Aspire Workforce and Recruitment Privacy Policy
We are committed to protecting personal information that we receive about our employees, agency staff, consultants and applicants applying to us for a position. We are committed to maintaining transparent practices and explaining how we collect, process, and share that information. Protecting your privacy is very important to us. This privacy notice explains how and why Aspire Health Management Solutions Operations Investments RSC LTD and its subsidiary Aspire Solutions Operations Health Insurance Claims Management L.L.C. (“Aspire”)collects personal information in relation to our employees, agency staff, consultants, and job applicants (“you”), and how we use it.
Who is Aspire ?
Aspire is a Third-Party Administrator company in the United Arab Emirates with its which focuses primarily on the administration of life- and health-related reinsurance solutions. Aspire is the controller responsible for the personal information we collect and process. Other entities may also be in respect of your personal information, depending on their involvement in recruitment and employment-related matters.
This Privacy Notice sets out:
• What personal information we may collect and hold;
• The purposes for which your personal information may be collected, held, used and disclosed;
• How we collect and hold your personal information;
• What other information we use about you;
• How we protect your personal information;
• With whom we may share your personal information (including overseas recipients);
• How you may access and correct your personal information; and
• How you can contact us.
Application of Local Laws
At times, the privacy legislation and an individual’s right to privacy differ by jurisdiction. Aspire recognizes that certain laws might be amended to require stricter standards than those described in this privacy notice, in which case we will ensure compliance with those stricter standards. Aspire will handle personal information in accordance with local law at the place where the personal information is collected. If applicable law provides for a lower level of protection of personal information than that established by this privacy notice, then this privacy notice shall prevail.
What do we mean by “personal information”?
Personal information is any information or combination of pieces of information that could reasonably allow an individual to be identified or that relate to an identifiable person. It includes information that can be used to identify a person, directly or indirectly, by reference to another.
How do we collect personal information?
If you are applying for a position with Aspire, we may collect your personal information in the following ways (to the extent permissible under local law):
• from your application and CV, which you provide directly to us;
• from your application and CV, which a recruiter provides to us on your behalf;
• by interviewing and communicating with you and conducting assessments to test your suitability for a role;
• by performing background checks with employment screening agencies or publicly available registers (as permitted by law).
• from publicly available professional profiles on websites or social media (e.g. LinkedIn);
• from former employers or other referees, including Aspire employees.
If you are an employee of Aspire, we may collect your personal information in the following ways (to the extent permissible under local law):
• through photography and videography with your voluntary participation;
• by performing engagement surveys;
• directly from you, when you first joined the company and throughout your employment;
• from our communications with you throughout your employment;
• from managers, other employees, clients, or service providers that provide feedback about you throughout your employment;
• by performing ad hoc background checks with employment screening agencies or publicly available registers
• from professional or regulatory bodies;
• through the use of CCTV and time management systems on our premises; and
• by monitoring the use of our IT systems and applications.
What types of information do we collect and process?
The type of personal information we collect and process about you will depend upon specific circumstances relating to your recruitment and employment with us and local laws relevant to the UAE office you are engaged with.
If you are applying for a position with Aspire, we may collect the following categories of personal information about you:
• Personal details: name, gender, date of birth, citizenship, nationality, military status, disability;
• Financial background information: credit check;
• Contact details: phone number, email address, postal address, mobile number;
• Educational and professional background information: educational and professional
history, qualifications, certifications, skills, licenses, and professional memberships;
• Right-to-work information: your citizenship, work, and residence permits, visas;
• Information about your current employment: job title, responsibilities, compensation history;
• Personality or psychometric tests information.
If you are an employee of Aspire, we may collect the following categories of personal information about you:
• Personal details: name, gender, date of birth, employee number;
• Contact details: phone number, email address, postal address, mobile number;
• Photographs, video footage, or your images;
• Identification documents: a copy of your passport, identity card, or driving license;
• Information about your family: marital status, dependents;
• Emergency contacts: next of kin, their names, relationship with you, and contact details;
• Employment information: your job role, employment contract, start and leave dates, salary (including your level and grade), working pattern;
• Pay-related information: your bank account details, payroll information, tax information, retirement and/or pension information, details of any leave, and expenses claimed;
• Benefits-related information: available benefits, payments claimed;
• Personality or psychometric tests information;
• Performance and training information: performance at work, promotions, training history, development needs;
• Investigations-related information: grievance and dignity at work matters, disciplinary records, warnings or penalties issued, whistleblowing concerns;
• Monitoring-related information: information derived from monitoring IT acceptable use standards, including employee user ID, IT systems access logs, CCTV records, time management system records
• Information about your personal and family life (only if you voluntarily share it with your colleagues).
Some of the personal information we ask you to provide is mandatory, which means that you must provide this to us for us to continue recruiting or employing you and/or to fulfill our legal obligations.
