Recruitment Privacy Policy

1.1This Privacy Policy applies to personal data processed in connection with recruitment for RSL, including where a candidate:

1. a.applies directly to RSL;
2. b.applies through RSL’s website or recruitment portal;
3. c.applies through an authorized third-party recruitment platform;
4. d.is referred to RSL by a recruitment consultant or service provider;
5. e.participates in screening, assessment or interviews;
6. f.communicates with RSL concerning employment;
7. g.submits a CV, résumé or other recruitment documentation; or
8. h.otherwise participates in an authorized RSL recruitment process.

1.2RSL may engage independent recruitment-support service providers, including Brandexo Global Private Limited (“BGPL”), to perform authorized activities such as candidate sourcing, application management, preliminary screening, preliminary interviews, assessments, shortlisting and interview coordination.

1.3Where a third-party service provider independently collects or processes personal data for its own separately identifiable services, its own privacy notice may additionally apply to such processing.

Depending upon the position and stage of recruitment, personal data processed in connection with RSL recruitment may include:

2.1Identity and Contact Information

1. a.name;
2. b.postal address;
3. c.email address;
4. d.telephone/mobile number;
5. e.date of birth, where relevant and lawful;
6. f.photograph, where relevant;
7. g.identity-related information where reasonably required; and
8. h.other contact or identification information voluntarily provided by the candidate.

2.2Educational and Professional Information This may include:

1. a.educational qualifications;
2. b.academic records;
3. c.professional qualifications;
4. d.certifications;
5. e.training;
6. f.employment history;
7. g.previous employers;
8. h.designation and responsibilities;
9. i.work experience;
10. j.professional skills;
11. k.technical competencies; and
12. l.information contained in a CV or résumé.

2.3Recruitment and Assessment Information We may process information concerning:

1. a.the position applied for;
2. b.application history;
3. c.screening results;
4. d.interview records;
5. e.assessment results;
6. f.skill or aptitude assessments;
7. g.recruiter observations;
8. h.candidate communications;
9. i.shortlisting status;
10. j.interview status;
11. k.selection status;
12. l.proposed designation;
13. m.expected or proposed compensation; and
14. n.expected availability or joining date.

2.4Verification Information Where appropriate for the relevant position and permissible under applicable law, RSL or an authorized service provider may process information necessary to verify:

1. a.educational qualifications;
2. b.employment history;
3. c.professional credentials;
4. d.references;
5. e.identity; and
6. f.other information provided by the candidate.

The nature and extent of any verification may vary according to the position concerned.

2.5Technical Information Where candidates interact with an authorized website, portal or digital recruitment system, technical information may be collected in accordance with the applicable website/privacy notice, which may include device, browser, IP address, log and security-related information.

2.6Other Information Candidates may voluntarily provide additional information during the recruitment process.

Candidates are requested not to provide personal data that is unnecessary for the relevant recruitment process.

Candidate personal data may be obtained:

1. a.directly from the candidate;
2. b.through RSL’s recruitment website or portal;
3. c.from BGPL or another authorized recruitment-support service provider;
4. d.through authorized recruitment/job platforms;
5. e.through employee or professional referrals;
6. f.from references identified by the candidate;
7. g.through verification undertaken with appropriate authority and in accordance with applicable law; and
8. h.from other lawful sources relevant to recruitment.

Personal data may be processed for purposes connected with RSL’s recruitment and employment-administration activities, including:

1. a.receiving and managing applications;
2. b.identifying potentially suitable candidates;
3. c.communicating with candidates;
4. d.preliminary screening;
5. e.evaluating qualifications, skills and experience;
6. f.conducting interviews;
7. g.conducting assessments;
8. h.shortlisting candidates;
9. i.coordinating interviews;
10. j.verifying information supplied by candidates;
11. k.evaluating suitability for a position;
12. l.making recruitment and selection decisions;
13. m.preparing and issuing employment documentation where a candidate is selected;
14. n.managing joining and onboarding activities;
15. o.maintaining appropriate recruitment records;
16. p.responding to candidate questions or complaints;
17. q.detecting or investigating fraud, impersonation, fake applications or misuse of RSL’s recruitment process;
18. r.protecting RSL’s systems, information, personnel, candidates, brand and legal interests;
19. s.complying with applicable legal or regulatory requirements; and
20. t.establishing, exercising or defending legal rights or claims where necessary.

5.1RSL retains exclusive authority concerning final selection, rejection, designation, compensation, appointment and employment of candidates.

5.2Information supplied to or generated by a recruitment-support provider during preliminary screening may be shared with RSL for RSL’s evaluation.

5.3A recommendation, assessment, screening result or shortlist prepared by BGPL or another service provider does not by itself constitute an employment decision by RSL.

6.1RSL may authorize Brandexo Global Private Limited (BGPL) or another recruitment-support service provider to process candidate information for specified recruitment activities.

