview process: information about your current level of remuneration, including benefit entitlements; whether or not you have a disability for which we need to make reasonable adjustments at interview or assessment stage; if the interview is at our offices, we may collect information about your health, specifically, your temperature, whether you are experiencing any COVID-19 symptoms or the results of any relevant COVID-19 tests; information about your performance at interview; If we offer you a job: Copies of documents to verify your identity such as your passport and driving licence; Your address and date of birth; Marital status and family details; National insurance number; Next of kin and emergency contact information; Nationality; Information about your entitlement to work in the UK; References; Information about your criminal record; and Information about your health. We collect this information in a variety of ways. For example, from recruitment agents, CVs or through interviews or other forms of assessment. Please note that if you have a telephone interview with us, it will be recorded. If we make a job offer to you, we ask you to complete certain forms containing the above data and further information about yourself, your experience, education and qualifications. We also collect Personal Data about you from third parties, such as references supplied by former employers, information from employment background check providers and information from criminal records checks. We will seek information from third parties only once a job offer to you has been made and ask for your consent to do so. You are under no statutory or contractual obligation to provide data to us during the recruitment process. However, if you do not provide the information, we may not be able to process your application properly or at all. Sports Professionals We collect and process the Personal Data of certain sports professionals for the purpose of our specialist analysis, which may include: name, gender, age, height, position/role, current and previous clubs, league/competition the individual plays in, nationality, publically available information about injuries and suspensions, various statistics and other match-related information. Why do we use your Personal Data? Recruitment We have a legitimate interest in collecting Personal Data during the recruitment process and for keeping records of the process. Collecting data from job applicants allows us to manage the recruitment process, assess and confirm a candidate’s suitability for employment and determine the terms on which a candidate might work for us. We may also need to use data from job applicants to deal with any issues which may arise about the way the recruitment process was conducted. In some cases, we need to use data to ensure that we are complying with our legal obligations. For example, we are required to check a successful applicant’s eligibility to work in the UK before employment starts and we are required to ensure that we provide our employees with a safe working environment. We collect health information about candidates in case we need to make reasonable adjustments to the recruitment process for candidates who have a disability. This is to carry out our obligations and exercise specific rights in relation to employment. If we offer you a job, we also ask you to complete a medical form in order that we can ensure your health and safety in the workplace, to assess your fitness to work and to provide appropriate workplace adjustments. We seek information about criminal convictions and offences with your consent in order to make an informed decision about your recruitment. Sports Professionals The collection and processing of sports professionals’ Personal Data is central to our business of providing specialist sports betting statistical analysis and integrity assessments and as such, we have a legitimate interest in collecting and processing this data. Who has access to your data? Recruitment Your information will only be shared internally for the purposes of the recruitment exercise with members of staff who are involved in interviewing you or otherwise making a decision about your recruitment. We will not share your data with third parties unless we offer you a job. We will then share your data with former employers to obtain references for you, employment background check providers to obtain necessary background checks and the Disclosure and Barring Service to obtain necessary criminal records checks. We will not transfer your data outside the European Economic Area except in instances where data is stored in a data centre outside the EEA and the EU Commission has made an ‘adequacy decision’ in relation to the country where that data centre is located. Sports Professionals We may disclose sports professionals’ information with a small, highly secure and trusted group of sub-processors with whom we share resources for internal and operational purposes. We may be legally required or otherwise be requested to disclose your Personal Data to law enforcement agencies or legal representatives, for example to cooperate with law enforcement investigations or other legal proceedings. In addition, we may use your Personal Data to provide an analysis of sports professionals’ performance for third parties such as sports governing bodies, sports federations and clubs and law enforcement agencies in order to assist with the fight against betting-related match-fixing and other sporting integrity threats. How do we protect data? We take the security of all Personal Data very seriously. We have implemented the appropriate technical and organisational controls and internal policies to ensure that your data is not lost, accidentally destroyed, misused or inadvertently disclosed, and is processed by authorised individuals in accordance with this Privacy Policy. If any Personal Data is transferred to countries outside the EEA, we will ensure that similar levels of protection are in place. In order to ensure similar levels of protection, we may do the following: only transfer your Personal Data to countries that have been found to provide an adequate level of protection for Personal Data by the EU; and/or use the EU Standard Contractual Clauses when entering into contracts with partners based in countries outside the EU/EEA who may handle your data. These standard clauses give your Personal Data the same protection it has in the EU/EEA. For how long do we keep data? Recruitment If your application for employment is unsuccessful, we will hold your data on file for 12 months after the end of the recruitment process, other than the recording of any telephone interview you had with us, which will only be kept for 60 days. Your data will be securely destroyed at the end of these time periods. If your application for employment is successful, Personal Data gathered during the recruitment process will be transferred to your personnel file and retained during your employment in accordance with the privacy policy applicable to employees. Sports Professionals We have implemented and maintain robust organisational controls and data retention policies to ensure that we retain your Personal Data only for as long as is reasonably required for legal or business purposes. When we no longer need Personal Data for the specific purposes, we securely delete or destroy it. Your rights As a data subject, you have a number of rights: The right to be informed about the use of your Personal Data – That is the aim of this Privacy Policy; The right of access – upon request, you have the right to access and obtain a copy of your data; The right to rectification – you can require us to change incorrect or incomplete data; The right to erasure – in certain circumstances, you can require us to delete your data; The right to restrict processing – in certain circumstances, you can restrict the use of your data; The right to data portability – in certain circumstances, move, copy or transfer your data; The right to object – in certain circumstances, you can object to the use of your data; and Rights in relation to automated decision making and profiling. The right to withdraw consent – You may withdraw your consent to the processing of your data only where the processing is based on your consent. However, this right does not apply if the processing of your personal data is required for the performance of a contract between us or if the processing is based on our legitimate interests. Please note that we reserve the right to refuse to give effect to a request to exercise any of the above data protection rights if we are unable to ascertain your identity. If you believe that we have not complied with your data protection rights, you also have the right to complain to the Information Commissioner. How to contact us Should you have any questions regarding the processing of your Personal Data or should you wish to exercise your rights under this Privacy Policy, please contact our Data Protection Officer on dataprotection@starlizard.com. Registered in England no: 5686221 | Registered Office: Maria House, 35 Millers Road, Brighton BN1 5NP Privacy Policy | Gender Pay Gap | Terms | Staying Covid-19 Secure | Cookies