Candidate privacy notice

We take privacy seriously. This notice tells you who we are, what information about you we collect, and what we do with it. We will use information about you only in accordance with applicable data protection laws. For anything not contemplated by this notice, we may issue a supplemental notice. You should read any supplemental notice in conjunction with this notice. In the section introduced as “What rights and options do you have?”, you can also find information about your rights.
 

Who are we?

This candidate privacy notice is issued by the Vectura Fertin Pharma group of companies, which is made up of a number of companies or “affiliates” as set out at the end of this notice. “We” (or “us” or “our”) refers to Vectura Fertin Pharma Inc. and its affiliates. When you set up a candidate profile or apply for a job, you provide information about yourself to each affiliate, and each affiliate may process information about you for its own recruitment purposes. This is the case even where you respond to a job posting that mentions a particular affiliate or country/territory.
 

How do we collect information about you?

We may collect information about you in various ways:
 

• You may provide us with information directly (e.g. when creating an account, creating a candidate profile, applying for a job, attending an interview, completing a test/assessment, sending an e-mail, or making a call to us).
• We may collect information automatically when you interact with our systems or we communicate with you (e.g. when you use a company app or website or, where we use technologies to observe when you receive or open e-mails or receive SMS messages).
• We may also acquire information from third parties (e.g. from recruitment agencies, reference providers, (where permitted by law) background screening providers and publicly-available sources, such as a company website, internet searches or social media platforms such as LinkedIn).

In this notice, we refer to all the methods by which you are in contact with us as “touchpoints”. Touchpoints include both physical (for example, offices, careers fairs and events) and digital (for example, apps and websites). We may also collect information in other contexts made apparent to you at the time.
 

What information about you do we collect or create?

We may collect various types of information about you:
 

• information necessary to manage and administer our relationship with you (including, where we agree, to reimburse certain expenses to attend interview) and to run our business, including to meet our legal and regulatory obligations (e.g. verifying your identity, your right to work, application details and, where permitted by law, your suitability for a job using background checks)
• information you give us in your candidate profile, job application, forms or surveys
• information necessary to assess your eligibility for a role, shortlist and select candidates
• information about your visits to our offices and attendance at events
• where applicable, information necessary to offer you a job and on-board you (such as issuing an offer, drafting an employment contract, providing benefits information and arranging access to systems) •
• information gathered as part of our monitoring and continuous improvement of the recruitment process
• information you give us in calls you make to us or e-mails you send to us
• information about your preferences, interests and career aspirations (including information that we infer from other information, for example from statistical information)
• information gathered as part of business analytics and improvements
• details of your use of digital touchpoints
• statistical information about you (for example, statistical information about people in certain geographical areas)

Information we collect and process about you may include your:
 

• name
• password
• address including home and correspondence
• contact details including personal e-mail address and home/personal mobile phone number where these details are provided as part of your application
• sex
• cover letter
• nationality
• resume/job application, including personal and professional information
• how you heard about the job
• geographical mobility and sponsorship
• eligibility to work, including passport or other official identification document
• references
• qualification transcripts and certificates
• education and employment history
• information about military service
• jobs applied for
• current, expected and offered employment terms and conditions (e.g. pay, hours of work, holidays, benefits)
• interview notes and assessment results
• application outcome and reason
• reason for withdrawing your job submission (where applicable)
• social insurance and personal income tax data
• tax code
• date of birth
• family status and situation
• bank account information (if we agree to reimburse you certain expenses to attend interview, or if you are offered a job and accept it)
• photographs and video recordings
• system user information
• automated records of your use of company information systems
• information submitted to us when using information systems that the company operates
• information about your visits to our offices and events

We may also collect and process special categories of information about you such as your:
 

• racial or ethnic origin (e.g. for equal opportunities monitoring)
• political opinions (only if you voluntarily share this information)
• religious or philosophical beliefs (e.g. for reasonable accommodation)
• sexual orientation (e.g. for equal opportunities monitoring or if you voluntarily share this information)
• trade union membership (only if you voluntarily share this information)
• data concerning your health, including any disability (e.g. for reasonable accommodation)

We will process these types of data if you voluntarily share them with us, if we have a legal obligation to process the information and, in relation the recruitment process, to provide reasonable accommodation.
 

For what purposes do we use information about you, and on what legal basis?

In this section, we describe the purposes for which we use personal information. However, this is a global notice, and where the laws of a country restrict or prohibit certain activities described in this notice, we will not use information about you for those purposes in that country.

