Talent Acquisition AI Transparency and Privacy Notice

This AI Transparency and Privacy Notice explains how OpenPayd Group companies collect, use, store and share personal data during the recruitment and selection process.

It also explains how OpenPayd may use approved artificial intelligence systems or AI-enabled tools during recruitment, what safeguards apply, and what rights candidates have in relation to the use of their personal data and AI-supported recruitment processes.

This notice applies to job applicants, prospective candidates, referred candidates, candidates sourced through professional platforms, individuals participating in interviews or assessments, and individuals who receive an offer of employment or engagement from OpenPayd.

This notice covers the following:

1. Who is the controller of your data?
2. What personal data do we collect?
3. How do we collect personal data?
4. How do we use your personal data?
5. How do we use AI-enabled tools in the recruitment process?
6. Human oversight and decision-making
7. Fairness, non-discrimination and AI safeguards
8. What is the legal basis for processing your personal data?
9. What happens if you do not provide the personal data that we request?
10. How do we share your personal data?
11. Data security
12. International data transfers
13. Data retention
14. Your rights
15. Candidate transparency in relation to AI-enabled tools
16. How to exercise your rights
17. Complaints
18. Changes to this notice

CONTACT DETAILS

Contact:People Team

Email: [email protected]

Contact: OpenPayd Data Protection Officer

Email: [email protected] 

Our office locations: https://www.openpayd.com/legal

1.WHO IS THE CONTROLLER OF YOUR DATA?

Whenever you apply for a role with one of the OpenPayd Group companies, or otherwise participate in a recruitment process, the data controller of your personal data will be the OpenPayd company that has the relevant job opening and determines how and why your personal data is processed for the purposes of recruitment and selection.

Where this notice refers to “OpenPayd”, “we”, “our” or “us”, this means the relevant OpenPayd company acting as the controller of your personal data during the recruitment and selection process.

More information about OpenPayd companies is available on OpenPayd’s Group overview webpage: https://www.openpayd.com/legal/openpayd-group-overview/

2. WHAT PERSONAL DATA DO WE COLLECT?

We may collect personal data that you provide to us during the recruitment and selection process, as well as personal data obtained from other sources where permitted by law.

The personal data we collect may include:

1. Identification information, such as your name, surname, title, gender, date of birth, nationality, photograph, and identification documents where required.
2. Contact details, such as your postal address, email address, telephone number and country of residence.
3. Recruitment information, such as your CV or resume, cover letter, employment history, education, qualifications, professional certifications, skills, languages, salary expectations, availability, notice period, work preferences, and information provided during the application process.
4. Right to work information, such as documents or information required to confirm your legal entitlement to work in the country where the role is located.
5. Interview and assessment information, such as interview notes, interview feedback, answers to interview questions, responses to tasks, case studies, tests, technical exercises, presentations or other assessments.
6. Reference and background check information, where applicable and permitted by law, such as employment references, verification of qualifications, employment history, and pre-employment screening checks.
7. Communication information, such as emails, messages, call notes, scheduling information and records of communications between you and OpenPayd or our recruitment partners.
8. Source information, such as how we identified you or how you came to apply for a role, including whether you applied directly, were referred, were sourced through a professional platform, or were introduced by a recruitment agency.
9. Equal opportunities information, where collected and permitted by applicable law, such as information used to monitor diversity and equal opportunities. Where this information is collected, it will be treated carefully, used only for appropriate monitoring purposes, and will not be used to make recruitment decisions about you.
10. AI-related recruitment information, where approved AI-enabled tools are used, such as interview transcripts, interview summaries, interview notes, scheduling outputs, candidate communication drafts, recruitment workflow records, audit logs, or similar records generated by approved AI-enabled recruitment tools.

We may also process information that you voluntarily provide to us. Please do not provide information that is not relevant to your application or the recruitment process.

3. HOW DO WE COLLECT PERSONAL DATA?

We collect personal data about you in the following ways:

1. Directly from you, when you apply for a role, submit your CV, complete an application form, communicate with us, participate in interviews, complete assessments, or provide information during the recruitment process.
2. From professional and recruitment platforms, such as job boards, recruitment platforms, professional networking websites, or other sources where you have made your information available or where we are permitted to contact you.
3. From recruitment agencies or referral sources, where you are introduced to us by a recruitment agency, employee referral, business contact or other third party.
4. From publicly available sources, such as professional profiles, company websites, public registers or other lawful sources relevant to recruitment.
5. From referees or previous employers, where we conduct reference checks and where this is permitted by law.
6. From screening or verification providers, where pre-employment screening checks are required and permitted by law.
7. From approved AI-enabled tools, where such tools are used to support recruitment administration and documentation, such as interview transcription, interview summarisation, scheduling support, candidate communications or recruitment workflow management.

