In this notice “MTN”, “we”, “our” and “us” refers to MTN Nigeria Communication Plc (“MTN”) a public limited liability company, incorporated in the Federal Republic of Nigeria with registration number 395010 and its principal office at MTN Plaza, Falomo Roundabout, Awolowo Road, Ikoyi, Lagos. We are committed to protecting and respecting your privacy. This Job Applicant Privacy Notice describes our commitments to the fair and transparent processing of your Personal Data, including your privacy rights in relation to the Personal Data we Process.
MTN is committed to being transparent with you regarding the collection and Processing of your Personal Data (including Sensitive Personal Data). This is not intended to be an exhaustive list of Personal Data / Senstive Personal Data that MTN may Process and all potential purposes for Processing. Instead, it indicates the typical Personal Data Processed in the recruitment context and the general purposes of such Processing.
MTN will endeavour to inform you if we intend to Process your Personal Data (including Senstive Personal Data) for any additional purposes prior to collecting or Processing that Personal Data.
Who does this notice apply to?
This notice applies to any person, other than an independent contractor, who applies for employment with MTN whether for a permanent, temporary or fixed-term contract (hereinafter referred to as “MTN Job Applicants” / “you” / “your”). This notice applies to MTN Job Applicants whether they apply for a position directly with MTN or indirectly through, for example, a recruitment agent.
What are the important terms we need to understand when reading this notice?
|Applicable Data Privacy Law(s)||Data privacy and data protection legislation and regulations applicable to the Processing of Personal Data carried out by MTN , or for or on behalf of MTN .|
|Local Regulatory Requirements||Legal, statutory, regulatory, license conditions rules, guidelines, Ministerial/National Security orders or directives, and Directives relating to Public safety (where applicable) and Data Sovereignty*-related requirements with which MTN is required to comply by applicable authorities in the jurisdictions in which MTN operates or where Personal Data is Processed by MTN or on its behalf. *“Data Sovereignty” relates to the laws and governance structures that Personal Data is subject to, due to the geographical location of where it is Processed.|
|Personal Data||Means any information relating to an identified or identifiable natural person (Data Subject). Examples of “Personal Data” includes, but is not limited to, the following: a name; any identifying number, symbol; contact information (e.g., e-mail address, postal address, telephone number); location data or physical address;online identifier or unique identifier such as but not limited to MAC address, IP address, IMEI number, IMSI number, other assignment to the person;the biometric information of the Data Subject;the personal opinions, views or preferences of the Data Subject;correspondence sent by the Data Subject that is implicitly or explicitly of a private or confidential nature or further correspondence that would reveal the contents of the original coinrrespondence;the views or opinions of another person about the Data Subject; the name of the Data Subject if it appears with other Personal Data relating to the Data Subject or if the disclosure of the name itself would reveal information about the Data Subject; andSensitive Personal Data.|
|Personal Data Breach||Means an event or occurrence (including but not limited to a breach of security) leading to the accidental or unlawful destruction, loss or damage, alteration, disclosure of, or access to, Personal Data transmitted, stored or otherwise Processed.|
|Processing||Any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, including collection, receipt, recording, organisation, structuring, collation, storage; adaptation or alteration, updating, retrieval, consultation, use, dissemination, disclosure by means of transmission; or otherwise making available, alignment or combination, merging, restriction, erasure, destruction, and/or degradation.|
|Sensitive Personal Data||A sub-set of Personal Data which is considered more sensitive than other categories of Personal Data. Sensitive Personal Data includes but is not limited to Personal Data revealing a Data Subject’s racial or ethnic origin; political opinions or persuasions; religious or philosophical beliefs; trade union membership; criminal behaviour relating to the alleged commission of a crime or proceedings relating to the alleged commission of a crime; genetic data; biometric data; data concerning health; and/or data concerning a Data Subject’s sex life or sexual orientation.|
What Personal Data does MTN collect and use?