Where it is mandatory for you to provide certain information, we will make this clear to you when we ask for the information.
Do we process any special category personal information?
If you are applying for a position with Aspire, we may collect the following special category personal information:
• Criminal records: confirmation whether you have committed any criminal offense and security measures that were applied.
• Information relating to your diversity (only if you voluntarily shared it with Aspire).
If you are an employee of Aspire, we may collect the following special category personal information:
• Criminal records: confirmation whether you have committed any criminal offense and security measures that were applied;
• Health information: sick leave forms, details of reasonable adjustments at the office;
• Accident records (only if you have an accident at work);
• Information relating to your diversity (i.e., ethnicity, race).
For what purposes do we use your personal information?
If you are applying for a position with Aspire, we use your personal information to:
• facilitate the recruitment process and match your details to job opportunities;
• check whether you have previously applied for a job with us
• communicate with you in relation to your application;
• assess your professional experience, skills, and abilities for a specific role;
• provide you with an adequate offer;
• keep you informed of job opportunities that we think may be of interest.
Under certain circumstances, we may also use your special category personal information to take precautionary measures and ascertain that you were not involved in criminal activities and are able to carry out specific responsibilities at Aspire.
If you are an employee of Aspire we use your personal information to:
• take precautionary measures and ascertain that you were not involved in criminal activities and are able to carry out specific responsibilities at Aspire;
• monitor diversity among job applicants and foster inclusion;
• ensure data accuracy regarding the records that Aspire already retains;
• represent Aspire’s workforce accurately, including its diversity, in internal and external communications, promotional and marketing materials (only with your explicit consent and in compliance with local data protection laws);
• carry out the contract we have with you and manage our human resources processes;
• compensate you for your work, administer our payroll and your leave entitlements;
• provide you with applicable pension entitlements and benefits;
• assess your performance, identify development needs, conduct pay and grading reviews, administer promotions, and provide training;
• plan succession;
• deal with any disputes or reported misconduct and comply with legal obligations to which we are subject and cooperate with regulators and law enforcement bodies;
• conduct investigations and resolve employee disciplinary or grievance issues;
• provide you with access to our premises, equipment, and systems;
• maintain the security of our premises, systems, facilities, and data.
We may also process your special category personal information for the following purposes:
• to comply with a legal obligation to prevent unfair discrimination;
• to represent Aspire’s workforce accurately, including its diversity, in internal and external communications, promotional and marketing materials (only with your explicit consent and in compliance with local data protection laws);
• to take precautionary measures and ascertain that you were not involved in criminal activities and are able to carry out specific responsibilities at Aspire;
• to comply with our health and safety obligations, including administration of sick pay, monitoring and managing of sickness absence, and adapting the workplace or our facilities for your needs;
• to foster diversity in the workplace, for example, to make special arrangements to accommodate religious beliefs or to promote diversity in the workplace.
Do we use personal information for profiling and automated decision-making?
We may use technology (including technology provided by third-party service providers) to process your personal information in a manner that constitutes “profiling” (to the extent permissible under local laws). This involves the use of software that can evaluate your personal aspects and predict risks or outcomes. The main examples of when we conduct profiling are:
• when we use personality or psychometric tests, particularly in the recruitment process.
These tests analyze your responses to highlight potential strengths and weaknesses and your possible match for certain types of roles, but we do not use these tests to automatically select or eliminate candidates; and
• for workforce management. We may use software to ensure our workforce is managed and utilized efficiently, to predict risks in staff retention, and to ensure that employees are being compensated fairly.
Although we may use profiling to assist our decision-making, we do not make solely automated decisions about individuals. We do not make decisions about hiring, compensation, dismissal, promotion, or other matters which may significantly impact an individual, without assessing all the circumstances.
What are the legal bases on which we use your personal information?
We are committed to processing your personal information fairly and lawfully and only to the extent necessary to achieve the purposes listed above.
We must have a legal basis to process your personal information. In most cases, our ability to obtain and process your personal information is based on one of the following:
• to take necessary steps prior to entering a contract with you.
• to fulfill our contractual obligations to you in connection with your contract with us.
• to comply with our legal obligations, for example obtaining proof of your right-to-work status or carrying out background checks or preventing unfair discrimination.
• to comply with our legal obligations to you, for example health and safety obligations that we must comply with as your employer, applicable laws in the reinsurance sector, or other applicable employment laws.