This notice applies to personal data collected from any of these sources.

Where we obtain your personal data from a source other than you, for example a professional networking platform, job board, recruitment agency, employee referral, public source, referee or screening provider, we will normally provide you with this at the first meaningful contact with you about a role.

4. HOW DO WE USE YOUR PERSONAL DATA?

We use your personal data for the following recruitment and selection purposes:

1. To identify and contact potential candidates.
2. To manage your application and communicate with you during the recruitment process.
3. To assess your suitability for a role, including your skills, experience, qualifications, competencies and motivation.
4. To arrange and conduct interviews, assessments, tests, case studies or other recruitment activities.
5. To make decisions about your recruitment, selection and appointment.
6. To check that you are legally entitled to work in the country where the role is located.
7. To verify information you provide, including qualifications, employment history or references, where applicable.
8. To conduct pre-employment screening checks, where required or permitted by law.
9. To manage candidate feedback and candidate experience.
10. To carry out equal opportunities monitoring and reporting, where permitted by applicable law.
11. To conduct recruitment analytics, such as reviewing application rates, recruitment process efficiency and candidate experience, using aggregated or anonymised data where possible.
12. To prevent fraud, protect our business, comply with legal and regulatory obligations, and deal with legal claims or disputes.
13. To support administrative recruitment activities, such as interview scheduling, internal reporting, candidate communications and recruitment workflow management.
14. To use approved AI-enabled tools for recruitment administration and documentation, including interview transcription, interview summarisation, scheduling support, candidate communications and recruitment workflow management, as explained in this notice.

OpenPayd will use AI-enabled tools only for the approved recruitment purposes described in this notice and only where the use is necessary and proportionate. OpenPayd will not use candidate personal data processed through approved AI-enabled tools for unrelated purposes, such as training general-purpose AI models, developing unrelated products, employee monitoring, marketing, profiling unrelated to the role, or assessing protected or sensitive characteristics.

5. HOW DO WE USE AI-ENABLED TOOLS IN THE RECRUITMENT PROCESS?

OpenPayd may use approved AI-enabled tools during the recruitment process to support interview administration, documentation, scheduling, candidate communications and process efficiency.

In particular, OpenPayd may use AI-enabled tools in connection with one-way interviews, such as pre-recorded candidate interviews, and two-way interviews, such as live interviews with OpenPayd interviewers, to create interview transcripts, summaries, notes or similar records of the interview.

The purpose of using AI in this context is to support the Talent Acquisition team, Hiring Managers and interviewers by improving the efficiency, accuracy and consistency of interview documentation. For example, AI-generated transcripts or summaries may help interviewers review what was discussed during an interview, prepare interview notes, reduce manual note-taking and maintain appropriate recruitment records.

OpenPayd does not use AI-enabled tools to make recruitment, selection, rejection, ranking or hiring decisions about candidates. AI-generated transcripts, summaries, notes or other outputs are used only as administrative and documentation support. They do not replace human judgment and must not be treated as final or automatically accurate.

OpenPayd does not use AI-enabled interview tools to generate suitability scores, candidate rankings, personality scores, sentiment scores, emotion recognition results, biometric identification, biometric categorisation, social scoring or automated assessments of protected or sensitive characteristics.

Final recruitment decisions are always made by authorised OpenPayd employees, such as members of the Talent Acquisition team, Hiring Managers and relevant interviewers. Decisions about whether to progress, reject, select or hire a candidate are based on human assessment of objective, role-related criteria, such as skills, experience, qualifications, competencies, interview performance and role requirements.

Where AI-generated transcripts, summaries or notes are used, they may be reviewed, corrected, supplemented, challenged, disregarded or overridden by OpenPayd employees. Candidates will not be rejected, ranked lower, selected or otherwise treated less favourably solely because of an AI-generated transcript, summary, note or other AI-generated output.

By reading this notice, you acknowledge that your interview may be recorded, transcribed, summarised or otherwise documented using AI-enabled technology. Where required by applicable law, OpenPayd will obtain the candidate’s consent before recording or transcribing the interview. Candidates may contact OpenPayd if they have questions about the use of AI-enabled tools or if they require a reasonable alternative or adjustment.

