Recruitment Privacy Policy

At Gratia, we are committed to protecting the privacy and security of your personal data throughout our global recruitment process. This policy explains what personal data we collect, why we collect it, how we use it, and your rights as a job applicant, regardless of your location.

Effective Date: 11 Dec 2025

1. Who We Are

The responsible entity that determines the purposes and means of processing your personal data is Gratia Inc. with an address at P.O. Box 692861, Stockton, CA 95269.

Should you have any questions, you can email us at recruiting@gogratia.com.

2. The Personal Data We Collect

We collect and process various categories of personal data to evaluate your application. The data we collect includes:

Identity & Contact Data: Name, address, personal email, phone number, and nationality.
Application Data: CV, cover letter, education, employment history, qualifications, skills, and salary expectations.
Assessment Data: Interview notes, assessment scores (e.g., from skills testing platforms), and work samples.
Source Data: Information provided by the Gratia employee who referred you, or external recruitment agencies.
Verification Data: References, confirmation of qualifications, and legal right-to-work status.
Technical Data: Information gathered if you use our careers page (e.g., IP address, browser type).
Voluntary Diversity Data: Optional information, where permitted by local law, used for equal opportunity monitoring.

We source this data primarily from you, our career channels, external recruiters, and your provided referees.

3. How and Why We Use Your Personal Data

We use your personal data only where we have a lawful basis under applicable data protection laws. Our purposes for processing your data include:

To Assess Suitability: To evaluate your skills and experience to take steps necessary for potentially entering into an employment contract with you.
To Communicate: To manage your application, schedule interviews, and provide essential feedback.
To Conduct Due Diligence: To verify references and confirm your legal right to work, often based on our legal obligations.
To Maintain Fair Practices: To analyze our processes and ensure our global recruitment practices are fair, non-discriminatory, and effective (based on our legitimate business interests).

4. Automated Decision-Making and Artificial Intelligence (AI)

Gratia utilizes certain AI tools and automated processing to enhance the efficiency and fairness of our global recruitment process.

Our Use of AI:

We use AI to assist our human recruitment teams, including:

Interview Notetaking and Transcription: We may use an AI tool to record and transcribe interviews for internal documentation, accuracy, and efficient sharing of information across the interview panel.
Sourcing and Screening: To analyze application materials (like CVs) and identify relevant experience, which helps our recruiters prioritize candidates for human review.
Assessment Analysis: To score or summarize responses provided in online skills assessments and generate insights for the human reviewer.
Consent, Human Oversight, and Candidate Rights:
Right to Opt-Out: When an AI notetaker is used during an interview, we will provide clear notice in the interview confirmation email and include an easy mechanism for the candidate to opt out (refuse) the use of the notetaker prior to the session. Candidates always have the right to refuse the use of the notetaker without penalty to their application.
No Solely Automated Decisions: Gratia does not make any final hiring decisions based solely on automated processing. Every significant decision, including shortlisting, interview progression, and offer decisions, is reviewed and confirmed by a human recruiter or hiring manager.
Transparency and Challenge: You have the right to know if and how automated tools were used in evaluating your application. You also have the right to express your point of view and contest any decision that you believe was significantly affected by automated processing.

5. How Long We Keep Your Data (Retention)

If successful: Your data will be transferred to your official employee record. Details regarding this processing will be provided to you in another privacy notice once you have accepted the offer.
If unsuccessful: We generally retain your personal data for a period of 1 year after the recruitment process concludes, to address legal claims and queries.
Talent Pool: If you provide consent to join our talent pool for future openings, we will retain your data for a period of 2 years unless you withdraw your consent.

6. Data Sharing and Client Transfer

We only share your data when strictly necessary for the recruitment process:

Gratia Employees: Relevant recruitment staff, hiring managers, and interviewers across our global offices.
Service Providers (Processors): Third-party vendors that operate on our behalf, such as Applicant Tracking Systems (Ashby), skills assessment platforms (TestGorilla), and background check providers.
Legal Compliance: Regulatory bodies or law enforcement when legally required.

Sharing Data with Clients and Our Platform (For Successful Candidates Only)

If you successfully accept an offer of employment with Gratia, we will share and transfer certain personal data necessary for project placement and management.

We will share relevant professional data (such as your name, skills, experience, and professional background) with our clients to facilitate project staffing and introduction.

We will transfer your professional profile and hire information into our proprietary platform. This platform is used to manage profiles of Gratia hires, making it easier for our clients and Gratia staff to view your professional background and match you with potential projects.

7. International Data Transfer

As a global company, your data may be transferred to and processed in countries outside of your home region (including where Gratia's main servers or service providers are located).

We ensure that all such transfers comply with applicable laws and are protected by appropriate safeguards (such as using contractual obligations or reliance on recognized legal mechanisms) to keep your personal data secure.

8. Your Global Rights as a Candidate

Under applicable data protection laws, you have specific rights regarding the personal data we hold about you. These generally include the right to:

Access: Request a copy of the data we hold about you.
Rectification: Ask us to correct inaccurate or incomplete data.
Erasure (Deletion): Ask us to delete your data in certain circumstances.
Restriction: Ask us to suspend the use of your data.
Object: Object to the processing of your data based on certain legal grounds.
Portability: Request that we transfer your data to you or another party.
Withdraw Consent: Withdraw any consent previously given at any time.

9. Third-Party Links

Our careers website or correspondence may, from time to time, contain links to the websites of our partner networks, advertisers, and affiliates (e.g., links to assessment provider login pages).

Please note that these external websites have their own privacy policies. We do not accept any responsibility or liability for these third-party policies. Therefore, if you choose to follow a link, please ensure you review their privacy policies before submitting any personal data to those external websites.

10. Changes to This Policy

We reserve the right to update this recruitment privacy policy at any time.
When we make significant changes, we will post the updated policy on our careers website and update the "Effective Date" at the top of this document. We encourage you to review this policy periodically to stay informed about how we are protecting your information.