Job Candidate Privacy Notice | Kenya
TransUnion Kenya
Last revised: 22 September 2022
Version 1.1
© 2022 TransUnion LLC
All Rights Reserved
No part of this publication may be reproduced or distributed in any form or by any means, electronic or otherwise, now known or hereafter developed, including, but not limited to, the Internet, without the express written permission of TransUnion. This document is protected by U.S. and International copyright laws. This document and the subject matter contained herein is TransUnion proprietary and confidential information, and may not be shared or used for any purposes other than the purpose for which it was provided by TransUnion, without the express written permission of TransUnion. By using this document, you are agreeing that you will not attempt, directly or indirectly, to reverse engineer, decompile, or disassemble any TransUnion services or service information, any confidential or proprietary criteria developed or used by TransUnion relating to services you receive from TransUnion, or any of the TransUnion confidential and proprietary information contained herein. The entire right, title and interest in and to this document and TransUnion services, and all copyrights, patents, trade secrets, trademarks, trade names, and all other intellectual property rights associated with any and all ideas, concepts, techniques, inventions, processes, or works of authorship including, but not limited to, all materials in written or other tangible form developed or created by TransUnion, shall at all times vest exclusively in TransUnion. You acknowledge that any misuse, misappropriation or threatened misappropriation of TransUnion’s intellectual property rights, or any breach or threatened breach of the foregoing restrictions, may cause immediate and irreparable injury to TransUnion, and in such event, TransUnion shall be entitled to seek injunctive relief. Nothing stated herein will be construed to limit any other remedies available to TransUnion including, but not limited to suspension and/or termination of the services provided to you.
Requests for permission to reproduce or distribute any part of, or all of, this publication should be mailed to:
Law Department
TransUnion
Delta Corner Annex, 2nd Floor, Ring Road,
Westlands, Nairobi.
The “tu” logo, TransUnion, and other trademarks, service marks, and logos (the “Trademarks”) used in this publication are registered or unregistered Trademarks of TransUnion LLC or their respective owners. Trademarks may not be used for any purpose whatsoever without the express written permission of the Trademark owner.
Table of contents
- Who we are and how to contact us
- What we use personal information for
- Kinds of personal information we use and where we get it
- How long we keep personal information
- Our legal basis for handling personal information
- Who we share personal information with
- Where we store and send personal information
- Your rights concerning your personal information
- Where to lodge a complaint
Introduction
This privacy notice provides information about how we use and share the personal information we obtain during the job application process.
1. Who we are and how to contact us
Information for Good®
We’re in an era of rapid digital transformation where consumers demand more access to seamless, personalised products and services online. However, the currency of personal data that fuels this platform economic boom poses threats to individuals and endangers corporate security.
Now more than ever — and likely more so in the future — consumers and corporates need new levels of trust and transparency.
As a global information and insights company, TransUnion seeks to make trust possible in modern commerce. We do this by curating a robust and actionable picture of each consumer so they’re reliably represented in the marketplace. This enables businesses and consumers to transact with confidence and achieve great things. We call this Information for Good®.
We’re a company with registered offices at Delta Corner Annex, 2nd Floor, Ring Road, Westlands, Nairobi. Although we’re part of a larger group, this notice covers only the activities of TransUnion companies within the Republic of Kenya.
Joint responsible parties
TransUnion companies sometimes cooperate with other TransUnion companies when sharing and making decisions about your personal information. When this happens, all employees across the group ensure each company involved complies with data protection rules.
Contact our Consumer Services Team to enquire about any of our companies or exercise your rights regarding your personal information.
Contact details
Contact us about personal information issues, including the contents of this notice via:
- Post: TransUnion P.O Box 46406-00100 Nairobi
- Telephone: TransUnion Contact Centre: +254 742 258478, +254 768 617074, +254 768 253748, +254 768 262495, +254 706 565285
2. What we use personal information for
Managing end-to-end recruitment
TransUnion Information Group personnel involved in the recruitment process (and relevant third parties) may communicate with you on a strict need-to-know basis. In doing this, we show how we conducted the application and recruitment process and arrived at our decision.