If OpenPayd proposes to use an AI-enabled tool to directly communicate or interact with you, or to screen, filter, score, rank, evaluate, recommend progression or rejection, or otherwise materially affect a recruitment decision, OpenPayd will provide you with any additional transparency information and safeguards required by applicable law before the tool is used.

AI-enabled tools used in the recruitment process are subject to OpenPayd’s internal governance, privacy, information security and supplier review processes. Candidate personal data must only be processed through approved systems and must not be uploaded into unapproved public AI tools, personal AI accounts or unvetted third-party AI platforms.

 6. HUMAN OVERSIGHT AND DECISION-MAKING

AI-enabled tools may support recruitment administration and documentation, but they do not make decisions about candidates.

OpenPayd applies human oversight to ensure that AI-generated outputs are used appropriately. This means that:

1. AI-generated transcripts, summaries, notes or other outputs are treated as administrative and supportive records only.
2. AI-generated outputs are not treated as final, complete or automatically accurate.
3. OpenPayd employees may review, correct, supplement, challenge, disregard or override AI-generated outputs.
4. Recruitment decisions are made by authorised OpenPayd employees.
5. Candidates are assessed against objective, role-related criteria.
6. Candidates are not rejected, ranked lower, selected or otherwise treated less favourably solely because of an AI-generated output.
7. Employees involved in recruitment must not place undue reliance on AI-generated outputs.

Where OpenPayd uses any AI-enabled tool that could materially affect a recruitment decision, additional governance, privacy, information security, legal and AI risk reviews must be completed before the tool is used.

7. FAIRNESS, NON-DISCRIMINATION AND AI SAFEGUARDS

OpenPayd is committed to fair, transparent and non-discriminatory recruitment.

Where AI-enabled tools are used in recruitment, OpenPayd applies safeguards to reduce the risk of unfair, inaccurate, biased or discriminatory outcomes. These safeguards include:

1. using only AI-enabled tools that have been approved through OpenPayd’s internal governance processes;
2. using AI-enabled tools only for approved recruitment purposes;
3. carrying out privacy, information security, supplier and AI governance review where applicable;
4. ensuring that AI-generated outputs are used only as administrative or documentation support;
5. ensuring that recruitment decisions remain based on objective, role-related criteria;
6. ensuring that AI-generated outputs can be reviewed, corrected, supplemented, challenged, disregarded or escalated;
7. restricting or suspending the use of an AI-enabled tool where significant fairness, accuracy, privacy, security, legal or operational risks are identified;
8. ensuring relevant employees receive appropriate guidance on the permitted use and limitations of AI-enabled tools;
9. maintaining appropriate records where AI-enabled tools are used to support recruitment documentation; and
10. preventing candidate personal data from being uploaded into unapproved AI tools, public AI platforms, personal AI accounts or unvetted third-party systems.

If OpenPayd identifies that an AI-enabled tool may produce unfair, discriminatory, inaccurate or inappropriate outputs, OpenPayd will review the use of that tool and take appropriate action. This may include correcting records, restricting access, suspending use of the tool, changing the process, or escalating the matter to the Data Protection Officer, Legal, Information Security and/or the AI Governance Team. OpenPayd will apply proportionate checks to reduce risks of inaccuracy, over-reliance, bias or unfairness. For example, AI-generated transcripts and summaries may contain errors or omissions, and employees are instructed to verify relevant content against the interview context and candidate-provided information before relying on it.

8. WHAT IS THE LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA?

Under data protection legislation, we may only use your personal data where we have a lawful basis to do so.

Applicable data protection legislation may include, as applicable, the EU General Data Protection Regulation, the UK GDPR, the UK Data Protection Act 2018, the Maltese Data Protection Act, the Bulgarian Personal Data Protection Act, the Turkish Personal Data Protection Law, Canadian privacy laws, and other applicable privacy and data protection laws in countries where OpenPayd operates or recruits.

