Candidate Privacy Policy

Effective Date: 01/04/2023

Company: The Free Spirits FZCO

Website: www.worldwidenanny-uk.com

1. Purpose of This Document

This Privacy Policy outlines how The Free Spirits FZCO (“we”

“us” “our”) collects, uses, stores, and shares your personal data when you apply for domestic staffing roles through our agency. We are the data controller and are responsible for protecting your personal information in compliance with applicable laws in the United Arab Emirates, including the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL).

This policy explains:

What personal data we collect
Why and how we use it
How we store and secure it
With whom we may share it
Your legal rights regarding your data
Please read this document carefully. By submitting your application, you acknowledge and agree to the terms of this

2. Data Protection Principles

We are committed to processing your personal data in accordance with the following principles under UAE law. Your data will be:

Processed fairly, lawfully, and transparently
Collected for specific, legitimate purposes
Adequate, relevant, and limited to what is necessary
Accurate and kept up to date
Retained only for as long as necessary
Secured against unauthorized access, alteration, or loss
Not transferred outside the UAE unless an adequate level of data protection is ensured

3. Types of Personal Information We Collect

As part of your application process, we may collect the following personal information:

Basic Data:

Full name, title, date of birth, gender
Contact details (address, phone number, email)
Employment history, qualifications, and experience
Information provided in your CV, application forms, cover letters, or interviews
Language skills, nationality, visa/residency status

Supporting Documentation:

Passport copy, Emirates ID, residence visa
First aid certificates, driving licence, training records
Police clearance or criminal record check
Reference letters and details from referees (with your prior consent)

Sensitive Personal Data (“Special Categories”):

Information regarding health or disability (for workplace adjustments)

Ethnic background, religious beliefs, or other diversity data (for equal opportunity reporting, only where applicable)

Information on criminal convictions (with your explicit consent and where necessary for job suitability)

We will only process sensitive personal data with your explicit consent or where required by law.

4. How We Collect Your Data

We collect your personal data through:

Direct submission (CV, emails, application forms, phone, or in-person contact)
Interviews or screening calls
Supporting documents and certificates you submit
References and referee feedback (with your consent)
Public sources such as LinkedIn, where applicable
Background checks (criminal or medical, where legally required)

5. Why We Collect and Use Your Data

We use your personal data to:

Assess your suitability for roles we represent
Communicate with you during the recruitment process
Present your profile to clients seeking domestic staff (nanny, maternity nurse, governess, etc.)
Verify references, qualifications, and employment history
Conduct background or criminal checks (if required by the client or UAE law)
Maintain internal records and comply with applicable regulations

Legal Basis for Processing:

We rely on one or more of the following legal bases under UAE law:

Your consent
Performance of a contract or steps prior to entering a contract
Our legitimate interests in running a recruitment business
Legal obligations, including compliance with UAE regulations

6. Sensitive Personal Information

We may process sensitive information only:

To consider reasonable adjustments if you have a disability
To monitor diversity and equal opportunity, where applicable
To ensure suitability for roles involving childcare or vulnerable individuals (e.g., criminal background checks)
You will always be informed in advance and asked for your explicit written consent before such processing occurs.

7. Information About Criminal Convictions

For roles involving work with children or vulnerable individuals, employers may request background checks. You may be asked to obtain a police clearance certificate or equivalent documentation.

We will only process this information:

With your explicit consent, and
Where it is necessary for the role and permitted by UAE law

8. Automated Decision-Making

We do not make recruitment decisions based solely on automated processing or profiling.

9. Data Sharing

We may share your personal data with:

Potential employers (with your prior approval)
Third-party background check providers, where required
Regulatory authorities, where legally required
Our internal staff and consultants directly involved in the recruitment process

We will never sell your data or share it for unrelated purposes. All third parties are contractually bound to handle your data in accordance with UAE data protection laws and maintain confidentiality.

10. Data Security

We implement strict physical, technical, and organizational safeguards to ensure your personal information is:

Stored securely
Accessed only by authorized personnel
Protected from loss, misuse, alteration, or unauthorized disclosure

In the event of a data breach, we will notify you and the UAE Data Office, where required by law.

11. Data Retention

We retain your personal data for up to 24 months after the conclusion of your recruitment process unless:

You request its earlier deletion
We have a legal obligation to retain it longer
You give consent for extended retention (e.g., for future opportunities)

After this period, we securely delete or anonymize your data.

If we wish to retain your details for future roles, we will request your explicit consent.

12. Your Rights Under UAE Law

Under the UAE Personal Data Protection Law, you have the right to:

Access your personal data
Correct inaccurate or outdated data
Request deletion of your data (where no legal basis for retention exists)
Object to certain types of processing
Restrict processing under specific conditions
Withdraw consent at any time
Request portability of your data to another service provider (where technically feasible)

To exercise any of your rights, please contact:

Sonia Mateos

contact@worldwidenanny-uk.com

Subject line: “Data Access Request”

13. Right to Withdraw Consent

If you have provided consent for us to process your data for recruitment purposes, you may withdraw that consent at any time by contacting:

contact@worldwidenanny-uk.com

Subject line: “Withdraw Consent”Once we receive your withdrawal request, we will stop processing your data (unless we have a legal obligation to retain it) and securely delete it according to our retention policy.

14. Contact Us

For any questions or concerns about this Privacy Policy or our handling of your personal information, please contact:

The Free Spirits FZCO

contact@worldwidenanny-uk.com

www.worldwidenanny-uk.com

Registered Office Address:

Dubai Digital Park, Building A1

Dubai Silicon Oasis

Dubai, United Arab Emirates