Unum Ireland Applicant Privacy Notice

1. PURPOSE AND SCOPE OF NOTICE

As part of our recruitment process Unum Ireland Limited (“Unum”) (the "Company", "we" "us" “our”) collects and processes personal data relating to job applicants and prospects.

Notice”) is intended to explain how your Personal Data will be handled by the Company and sets out the information including the personal information detailed below relating to you ("Personal Data") that will be collected and processed by the Company and/or on its behalf by its third party service providers in the context of your seeking of employment opportunities. Unum Ireland Limited is a subsidiary of Unum Group, which also may receive and process Personal Data about you as explained below.

For the purposes of this Notice, the controller of your Personal Data is Unum Ireland Limited.

This Notice applies to all applicants and prospects who join our Talent Community or take part in other recruitment initiatives coordinated by Unum (each of whom is referred to as an "applicant"). If you commence employment with us, the way we process your Personal Data will no longer be dealt with under this Notice (and will instead be dealt with under our Employee Data Protection Notice).

If you have any questions, comments, or concerns about the way your Personal Data are being used or processed by us, please contact IrelandPrivacy@Unum.com.

2. PERSONAL DATA WE COLLECT FROM YOU

IMPORTANT: Please note that the below list of Personal Data we may collect about you, while intended to be as complete and accurate as reasonably possible, is not exhaustive and may be updated from time to time in accordance with section 9 of this Notice.

We may collect and process some or all the following Personal Data about you as part of our recruitment process:

Category of Personal Data	Details
Talent Data	Name (including First Name, Middle Name, Last Name)s Title Contact details, including phone number, email address and address Eligibility to work in Ireland Education history Employment history Professional qualifications Referee contact details Curriculum Vitae

3. SOURCES OF YOUR PERSONAL DATA

During the course of your relationship with us as an applicant, we will collect Personal Data:

From you: for example, through your candidate profile in our Talent Community, an application or information you provide directly to us; or
From third party sources about you: including information from recruitment agencies, job sites where we searched for candidates for your potential role, professional networking sites, employment references from your referees and previous employers, and referral information from current employees.

4. HOW AND WHY WE PROCESS YOUR PERSONAL DATA

We need to process your data to assess your suitability for employment with us and prior to entering into a contract of employment with you. The following table outlines the legal grounds and further explains for what purposes we may process your Personal Data:

Category of Personal Data	Legal Basis	Nature of Processing and Purposes
Talent data	Compliance with Legal Obligations It is necessary for us to collect and process your Personal Data in order to comply with the legal obligations imposed on us under applicable law (as implemented or amended from time to time), including in the field of employment, social security and social protection law. For example, it is mandatory to ensure all employees of the company are eligible to work in the Republic of Ireland.	We will collect, use, store and otherwise process your Personal Data for the following purposes: To perform background checks on entitlement to work/reside in Ireland. To comply with employment, equality and health and safety law. To comply with applicable tax laws. To comply with other applicable laws to which we may be subject, and to assist the courts in acting in their judicial capacity where required.
Talent data	Legitimate Interests Depending on our business needs, it is necessary to process your Personal Data where we have legitimate business interests to do so. IMPORTANT: Before we process your Personal Data to pursue our legitimate interests for the above purposes, we determine if such processing is necessary, and we carefully consider the impact of our processing activities on your fundamental rights and freedoms. On balance, we have determined that such processing is necessary for our legitimate interests and that the processing which we conduct does not adversely impact on these rights and freedoms. You have certain rights when we process your Personal Data for this Legal Basis, such as the right to object.	We will collect, use, store and otherwise process your Personal Data for the following purposes: To assess your Personal Data against roles which we think may be suitable for you. To verify details you have provided to us using third party sources. To request information from third parties, such as professional qualifications and employment references. To enable us to assess and confirm your suitability for employment with us, to contact you in relation to job interviews and/or to provide you with a job offer. To contact you about potential roles that may be of interest to you. To collect feedback on our recruitment process. To promote our recruitment events.
Talent data	To Defend Legal Claims It is necessary for us to collect and process your Personal Data to investigate, establish, exercise or defend legal claims.	We will collect, use, store and otherwise process your Personal Data for the following purposes: To file legal proceedings. To investigate, establish, exercise or defend a legal claim. To settle legal claims.