We rely on the following legal bases to process your personal data during the recruitment and selection process:

1. Steps prior to entering into a contract. We process your personal data where necessary to consider your application and take steps before entering into an employment or engagement contract with you.
2. Compliance with legal obligations. We process your personal data where necessary to comply with legal obligations, such as right to work checks, employment law obligations, regulatory requirements, tax or immigration obligations, and pre-employment checks where required or permitted by law.
3. Legitimate interests. We process your personal data where necessary for our legitimate business interests, provided that your interests and fundamental rights do not override those interests. Our legitimate interests include managing recruitment, assessing candidates, improving recruitment processes, protecting our business, communicating with candidates, managing recruitment systems and using approved tools to support efficient, fair and secure recruitment.

OpenPayd may also rely on legitimate interests to use approved AI-enabled tools for interview administration, transcription, summarisation, note-taking, scheduling support, recruitment workflow management and process efficiency, provided that OpenPayd has assessed that its interests are not overridden by the candidate’s rights and freedoms. Where we rely on legitimate interests, you have the right to object to that processing. You can do this by contacting [email protected]

4. In limited circumstances, we may rely on your consent. For example, we may ask for your consent to keep your details for future job opportunities after the recruitment process for a specific role has ended, where consent is the appropriate legal basis.Where applicable law requires consent for recording, transcription or similar interview processing, OpenPayd will request consent before carrying out that processing. Where a candidate does not wish to consent, OpenPayd will consider whether a reasonable alternative is available.

Some personal data is classified as “special category data” or “sensitive personal data” under data protection laws. This may include information relating to health, disability, racial or ethnic origin, religious or philosophical beliefs, political opinions, trade union membership, sex life, sexual orientation, genetic data or biometric data.

We only process special category data where permitted by law. For example, we may process health or disability information where you ask us to make reasonable adjustments during the recruitment process, or we may process equal opportunities information where permitted by law and appropriate safeguards are in place.

Where criminal record or background check information is required, we will only process such information where permitted by applicable law and where appropriate safeguards are applied.

Where EU or UK data protection law applies, OpenPayd will process special category data only where an Article 9 condition, UK Data Protection Act 2018 condition, or equivalent local-law condition applies, such as employment law obligations, equality of opportunity monitoring, reasonable adjustments, legal claims, substantial public interest, or explicit consent where appropriate.

Candidates should avoid sharing special category data or sensitive personal data during interviews or assessments unless it is relevant to the recruitment process, such as information needed for reasonable adjustments. Where special category data or sensitive personal data is incidentally captured in a recording, transcript, summary, note or other AI-generated record, OpenPayd will restrict access and use, will not use that information to make recruitment decisions except where permitted or required by law, and will delete, redact or minimise the information where appropriate.

9. WHAT HAPPENS IF YOU DO NOT PROVIDE THE PERSONAL DATA THAT WE REQUEST?

We need certain personal data to conduct the recruitment and selection process.

If you do not provide personal data that is necessary for the recruitment process, we may not be able to continue with your application or offer you employment or engagement.

Where information is optional, we will make this clear where appropriate. If you choose not to provide optional information, this will not normally affect your application.

10. HOW DO WE SHARE YOUR PERSONAL DATA?

We may share your personal data with the following recipients where necessary for the recruitment process:

1. OpenPayd employees involved in recruitment, such as the Talent Acquisition team, Hiring Managers, interviewers, People team, Legal, Compliance, Risk, Finance or other relevant internal stakeholders.
2. Other OpenPayd Group companies, where necessary for recruitment, internal reporting, workforce planning, group administration, or where the role involves more than one OpenPayd entity.
3. Recruitment agencies, search firms, local advisors or referral sources involved in the recruitment process.
4. Third-party service providers that support recruitment, such as applicant tracking systems, talent acquisition platforms, assessment providers, scheduling tools, background screening providers, communication tools, cloud hosting providers, and approved AI-enabled tool providers.
5. Professional advisors, such as lawyers, auditors, insurers or consultants.
6. Regulators, supervisory authorities, law enforcement agencies, courts or other public authorities, where required by law or necessary to protect our rights or comply with regulatory obligations.
7. Prospective purchasers, investors, joint venture partners or advisers, where relevant in the context of a business reorganisation, restructuring, sale or transfer.

Where we share your personal data with third parties, we take steps to ensure that appropriate contractual, technical and organisational safeguards are in place.

Where OpenPayd uses approved AI-enabled recruitment tools, the relevant provider will act as a processor unless otherwise stated. OpenPayd maintains a current list of key recruitment technology and AI-enabled tool providers, including their processing purpose and applicable transfer safeguards. Candidates may request further information about the providers used in their recruitment process by contacting [email protected].

