Company's terms of use
Last updated: October 6, 2018
Introduction
Genius Sports Group is committed to protecting your privacy. This privacy policy explains how Genius Sports Group Limited and the companies in its corporate group (“Genius Sports”, “we”, “us” or “our”) use your personal data (or personally identifiable information) when you apply for an opportunity with us. It also advises you of your rights as a data subject and how those rights may be exercised. We will ensure that any information that we collect or that you submit to us when applying for a role will be used only for the purposes set out in this policy.
We keep our privacy practices under review and may amend this policy from time to time. This version is dated May 2023.
About us
This privacy policy is issued on behalf of the Genius Sports group of companies. When we mention “Genius Sports”, “we”, “us” or “our” in this policy, we are referring to the company in the Genius Sports Group that is relevant for processing your personal data.
Genius Sports Group Limited is the data controller responsible for processing your personal data. It is a company registered with Companies House in England and Wales under company number 09706742 and with the Information Commissioner’s Office under registration number ZA198905.
We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this policy. If you have any questions about this policy, including any requests to exercise your legal rights, then please contact the DPO using the contact details given at the end of this policy.
Personal data we collect
Broadly speaking, your personal data is any information about you from which you may be directly or indirectly identified. In connection with your application for a role with us, we may collect, store and process the following categories of your personal data:
- The information you have provided to us in your CV or resume and covering letter.
- The information you have provided on our application form, including full name, title, gender, email address, telephone number, LinkedIn profile, authorisation to work, travel time to work, salary expectation, availability to work (including notice period), educational background information and professional background information.
- Information relating to equal opportunities, including race or national or ethnic origin and gender (this information may be submitted on a voluntary basis during the recruitment process).
- Communications between you and us in relation to the job application.
- Information relating to interviews, including any information you provide to us during the interview process, our notes taken in interviews and internal records of performance (scorecard feedback).
- Details relating to the role on offer, including salary expectations, availability to start/notice period, distance from work location, authority to work and visa/sponsorship requirements.
- Information obtained through reference checks.
- Information obtained through background checks (please see below for further details).
There are certain types of personal data (referred to as “special category data”) that are afforded a higher level of protection under applicable data protection law because they are more sensitive. Special category data include personal data relating to a person’s racial or ethnic origin, religious or philosophical beliefs, trade union membership, genetics, biometrics, health, sex life or sexual orientation. We may collect the following types of special category data in connection with your application:
- Information about your race or ethnicity.
- Information about your health, including any medical condition or disability, and health and sickness records.
Finally, depending on the role you are applying for, we may also collect information about any criminal convictions and offences, as further explained below.
How we collect your personal information
We may collect your personal data in the following ways:
Directly from you
We may collect personal data directly from you via the careers section of our website if you choose to complete an application form for a role with us or via Hired.com if you choose to respond to a contact request from us (please see Hired.com’s privacy policy here: Privacy – Hired). Alternatively, if we have headhunted you, we may receive personal data directly from you, which will be uploaded manually into our recruitment systems by our Talent Acquisition Team.
Recruitment consultancies
We have relationships with a number of recruitment consultancies who may submit an application and associated personal data to us on your behalf. If you apply for a role with us via a recruitment agency, you will be asked to give your consent to the third party sharing your personal data with us for the purposes of your application. Please contact your recruiter for further information on their privacy terms.
Job boards
We use the following third party job boards from which we receive candidate applications and associated personal data:
- LinkedIn (please see LinkedIn’s privacy policy here: LinkedIn Privacy Policy);
- CV Keskus (please see CV Keskus’ privacy policy here: CV Keskus);
- Meet Frank (please see Meet Frank’s privacy policy here: MeetFrank – Secret Recruitment App);
- Indeed (please see Indeed’s privacy policy here: Indeed Privacy Policy);
- CV.ee (please see CV.ee’s privacy policy here: Terms | CV-Online);
- Total Jobs (please see Total Job’s privacy policy here: Privacy policy | Totaljobs);
- Computrabajo (please see Computrabajo’s privacy policy here: Privacy Policy (computrabajo.com.co));
- Zip Recruiter (please see Zip Recruiter’s privacy policy here: Global Privacy Policy | ZipRecruiter).
- Otta (please see Otta’s privacy policy here: Otta Privacy Policy)
If you apply for a role with us via a job board, you will be asked to give your consent to the third party sharing your personal data with us for the purposes of your application.
Referrals
If you are referred for a role with us by a Genius Sports employee (under our referral scheme), then we may collect personal data about you from your referrer, including your CV or resume, name and contact details.
