1 Our Privacy Promise

We aim to create a culture where everyone at Vodafone has a clear understanding of how important privacy is to our employees and how to ensure it is respected. Our Privacy Promise sets out the principles that govern our approach to privacy and how we communicate with employees, partners and other stakeholders on relevant issues – such as designing products to protect privacy or assisting with law enforcement.

Vodafone’s privacy principles are:

How we operate

• Accountability: we are accountable for living up to these principles throughout our corporate family, including when working with our partners and suppliers. We have in place accountable privacy compliance measures and we monitor and enforce our compliance with these principles;
• Fairness and lawfulness: we comply with privacy laws and act with integrity and fairness. We will work with governments, regulators, policy makers and opinion formers for better and more meaningful privacy laws and standards;
• Openness and Honesty: we communicate clearly about actions we take that may impact privacy, we ensure our actions reflect our words, and we are open to feedback about our actions;
• Choice and access: we give people the ability to make simple and meaningful choices about their privacy and allow individuals, where appropriate, to access, update or delete their personal information.

How we manage and protect information

• Responsible Data Management and limited disclosures: we apply appropriate data management practices to govern the processing of personal information. We choose the partners who participate in processing of personal information carefully and we limit disclosures of personal information to such partners to what is described in our privacy statement or to what has been authorized by our  employees;
• Security safeguards: we implement appropriate technical and organisational measures to protect personal information against unauthorized access, use, modification or loss.

How we design our products and services

• Privacy by Design: respect for privacy is a key component in the design, development and delivery of our products and services

How we make decisions

• Balance: when we are required to balance the right to privacy against other obligations necessary to a free and secure society, we work to minimize privacy impacts

2 Who we are

Vodafone New Zealand Limited is the controller of your personal information. We are a Partner Market member of the Vodafone Group and manage HR operations, including the processing of personal information about the employees and applicants to the Vodafone New Zealand to which you are applying.

Our registered office is 74 Taharoto Road, Takapuna, Auckland 0622. We are registered in New Zealand under company number 927212. We provide details of how to contract us in the How to contact us section of this privacy statement.

3 Definitions

In this privacy statement:

• “personal information” is information about an identifiable employee;
• “third party” means someone who is not you or us or a part of Vodafone Group; and
• “Vodafone Group” means Vodafone Group Plc and any company or other organisation in which Vodafone Group Plc owns 50% or above of the share capital; and
• “we/us” means Vodafone New Zealand Limited.

4 The Basics

4.1 Personal information we collect about you

4.1.1 Vodafone will process your personal information based on:

1. Vodafone’s legitimate business interest, when you apply for a role at Vodafone you provide us with your personal information so that we can use this information to assess your application, progress your application through the recruitment process, make a decision about your suitability for the role and contact you throughout the recruitment and on boarding process;
2. Consent you provide, we may ask you to provide information voluntarily, including for example your age group and gender. You can withdraw your consent at any time by editing your candidate profile;
3. Necessary for entry into, or the performance of a contract, we may ask you to provide personal information that is required to enter into an employment contract with us; and
4. Compliance with the law, where certain information is necessary to satisfy a legal or regulatory requirement.

4.1.2 How we collect personal information about you

We collect personal information about you when you register a general interest in careers at Vodafone or when you apply for a specific role at Vodafone. Some of the information we collect about you is required to make an assessment on your application to Vodafone and contact you about your progress through the recruitment process, for example your telephone number, email address, CV. If you do not provide this information then we will be unable to assess your application or contact you to invite you to interview, or make you an offer, if you are successful in the process. We may collect information about you from recruitment agencies or from the public internet where you have made this information publicly available, for example, we may find your profile on LinkedIn and contact you about suitable roles.

4.1.3 The types of information we may collect about you are, for example:

1. Personal details, such as name, personal email address, current address, telephone number;
2. Recruitment information, such as application form , CV, résumés, interview notes of successful candidates, interview notes of unsuccessful candida tes, video interviews, references from previous employer, psychometric test results;
3. Diversity information, such as your age group, gender or nationality;
4. Internal candidate information, such as references given by Vodafone, interview notes, internal transfer or promotion, succession planning documents
5. Identification information, such as proof of identity;
6. Authentication information, user name and password for the recruitment portal;
7. Cookies, such as recruitment portal performance and functionality cookies;

We may also process sensitive personal information about you – but only where this is strictly necessary to assess your suitability for the role you have applied for or where we have a legal obligation. For example,

1. We may collect records of criminal convictions or right to work in the country you are applying to in order to perform security background checks where it is required by local law;
2. We may collect information such as your ethnicity, race, but only where it is required by law or we have collected your explicit consent to process this information

4.2 How we use information about you

The purposes for which we may process the personal information that we collect about you are likely to include (but not be limited to) the following purposes:

• Recruiting people into jobs, to assess and progress your job application and to make any verifications required by law;
• Resourcing for jobs, if you register a general interest in pursuing a career with Vodafone, the information that you provide will be retained by us and searched by people who are employed by Vodafone to help us fill future vacancies. If you apply for a specific vacancy and you are unsuccessful, the information you provide to us will be retained so that we can consider you for future suitable vacancies – but only where we have collected your consent to do so;
• Creating an employee record, if your job application is successful, the information you give during the application process will form part of your employee record and will be used to administer your employment and manage your career at Vodafone;
• Contacting you about other roles, where we have collected your consent to do so;
• Analytics, we may use some of the personal information you provide for various reporting purposes including, for example, to report on our diversity targets or the type of candidates and volumes of applications made to Vodafone and related trends – you will not be personally identified from these reports;
• Screening, in certain circumstances we will make an automatic decision on the suitability of your application based on certain criteria. For example, graduates must be proficient in English and have completed a university degree to be considered for a role at Vodafone.
• Cookies, we use cookies to understand how you use our recruitment website and how we can improve the customer experience.

4.3 Who we share information about you with

We may share personal information about you with:

Except where certain exceptions under the Privacy Act 1993 apply, the intended recipients of your personal information will be only those people who have a need to see the information in light of the purpose for which it was collected. This may include people employed or engaged by Vodafone New Zealand Limited or Vodafone Group or third parties, including outside New Zealand. This means that we may share personal information about you with:

• Other companies in the Vodafone Group, which will process your personal information solely and only, for the purposes in section 4.1.4;
• Third parties, such as recruitment agencies, test providers and others who help us fill vacancies and assess the suitability of candidates and progress applications. Where we use third parties, Vodafone ensures that there is a written agreement and that they meet the same privacy and security standards as Vodafone;
• Law enforcement agencies, government bodies, regulatory organisations, courts or other public authorities if we have to, or are authorised to by law;
• A third party or body where such disclosure is required to satisfy any applicable law, or other legal or regulatory requirement.

4.4 Where we process information about you

In doing the above, we may need to transfer personal information about you to other companies in the Vodafone Group or third parties located (or whose servers may be located) in countries outside New Zealand.

4.5 How long we keep information about you

We will keep your information for as long as it is necessary for the recruitment process. If you are successful, we will keep your information for the duration of your employment, should you wish to apply for other roles within Vodafone. If we are not able to offer you a role, we may keep your information for up to 6 months to contact you about future roles that may interest you, but only where we have collected your consent to do so – you can withdraw your consent at any time in your candidate profile.

We will anonymise your information in accordance with our retention policy and may retain those anonymised records to monitor the effectiveness of our recruitment process. For example, we may create reports to understand what nationalities have applied for roles with Vodafone in the last 12 months – you will not be identifiable in these reports and you can withdraw your consent at any time by updating the information in your candidate profile.

5 Your rights

You may make a request to the data controller to exercise the following rights over your personal information:

1. Right to correct or update information: Before using personal information, we will take any steps that are reasonably necessary to ensure that the information is accurate and up to date, complete and not misleading, with regard to the purpose for which it is to be used. You have the right to request that the information we hold about you be corrected. You can do this by emailing askhrnz@vodafone.com. If we don’t agree that a correction is required, we will let you know, and you can request that your correction is attached to the information, to be read by anyone accessing the information. If the information we hold about you on EVO needs updating, or you think it may be inaccurate, you can log in to your employee profile on EVO directly, to update it yourself.
2. Right to access: You have right to access your personal information in accordance with the Privacy Act 1993. If you wish to access your personal information, you can apply for a copy by emailing askhrnz@vodafone.com. You should be aware that privacy law does allow Vodafone to refuse to disclose personal information in certain situations. This includes if the information does not exist, cannot be found, or is not readily retrievable. This is also the case if your request is frivolous or vexatious, or where disclosure of the information would disclose trade secrets, involve unwarranted disclosure of the affairs of another individual, or prejudice your physical or mental health. We will let you know when we respond to your request if there is a reason we have refused access.

Vodafone has an effective Data Retention policy and will not process your personal information when it is no longer necessary. If you think that we are processing your personal information unnecessarily, please contact us at askhrnz@vodafone.com and we will review your request.

You may exercise the same rights over your personal information controlled by Vodafone Group Services Limited by emailing AskHRGroupUK@vodafone.com.

If we do not take action based on any of the above requests, we will inform you of the reasons why.

6 Changes to this Privacy Statement

This privacy statement is updated from time to time, so we would encourage you to check it regularly in your candidate profile on the recruitment portal. If we make a major change, we will let you know by email.

7 How to contact us

If you have any further questions about this privacy statement or how we process your information, please contact your local Privacy Officer at privacyofficernz@vodafone.com. We’ll do our best to help but if you’re still unhappy, you can contact the Office of the Privacy Commissioner: https://privacy.org.nz/about-us/contact/3