Category of Personal Data

Legal Basis

Nature of Processing and Purposes

Talent data

Compliance with Legal Obligations

It is necessary for us to collect and process your Personal Data in order to comply with the legal obligations imposed on us under applicable law (as implemented or amended from time to time), including in the field of employment, social security and social protection law.

For example, it is mandatory to ensure all employees of the company are eligible to work in the Republic of Ireland.

We will collect, use, store and otherwise process your Personal Data for the following purposes:

To perform background checks on entitlement to work/reside in Ireland.
To comply with employment, equality and health and safety law.
To comply with applicable tax laws.
To comply with other applicable laws to which we may be subject, and to assist the courts in acting in their judicial capacity where required.

Talent data

Legitimate Interests

Depending on our business needs, it is necessary to process your Personal Data where we have legitimate business interests to do so.

IMPORTANT: Before we process your Personal Data to pursue our legitimate interests for the above purposes, we determine if such processing is necessary, and we carefully consider the impact of our processing activities on your fundamental rights and freedoms. On balance, we have determined that such processing is necessary for our legitimate interests and that the processing which we conduct does not adversely impact on these rights and freedoms.

You have certain rights when we process your Personal Data for this Legal Basis, such as the right to object.

We will collect, use, store and otherwise process your Personal Data for the following purposes:

To assess your Personal Data against roles which we think may be suitable for you.
To verify details you have provided to us using third party sources.
To request information from third parties, such as professional qualifications and employment references.
To enable us to assess and confirm your suitability for employment with us, to contact you in relation to job interviews and/or to provide you with a job offer.
To contact you about potential roles that may be of interest to you.
To collect feedback on our recruitment process.
To promote our recruitment events.

Talent data

To Defend Legal Claims

It is necessary for us to collect and process your Personal Data to investigate, establish, exercise or defend legal claims.

We will collect, use, store and otherwise process your Personal Data for the following purposes:

To file legal proceedings.
To investigate, establish, exercise or defend a legal claim.
To settle legal claims.

5. DISCLOSURE OF YOUR PERSONAL DATA

We may disclose some or all of your Personal Data to the following third parties ("Recipients"):

Recipient Category	Details
The Company	Other entities within the Unum Group. Internal business units such as Human Resources, IT, Legal, managers, system administrators and support staff.
Third Party Service Providers	Outsourced service providers who assist us with our recruitment initiatives, such as our Talent Community. Recruitment Agencies. Service providers who otherwise provide support services or require your Personal Data to perform the services requested by us.
Legal/Regulatory Bodies	Regulatory authorities and law enforcement agencies (where we are under a duty to disclose or share your Personal Data in order to comply with any legal or regulatory obligation or request) such as the Revenue Commissioners, Department of Social Protection, the Data Protection Commission, the Irish courts, An Garda Síochána or other body.
Third Party Advisors / Professionals	External advisors e.g. lawyers, accountants and auditors (as necessary to protect our legitimate and legal interests).
Your References	Your previous employers and other individuals where you have provided them as referees.

6. TRANSFER OF YOUR PERSONAL DATA

We may transfer your Personal Data outside the European Economic Area ("EEA") to members of the Unum Group and other Recipients. Certain Recipients who process your Personal Data on our behalf may also transfer your Personal Data outside the EEA. In either case, these transfers may be to a country that does not offer the same level of protection that is required by EU data protection law. Where such transfers occur, it is our policy that: a) they do not occur without our prior written authority; and b) that each transfer is subject to appropriate safeguards that are contractual, technical and/ or organisational in nature, and/or an appropriate transfer mechanism, including: (i) when that country is deemed adequate by the European Commission; (ii) Module 1 (controller-to-controller) or Module 2 (controller-to-processor) of the European Commission's standard contractual clauses ("EU SCCs") (a copy of which are available here); or (iii) other transfer mechanisms (e.g. binding corporate rules, EU-US data privacy framework or derogations under Article 49 of the GDPR).