11. DATA SECURITY

We apply appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, loss or destruction.

These measures may include:

1. Secure recruitment systems and access controls.
2. Restricting access to personal data to employees and service providers who need access for recruitment purposes.
3. Authentication and authorisation controls.
4. Confidentiality obligations for employees and service providers.
5. Security review of relevant technology providers.
6. Internal information security and acceptable use policies.
7. Data protection policies and procedures.
8. Training or guidance for employees handling candidate personal data.
9. Controls to prevent use of non-approved AI tools or public AI platforms for candidate personal data.
10. Incident management and personal data breach procedures.

Candidate data must not be uploaded into non-approved public AI tools, personal accounts or unvetted external platforms.

12. INTERNATIONAL DATA TRANSFERS

Your personal data may be transferred to, stored in or accessed from countries outside the country where you are located, including countries outside the European Economic Area or the United Kingdom.

This may happen where personal data is processed within OpenPayd or by third-party service providers located in other countries.

Where we transfer personal data internationally, we will ensure that appropriate safeguards are applied in accordance with applicable data protection laws. These safeguards may include:

1. Adequacy decisions, where the relevant country has been recognised as providing an adequate level of protection.
2. EU Standard Contractual Clauses.
3. The UK International Data Transfer Addendum or other UK transfer mechanisms.
4. Transfer risk assessments or third-country assessments, where required.
5. Data processing or data sharing agreements.
6. Additional technical and organisational measures where appropriate.

You may contact us if you would like more information about the transfer safeguards used for your personal data.

Where personal data is transferred outside the United Kingdom or European Economic Area, including through access by OpenPayd group companies or approved third-party providers, OpenPayd will assess the transfer mechanism and destination risk where required. Candidates may request further information about the applicable transfer mechanism and, where legally available, a copy or summary of the relevant safeguards.

13. DATA RETENTION

We keep your personal data for as long as necessary to fulfil the purposes for which it was collected and processed, including recruitment, legal, regulatory, accounting, reporting, audit and recordkeeping purposes.

To determine the appropriate retention period, we consider:

1. The amount, nature and sensitivity of the personal data.
2. The purposes for which the data is processed.
3. Whether those purposes can be achieved through other means.
4. The potential risk of harm from unauthorised use or disclosure.
5. Applicable legal, regulatory, employment, limitation and data protection requirements.
6. Whether the data may be needed in connection with legal claims.

If you are a successful candidate, some of your personal data may become part of your employment record and will be retained in accordance with applicable employee privacy information and internal retention policies.

If you are an unsuccessful candidate, we will generally delete or anonymise your recruitment information after the applicable retention period, unless:

1. You consent to us keeping your information for future opportunities.
2. We are required by law to keep the information for a longer period.
3. We need to keep the information for legal claims, regulatory purposes, audit purposes or legitimate business reasons.

We keep unsuccessful applicants’ information no longer than the below defined period from the date the job posting has been closed, unless a longer period is required or permitted by law:

AI-generated transcripts, summaries, notes and related recruitment records will normally be retained in line with the applicable recruitment retention period set out above, unless a shorter period applies. Where interview recordings are created, OpenPayd will retain them only for as long as necessary for the recruitment purpose, quality review, dispute handling or legal/regulatory requirements, and will delete or anonymise them when no longer required.

14. YOUR RIGHTS

Data protection laws provide you with several rights in relation to your personal data. These rights apply to processing carried out by OpenPayd Group companies as data controllers during the recruitment and selection process.

Depending on the applicable law and circumstances, your rights may include:

1. Right to be informed. You have the right to receive clear information about how we collect and use your personal data, including information about the use of AI-enabled tools where applicable.
2. Right of access. You have the right to ask whether we process your personal data and to request a copy of the personal data we hold about you, subject to applicable exemptions.
3. Right to rectification. You have the right to ask us to correct inaccurate or incomplete personal data.
4. Right to erasure. You have the right to ask us to delete your personal data in certain circumstances.
5. Right to restriction of processing. You have the right to ask us to restrict the processing of your personal data in certain circumstances.
6. Right to object. You have the right to object to processing of your personal data where we rely on legitimate interests, subject to applicable legal conditions.
7. Right to data portability. Where applicable, you have the right to receive personal data you provided to us in a structured, commonly used and machine-readable format.
8. Right to withdraw consent. Where we rely on your consent, you have the right to withdraw that consent at any time. This will not affect processing carried out before your consent was withdrawn.
9. Rights relating to automated decision-making. OpenPayd does not make recruitment, selection, rejection, ranking or hiring decisions solely by automated means where such decisions would produce legal effects or similarly significantly affect you. If this position changes, OpenPayd will provide additional information and apply any safeguards required by applicable law..
10. Rights relating to AI-generated personal data. Where AI-generated transcripts, summaries, notes or similar outputs contain your personal data and form part of your recruitment record, you may exercise your applicable data protection rights in relation to that personal data, including the right of access, rectification, erasure, restriction, objection and withdrawal of consent where consent is relied upon, subject to applicable legal conditions and exemptions.
11. Right to complain. You have the right to complain to a relevant data protection supervisory authority if you believe your personal data has been processed unlawfully or unfairly.