Such activities may include:

1. a.receiving applications;
2. b.candidate sourcing;
3. c.preliminary CV screening;
4. d.preliminary qualification and experience review;
5. e.preliminary candidate interactions;
6. f.RSL-approved assessments;
7. g.preliminary interviews;
8. h.preparation of candidate shortlists; and
9. i.coordination of interviews with RSL.

6.2BGPL shall not, merely because it provides recruitment-support services, have authority to make final employment decisions on behalf of RSL.

6.3Where BGPL processes candidate information specifically for an RSL recruitment assignment, it is required under its contractual arrangements with RSL to use such information for authorized recruitment-related purposes and to maintain appropriate confidentiality and security.

6.4BGPL is contractually restricted from selling candidate information, commercially exploiting candidate information for unrelated purposes, disclosing such information to unauthorized unrelated third parties or using it for unauthorized marketing in connection with RSL recruitment.

7.1In limited circumstances, an independent recruitment-support provider may separately provide an identifiable service directly to a candidate, subject to applicable law and the arrangements governing the relevant recruitment process.

7.2Where BGPL or another third party independently collects personal data from a candidate for its own separately identifiable service, that entity may be independently responsible for providing the candidate with appropriate information concerning its processing of such personal data.

7.3Candidates should review the applicable third party's:

1. a.privacy notice;
2. b.terms and conditions;
3. c.service description; and
4. d.refund/cancellation policy,

before purchasing or using a separately provided service.

7.4RSL's authorization for a third-party provider to participate in a recruitment process does not by itself authorize that provider to use candidate data for unrelated commercial, marketing or other purposes.

8.1As stated in RSL’s Recruitment Disclaimer Policy, RSL does not require candidates to pay an application, registration, recruitment, interview, placement or similar fee merely for applying for, being considered for, interviewing for or obtaining employment with RSL.

8.2Where an independent service provider lawfully provides a separately identifiable candidate-paid service, payment information may be collected by that service provider or its authorized payment-service provider.

8.3Where RSL does not collect or receive such payment information, the processing of such information shall be governed by the privacy and security terms applicable to the relevant service provider/payment processor.

8.4Candidates should not provide banking credentials, passwords, OTPs, PINs or other unnecessary financial-security information to persons merely claiming to represent RSL.

Subject to applicable law and the requirements of the relevant recruitment process, candidate personal data may be shared with:

1. a.authorized RSL employees involved in recruitment, HR, management, legal, compliance,

information security or administration;

1. b.BGPL or another authorized recruitment-support service provider;
2. c.assessment, verification or background-check providers where appropriately engaged;
3. d.information-technology, hosting, communication or recruitment-platform service providers;
4. e.professional advisers;
5. f.governmental, regulatory, judicial or law-enforcement authorities where disclosure is required or permitted by law; and
6. g.other persons where the candidate has authorized disclosure or where another lawful basis exists.

Personal data shall not be shared merely because a third party requests access to it.

RSL intends to process personal data that is reasonably necessary and relevant for the applicable recruitment purpose.

Candidates should avoid providing excessive or irrelevant personal information.

Where additional information is required at a later recruitment stage, candidates may be requested to provide it separately.

11.1Candidates are responsible for providing information that is accurate and not materially misleading.

11.2Candidates should notify the relevant recruitment contact where material information submitted during the recruitment process changes or requires correction.

11.3Submission of materially false, fabricated, forged or misleading information may affect candidature and may result in other action permissible under applicable law.

12.1RSL shall take reasonable and appropriate measures designed to protect personal data processed under its control against unauthorized access, disclosure, alteration, misuse, loss or destruction.

12.2Recruitment-support providers processing candidate data in connection with RSL recruitment are expected to implement appropriate technical and organizational safeguards applicable to their processing activities.

12.3No method of electronic transmission or storage can be represented as absolutely secure. Candidates should therefore use reasonable precautions when transmitting personal information electronically.

Where RSL becomes aware of a personal-data breach affecting candidate information, RSL shall assess and respond to the incident in accordance with applicable law.

Recruitment-support providers processing candidate data in connection with RSL recruitment may be contractually required to notify RSL of relevant data-security incidents and cooperate with investigation, mitigation and legally required response.

14.1Candidate personal data shall be retained only for such period as is reasonably necessary for the purposes for which it was collected or as otherwise required or permitted by applicable law.

14.2Relevant considerations may include:

1. a.duration of the recruitment process;
2. b.whether the candidate is selected;
3. c.legitimate recruitment-record requirements;
4. d.possible consideration for other suitable vacancies where legally permissible;
5. e.legal limitation periods;
6. f.regulatory requirements;
7. g.dispute or complaint management; and
8. h.establishment, exercise or defence of legal claims.

14.3Where personal data is no longer reasonably required and there is no lawful reason for continued retention, it may be securely deleted or anonymized in accordance with applicable procedures.

Information concerning unsuccessful candidates may be retained for a reasonable period for legitimate recruitment, record-keeping, dispute-management or legal-compliance purposes, subject to applicable law.

Where RSL proposes to retain candidate information for future recruitment opportunities beyond what is otherwise permissible, appropriate notice or consent shall be obtained where required by applicable law.

