Job Applicant Privacy Policy

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 a recruitment agent or special appointments.

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). 

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.

In some cases, the Personal Data of MTN Job Applicants that we collect will also include Sensitive Personal Data such as:

• Diversity related information (including data about citizenship and status of citizenship applications, racial and ethnic origin); 
• Health data where this is relevant to the job being applied for (such as disability records);
• Salary information; and 
• Data about alleged or proven criminal offences.

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:

•  Assessment agencies for personality and cognitive ability tests;
• Higher institutions of learning; 
• background check providers such as former employer, referees; and/or pre-employment check providers such as medical institutions, Security institution for criminal background checks, citizenship;
• recruitment agencies;
• other entities within the MTN group if you transferred to us from that MTN entity; 
• publicly available sources such as LinkedIn.

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 policy 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.

We may also request to retain your Personal Data for consideration of any other suitable positions that may become vacant in the future. If you consent to this, we may proactively contact you in respect of any suitable vacancies that arise. 

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:

• such further Processing is authorised in terms of Applicable Data Privacy Laws;
• we have obtained your consent to the further Processing;
• the further Processing is necessary to comply with an obligation imposed by Local Regulatory Requirements or for conducting proceedings in a court or tribunal; or
• it is for scientific or historical research purposes or statistical purposes.

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:

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:

• You have given explicit consent to the Processing of your Sensitive Personal Data for one or more specified purposes (for example when performing criminal background checks). You may withdraw such consent at any time in written form;
• Processing is necessary for the purposes of conducting the obligations and exercising your or MTN’s specific rights in the field of employment, social security, and social protection law;
• Processing relates to Sensitive Personal Data which was intentionally made public by you;
• Processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity;
• Processing of Personal Data related to criminal behaviour is obtained and used in accordance with Local Regulatory Requirements.

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. Your failure to provide the Personal Data requested for 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).

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.

We make reasonable efforts to retain Personal Data only for so long as:

• the Personal Data is necessary to comply with our obligations to you in terms of our job application process, policies, and procedures; 
• is necessary to comply with legal, regulatory, or internal policy requirements that may apply; and/or
• is necessary to evidence the fairness of the recruitment process should it be contested by an unsuccessful MTN Job Applicant within a reasonable period of time.
• The retention of MTN Job Applicants’ records will be in accordance with our Data retention policies and retention schedule which is available on the MTN Uganda website. These policies or relevant extracts may be requested by job applicants by contacting Human Resources at AskHR.UG@mtn.com 

Yes, we may share Personal Data with third parties, as necessary for our legitimate business needs, to fulfil 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:

• Our service providers: We transfer your Personal Data to our third-party service providers, such as our (IT) systems providers, our hosting providers, consultants (such as legal advisers, assessors, auditors) and other services providers. These providers process your Personal Data on behalf of MTN in terms of a binding agreement with appropriate security safeguards. MTN will only transfer Personal Data to them when they meet our strict standards on the Processing of data and security. We only share Personal Data that allows our service providers to provide their services and they are not allowed to process your Personal Data for any other purpose.
• Courts, tribunals, law enforcement or regulatory bodies: MTN will disclose Personal Data in order to respond to requests of courts, tribunals, government, or law enforcement agencies or where it is necessary or prudent to comply with Local Regulatory Requirements, court or tribunal orders or rules, or government regulations. We will also disclose Personal Data necessary to defend the fairness of the recruitment process.

Yes, MTN may transfer Personal Data outside of Uganda but only if such transfers are permitted in accordance with Local 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 Uganda to third parties collaborating 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.

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:

• accidental loss of, damage to, or unauthorised destruction of your Personal Data;
• unlawful or unauthorised access to / dissemination of your Personal Data; and
• unlawful or unauthorised Processing of your Personal Data.

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.

While MTN implements reasonable measures to prevent or reduce the likelihood and impact of Personal Data Breaches, this risk cannot 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 is compromised, MTN adheres to its Personal Data Breach Incident Management and Notification Guidelines governing the handling and reporting of Personal Data Breaches. This guideline is available to MTN Job Applicants on the MTN Uganda website.

If MTN processes Personal Data about you, you have the following rights:

• • Access and correction: You have the right to access the Personal Data retained by MTN. This is also known as a ‘Data Subject Access Request.’ If we agree that we are obliged to provide Personal Data to you, we will provide it to you free of charge. Before providing Personal Data to you, we may ask for proof of identity and sufficient information about your interactions with us in order to locate your Personal Data. If the Personal Data we hold about you is incorrect, you are entitled to ask us to correct any inaccuracies in the Personal Data.
  • Object to Processing: You have the right to objects the Processing your Personal Data, in written form, on grounds relating to your particular situation, under certain circumstances. For example, if we are Processing your Personal Data on the basis that is necessary for purposes of our or a third party’s legitimate interest, you may object to us Processing your personal data for purposes of direct marketing. You may also object if you believe there is no legal basis for us to process your Personal Data anymore.
  • Withhold consent: You have the right to withhold your consent, in written form without any fear of negative repercussions in circumstances that we seek your consent to process your Personal Data. If you experience any intimidation or negative repercussions for withholding your consent, you should report this to the whistleblower hotline at anonymous@tip-offs.com and Telephone number: 0800 212 800. 

• Withdraw consent: You also have the right to withdraw your consent, in written form at any time and we will cease Processing your Personal Data unless there is an alternative legal basis to continue Processing your Personal Data. We will advise you if we intend to continue Processing your Personal Data in these circumstances.

• Disposal / Restrictions: In addition, you may have rights to have your information deleted / destroyed if we are keeping it too long or have no legal basis to process it. You may also expressly request that the Processing of your Personal Data is restricted in certain circumstances.
• Lodge complaints: You have the right to lodge a complaint regarding the way your Personal Data is processed with MTN or if you believe there has been a breach of MTN privacy policies and/or data privacy laws.

You can make a request or exercise these rights by contacting MTN at dataprotectionofficeUG@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.

Finally, you always have the right to lodge a complaint with the supervisory authority in charge of protecting Personal Data, the Personal Data Protection Office, Uganda, whose contact details are: 

• [Email Address:] info@pdpo.go.ug
• [Telephone number:] 0417801008/9
• [Website:] www.pdpo.go.ug