Background and credit reference checks
We use HireRight Limited to conduct pre-employment background checks. The background checks undertaken will depend on the seniority of the role you are applying for with us and local laws. For all prospective employees, we will undertake an employment verification check and identification check. For executive or senior management positions, or certain positions in the finance team, we may also require a credit reference check and/or criminal record check, but only where it is directly relevant to the role being recruited.
Before any checks are conducted, HireRight will provide you with a full privacy notice and obtain your consent to proceed.
Publicly available sources
We may process and store relevant personal data about candidates from their LinkedIn profile pages.
How we use your personal data
Our use of your personal data
We will only use your personal data where this is permitted by law. We have set out below an explanation of the way in which we use your personal data and which of the lawful bases we rely on to do so (special category data is considered separately below).
| Purpose | Personal data used | Lawful basis for processing |
|---|---|---|
| To assess your skills, qualifications and suitability for the work or role | Contact details, professional/educational background information and details related to the role on offer (including salary expectations, motivation for the role, authorisation to work, distance from work and availability to work) | Necessary for our legitimate interests (to enable us to hire the people we need to develop and grow our business) |
| To communicate with you about the recruitment process and application status, including resolving any complaints or grievances | Name and contact details | Necessary for our legitimate interests (to enable us to hire the people we need to develop and grow our business) |
| To carry out background, credit reference and reference checks, where applicable | Name, contact details, previous employment contact details, passport, driving licence, National Insurance number (or local equivalent if not UK-based), employment and educational history, criminal record information and credit check information | Consent (you may withdraw your consent at any time by emailing HireRight at [email protected] or by contacting us using the details in the “Contact and DPO” section below) |
| To comply with legal or regulatory requirements | Right to work information | Necessary to comply with a legal obligation |
| If you have not been successful in your application for the role, to keep your details on file for any other suitable opportunities with us | Name, referring agency, date of application | Necessary for our legitimate interests (to enable us to hire the people we need to develop and grow our business) |
| In relation to self-declared disabilities, to allow us to make a reasonable adjustment to support your application and any future employment | Nature of disability or other requirement requiring adjustment | Necessary for compliance with a legal obligation |
| In relation to any voluntarily provided equal opportunities information, to monitor our equality and diversity composition | Gender, race, ethnic origin | Consent (you may withdraw your consent at any time by contacting us using the details in the “Contact and DPO” section below) |
| In the event that your application is successful, to generate offer documentation and a contract of employment | Name, contact details, salary | Necessary to take steps at the request of the data subject prior to entering into a contract |
| In the event that your application is successful, to transfer your personal data to our internal Human Resources platform in order to create an employee record and begin onboarding | Name, contact details, CV, offer letter | Necessary for the performance of a contract |
We will only use your personal data for the purpose for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will contact you and explain the legal basis which allows us to do so.
Once we have received your application, we will process the information provided to decide whether you meet the requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to invite you for interview. If you are called for an interview or interviews, then we will use the information you provide to us during the interview process to decide whether to offer you the role or work. Any offer for work will be conditional upon completion of satisfactory reference and background checks.
If you fail to provide information
We will not be able to process your application successfully if you fail to provide us with required information when requested (for example evidence of qualifications or work history).
How we use your special category data
We will use your special category data for the following purposes:
- We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during an interview.
- We will use information about your race or national or ethnic origin, and gender, to ensure meaningful equal opportunity monitoring and reporting.
Information about criminal convictions
Depending on the nature of the role applied for, we may process information about any criminal convictions (but only where it is relevant to the role being recruited). We are entitled to carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role.
If your application is successful
If you are successful in your application for a role with us, your personal data will be transferred to the internal systems we use for collecting, storing and processing the data of our employees and contingent workers. You will be provided with separate information on how your data is processed as an employee or contingent worker.
Cross-border transfers
Regardless of where in the world you are based, we share your personal data with the Genius Sports Group. This will involve transferring your personal data outside of your country, including in particular to locations in which we have offices, namely Australia, Bulgaria, Colombia, Estonia, Latvia, Lithuania, Switzerland, the UK and the US.
This means that your personal data will be shared outside of the UK and European Economic Area (“EEA”), where the standard of protection of personal data may be lower than it is in the UK and EEA.
In addition, many of our third party suppliers (please see the “How we Share Your Personal Information” section above) are based outside of the UK and EEA, or have subsidiaries or processors based outside of the UK and EEA, so their processing of your personal data will also involve a transfer outside of the UK or EEA or your originating country.
Whenever we transfer your personal data outside of the UK or EEA, we ensure that a similar degree of protection is afforded to your data as in the UK or EEA by implementing one of the following safeguards:
- We will only transfer your personal data to countries that have been deemed by the UK or EEA to provide an adequate level of protection for personal data; or
- We will use standard contractual clauses that have been approved for use in the UK or EEA (as appropriate), together with any supplementary measures required.