Where a candidate is selected and joins RSL, relevant recruitment information may become part of the individual's employment/personnel records and may thereafter be processed in accordance with applicable employee privacy requirements, RSL policies and applicable law.

Subject to applicable law and any applicable exceptions, candidates may have rights in relation to their personal data.

Where applicable, candidates may contact RSL to:

1. a.request information concerning personal data processed about them;
2. b.seek correction, completion or updating of inaccurate or incomplete personal data;
3. c.request erasure of personal data where legally applicable;
4. d.raise a grievance concerning processing of personal data; and
5. e.exercise such other rights as may be available under applicable data-protection law.

Requests may be subject to reasonable identity verification.

Questions, concerns or grievances relating to personal data processed by RSL in connection with recruitment may be submitted to:

Royal Sense Limited

Attention

Data Protection / Recruitment Privacy Grievance Contact

Email

[email protected]

Telephone

+91-8860601013

Address

1st Floor, C-7, Phase-3, Badli Industrial Area, Delhi-110042

RSL may request information reasonably necessary to identify the applicant and investigate the matter.

19.1Where a candidate's privacy concern relates specifically to data independently collected or processed by BGPL for BGPL's own separately identifiable service, the candidate may be required to contact BGPL through BGPL's designated privacy/grievance channel.

19.2Where the complaint concerns candidate data processed by BGPL in connection with an RSL recruitment assignment, or alleges misuse of RSL's name or recruitment process, the candidate may also notify RSL through the contact specified in this Policy.

19.3RSL may require BGPL to provide reasonable cooperation in investigating matters relating to candidate data processed in connection with an RSL recruitment assignment.

Where RSL operates an online recruitment page or portal that uses cookies or similar technologies, information concerning such technologies should be provided through the applicable website cookie/privacy notice.

Where a candidate is redirected to a third-party website, recruitment platform or payment gateway, the third party's own privacy and cookie practices may apply.

RSL recruitment communications may contain links to websites or platforms operated by third parties.

RSL does not control the privacy practices of an independent third-party website merely because a link to that website appears in an authorized recruitment communication.

Candidates should review the privacy notice applicable to the third-party platform before providing personal data through it.

RSL's recruitment processes are intended for individuals legally eligible for the relevant employment opportunity.

Where a position may lawfully be available to a person below eighteen years of age, any processing of personal data relating to such individual shall be undertaken subject to applicable legal requirements.

RSL or an authorized service provider may use digital tools to assist with application management, screening or assessment where appropriate.

Unless specifically disclosed otherwise, such tools should not be understood as independently creating a binding employment offer.

RSL retains final authority concerning employment decisions.

RSL may process relevant information for the prevention, detection, investigation and reporting of suspected:

1. a.fake applications;
2. b.forged qualifications or documents;
3. c.recruitment fraud;
4. d.fake employment offers;
5. e.impersonation;
6. f.unauthorized candidate charging;
7. g.misuse of RSL's name or logo;
8. h.unauthorized access to recruitment systems; or
9. i.other unlawful or fraudulent conduct affecting RSL, candidates or the recruitment process.

Where appropriate and legally permissible, relevant information may be shared with competent authorities.

Where candidate personal data is transferred or processed outside India in connection with recruitment or use of a service provider, RSL shall address such processing in accordance with applicable legal requirements in force from time to time.

RSL may preserve or disclose personal data where reasonably necessary and legally permissible to:

1. a.comply with applicable law;
2. b.comply with a lawful governmental, regulatory or judicial requirement;
3. c.investigate suspected fraud or unlawful conduct;
4. d.protect the rights, property, systems or security of RSL;
5. e.protect candidates or other persons; or
6. f.establish, exercise or defend legal claims.

RSL may amend this Privacy Policy from time to time to reflect changes in:

1. a.recruitment practices;
2. b.technology;
3. c.third-party recruitment arrangements;
4. d.legal or regulatory requirements; or
5. e.RSL's data-processing practices.

The updated version may be published through RSL's authorized website, recruitment portal or other appropriate channel together with the revised effective/update date.

Material changes shall be communicated where required by applicable law.

This Privacy Policy should be read together with RSL's Recruitment Disclaimer Policy.

The Recruitment Disclaimer explains, among other matters, the respective recruitment roles of RSL and third-party recruitment-support providers, the absence of any employment guarantee and RSL's position concerning candidate charges.

This Privacy Policy principally addresses the collection, use, disclosure, security, retention and other processing of candidate personal data.

Submission of personal data, creation of a candidate profile, completion of an application, participation in an assessment or interview, or processing of candidate information under this Privacy Policy does not create a right or guarantee of employment with RSL.

RSL's employment decisions remain subject to its recruitment requirements and applicable law.

For recruitment privacy questions or grievances:

ROYAL SENSE LIMITED

Registered Office

C-7, Phase-3, Badli Industrial Area, Delhi-110042

CIN

L21006DL2023PLC412051

Recruitment Privacy/Grievance Email

[email protected]

Telephone

+91-8860601013

Website

www.royalsense.in