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Job Applicant Privacy Notice

Introduction

In this Recruitment Notice, “Globacom”, “we”, “our” and “us” refer to Globacom Limited, incorporated under the laws of the Federal Republic of Nigeria, with its registered office at Mike Adenuga Towers, 1 Mike Adenuga Close, Off Adeola Odeku Street, Victoria Island, Lagos. We are committed to the fair, transparent, and lawful processing of your personal data in accordance with the Nigeria Data Protection Act (NDPA), and to safeguarding your privacy in every step of our recruitment process.

Definitions

Personal Data	Any information relating to an identified or identifiable natural person, including but not limited to names, contact details, identification numbers, education history, and employment information.
Sensitive Personal Data	Special categories of data such as health, race or ethnic origin, religious beliefs, trade union membership, biometric data, or criminal records.
Data Subject	A natural person whose personal data is being processed — in this case, a job applicant.
Processing	Any operation performed on personal data (collection, storage, use, disclosure, deletion) whether automated or not.
Third Party	Any person or entity other than the data subject, the data controller, or those authorized to process data under the controller’s direct authority.

Scope

This notice applies to all individuals applying for employment at Globacom, whether through our official careers portal, third-party platforms, or recruitment agencies.

Types of Data Collected

Bio data: Full name, date of birth, gender, etc.
Contact information: phone number, email, address.
Academic and professional qualifications, employment history and references, CVs, certificates, identification documents, background checks, and any other information relevant to evaluating your application.

Lawful Basis for Processing

Your personal data is processed on one or more lawful bases including: performance of a contract/pre-contractual obligations, legal obligations, consent (for sensitive personal data or retention for future roles), and legitimate interests (improving recruitment, diversity, fraud prevention). You may withdraw consent at any time where processing relied on consent.

Data Collection Methods

We collect data via our online application platform, email submissions, third-party recruitment agencies, Google Forms, and in-person or virtual interviews and assessments.

Data Use Purpose

We use your personal data to process applications, assess qualifications, conduct interviews and background checks, contact you about application status, and retain information for future recruitment where you consent.

Data Sharing & Disclosure

Personal data may be shared with internal HR and recruitment teams, third-party service providers under NDPA-compliant agreements, regulatory authorities where required, and affiliated companies for group-level recruitment purposes.

Data Retention

Personal data is kept, reviewed periodically and destroyed in line with law, the purpose it was obtained for, contract terms, statutory requirements, or upon a valid deletion request where no investigation or statutory restriction applies.

Your Rights

Right to request and access Personal Data held about you (including a common electronic format where structured).
Right to information on personal data collected and stored.
Right to object or request restriction, rectification, or deletion (subject to legal limitations).
Right to data portability.
Right to object to automated decision making/profiling.
Right to opt out of marketing and unsolicited messages.
Right to lodge a complaint with the Nigeria Data Protection Commission (NDPC).

Data Security & Breach Response

We use industry-standard technical and organisational measures (encryption at rest, access controls, security audit logging, physical security) to protect personal data. In case of a breach, we will contain, investigate, notify affected applicants and the NDPC within 72 hours (where required), and provide guidance to affected individuals.

Third Parties & Cross-Border Transfers

We may disclose data to service providers, law enforcement, regulators, or in corporate transactions. Cross-border transfers occur only with appropriate safeguards such as NDPC-approved instruments (SCCs, BCRs), and only when adequate protections are in place.

Changes to this Notice

Globacom may update this Recruitment Notice periodically to reflect legal, regulatory, or operational changes. Significant changes will be notified via our website or email.

Contact Information

Data Protection Officer

Globacom Limited

Email: [email protected]

NDPC (for complaints): [email protected] · Phone: +234 (0) 916 061 5551

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