We Process Personal Data which is required in terms of our internal recruitment processes. This information typically includes, but is not limited to, your name, current title and position, professional employment history, language skills, experience, qualifications, contact details, as well as your current and expected earnings, results from personality or cognitive ability tests, opinions of others about you (example through referees and previous employers).
We also Process electronic identification data to the extent that you apply through our web-based application portal (e.g., login information, online identifiers/cookies) or when you use an electronic signature to complete any necessary forms.
What Sensitive Personal Data does MTN Process?
In some cases, the Personal Data of MTN Job Applicants that we collect will also include Sensitive Personal Data, such as:
Where does MTN collect my Personal Data from?
In most circumstances, we collect Personal Data directly from you, for example, when you complete your information on our website career portal, send us your curriculum vitae and where you provide information about yourself during interviews.
In some cases, MTN will also collect Personal Data indirectly from third parties, such as:
For what purposes does MTN use my Personal Data?
MTN is committed to only Process Personal Data for specified, explicit and legitimate purposes related to its business activities.
We Process Personal Data of MTN Job Applicants to assess your suitability for a role within MTN in accordance with our recruitment and selection policies and procedures and, if the application is successful, for the execution of the employment relationship. If you are unsuccessful in the role you applied for, we continue to store your Personal Data for a limited period to maintain a record of the recruitment process should the fairness of the process be contested by an unsuccessful MTN Job Applicant.
MTN will not further Process Personal Data for any purpose that is incompatible with the original purpose that the Personal Data was collected for unless:
Is MTN allowed to Process my Personal Data and Sensitive Personal Data?
We are allowed to Process Personal Data, so long as we have a legal basis to do so. When we Process your Personal Data, we will rely on one of the following legal basis as appropriate having regard to the purpose of Processing:
|Processing of Personal Data is necessary in order to carry out actions necessary for the conclusion of a contract (i.e. employment contract) to which you are or may be a party.||To verify the Personal Data provided by you during the job application process before entering into an employment contract. To agree on the terms and conditions of your employment prior to entering into an employment contract with you.|
|Processing of Personal Data is necessary in order to comply with legal obligations, such as Local Regulatory Requirements, to which MTN is subject to.||To comply with Local Regulatory Requirements (i.e. labour laws) applicable to recruitment of MTN Job Applicants.To comply with laws which seek to achieve a diverse workforce, which promote recruitment of local nationals or which promote employment opportunities for certain categories of persons.|
|Processing is necessary for pursuing the legitimate business interests of MTN or of a Third Party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of Personal Data.||Preventing fraud or criminal activity and to safeguard our IT systems, assets, and places of work.To benefit from cost effective services (e.g., We may opt to use certain IT platforms offered by suppliers) or share basic Personal Data with another MTN group entity if you transfer to that entity, for use by that entity in conducting legally required background checks without collecting the information from you again).To support in our decision making we may obtain information which is publicly available on professional social networks such as LinkedIn, to maintain a record of the recruitment process should the fairness of the process be contested by an unsuccessful MTN Job Applicant|
|You have given consent to the Processing of your Personal Data for one or more specific purposes. You may withdraw such consent at any time.||We will only Process your Personal Data in this way if you agree to us doing so (for example performing reference checks or verifying your qualifications). We will ensure the purpose for Processing your Personal Data is clearly communicated at the time that we request your consent so that you can make an informed decision. We will also provide you with any other relevant information you require to make an informed decision.|
|Processing is necessary in order to protect the vital interests of the Data Subject or of another natural person.|
|Processing is necessary for the performance of a task carried out in the public interest or in exercise of an official public mandate vested in the controller|
When we Process your Sensitive Personal Data, we will rely on one of the following legal basis as appropriate having regard to the purpose of Processing:
Is it mandatory to provide MTN the Personal Data asked for?