• to meet our legitimate interests, for example, to conduct the recruitment process efficiently and fairly, to manage our employees effectively, to develop, train and provide feedback on our employees, to monitor compliance with internal policies, to communicate effectively internally, to budget for payroll expenses, and to protect the company (and other employees) against theft, cybersecurity threats or other crimes. When we process personal information to meet our legitimate interests, we put in place robust safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms. If you wish to obtain further information concerning the balancing test that we carry out, please contact us at the details contained in the “Contact us” section below; and
We may obtain your explicit consent to collect and use certain types of personal information, for example when we are required to do so by law, when taking photographs or video, or if candidates ask us to pass their details to a third party for recruitment or background check purposes. If we ask for your consent to process your personal information, you may withdraw your consent at any time by contacting us at the details contained in the “Contact us” section below.
For more information about how these legal bases apply to the processing of your personal information, please seek for more detail at the following
link: https://www.healthaspire.com/
With whom do we share your personal information?
Depending on the circumstances relevant to the processing of your personal information, we may share it with the following parties:
• Service providers. We may share your personal information with service providers that perform services and other business operations for us, for example, we may partner with other companies for payroll administration, offering and administering benefits, employee vetting, immigration advice, psychometric testing, hosting the HR platform, photography/videography, budget administration and analyzing information to improve our processes and policies.
• Hotels, transport providers, and relocation companies, in order to provide relocation support or to arrange transport and accommodation for you, when needed.
• Any law enforcement agency, court, regulator, government authority, or professional body. We may share your personal information with these parties where we believe this is necessary to comply with a legal or regulatory obligation or otherwise to protect our rights or the rights of any third party.
How do we protect personal information?
We implement technical and organizational measures to ensure a level of security appropriate to the risk to the personal information we process. These measures are aimed at ensuring the on- going integrity and confidentiality of personal information. We evaluate these measures on a regular basis to ensure the security of the processing.
How long do we retain personal information?
If you are an employee, we will keep your personal information for up to 11 years following the termination of the relationship in accordance with our retention policy that enables us:
• Provide you with any continuing benefits such as pension or insurance;
• Comply with record retention requirements under the law;
• Defend or bring any existing or potential legal claims;
• Deal with any queries or complaints you may have; and
• Conduct checks against departing employees that move to certain controlled functions, in accordance with regulations.
We will delete your personal information when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.
If you are applying for a job with us, we will retain your personal information until the position you are applying for has been filled, after which we will retain your personal information in accordance with our retention policy for a period of time that enables us to:
• Check our records should you apply for another role with us;
• Comply with record retention requirements under the law;
• Defend or bring any existing or potential legal claims; and
• Deal with any queries or complaints you may have.
We will delete your personal information when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.
Where do we process your personal information?
Your personal information may be transferred to, stored, and processed by entities in other countries, which may include countries that are not regarded as ensuring an adequate level or protection for personal information under your local law. Therefore, Aspire has adopted Binding Corporate Rules (“BCRs”) to enable us to make international transfers of your personal information in compliance with data protection laws.
We typically put in place appropriate safeguards in accordance with applicable legal requirements to ensure that your personal information is adequately protected. We have implemented appropriate controls in each Aspire location that processes your personal data.
For more information on the appropriate controls and safeguards in place, please contact us at the details contained in the “Contact us” section below.
What Rights do you have in relation to the personal data we hold?
• You have certain rights regarding your personal information, subject to local laws and circumstances relating to the processing of your personal data.
• Right to be informed
• Right to access
• Right to rectification
• Right to erasure
• Right to object/opt-out
• Right to data portability
• Right not to be subject to automated decision-making
• Right to restriction of processing
If you would like to discuss or exercise such rights, please contact the HR department or the Global Privacy & Security Office (GSPO) at dsr@Aspire.com, or by using the contact details provided in the section ‘Contact us’ below. We encourage you to contact the HR department to update or correct your information if it changes or if the information, we hold about you is inaccurate.
We are committed to working with you to obtain a fair resolution of any request, complaint, or concern about privacy. If, however, you believe that we have not been able to assist with your request, complaint, or concern, you may have the right to make a complaint to your local supervisory authority. Contact details of the supervisory authority are available at the following link: https://www.centralbank.ae/
Contact us
Aspire Solutions Operations Health Insurance Claims Management L.L.C. is the controller responsible for the personal information we collect and process.
Our headquarters postal address is:
Aspire Solutions Operations Health Insurance Claims Management L.L.C. 4303, Al Salam Tower, Media City, Sheikh Zayed Road, Dubai, UAE, P.O. Box: 186907
Our telephone number is:
Tel: +971 4 272 1120
How do we make changes to this privacy notice?
You may request a copy of this privacy notice from us using the contact details set out above. We may modify or update this privacy notice from time to time. If we make a significant change to this privacy notice, we will notify you and, where appropriate, give you sufficient advance notice so that you have the opportunity to exercise your rights (e.g., to object to the processing).
You will be able to see when we last updated the privacy notice because we will include a revision date, shown below.
Last updated: 15 April 2024
Thank you for choosing Aspire. We are dedicated to providing you with excellent service while respecting your privacy and protecting your personal data.