Sosei Website Privacy Notice
Sosei Group Corporation and its subsidiaries (“we” or “us”) place great importance on the protection of your personal data and is committed to comply with all applicable data protection laws and regulations.
The following Privacy Notice will provide you with information about the personal data we collect, process and use when you visit Sosei Heptares’s website.
1. Who is responsible for the processing of your personal data?
The responsible data controller, that means the entity deciding why and how to process your personal data, is:
Sosei Group Corporation
PMO Hanzomon 11F, 2-1 Kojimachi, Chiyoda-ku, Tokyo 102-0083 Japan
2. What personal data do we collect?
We collect information from you when you use our website or complete our “Contact Us,” “Email Alerts” forms. The personal data we collect might include first name, surname, zip code, address, email address, phone number, or your IP address (as outlined below in Section 8).
We also collect job-related information from you through our “Career Page.” We may collect this information, for example, through application forms, CVs or resumes or other documents that you provide to us. This may include:
· job applicant information, including job history, academic background, information about the current level of remuneration, including benefit entitlements;
· if you provide such information, whether or not you have a disability for which we need to make reasonable adjustments during the recruitment process;
· information about your entitlement to work in the country of the relevant position (if applicable)
In the course of the recruiting process, Sosei Group Corporation or, if you are applying for a position in Europe, our UK-based subsidiary Heptares Therapeutics Limited, Granta Park, Great Abington, Cambridge, Cambridgeshire, CB21 6DG (Heptares) may also collect personal data about you through interviews or other forms of assessment, including online tests, whereas these processes may be described in more detail in separate privacy notices. In this context we may also collect information about you from third parties, such as references supplied by former employers. However, we would only seek this information from third parties if a job offer has been made and we will inform you that we are doing this.
3. For which purposes do we process your personal data?
We process your personal data for the following purposes:
· Communicating with you, upon your request through the “Contact Us” form;
· Delivering you, upon your subscription through the “Email Alerts” form, the latest updates on our website;
· At your request, recruiting activities conducted through our “Career Page”;
· Compliance with our terms and policies, for example, to prevent or detect fraud or other crimes.
4. Our Career Page
As part of our recruitment process, we will collect and process personal data relating to our job applicants. The online recruitment website is provided and hosted by our provider Cezanne HR Limited, 46 Loman Street, London SE1 0EH with whom we have entered into appropriate data processing agreements.
You are under no statutory or contractual obligation to provide data to us during the recruitment process. However, if you do not provide the information, we may not be able to process your application properly or at all.
5. Who has access to your personal data?
We will disclose your personal data to our third-party service providers for the purposes of hosting our website. Where you get in touch with us for recruiting purposes that relate to Europe, we may share the personal data you provide to us with Heptares who are based in the UK. We may also disclose your personal data to legal consultants or similar third parties where this is necessary for our legitimate interests, for example for the prevention or detection of fraud or other crimes.
Your information that you provide to us through the “Career Page” may be shared internally for the purposes of the recruitment exercise. This includes members of the relevant HR team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.
Whenever we share your personal data with third parties or with other Sosei group companies, we disclose only the personal information that is necessary for the respective purposes and we generally have contracts that require them to keep your information secure and not to use it for their own purposes.
Where we are required by applicable laws, we will also disclose your personal data to law enforcement, government authorities or courts.
6. On which legal basis do we process your personal data?
We will process your personal data on the following legal bases:
· Legitimate business purposes: Where the processing is necessary for our legitimate interests (such as to communicate with you, after you have contacted us; to protect us from harm by preventing or detecting illegal activities, fraud or similar threats; to exercise or defend against legal claims, unless we determine in a case-by-case assessment that our interests are overridden by your interests or rights; or for the purpose of keeping records of the recruiting process in compliance with applicable data protection regulation).
· Consent: To deliver to you, upon your subscription, latest news on our website. If your application is unsuccessful, we may keep your personal data on file in case there are future employment opportunities for which you may be suited but we will ask for your consent before we keep your data for this purpose and you are free to withdraw your consent at any time.
· Performance of a contract / pre-employment: So that you can provide us with information for recruiting purposes and to assess and confirm a candidate's suitability for employment and decide to whom to offer a job which is a necessary first step before entering into an employment contract.
· Legal obligations: To comply with legal obligations to which we are subject (for example, where we are requested by a court to disclose your data or may be required to check a successful applicant's eligibility to work in the UK before an employment contract in the UK starts; processing information about whether or not applicants are disabled may be legally required to be able to make reasonable adjustments in line with applicable employment law requirements.).
7. Where will your personal data be processed?
Your personal data that is collected through Sosei Heptares’s website will be processed in Japan. In case information is shared with third parties as described in Section 5 above, this may entail a transfer to another country, depending on where the third party is located.
Please note that the laws and rules that protect your personal data in Japan or in other countries where third parties may process your personal data as described in this privacy notice can be different (or less protective) from those in the country in which you live.
9. How do we protect your personal data?
We maintain appropriate technical and organizational security measures designed to protect your personal data against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
Non-sensitive details (your email address etc.) are transmitted normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal data, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your personal data, we make our best effort to ensure its security on our systems.
10. How long do we store your personal data?
We will not retain your personal data longer than necessary to fulfil the purposes the data was collected for or to fulfil our legal obligations. Afterwards, we will delete your personal data.
If we receive your application through our “Career Page” and the application is unsuccessful, we will hold your data on file for up to 12 months after the end of the relevant recruitment process. At the end of that period, or once upon your request, your data will be deleted or destroyed. If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which your data will be held will be provided to you in a new privacy notice.
If you wish to receive further specific information on the applicable retention periods, please contact us under the contact details mentioned in Section 11.
11. What are your rights in respect of your personal data?
To the extent permitted by applicable data protection laws and regulations, you have the right to access your personal data that we hold on you, to update or correct your data so that it is always accurate and to request the deletion of your personal data if it is no longer needed for the purposes above. Furthermore, you have the right to withdraw consent that you have provided to us to receive news (by clicking the unsubscribe link in our emails), to restrict the processing of your data in certain circumstances (for example, where you have contested the accuracy of your data, for the period enabling us to verify its accuracy) and to obtain a copy of your personal data (including in an electronic, machine-readable format).
Please note that legal exceptions (such as mandatory retention periods or rights of third parties) may limit your rights.
To exercise your rights, please reach out to us via the contact details mentioned in Section 12. You also have the right to lodge a complaint with a competent data protection supervisory authority in your jurisdiction such as the Information Commissioner in the UK) or the Personal Information Protection Commission in Japan.
12. How can you contact us?
We welcome any queries and complaints you may have regarding how we process your personal data via the “Contact Us” form.
13. How often do we update this privacy notice?
This privacy notice will be updated to reflect changes either regarding the way in which we process your personal data or changes to data protection legislation. We will bring any significant changes to your attention by updating this information and making it available on our website. To make sure that you keep up to date, we suggest that you revisit this notice from time to time. In addition, we will examine whether in individual cases there is an obligation to provide other notification in the event of any changes to this information and in this case, we will comply with the existing notification obligation.
This Privacy Notice was last updated in January 2019.