NTT Disruption Privacy Policy

Effective day 17 September 2019


                                                                                                 Privacy Policy

This Privacy Policy aims to inform the candidates for job applications published by NTT Disruption about the collection and processing of their personal data.

1. Data controller

  • Identify: NTT Disruption Europe S.L. (hereinafter "NTT Disruption").
  • VAT Number: B88353586
  • Address: Paseo de la Castellana 77 - 13º Floor 28046 Madrid
  • Data Protection Officer: For all inquiries and complaints regarding the security and privacy of your data please contact our Data Protection Officer: data.protection.office@nttdisruption.com.

2. Data processor

NTT Data uses TalentLyft, an application developed by AdoptoTech Itd. (in further text "TalentLyft"), as part of our selection process.

TalentLyft, acting as a Data Processor, processes all personal data at NTT Disruption requests and based on their instructions.

NTT Disruption and TalentLyft have signed a Data Protection Agreement (hereinafter, "DPA") to secure and protect your right to data privacy.

3. Why is NTT Disruption legitimated to process your personal data?

NTT Disruption gathers your specific, informed and free consent in order to process your personal data (article 6.1.a) GDPR) at the time you submit your candidature, without your due consent, NTT Disruption will not process your personal data.

4. What does NTT Disruption use your personal data for?

The collected data will be used only for the selection process. This process may include the following:

  • Verification of the entered data;
  • Reference checks;
  • Assessment of the qualifications and skills needed to perform the job you are applying for;
  • Communications concerning the process (e-mails, phone calls, SMS messages, WhatsApp);
  • Filling out questionnaires and tests;
  • Fulfilling legal regulations;
  • To consider your application in respect of a role for which you have applied;
  • To consider your application in respect of other roles.

Within NTT Disruption we believe in the importance of your privacy status. Please, do not hesitate to contact our data protection office (data.protection.office@nttdisruption.com) if you have any doubts about for what purposes we process your personal data.

5. Personal data collected

The personal data you will supply to us during your job application may include:

  • Full name (fist name, last name, middle name, title)
  • Profile image
  • Headline (job title)
  • Social network profile URL (LinkedIn, Facebook, Github, StackOverflow, AngelList, Xing, Google Plus, Twitter or free input, any valid URL is allowed)
  • Address
  • Email address
  • Skype name
  • Phone number
  • Education history (institution name, degree, period)
  • Employment history (company name, job title, period)

NTT Disruption seeks to not gather more personal data that the ones already listed before. In the case of open fields within the candidate submission, candidates guarantees to not submit other personal distinctly that the ones already mentioned.

If there is the case that the cantidate submits inadequate, irrelevant and unlimited data to what is necessary to fulfil the purposes of the candidate process, NTT Disruption will automatically delete them.

6. Data accuracy

Candidates guarantee that personal data provided are accurate, in case that personal data is not updated or inaccurate, they must to inform NTT Disruption of this situation. In any event, candidates will be responsible for the veracity of their data, and NTT Disruption reserves the right to not consider a candidature with false information, without prejudice to other legal actions.

In short, any modification or update of personal data must be communicated to NTT Disruption through the channel (email) indicated within the Privacy Policy.

7. Data transfers

Your personal data may be transferred to the following sub-processors:

  • Intercom (San Francisco, USA), for providing technical support to application users. The personal data that can be transferred to this sub-processor are: first and last name, and email address. Intercom already has in placed security measures from article 42 of GDPR (Privacy Shield).
  • Mailgun Technologies (San Francisco, USA), for sending all email messages through the application. As such, the email address of candidates can be transferred to it. Mailgun already has in placed security measures from article 42 of GDPR (Privacy Shield).

8. How can you exercise your rights?

You have the following rights in relation to the personal data you provide:

  • Access to your data: You have the right to obtain from NTT Disruption confirmation as to whether or not your personal data are being processed and, if so, to access your personal data.
  • Rectification: You have the right to request the erasure of your personal data, and to request that your data not be shown on any site external to TalentLyft's webpage.
  • Object to processing of your personal data: You have the right to object, at any point, to the processing of your personal data by NTT Disruption where it is carried out on the basis of legitimate or public interest.
  • Request the portability of your personal data: You have the right to receive the personal data provided to NTT Disruption in a structured, commonly used, and machine-readable format. You also have the right to transfer the data to another controller without interference of NTT Disruption, so long as the processing is based on an authorisation or contract and it is carried out by automated means.
  • Lodge a complaint: You have the right to lodge a complaint with competent supervisory authority. In this case, the supervisory authority is the Spanish Data Protection Agency (Agencia Española de Protección de Datos), located in Calle de Jorge Juan 6, 28001 Madrid, and which can also be contacted via email at dpd@agpd.es.
  • Automated individual decision-making, including profiling: You have the rigth to not be subject to profiling, for instance for commercial purposes, based on your data. You also have the right to request that your data not be processed by means of any tool that may lead to a decision made, for instance, by algorithm, which may have a result that affects you directly.

You can exercise these rights through the means indicated in this Privacy Policy, or by sending their request at the post address of NTT Disruption, also already specified at the beginning of this Privacy Policy ("1. Data controller" section).

9. Data security and storage

The preservation of privacy and protection of your personal data is very important for NTT Disruption. As such, NTT Disruption takes all possible measures to prevent the inadequate use of data and the access to your personal records is limited to employees who participate in the selection process.

Your personal data will be saved until the end of the selection for the open position which you have applied for, unless you decide to allow us to keep them for a longer period (24 months) and keep you updated regarding new job position offers.

The data is stored within the European Union, and access to it is secured with the highest level of technical standards and practices; in the case of international transfers, sub-processors are compliant with privacy shield security measures.

10. Updates and changes to this Pricacy Policy

NTT Disruption reserves the right to make changes to this Privacy Policy. When such changes are made, applicants will be notified by email or by any other means considered appropiate for the specific circumstances.