15. CANDIDATE TRANSPARENCY IN RELATION TO AI-ENABLED TOOLS

OpenPayd is committed to transparency where AI-enabled tools are used in the recruitment process.

This notice informs candidates that OpenPayd may use approved AI-enabled tools to support recruitment administration and documentation. This may include the recording, transcription, summarisation, note-taking or other documentation of interviews, including one-way interviews, such as pre-recorded candidate video interviews, and two-way interviews, such as live video or in-person interviews with OpenPayd interviewers.

Where AI-enabled tools are used for these purposes, they are used only to support administrative and documentation activities, including interview records, interview summaries, scheduling support, candidate communications and recruitment workflow management. They are not used to screen, filter, score, rank, evaluate, recommend progression or rejection, or make recruitment, selection, rejection or hiring decisions about candidates.

AI-generated transcripts, summaries, notes or other outputs may contain errors or omissions. They are not treated as final, complete or automatically accurate and may be reviewed, corrected, supplemented, challenged, disregarded or overridden by authorised OpenPayd employees. Final recruitment decisions are always made by authorised OpenPayd employees using objective, role-related criteria, such as skills, experience, qualifications, competencies, interview performance and role requirements.

Where candidates communicate or interact directly with an AI, OpenPayd will inform candidates clearly and in a timely manner that they are interacting with AI, unless this is obvious from the context. This information will be provided before or at the time of the direct AI interaction.

Where applicable law requires consent for recording, transcription or similar interview processing, OpenPayd will request consent before carrying out that processing. If a candidate does not wish to consent, OpenPayd will consider whether a reasonable alternative or adjustment is available.

Further information about the approved AI-enabled recruitment tools and providers used in the recruitment process is available on request. Candidates may contact OpenPayd at [email protected] for recruitment-process questions or [email protected] for data protection questions, provider information, transfer safeguards, rights requests, concerns about AI-generated records, or requests for a reasonable alternative or adjustment.

16. HOW TO EXERCISE YOUR RIGHTS

You can exercise your rights at any time by contacting:

People Team: [email protected]
Data Protection Officer: [email protected]

When submitting a request, please provide:

1. A clear description of the right you want to exercise.
2. A description of the personal data or recruitment process your request relates to.
3. Information that allows us to verify your identity.
4. Any relevant details that will help us respond to your request.

We may ask you for additional information where necessary to confirm your identity or clarify your request.

You will not usually have to pay a fee to exercise your rights. However, we may charge a reasonable fee or refuse to comply where a request is clearly unfounded, repetitive or excessive, where permitted by law.

We aim to respond to legitimate requests within one month, unless a different timeframe applies under applicable law. If your request is complex or you have made several requests, we may need more time. Where this happens, we will inform you.

17. COMPLAINTS

If you have a complaint, please contact us first so that we can review and respond to your complaint.

You also have the right to complain to a relevant data protection supervisory authority.

Depending on your location or the relevant OpenPayd entity, this may include:

1. In the United Kingdom, the Information Commissioner’s Office.
2. In Malta, the Office of the Information and Data Protection Commissioner.
3. In France, the Commission Nationale de l’Informatique et des Libertés.
4. In Turkey, the Personal Data Protection Authority.

5. In Bulgaria, the Commission for Personal Data Protection.
6. In other EEA countries, the relevant local data protection supervisory authority.

18. CHANGES TO THIS NOTICE

We may update this Talent Acquisition AI and Privacy Notice from time to time, including where our recruitment processes, AI-enabled tools, legal obligations or internal policies change.

Any updated version will be made available to candidates through appropriate channels.