Privacy Notice 

Scope of this Notice and Controller

This Notice applies to candidates applying to work at MoneyGram.

This Notice applies to personal data of candidates applying to work at MoneyGram.

“MoneyGram,” “we,” and “our” throughout this Notice refers to MoneyGram Payment Systems, Inc. based in Minneapolis (Minnesota, USA) which is the entity in the MoneyGram Group responsible for recruitment on a global basis.

For all candidates applying through our website (www.moneygramjobs.com), MoneyGram Payment Systems, Inc. based in 1550 Utica Ave S #100, Minneapolis, MN 55416, USA, telephone number: +1 952-591-3000 will be a “controller” for the purposes of GDPR and/or other local laws. As a controller we are responsible for deciding how we process personal data about you.  In the course of the recruitment process, your personal data may be shared with other MoneyGram Group entities for administrative purposes. This includes MoneyGram legal entities which, in particular:

• hold the vacancy for the job position you apply for;
• are involved in the recruitment process;
• employ responsible hiring managers.

These entities will also be “controllers” in this context (Schedule 1)

Personal Data

Personal data means information that identifies you, or can be used to identify you, as an individual.

For purposes of this Notice, personal data means any information that identifies you, or can be used to identify you, as an individual. The personal data we may process about our candidates may include:

• name, home address and telephone number, date of birth, image;
  
  
• work permit status, nationality;
  
  
• recruitment data: information obtained throughout the candidate’s recruitment process, including information provided in the application (such as personal details, Curriculum Vitae, resumes, application form, references, employment history, experience and qualification), record of interview or interview notes, selection and assessment information, personality profile, professional certifications and registrations, special skills, language capabilities, memberships of committees or other bodies and educational background;
  
  
• results of pre-hire screenings, but only to the extent required for our hiring decision with regard to the specific position a candidate has applied for (e.g. references, credit checks, criminal record checks, if permitted under local laws).

How We Collect Personal Data

We collect personal data directly from you, and from other sources.

We collect personal data directly from you, for example when you provide your application to become a MoneyGram employee and let us know about your work history.

Unless otherwise stated, all personal data we request from you is obligatory. If you do not provide and/or allow us to process all obligatory personal data as requested, this may affect our ability to interact with you as a candidate and prevent us from deciding on your suitability to work for us or respectively from hiring you.

In some situations, we also collect your personal data from third parties. Please find a list of the categories of these third parties below:

• Previous employers [depending on previous employers, privately or publicly held source];
  
  
• Recruitment agencies [privately held source, HR service provider/HR/recruitment services];
  
  
• Vendors conducting background checks [privately held source, HR service provider/HR/HR services];
  
  
• Individuals recommending your candidacy [privately held source, natural persons];
  
  
• MoneyGram employees working in MoneyGram locations collecting applications on site [privately held source, natural persons].

Purposes We Process Personal Data For & Legal Bases For The Processing of Personal Data

We collect and use your personal data to manage and administer your application to work for us.

We collect, use, and disclose or otherwise process personal data about candidates for a variety of purposes, namely:

• to assess the candidate’s suitability to work for us, compare them with other candidates and make a decision whether to offer them employment;
  
  
• to carry out pre-hire screenings, but only to the extent required for our hiring decision with regard to the specific position a candidate has applied for (e.g. references, credit checks, criminal record checks, if permitted under local laws);
  
  
• to make a job offer if we make the decision to offer this to a candidate;
  
  
• to contact a candidate whose application is not successful should another potentially suitable vacancy arises during the 1 year following completion of the recruitment process for the role the candidate has applied for;
  
  
• to centralise recruitment administration and management processing operations in an efficient manner for the benefit of both candidates and us;
  
  
• to carry out any required fit and proper test under financial services regulations for candidates for senior management positions;
  
  
• to provide the candidate’s personal data to our regulatory bodies, in particular including required fit and proper test under financial services regulations for senior management; and
  
  
• to deal with any query, challenge, request for feedback or claim received in relation to our recruitment decisions.
   

