Candidate Privacy Notice

1. Introduction and Key Terms

IMI plc, together with members of the IMI Group, Industrial Automation, Process Automation, Life Science & Fluid Control, Climate Control and Transport sectors: (“IMI”, “we” “us”. “our”) is committed to safeguarding the privacy of candidates. This Candidate Privacy Notice is issued on behalf of the IMI group. The data controller responsible for your personal data is the employing entity that is recruiting for a role and is named on the job advert.  

IMI complies with applicable local laws, and this notice describes how and why IMI collects and uses your personal data for recruitment purposes across our business globally. Where such laws vary from the practices described here, IMI has adopted specific practices to satisfy local requirements.  

In this notice “personal data” refers to any information relating to an identified or identifiable individual or equivalent definition under applicable local law.

For California candidates only: the description of IMI’s data practices covers the twelve (12) months prior to the Effective Date.

[More+]

2. Contact

If you have any questions about this notice or wish to exercise your rights under applicable law, please contact [email protected]. Please include the name of the role in your e-mail.

3. What personal data is processed and how it is used?

IMI minimises the types of personal data processed. The specific personal data processed at any time will vary depending on the stage of the recruitment process, as well as country-specific legal and business requirements. IMI shall only process personal data when relevant to each stage of the recruitment process.

Categories and Types of Personal Data*	How Personal Data is Used (Purposes)	Disclosures for Business Purposes in previous 12 months (see s6)
Contact information – names, titles, mailing and / or email address, telephone numbers	Contacting you in relation to recruitment and (where you have consented) new opportunities that may be suitable	Y
Professional Data – data about your education, work experience, professional licences, drivers’ licence, certifications, skills, interests, hobbies, professional goals and interests included in CV / resumes / cover letters including photographs if included.	Assessing your skills, qualifications, and interests against roles to which you have applied or future IMI opportunities where you have consented to have your details included on our recruitment database	Y
Application Data – interview scheduling information, interview notes, any job-related assessments that are part of a recruitment process, salary expectations and information.	Managing recruitment process and evaluating your application. Preparing an offer for successful candidates.	Y
Online Professional Data – information about you and your professional experience that is available publicly such as on LinkedIn, or through trade publications and professional associations – this is only processed where it is legal to do so under applicable local law.	Identifying and contacting potential candidates for opportunities at IMI Evaluating specific requirements for roles to which you have applied – only where it is legal to do so under local law	Y
Digital Identifiers / Device Information – IP address, user agent, device identifiers, digital signatures and similar technologies including rough geolocation data that can be inferred.	Delivering our online recruitment system and services on IMI websites and through third parties.	Y
Citizenship / Nationality / Work Eligibility – passport, visa, government IDs and other licences.	Verifying your eligibility to work in a particular role in specific countries.	Y
Diversity and Inclusion Information / Protected Classifications – information about race or ethnicity, sexuality, disability, religion, or military or vet status or other protected classifications or sensitive personal information defined under California and other laws (only where required or permissible in accordance with local law).	To enable IMI to perform legally required or permissible diversity reporting and analysis.	Y
Audio Visual Data and Recordings – recordings of interviews and online assessments. CCTV footage were captured on IMI sites.	To perform interviews and online assessments, and (only with your consent and only where legally permissible) record interviews and online assessment recordings. Evaluating interviews and online assessments. For crime prevention and safety purposes where CCTV is used on a site visited by the candidate.	Y
Medical or Health information – information related to disabilities and health conditions where relevant and necessary to comply with local legal requirements or as otherwise permissible.	Where strictly required to support the recruitment process (e.g., provide appropriate accessibility tools for interviews, for controlling access to premises) and to determine if you can safely perform the duties of the role and what reasonable accommodations may be needed in event of your employment.	Y
Professional and Educational references – written and verbal information from professional referees relating to your suitability for a role.	To evaluate your suitability for a role, or as a part of pre-employment background checks to validate your professional background and educational / other certifications.	Y
Additional Screening / Eligibility Information – Drivers’ licence, citizenship and nationality data, government identifiers, passport numbers, certifications and licence numbers, criminal record information (only as strictly required and permissible by local law).	For pre-employment verification and background screening including reference checks, criminal record sanctions assessments, fraud prevention and similar purposes all subject to applicable law and limited to scope of roles.	Y
Other Personal Data – date of birth, citizenship/nationality, financial account information.	To prepare an offer of employment for you, and as otherwise necessary to prepare for onboarding you to IMI.	Y
All information may be used where necessary, and strictly as permitted by law, in emergency situations or where necessary to protect an individual, for compliance, fraud prevention (such as recruitment fraud) and safety or security purposes and to protect IMI’s legal interests.

*this list represents personal data (that shall have the same meaning as “personal information” and includes “sensitive personal information” – as defined in the California Consumer Privacy Act of 2018 (CCPA) California Privacy Rights Act (CPRA)) that IMI has obtained and used for business purposes in previous 12 months. To the extent that IMI collects and discloses personal data, IMI does not use or disclose “sensitive personal information” for any purpose not expressly permitted by the CPRA.

4. Sources of Personal Data

We obtain your personal data only where permissible and in accordance with local law from the following sources:

• from you directly (e.g. through our application system);
• from referees when providing references, from academic institutions, training or certification providers;
• from publicly available sources including social media platforms;
• from background checking agencies and other external database services (e.g. credit reference agencies and professional / sanctions registries); or
• from third party entities including recruitment and executive search agencies or from other IMI entities that have your information retained on file.

