Recruitment Privacy Notice

1. INTRODUCTION

This notice provides information about how Family Bank Limited to which you are applying, and any of our related affiliates and subsidiaries (collectively "us" or "we"), protect your personal data in accordance with the Data Protection legislation, including the Data Protection Act 2019 and The Data Protection Regulations 2021.

By submitting your personal data to us, you acknowledge that:

1. You have read and understood this Notice and agree to the use of your personal data as set out herein.
2. Your personal data may be transferred and processed to external third parties.
3. Your failure to submit your data may result in us not being able to continue your candidacy for the job for which you have applied.
4. All your representations are true and correct to the best of your knowledge and belief, and you have not knowingly omitted any related information of any adverse nature. Providing any inaccurate information may make you ineligible for employment or may lead to termination.

This notice applies to applicants for recruitment, as well as any third parties whose information you provide to us in connection with your application (for example, referees or emergency contacts).

This notice is not an offer of employment, nor does it put any contractual right on you, or place any contractual obligation on the Bank.

We collect and process your personal data in accordance with our main Privacy Notice Privacy Statement - Family Bank Limited, Kenya .This Notice describes our privacy practices that are specific to recruitment.

2. PURPOSE AND BASIS

The Bank will use your personal data only as part of our recruitment process, including to evaluate your suitability for a position, respond to your application, improve our recruitment process, comply with any applicable procedures, laws and regulations and for human resources analysis purposes. Upon successful hiring, your information shall be transferred to our internal human resources systems for the purpose employment-related activities. Once you are officially on boarded as a Family Bank Limited employee, you will be subject to our Data Protection policy.

The Bank will not use your data for other purposes, nor share it outside of Family Bank Limited except as specified in this notice. If you are not hired, we may contact you in the future for other positions that match your qualifications. If you are unsuccessful, your data shall be kept for a
period of 6 months.

The Bank has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. We will seek your written consent to allow us to process sensitive data i.e. on background checks. If we do so, we will provide you with full details of the information that we would like and the reason we need it.

What data we collect about you

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

1. Identification data – Names, government identification documents (national ID/passport/Maisha Namba), date of birth, and gender.
2. Contact data – Home address, email addresses, and phone number.
3. Employment data – your resume / CV, qualifications, skills, employment history (such as start and end dates of previous employment, job titles, responsibilities, your current level of pay and employment benefits, notice period), and preferred work location.
4. Any other personal data - which you choose to disclose to us during the application or interview process, whether verbally or in written form, including in particular any other information which you disclose on a CV / resume.
5. Informal data - including opinion data generated during the application or interview process.
6. Biometric finger- prints for Physical identity access management upon successful hiring.
7. Emergency Contacts upon successful hiring
8. CRB Certificate, Marriage certificate, Beneficiary and Dependants Details including birth certificates, HELB Certificate and Police Clearance Certificate, Tax Compliance, NSSF, NHIF-Upon Successful hiring,

When you are invited to an interview, we may ask you to provide:

1. Your CV
2. Original Copies of All your Certificates

When you undergo pre-employment checks we shall ask for:

1. Contact details for your referees.

When you contact us with feedback or an enquiry we will process:

1. Your email address

How is your personal information collected;

1. Through information that you give us
2. by signing on and using our digital platforms and tools such as LinkedIn
3. by communicating with us via email, letter, phones
4. by entering our buildings and passing through our security and CCTV monitoring
   systems
5. Through information that you ask us to collect from third parties; If you specifically ask us to collect information from a third party, we will do so in accordance with your request, which we may ask you to put in writing.

Information we obtain from CCTV images and building access

We operate CCTV at all our premises. While you are on-site at any of our offices, you may be recorded by our CCTV system.

Please note that some of the data listed above will only be required for successful candidates in the pre-employment screening process.

3. BACKGROUND SCREENING

If you receive an offer from us, we will conduct a background check on you or instruct a third party to do so on our behalf, for example references from a previous employer. Background screening will only be done to the extent necessary and proportionate to the role that you are
being offered.

Consent is sought for integrity background check as a condition to be considered for employment. These checks may include but not limited to the following: Previous/Concluded court cases, integrity and ethical issues, professional background, academic history.

Personal data provided by the candidate following an offer of employment may be used to facilitate a background check. No background checks will be undertaken prior to a conditional offer of employment being made. Failure to pass a background check may result in the withdrawal of the employment offer, in line with the requirements of all applicable laws and FBL policies.

Conducting background checks may involve the collection of additional information about the candidate from educational institutions, government agencies, previous employers, credit reporting agencies, information in the public domain, and law enforcement agencies at the international, national, or local level so far as is permitted by applicable law. If a candidate's prior employers and/or other referees are contacted, the report may include information obtained through personal interviews. Please note that it is your responsibility to obtain consent from referees before providing their personal data to us.