If you are applying from a country where GDPR applies, the legal bases for the processing of personal data by us are in accordance with GDPR -:

• Art. 6 par. 1 lit. b) GDPR (processing necessary for performance of the contract or take steps preparatory to such a contract) – in the scope of data concerning the application to work for MoneyGram, in particular for the purposes of assessing the candidates’ suitability, carrying out pre-hire screenings and fit & proper tests for senior management positions and making job offers;
  
  
• Art. 6 par. 1 lit. c) GDPR (processing necessary for compliance with our legal obligations) - in particular as regards data (i) regarding MoneyGram's obligations arising from labor law, social security and social protection regulations, in particular those ensuring that no unlawful discrimination takes place in our recruitment decision and enabling us to demonstrate our compliance with data protection laws and anti-discrimination laws and (ii) regarding compliance with financial services regulations;
  
  
• Art. 6 par. 1 lit. f) GDPR (processing necessary for the purpose of our legitimate interests) - MoneyGram has a legitimate interest in: (i) being able to provide feedback to candidates and to be able to defend any challenge or claim made in connection with our recruitment decision; this will assist MoneyGram in avoiding the risk of financial exposure or costs incurred through challenges to recruitment decisions and to maintain its reputation, (ii) ensuring that candidates do not pose an unacceptable risk to the business or its customers, in preventing crime and other unlawful acts and to protect the business and customers from fraud, dishonesty or incompetence, (iii) being able to contact a candidate whose application is not successful should another potentially suitable vacancy arise during the 1 year following completion of the recruitment process for the role the candidate has applied for, (iv) processing for internal administration purposes of MoneyGram and MoneyGram Group, including in order to manage applications more efficiently.
   
  

Whenever the local laws provides the legal bases for the processing of personal data that are not specifically mentioned above or do not have similar meaning - we comply with those regulations.   

How We Sh

are Your Personal Data

We share your personal data to manage and administer your application.

In connection with the processing of data for the purposes referred to in section “Purposes We Use Personal Data & Legal Bases for The Processing of Personal Data”, recipients of your personal data may be:

• other entities from the MoneyGram Group, in particular: (i) MoneyGram International, Inc. based in Dallas (Texas, USA); (ii) MoneyGram Payment Systems, Inc. based in Minneapolis (Minnesota, USA); (iii) MoneyGram Poland sp. z.o.o (Warsaw, Poland); (iv) MoneyGram International SRL Branch in the UK (London, UK), (v) MoneyGram legal entities which, in particular:
  
  
  • hold the vacancy for the job position you apply for;
  • are involved in the recruitment process;
  • employ responsible hiring managers.

   

   

• entities providing services listed below (“service providers”):
  
  
  • IT and new technologies [privately held source, IT service provider/IT/IT services];
  • Application management (provider of application management tool), [USA]
  • recovery [privately held source, recovery services provider/recovery];
  • printing [privately held source, printing services provider/printing];
  • destroying documents [privately held source, recycling services provider/utilization];
  • postal and courier services [privately held source, postal services provider/courier];
  • Legal services
    
    
• personnel providers and recruitment agencies who are engaged in certain applications;
  
  
• law enforcement bodies and authorities as well as state or local government institutions, if this results from the applicable law.

All our service providers are required to take appropriate security measures to protect your personal data in line with our policies. We only permit service providers to process your personal data for specified purposes. To the extent possible under applicable regulations we engage service providers as so-called processors which may only process your personal data in accordance with our instructions. We may need to share your personal data with a regulator or to otherwise comply with the law such as immigration bodies.

Jurisdiction and Cross-Border Data Transfers

MoneyGram’s global headquarter is based in the United States. When you interact with us, your information may be sent to a country other than your own, including the United States, for processing and storage.

Transfer to other MoneyGram Group entities

We will share your personal data with other entities in our group for data hosting purposes and for recruitment support; for details see section "How We Share Your Personal Data".

Cross-border transfer of your data

MoneyGram’s global headquarter is based in the United States and several material functions and systems are operated the US which require to process data in the US. When you interact with us, you understand that your personal data will be transferred to the United States, or a different country other than your own, for processing and storage. You also understand that data protection rules of other countries may be different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your information.

