1. Scope and controller

This notice explains how BCE Systems Limited uses personal data about applicants, prospective workers, interns, and other people who take part in a recruitment process through recruit.bce.systems or another BCE channel. BCE Systems Limited is the data controller for this processing. Our company and data-protection contact details are in section 12.

Where a role is offered by another BCE entity, the vacancy and collection point should identify that entity and provide any additional notice required.

2. Data we collect

Depending on the role and stage, BCE may collect:

identity and contact details, location, nationality where relevant to right-to-work checks, and communication history;

CV, cover letter, employment and project history, education, qualifications, memberships, licences, certifications, portfolio, and public professional profile;

vacancy preferences, availability, remuneration expectations, and right-to-work or immigration status;

interview notes, work samples, technical assessments, scoring, and hiring decisions;

referee details and references, after appropriate notice;

identity, integrity, sanctions, security-clearance, criminal-record, or other background-check information only where lawful, necessary, and proportionate for the role;

access, travel, medical fitness, emergency, or accommodation information where necessary for an assessment, site, or lawful adjustment; and

consent, privacy-request, complaint, audit, and security records.

Do not include sensitive information that BCE has not requested and does not need. If you need a disability-related or other reasonable accommodation, you may provide only the information necessary to arrange it. BCE limits access to that information.

3. Sources

BCE obtains information from you, a recruitment platform, a recruiter acting for BCE, referees you identify, former employers or institutions where verification is authorised, clients or facility operators involved in a disclosed accreditation process, lawful screening providers, and public professional or company sources relevant to the role.

If BCE obtains your details from another source for a potential role, BCE will give you appropriate privacy information within the period required by law and before using the information for a materially different purpose.

4. Purposes and lawful bases

BCE does not make agreement to future-opportunity contact a condition of applying for the current role. If a background or client-accreditation check is required, BCE will identify the check, recipient, consequences of not providing required data, and applicable basis before it begins.

5. Fair recruitment and accommodation

BCE makes employment decisions on relevant capability, qualification, conduct, operational need, and lawful eligibility. It does not discriminate on a ground prohibited by the Constitution, Employment Act, Persons with Disabilities Act, or other applicable law.

An applicant may request a reasonable accommodation for an application, assessment, interview, communication method, or accessible workplace process. BCE will consider the request individually, maintain appropriate confidentiality, and will not use the request itself as an adverse selection factor.

6. Who receives the data

Access is limited to people who need the information, which may include BCE human-resources and administration personnel, the hiring manager, authorised technical assessors, senior decision-makers, IT and security administrators, and legal or professional advisers.

BCE uses Zoho Recruit and related authorised service providers to administer recruitment. A recruiter, testing provider, screening provider, referee, former employer, educational institution, medical or security assessor, client, or secure-facility operator may receive limited data where the relevant step is lawful and necessary. BCE will provide advance information about a client or facility accreditation disclosure where practicable.

BCE may disclose information to a court, regulator, law-enforcement body, immigration authority, or other public body where required or permitted by law. BCE does not sell candidate information.

7. International transfers

Recruitment platforms, support providers, BCE regional operations, clients, or secure-site operators may process data outside Kenya. BCE applies the transfer assessment, documentation, and safeguards described in the Privacy and Data Protection Notice, with additional care for sensitive and security-related information. You may request information about the relevant destination and safeguard.

8. Retention

For an unsuccessful application, BCE normally retains the recruitment decision record and relevant application material for 12 months after the process closes to answer questions, demonstrate a fair process, and handle a legal claim. BCE then securely deletes or anonymises the record unless a legal hold or specific lawful requirement applies.

BCE contacts an unsuccessful applicant about future roles only where the applicant gave separate consent. The consent record will state the period. Withdrawal ends future contact and does not affect the original 12-month recruitment-record purpose, although a valid erasure or objection request will be assessed under the law.

If you join BCE, relevant information transfers to an employment file and is retained under the employee privacy and records schedule, including the Employment Act requirements. Unnecessary recruitment notes are not carried forward.

9. Automated processing

BCE does not make a hiring decision based solely on automated processing where the decision has legal or similarly significant effects. A platform may organise, search, or rank applications, but an authorised person reviews the relevant information and makes the decision. You may ask for information about the process and challenge an outcome as permitted by law.

10. Whether information is required

Applying is voluntary, but BCE cannot assess an application without the core identity, contact, experience, and suitability information. Information needed for a legal right-to-work obligation, an essential qualification, or a disclosed secure-site requirement may be mandatory for the relevant role. BCE will explain the consequence of not providing it.

11. Your rights and complaints

You have the access, correction, restriction, objection, erasure, portability, consent-withdrawal, and automated-decision rights described in the Privacy and Data Protection Notice, subject to their legal conditions. You may complain to the Office of the Data Protection Commissioner at www.odpc.go.ke.

12. Contact and updates

BCE Systems Limited
Attention: Data Protection
The Address, 7th Floor, Muthangari Drive, Nairobi, Kenya
P.O. Box 11474-00100, Nairobi, Kenya
Email: bce@bce.systems
Telephone: +254 20 440 9223

BCE applies reasonable access, confidentiality, transfer, retention, and breach-response controls to recruitment data. We may update this notice and will change the date above and provide appropriate notice of a material change.