It is voluntary to apply for a job with MTN. However, if you choose to apply for a job with MTN, the provision of the Personal Data requested is a requirement of our recruitment process to ensure we are able to assess each candidate fairly. Failing to provide the Personal Data requested may result in us being unable to fully assess your suitability for the position applied for and being unable to offer you the position within MTN. You are responsible for determining the nature and extent to which you share your Personal Data with MTN and acknowledge that you may share Personal Data that MTN has not specifically requested during the recruitment process (for example where you have disclosed your hobbies in your CV).
Does MTN Process my Personal Data automatically?
MTN does not perform any automated decision making (including profiling) which results in legal consequences for you and/or which affects you in a similarly significant manner. Should this change in the future, we will notify you and update this privacy notice accordingly.
How long does MTN keep my Personal Data for?
We make reasonable efforts to retain Personal Data only for so long as:
MTN will retain Job Applicants’ records in accordance with its internal data retention policy . These policies or relevant extracts may be requested by job applicants by contacting MTN Data Protection Officer (DPO) whose details are contained below.
Does MTN transfer my Personal Data to third parties?
Yes, we may share Personal Data with third parties, as necessary for our legitimate business needs, to carry out your requests, and/or as required or permitted by Local Regulatory Requirements and Applicable Data Privacy Law(s). This may include, but not limited to:
Does MTN transfer my Personal Data internationally?
Yes, MTN may transfer Personal Data outside of Nigeriabut only if such transfers are permitted in terms of Nigerian Regulatory Requirements and Applicable Data Privacy Law(s).
MTN may transfer your Personal Data to other entities within the MTN group of companies. All MTN entities are bound by binding corporate rules which ensures that the MTN entity receiving your Personal Data protects your Personal Data in accordance with those binding corporate rules.
MTN may also transfer certain Personal Data outside of Nigeriato third parties working with us or on our behalf for the purposes described in this Job Applicant Privacy Notice. When transferring Personal Data internationally to third parties we will ensure your Personal Data will continue to be protected for example, by entering to agreement incorporating clauses which protect your Personal Data or by ensuring there are adequate data privacy laws, which requires the relevant third party to adhere to the data handling and data protection requirements, acceptable to MTN.
How does MTN secure my Personal Data?
MTN secures the integrity and confidentiality of the Personal Data in its possession or under its control by implementing appropriate, reasonable technical, physical, and organisational measures to prevent:
As part of its processes, MTN takes reasonable measures to regularly identify and assess all reasonably foreseeable internal and external risks to Personal Data in its possession or under its control and implements reasonable and appropriate technical, physical and organisational security measures to protect against the identified risks.
How does MTN handle Personal Data Breaches?
While MTN implements reasonable measures to prevent or reduce the likelihood and impact of Personal Data Breaches, this risk can’t be completely eliminated. If MTN becomes aware of or reasonably suspects a Personal Data Breach has occurred or that the integrity or confidentiality of Personal Data has been compromised, MTN adheres to its Personal Data Breach Management Procedure governing the handling and reporting of Personal Data Breaches. MTN will report personal data breaches to the Data Privacy Regulator within 72 hours of knowledge of such breach.
What are my rights?
If MTN Processes Personal Data about you, you have the following rights:
You can make a request or exercise these rights by contacting MTN at DPONigeria@mtn.com and we will make all reasonable and practical efforts to comply with your request, so long as it is consistent with Local Regulatory Requirements, Applicable Data Privacy Law(s) and MTN’s internal policies.
If you have any questions or concerns regarding this Job Applicant Privacy Notice and would like further information about how we protect your Personal Data and/or when you want to contact MTN Nigeria’s Data Privacy Officer (DPO), please email us at DPONigeria@mtn.com or visit the MTN Nigeria Communication Plc (“MTN”) at its principal office at MTN Plaza, Falomo Roundabout, Awolowo Road, Ikoyi, Lagos
MTN may modify this Job Applicant Privacy Notice from time to time to reflect our current privacy practices. When we make changes to this notice, we will revise the “effective” date and version number at the top of this notice. We will make reasonable efforts to communicate any changes to this Job Applicant Privacy Notice through an appropriate channel, depending on how we normally communicate with you.