Where we use standard contractual clauses and supplementary measures as the relevant safeguard, we will also conduct a transfer impact assessment to ensure adequate protection of your personal data.
Please contact us using the details in the “Contact and DPO” section below if you would like further information on the specific mechanism used when transferring your personal data out of the UK or EEA.
Data security
We respect your personal data and have put in place appropriate technical and organisational security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way or altered or disclosed. In addition, we restrict access to your personal data to those employees, agents and contractors who have a business need to know. They will only process your personal data on our instructions and are subject to a duty of confidentiality.
Retention of your information
We will retain your personal information only for the time necessary to fulfil the purposes for which it was collected or as required by any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe that there is a prospect of litigation in respect of our relationship with you.
We will store the following categories of your personal information for the time periods indicated:
| Category of personal data | Storage time period |
|---|---|
| Candidate contact details, application details and profile, including all information provided by or on behalf of a candidate in connection with their application, interview notes and records of performance and internal decision-making | If candidate is successful, seven years after the date on which employment ceases. If candidate is unsuccessful, one year after the date on which candidate is advised that their application will not be progressed unless it is considered that it would be worthwhile retaining the candidate details for potential future opportunities beyond that period, in which case the candidate will be asked if they consent to a further retention period. |
| Candidate name, referring recruitment agency and date of application | One year after candidate has been accepted or rejected. |
| Background check information | Six months after background checks have been completed for all background checks except criminal record checks. For criminal record checks, any information relating to criminal conviction history is deleted immediately after receipt, save that a record is retained as to whether or not the check yielded a positive or negative result. |
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data, including the rights to:
- request access to your personal data;
- request rectification of any mistakes in your personal data;
- request erasure of your personal data;
- object to our processing of your personal data;
- request restriction of processing of your personal data;
- request transfer of your personal data (data portability);
- withdraw your consent to our use of your personal data (only where we rely on consent as the lawful basis for processing).
We may need to ask for information from you to help us confirm your identity and ensure your right to exercise your data privacy rights before we are able to act on your request. We reserve the right to refuse to comply with a request if it is unfounded, repetitive or excessive. Otherwise, we aim to respond to all complete and legitimate requests within one month. Occasionally, it could take us longer to respond if we require further information from you, the subject matter is particularly complex, or you have made a number of requests. In this case, we will notify you and keep you updated.
Further information on each of your legal rights and how to exercise them is set out below. It should be noted that the rights are not absolute but are subject to certain limitations and exceptions. We will provide reasons if we are unable to comply with any request for the exercise of your rights.
- Right of access: You have the right to ask us for a copy of the personal data we hold about you at any time.
- Right of rectification: If the personal data we hold about you is not accurate or is incomplete, you have the right to have the data rectified, updated or completed.
- Right of erasure: In certain circumstances, you have the right to request that personal information we hold about you is erased – for example, if the information is no longer necessary for the purposes for which it was collected or processed, or if our processing of the information was based on your consent and there is no other legal basis on which we may process the information.
- Right to object: In certain circumstances, you have the right to object to our processing of your personal data – for example, you may object to the use of your personal data for direct marketing purposes or you may object to processing based on our legitimate interests, unless there are compelling legitimate grounds for our continued processing.
- Right to restrict processing: In certain circumstances, you have the right to restrict our use of your personal information – for example, where you have challenged the accuracy of the information during the period where we are verifying its accuracy.
- Right to data portability: In certain circumstances, you have the right to receive the personal data that we hold about you in a structured, commonly used and machine-readable format. This right only applies in relation to personal data that you have provided to us and which is processed by us using automated means. Where the right applies, you may ask us to send the data directly to you or to a third party. However, we are not able to guarantee technical compatibility of the data we provide with a third party’s systems.
Complaints
If you are unhappy about our use of your personal information, you may contact us using the details in the “Contact and DPO” section below. We will investigate your complaint and notify you in writing of the outcome as soon as possible and in any event within 30 days of receiving the complaint.
If you are unsatisfied with our response to your complaint, you may refer your concerns to the relevant supervisory authority in your country. In the United Kingdom, we are regulated by the Information Commissioner’s Office (“ICO”). You may make a complaint to the ICO using any of the following contact methods:
Telephone:
+44 (0) 303 123 1113
Website:
https://ico.org.uk/make-a-complaint/
Post:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Contact and DPO
If you have any enquiries or if you would like to contact us about our processing of your personal information, including to exercise your rights as outlined above, please contact our DPO, Maria Hernandes, by one of the methods listed below. When you contact us, we will ask you to verify your identity.
Telephone:
+44 (0) 20 7851 4060
Email:
[email protected]
Post:
Data Protection Officer
9th Floor, 10 Bloomsbury Way
Holborn
London
England WC1A 2SL