Screening checks
TransUnion holds highly confidential data that’s subject to stringent legal and regulatory responsibilities. Therefore, we undertake identity verification checks and employment screening to protect the interests of TransUnion, its parent company, clients, partners and other stakeholders, including consumers and third parties.
Additional information
These checks are mandatory for your application and need to be complete before employment begins. To complete these checks, you may need to present specific documentation, provide additional details and sign authorisations or acknowledgements. (Further details will be provided with any offer of employment).
We’re mindful of your privacy and will only perform these checks at the appropriate application stage.
3. Kinds of personal information we use and where we get it
We obtain and use information from various sources summarised in the following table.
Type of Information | Description | Source |
Basic contact information: | Name, email address, phone number and job title. | You provide this information when you make an enquiry or when we subsequently request it. |
Your enquiry: | Any enquiry you make. | |
Proof of identity or authority and other supporting documentation: | If you enquire on someone else’s behalf, we may ask for proof of authority, such as a power of attorney. Sometimes we may require additional supporting documentation. | |
Information gathered in dealing with your enquiry: | Dealing with an enquiry involves investigating the circumstances. This type of information depends on the enquiry. | Internal records and external organisations, such as clients and suppliers. |
Our response and other correspondence: | Our response and other correspondence relating to your enquiry. | We produce these ourselves. |
Website usage: | If you access or submit information through our website, we record information, such as IP address, operating system and browser type. | We gather this through the website. |
You’re free to choose whether you give us your personal information. However, if you don’t provide the information we need, this may limit our ability to complete certain processes.
4. How long we keep personal information
We’ll keep your personal information for as long as we handle your application and an additional period after completion. That period depends on the following purposes:
- Showing we have processes to deal with enquiries, requests and complaints fairly and under our regulatory requirements
- Responding to you or a regulator about how we dealt with your request and to show we dealt with it appropriately
- Defending any potential legal claims or regulatory action that might arise because of the request
5. Our legal basis for handling personal information
Legitimate interests
The Data Protection Act No. 24 of 2019 allows personal information usage where necessary for legitimate purposes without undue adverse impact. We base most of our processing activities on the following legitimate interests:
- Administering and managing the recruitment process
- Assessing and confirming an applicant’s suitability for employment
- Deciding whom to offer a job
- Keeping records of this process to explain or justify our decision
6. Who we share personal information with
Our group of companies
As stated, we share personal information among TransUnion companies as appropriate. We’ve set out a list of current such companies below.
Group Company | Physical Address |
TransUnion Africa Holdings (Pty) Ltd | TransUnion |
Service providers
We may provide information to third parties who help us use it for purposes described in Section 2.
We may host our information database with third parties and use a third-party broadcasting service to send you emails or SMS messages.
These service providers may not use your information for their purposes or on behalf of other organisations unless you agree.
7. Where we store and send personal information
We access and use your information from our base in Kenya. We will not transfer personal information to a country lacking laws that provide an adequate level of information protection — unless we have an agreement with the recipient requiring measures that offer a similar level of protection as the Data Protection Act No. 24 of 2019 in Kenya.
8. Your rights concerning your personal information
We’ve outlined your rights concerning the personal information we hold about you below:
Access: You have the right to find out if and what personal information we hold about you. Refer all your data access enquiries to info@transunion.com or DPO_KE@transunion.com.
Correction/Destruction/Deletion: If the information we hold about you is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or obtained unlawfully, you have a right to ask us to correct or delete it.
Objection to processing: You may object (on reasonable grounds) to processing your personal information unless legislation provides for such processing.
Objection to direct marketing: You may object to us using your personal information for direct marketing, and if you do, we will stop.
To enquire about exercising these rights, please contact the TransUnion Contact Centre on: +254 768262495, +254 768617074, +254 768253748¬, +254 706565285
9. Where to lodge a complaint
We strive to deliver the highest levels of customer service. However, if you’re ever unhappy with us, please contact us so we can investigate.
- Post: O Box 46406-00100 Nairobi
- Telephone: +254 768262495, +254 768617074, +254 768253748, +254 706565285
You can also contact our Data Protection Officer at DPO_KE@transunion.com
You may complain to the Information Regulator via:
- Email:info@odpc.go.ke
- Post: O Box 30920-00100, Nairobi