Subject to the above, we use information about you for the following purposes:
 

• perform checks on identity, role eligibility and right to work
• verify employment history, qualifications, experience and references
• where permitted by law, perform candidate vetting and background screening
• perform recruitment and selection, including interviews, assessments, and psychometric profiling, shortlisting, job offer and benefits (where applicable)
• business administration, including record keeping obligations
• where applicable, administration of reimbursement of expenses to attend interview
• where applicable, pre-employment administration and management, including preparation of contractual and non-contractual documents, and arranging systems and building access
• monitoring of the recruitment process
• for business analytics and improvements, including for our recruitment process, events, digital touchpoints, company systems and devices and the information that we (or our affiliates) provide to job candidates

The legal basis for our use of information about you is one of the following (which we explain in more detail in the table below):
 

• compliance with a legal obligation to which we are subject
• to take steps at your request prior to entering into a contract
• a legitimate business interest that is not overridden by interests you have to protect the information
• where none of the above applies, or where law requires it, your consent (which we will ask for before we process the information)

The purposes for which we use information about you and legal basis for use are:

Comply with regulatory obligations

identity and right to work checks
assessing the demographic makeup of our workforce, such as equal opportunities monitoring

Method of collection and legal basis for processing
We use it because it is necessary for us to comply with a legal obligation to employ only people with a right to work in the country where the job is located and to monitor the demographics of our workforce, or, in countries where there is no such legal obligation, because we have a legitimate business interest to run our business in accordance with good practice requirements that is not overridden by your interests, rights and freedoms to protect information about you.

Application verification and candidate vetting (where permitted by law)
 

• verifying employment history, qualifications, experience and references
• where permitted by law, candidate vetting and background screening

Method of collection and legal basis for processing
We use it because it is necessary for us to comply with a legal obligation to employ only eligible and suitable people, or, in countries where there is no such legal obligation, we use it because we have a legitimate business interest in ensuring your suitability and eligibility for a role with us that is not overridden by your interests, rights and freedoms to restrict use of information about you.

Recruitment and selection
 

• candidate recruitment and selection, including interviews, recorded videos, assessments, psychometric testing
• review of application forms and online assessment tools and skills tests
• shortlisting
• where applicable, administering reimbursement of certain expenses to attend interview
• where applicable, making an offer and agreeing benefits • group, panel and individual interviews
• informing you of the outcome of applications and of other opportunities that may be of interest, advertising positions, and monitoring interest
• record keeping

Method of collection and legal basis for processing
We use it because we have a legitimate business interest in recruiting and selecting candidates for roles with us (including carrying out interviews and assessments), administering the process, and keeping records of the recruitment process, that is not overridden by your interests, rights and freedoms to restrict use of information about you.

Pre-employment workforce management
 

• hiring activities such as preparing, issuing and signing employment contract
• establishing electronic personal record and personal files
• creating payroll records
• enrolling new employee benefits
• reporting employment commencement to legal authorities

Method of collection and legal basis for processing
We use it because we have a legitimate business interest in preparing necessary employment documents and completing necessary internal records not overridden by your interests, rights and freedoms to restrict use of information about you. In the case of reporting to legal authorities we do so because it is necessary for us to comply with legal obligations.

Monitoring of the recruitment process
 

• quality control and checks to monitor compliance with our recruitment process

Method of collection and legal basis for processing
We use it because we have a legitimate business interest in checking compliance with our recruitment process that is not overridden by your interests, rights and freedoms to restrict use of information about you.

Support for all the above purposes
 

• administering your accounts
• enabling you to use touchpoints (for example, allowing you to remain logged in to sections of a touchpoint that are reserved for authorized users only, and administering your language preference)
• corresponding with you
• managing your appointments with us (for example, regarding an interview or assessment)
• enhancing your experiences
• administration and troubleshooting

Method of collection and legal basis for processing
We use it on the grounds that correspond to the purpose for using the information that we are supporting. For example, where we administer your account to support a job search or application, we use the information on the grounds that we have a legitimate business interest to run our business and recruit staff that is not overridden by your interests, rights and freedoms to protect information about you.

Business analytics and improvements
 

• assessing the effectiveness of our recruitment process
• business analytics and improvements (including for our recruitment process, events, digital touchpoints and the information that we (or our affiliates) provide to job candidates)

Method of collection and legal basis for processing
We use it on the grounds that we have a legitimate business interest to analyse, assess the effectiveness of and improve our recruitment efforts, processes, touchpoints, and events that is not overridden by interests, rights and freedoms to protect information about you.

Where we do not base our use of information about you on one of the above legal bases, or where law requires it, we will ask for your consent before we process the information (these cases will be clear from the context). We may ask for your explicit consent to process special categories of information about you. In some instances, we may use information about you in ways that are not described above. Where this is the case, we will provide a supplemental privacy notice that explains such use. You should read any supplemental notice in conjunction with this notice.
 

Do we make any automated decisions?

We may make automated decisions on any of the matters set out in this notice (for example, screening and whom to include on a shortlist for interview). If we do this, we will draw this to your attention at the time, together with information about the logic involved in the decision, as well as the significance and the envisaged consequences for you of such use of information about you.
 