5. Legal Basis of Processing – EEA and UK Candidates

We rely on different legal bases for processing personal data for purposes described in this notice as follows:

• Where you provide consent to the processing of your personal data in which case you have the right to withdraw consent at any time;
• On the basis of IMI’s legitimate interests to source, evaluate and select appropriate candidates as described in section 3;
• Where IMI is required to meet legal obligations including immigration and employment laws and regulations and to enable us to cooperate with law enforcement;
• To take steps in order to prepare an offer and/or enter into a contract with you where you are considered for employment; and
• Legal claims: where your information is necessary for us to defend, prosecute or make a claim against you, us or a third party.

6. Personal Data Sharing / Disclosure

IMI does not sell or share your data or rent or otherwise disclose personal data processed for purposes outlined in this notice to third parties for monetary or other valuable considerations. IMI only discloses personal data for business purposes as described in this section.

Personal data is shared only with employees who require access to perform their tasks and duties, and those with a legitimate purpose for accessing it. Whenever we permit a service provider or IMI group company to access personal data, we implement appropriate measures to ensure personal data is used in a manner consistent with this notice and that the security and confidentiality of the information is maintained.

IMI’s vendors and service providers – IMI uses a vendor platform for application and recruitment processes - Applied Training Systems, Inc., trading as Trakstar – based in the USA where candidate personal data will be stored. IMI also uses other vendors and service providers such as recruitment agencies, background checking and reference agencies, and technology platforms in its enterprise on which your personal data may be processed (e.g. Microsoft Office for emails and Teams conferencing platforms). These entities do not use personal data for their own purposes.

IMI group companies - we may share your personal data with individuals in other IMI group companies including contractors, consultants and service providers where it is necessary to administer the recruitment application, support, analyse and perform aggregate reporting on recruitment practices or to comply with applicable legal requirements.

Where you have consented to keep your application data on file IMI group entities may access your application information to assess your suitability and contact you related to future roles within IMI. You may withdraw you consent to keep your candidate profile open for review by other IMI entities at any time by contacting [email protected].

Third parties - We may also disclose personal data if we are required to do so by law or legal process; to enforce or protect the rights and policies of IMI; to assist in the investigation of suspected or actual misconduct or illegal activity; and/or as part of a sale of a IMI entity to another company.

7. Data Location and Data Transfers

IMI plc is headquartered in UK and has entities globally including in European Union, USA, Canada, Brazil and China. IMI has implemented appropriate safeguards to protect personal data were transferred outside EEA and UK such as implementing the European Commission's Standard Contractual Clauses (and UK’s equivalent), which requires IMI’s non-EEA and non-UK members to protect personal information they process from the EEA or UK in accordance with European Union or UK data protection laws. Please contact IMI for a copy of the Standard Contractual Clauses.

8. Data retention and deletion

Personal data is stored in accordance with applicable laws and retained only as long as needed to carry out the purposes set out in this privacy notice. Generally, this means that data is retained for a period of twelve (12) months after an application has been submitted or in accordance with the retention periods set out in IMI’s Retention Schedule where candidates become employees.

Retention periods may be extended if an individual consents to have personal data retained so IMI can contact them if suitable vacancies arise in the future, or if IMI has a legitimate business interest in retaining the information (e.g. where there is litigation).

At the end of the retention period or if an individual elects to delete their profile, personal data and records that are no longer needed are either irreversibly anonymised (and the anonymised information may be retained) or securely destroyed.

9. Your rights

You have rights in relation to your personal data which vary according to local laws. Where the UK General Data Protection Regulation (“UK GDPR”), EU General Data Protection Regulation 2016/679 ("GDPR"), the Brazilian General Data Protection Law ("LGPD"), the California Consumer Privacy Act of 2018 ("CCPA") / California Privacy Rights Act of 2020 (“CPRA”), the Personal Information Protection Law ("PIPL") of the PRC, or similar legal requirements apply to the processing of your personal data, especially when you are an applicant resident in UK or a country in European Economic Area ("EEA"), Brazil, the PRC or in the state of California or in a jurisdiction with similar legal protections, you have the following rights, subject to some limitations:

• The right to request information about our use of your personal data; (note also the information in this notice);
• The right to review and access your personal data;
• The right to rectify (correct, update or modify) the personal data we hold about you;
• The right to erase (e.g., delete), de-identify, anonymize or block your personal data;
• The right to restrict our use of your personal data;
• The right to object to our use of, or certain types of disclosures of, your personal data;
• The right to request the transfer of your personal data we hold about you to a third party;
• The right to receive your personal data in a usable format and transmit it to a third party (also known as the right of data portability); and
• The right to lodge a complaint with your local data protection authority (e.g. the Information Commissioner’s Office ICO in UK www.ico.org.uk).

To exercise any of these rights please contact [email protected]. We may ask that you provide certain information to verify your identity. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information you have requested. We will respond to your request in accordance with the law. If we deny your request, we will explain why.

Where the GDPR, LGPD, CCPA / CPRA, PIPL or similar legal requirements apply, you also have the right to withdraw any consent you have given to uses of your personal data. If you wish to withdraw consent contact [email protected]. Please note that the withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

When you exercise your privacy rights, such as those conferred by the GDPR, LGPD, CCPA / CPRA or PIPL, you have a right not to receive discriminatory treatment by IMI for the exercise of such privacy rights.

10. Security

IMI will take all steps reasonably necessary to ensure that personal is treated securely and in accordance with this notice and no transfer of personal will take place to an organization or a country unless there are adequate controls in place including the security of personal data.

11. Effective Date and Updates

We may update this Privacy Notice at any time and will include the last updated date and we encourage you to review this Privacy Notice from time to time. Where required by law, we will notify you of changes.

This Privacy Notice was last updated in July 2024.