Where we transfer data to Unum Group, we do so on the basis of the EU SCCs. If you would like to find out more about any such transfers, please contact our Data Protection Liaison whose details are set out in Section 9 of this Notice.

7. RETENTION OF YOUR PERSONAL DATA BY UNUM

If you are an applicant that has joined our Talent Community, we will retain your Personal Data for two years. At the end of the two-year period your Personal Data will be purged.

If your application for employment is unsuccessful, we will retain your Personal Data for two years. At the end of the two-year period your data will be purged.

If your application for employment is successful, Personal Data gathered during the recruitment process will be transferred to your Human Resources file (electronic and paper based) and retained during your employment. As noted above, if you commence employment with us, the way we process your Personal Data will no longer be dealt with under this notice and will instead be dealt with under our Employee Data Protection Notice.

Please note that in certain circumstances, we may hold your Personal Data for a longer period, for example, if we are processing an ongoing claim or believe in good faith that the law or a relevant regulator may reasonably in our view expect or require us to preserve your Personal Data.

8. YOUR RIGHTS REGARDING YOUR PERSONAL DATA AND HOW TO EXERCISE THEM

The table below sets out the rights which you have to address any concerns or queries with us about our processing of your Personal Data. Please be aware that these rights are not absolute.

Right	Further Information
Right of Access	You have the right to request a copy of the Personal Data held by us about you and to access the following information in relation to the processing of your Personal Data: the purposes of processing; the categories of Personal Data concerned; the recipients of your Personal Data; the period for which your Personal Data will be stored; the existence of your right to lodge a complaint with the Data Protection Commissioner; and the source of your Personal Data. Where you exercise your right of access, we may request proof of identity to ensure we are dealing with the correct person where we consider it necessary to do so. We will only charge you for making such an access request where we feel your request is unjustified or excessive.
Right to Rectification	You have the right to request that we amend any inaccurate Personal Data that we have about you.
Right to Erasure	You have the right to ask us to erase your Personal Data where it is no longer necessary for processing where: your Personal Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed by us; you withdraw your consent and no other legal ground permits us to process your Personal Data; you object to the processing and there are no overriding legitimate grounds for the processing; your Personal Data have been unlawfully processed; or your Personal Data must be erased in order to comply with a legal obligation. We may not be able to comply with a request where we require your Personal Data for compliance with a legal obligation or in connection with legal proceedings or for exercising the right of freedom of expression and information. Please note that erasure may not be complete or immediate to the extent that some of your Personal Data is necessary for the performance of your contract of employment with us.
Right to Restriction of Processing	You have the right to ask us to restrict processing your Personal Data in the following situations: where you contest the accuracy of your Personal Data; where the processing is unlawful, and you do not want us to delete your Personal Data; where we no longer need your Personal Data for the purposes of processing, but you require the data in relation to a legal claim; or where you have objected to us processing your Personal Data pending verification as to whether our legitimate interests override your interests or in connection with legal proceedings. When you exercise this right, we may only store your Personal Data and may not further process the data unless you consent, or the processing is necessary in relation to a legal claim or to protect the rights of another person or legal person or for reasons of important public interest.
Right to Object	You have a right to object at any time to the processing of your Personal Data where we process your Personal Data on the legal basis of pursuing our legitimate interests.

9. CHANGES TO AND QUESTIONS REGARDING THIS NOTICE

We may amend this Notice on occasion, in whole or part, at our sole discretion. Any changes will be effective immediately upon communicating the revised Notice to you.

If you have any concerns about the way your Personal Data are being used or processed by the Company or you are not satisfied, please contact our Data Protection Liaison by email at IrelandPrivacy@Unum.com.

If after this, you are not satisfied by the effort and response by the Company, you have the right to lodge a complaint with the Data Protection Commission of Ireland. Please see www.dataprotection.ie for further information.