4. LEGAL BASIS OF PROCESSING

The legal basis for processing your personal data is:

1. Contractual: It is necessary for the performance of a contract to which you are a party - an employment contract. This relates to information that we need to recruit and employ you.
2. Contractual: It is necessary to take steps at your request prior to entering into a contract for employment. This relates to information that we collect as part of the application and selection process.
3. Legal obligation: It is necessary to comply with a legal obligation placed on us as the data controller – which is the Employment Act.
4. Consent: If we rely on your consent to process your personal information for the purposes of recruitment, you have the right to withdraw your consent for processing for that purpose at any time by contacting the DPO at dataprotection@familybank.co.ke

5. DISCLOSURES OF PERSONAL DATA

We may share your personal data with other members of the Family Bank Group where required to, for example, to make decisions about your recruitment. Within Family Bank Limited, your personal data can be accessed, or may be disclosed internally on a need-to-know basis, by the
hiring manager for managing or making decisions in connection with your potential employment.

We may use third parties to help us provide recruitment services e.g. vetting companies that will process data under our instruction and be subject to a contractual relationship.

Your personal data may be shared with certain interconnecting systems (such as HR information, payroll and benefits systems) if your application for employment with us is successful. Data contained in such systems may be accessible by providers of those systems, their associated companies and sub-contractors who have signed Non -Disclosure Agreements with the Bank.

The Bank may be required to disclose your personal data to third parties Including:

1. KRA, IT administrators, lawyers, auditors, and other professional advisors.
2. In response to orders or requests from court, regulators, government agencies, parties to a legal proceeding or public authorities; or
3. To comply with regulatory requirements

The Bank requires third parties to process any data disclosed to them in accordance with applicable law, including with respect to data confidentiality and security. Where permitted by applicable law and depending on the stage of the recruitment, access to Personal Information is restricted to those individuals who need such access, including but not limited to members of the:

1. Human Resources Department
2. Department and the managers involved in the recruitment process, and to authorized representatives of the Company’s internal control functions such as Compliance, Risk, Audit and Information Security,
3. Background Screening Investigations, Corporate Security, Audit and Legal. Access may also be granted, on a strict need-to-know basis, to others as permitted by law.

6. COOKIES AND OTHER TRACKING TECHNOLOGIES

The Bank may use first- and third-party cookies and other tracking technologies, including web beacons, to manage our Sites and services, and to collect analytics about how you use our Sites and services. You have options regarding our use of cookies and other tracking technologies. Here
is a link to our cookie policy; Cookies Guideline - Family Bank Limited, Kenya

7. YOUR RIGHTS

You have a right to;

1. Request access to your personal data (commonly known as a “subject access request”).
2. Request correction of the personal data that we hold about you.
3. Request erasure of your personal data.
4. Object to processing of your personal data.
5. Request restriction of processing of your personal data.
6. Request the transfer of your personal data to you or to a third party.
7. Withdraw consent.
8. Automated decision-making: you have the right not to have a decision made about you that is based solely on automated processing, including profiling if that decision produces legal effects about you or significantly affects you. We do not, as part of its recruitment process, make solely automated decisions about candidates

You may access those rights by contacting Family Banks' Data Protection officer at dataprotection@familybank.co.ke

The Bank will always endeavour to respond to your request within one month of receiving it and any additional information we need to confirm your identity and understand your request.

However, sometimes we may need some more time to deal with your request, particularly if it is complicated. Where this happens, we will write to you within one month and let you know why we need some more time and when we will provide you with our response. If we are unable to carry out your request, we will send you a response explaining why.

8. DATA SECURITY

Family Bank maintains appropriate administrative, organizational, technical, and physical security measures to protect your personal data from accidental loss and unauthorized access or use. These measures include encryption, firewalls, roles-based data access, intrusion-detection software, and physical access controls to data centres.

9. DATA RETENTION

Collection, use, disclosure, transfer and other processing, including storage, of Personal Information may be by electronic or manual means, including, but not limited to, by hard-copy or soft-copy documents.

The length of time that we intend to retain each category of Personal Information will depend on a number of criteria, including

1. the length of time we are required to retain Personal Information in order to comply with applicable legal and regulatory requirements,
2. the length of time we may need to retain Personal Information in order to accomplish the business or commercial purpose(s) for which such Personal Information is collected, used or disclosed and
3. whether you choose to exercise your right, subject to certain exceptions, to request deletion of your Personal Information.

If you accept an offer of employment with Family bank, 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 data protection policy. Your data will be retained for 10 years.

10. CONTACTS

If you have any questions about this Privacy Notice or if you would like to communicate with the Data Protection Officer, please contact us at dataprotection@familybank.co.ke

Download Data Request Subject Form