Who do we share your information with, and for what purposes?

We may share information about you with:
 

• Companies in the Vectura Fertin Pharma group of companies; its owner, Philip Morris International and its affiliates;
• third parties who provide the company or you with products or services (such as recruitment agencies, background screening, online assessment providers and vendors that support the company’s endeavours to improve the candidate experience); and
• other third parties, where required or permitted by law (such as regulatory authorities; government departments; past, potential or future employers; and in the context of organisational restructuring).

We share information about you with others only in accordance with applicable laws. Thus, where law requires your consent, we will first ask for it.
 

Where might information about you be sent?

When using information as described in this notice, information about you may be transferred either within or outside the country or territory where it was collected, including to a country or territory that may not have equivalent data protection standards. For example, if you are in the European Economic Area (“EEA”), your information may be transferred outside the EEA.

Wherever we transfer personal data to other countries, we will take legally required steps to ensure that appropriate safeguards are in place to protect it. You may contact us for an explanation of the basis on which we have transferred your personal data and, where relevant, to request a copy of the legal safeguards we have put in place.
 

How do we protect information about you?

We implement appropriate technical and organisational measures to protect personal information that we hold from unauthorised disclosure, use, alteration or destruction. Where appropriate, we use encryption and other technologies that can assist in securing the information you provide. We also require our service providers to comply with equivalent data privacy and security requirements.
 

How long will information about you be kept?

We will retain information about you for the period necessary to fulfil the purposes for which the information was collected in accordance with our internal data retention standards. After that, we will delete it. The period will vary depending on the purposes for which the information was collected. Typically, recruitment information about you is kept for up to 12 months after the date of our last interaction. Note that in some circumstances, you have the right to request us to delete the information. Also, we are sometimes legally obliged to retain the information, for example, for tax and accounting purposes, to either retain the information for a set minimum period of time, or to delete it after a set maximum period of time.
 

What rights and options do you have?

You may have some or all of the following rights in respect of information about you that we hold:
 

• request us to give you access to it;
• request us to rectify it, update it, or erase it;
• request us to restrict our using it, in certain circumstances;
• object to our using it, in certain circumstances;
• withdraw your consent to our using it;
• data portability, in certain circumstances; and
• lodge a complaint with the supervisory authority in your country (if there is one).

We offer you easy ways to exercise these rights, such as “unsubscribe” links or by using the contacts in the paragraph “who should you contact with questions?” at the end of this notice.
 

Who should you contact with questions?

If you have any questions, or wish to exercise any of your rights, you can contact us:
 

• at privacy@vectura.com for Vectura affiliates;
• at privacy@fertin.com contact for Fertin affiliates;
• at privacy@vectura.com for Vectura Fertin Pharma affiliates.

If your country has a data protection authority, you have a right to contact it with any questions or concerns. If the company cannot resolve your questions or concerns, you also have the right to seek judicial remedy before a national court.
 

Vectura Fertin Pharma Inc. affiliates

US
Vectura Inc. 677 Washington Blvd, Suite 1100, Stamford, CT 06901

Singapore
Vectura Fertin Pharma Laboratories 50 Science Park Road, The Kendall, Science Park 2 #02-07, Singapore 117406

UK
Vectura Group Ltd Manning House, 22 Carlisle Place, Westminster, London, SW1P 1JA
Vectura Ltd One, Prospect West, Chippenham, Wiltshire, SN14 6FH
Vectura Delivery Device Ltd 205 Cambridge Science Park, Milton Road, Cambridge, CB4 0GZ

Ireland
Vectura Ireland Ltd Block 2, Newtown mount Kennedy Business Park, Newtownmountkennedy, Wicklow, A63 XV26

Switzerland
Vectura Fertin Pharma CH, the trading name of Jagotec AG Messeplatz 10, 4058 Basel

Denmark
Fertin Pharma A/S Dandyvej 19, 7100 Vejle

India
Fertin Pharma R&D India Private Ltd Plot No B-22, Ground Floor, TTC Industrial Area, Rabale MIDC, Navi Mumbai 400 708
Fertin India Private Ltd Plot No. L-10 & L-11, Cuncolim Industrial Estate, Goa 403 703
Vectura Fertin Pharma Private India Plot No. L-10 & L-11, Cuncolim Industrial Estate, Goa 403 703

Canada
Tab Labs Inc. 19720 94a Ave D107, Langley City, BC V1M 3B7
Cogent International Manufacturing Ltd 400-725 Granville Street, PO Box 10325, Vancouver BC V7Y 1G5
 

Changes to this notice

We may update this notice (and any supplemental privacy notice), from time to time. Where the law requires it, we will notify you of the changes; further, where the law requires it, we will also obtain your consent to the changes.

Last modified 8th June 2023.