Further, if you are applying from a country where GDPR applies and where MoneyGram engages recipients that are based outside the EU, then respective safeguards are in place if that country does not have same protection as in the European Economic Area (EEA). Appropriate protection of such data processing is safeguarded by MoneyGram through the application of standard contractual clauses on the protection of personal data adopted by the European Commission within the meaning of art. 46 (2) d) GDPR or through the self-certification of the recipient for the EU-US Privacy Shield within the meaning of art. 45 GDPR (for US recipients only).

If you are applying from a country where GDPR applies, you may receive an overview of third country recipients and a copy of the appropriate or suitable safeguards in place. Please use the details provided in section „Scope of this Notice” in order to do so.

Your Rights

You have certain rights to the personal data we process about you.

You can review, correct, update, suppress, restrict or delete personal information that you have given to us, or receive an electronic copy of your personal information to transmit it to another company (to the extent provided to you by applicable law).

Furthermore, if you are applying from a country where GDPR applies, you have the following rights:

• Right to access your Personal Data;
• Right to rectify your Personal Data if it is inaccurate or incomplete;
• Right to restrict the processing of your Personal if one or more of the conditions named in Art. 16 GDPR are met;
• Right to erasure of your Personal Data if one or more of the conditions named in Art. 17 GDPR are met;
• Right to data portability if one or more of the conditions named in Art. 20 GDPR are met;
• Right to object to processing of your Personal data for direct marketing purposes and to the processing of your personal data based on our legitimate interests on grounds that relate specifically to you (please see section “Information on Your Rights to Object” for further information);
• Right to lodge a complaint with a supervisory authority if you believe that the processing of your Personal Data violates applicable law.

If you have questions about this Notice or our privacy practices, or would like to exercise any of your rights, email the Privacy Program Office at privacyprogramoffice@moneygram.com, or write to:

MoneyGram
Attn: Chief Data Protection Officer
2828 N. Harwood Street
15th Floor
Dallas, TX  75201
U.S.A.

Our Information Security

We are committed to protecting the personal data we process.

Retention Period

Generally, your personal data will be kept as long as it is necessary to manage and administer the application or as long as we have a legitimate interest in continued storage, and then for the period indicated by the labor law regulations and other specific provisions, among others: Act on accounting, tax law, social security and social law.

We keep candidate’s personal data for the following periods of time:

• If an application is successful, we will keep the data for the duration of the employment and then for the period indicated by the labor law regulations and other specific provisions, among others: Act on accounting, tax law, social security and social law.
  
  
• If an application is not successful, we will delete the data within 1 year after we have informed the candidate about this or he/she has let us know that he/she is no longer interested in working with us. MoneyGram may retain personal data longer due to litigation needs or other extraordinary situations.

Contacting Us or Our Data Protection Officer

Please reach out to us at privacyprogramoffice@moneygram.com or:

MoneyGram Payment Systems, Inc.

Attn: Chief Data Protection Officer
2828 N. Harwood Street
15th Floor
Dallas, TX  75201
U.S.A.

if: (i) you have questions about this Notice or our privacy practices, (ii) you wish to request access to your information or (iii) you would like to contact our Chief Privacy Officer.

If you are applying from a country where GDPR applies, there is a right to lodge a complaint with a supervisory authority dealing with the protection of personal data.

Changes to this Privacy Notice

Information on Your Rights to Object

Right to object to direct marketing

Right to object to processing based on legitimate interest

Furthermore,  if you are applying from a country where GDPR applies, you have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data concerning you which is based on the legal basis legitimate interests.

In order to exercise this right please email the Privacy Program Office at privacyprogramoffice@moneygram.com, or write to:

MoneyGram
Attn: Chief Data Protection Officer
2828 N. Harwood Street
15th Floor
Dallas, TX  75201
U.S.A.

REGISTERED NAME OF COMPANY

COUNTRY OF INCORPORATION

REGISTERED ADDRESS

MoneyGram International Limited

UK

1st Floor, Senator House

85 Queen Victoria Street

London EC4V 4AB, UK

MoneyGram International SPRL

BELGIUM

Rue Joseph Stevens 7

BE-1000 Brussels, Belgium

MoneyGram Turkey Odeme Hizmetleri Anonim Sirketi

TURKEY

1Büyükdere Cad. Kırgülü Sok.

Metrocity AVM D Blok Kat:4

34394 Levent / Istanbul