Privacy notice applicants

Introduction

We and our affiliated companies care about your privacy and are committed to protecting your personal information in accordance with fair information practices and applicable data privacy laws.

 

This Data Privacy notice is intended to describe the practices we follow in relation to the Global Applicant Tracking System (“System”) with respect to the privacy of applicants.

The Global Applicant Tracking System is a cloud-based applicant tracking system. Our group uses this application globally to conduct its recruitment activities and to provide job opportunities in the country you are about to apply to as well as other countries
and regions. This notice will provide comprehensive information about how we will use your personal information within this System and to inform you about your rights in this regard. If you have any questions regarding the processing of your personal information in the System, please contact us using the email- address displayed below.

If you are merely a visitor to our Careers site, we do not collect any personal information about you, except to a limited extent through the use of cookies as described in the relevant section. However, if you are applying for an advertised position, we collect information about you when you create a Candidate Profile in the System.

The provision of your personal information is optional at any time. However, please be aware that your refusal to provide us with your personal information or to process it in the System may result in us not being able to carry out any activity related to your recruitment in this online environment.

Scope

This privacy notice explains how we – regardless of nationality or residence - handle the personal data of:

  • Any natural person who applies for an advertised job vacancy
  • Any natural person who applies spontaneously with the intention that his/her resume will be included in our database intended for recruitment and selection
  • Any natural person whose resume was passed on to us through a third party by a recruitment firm.

Personal data means any information relating to an identified or identifiable natural person (‘data subject’). An identifiable natural person is someone who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Special categories of personal data means personal data in the following categories: ethnic or racial origin, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, gender, sexual orientation, bio-metric data where processed to uniquely identify a person, genetics, criminal convictions.

Data controller

The data controller for your personal information is our entity which is responsible for the advertised position and to whom you address your application.

It is possible that entities may be jointly responsible for your personal information if you submit applications to multiple entities via the System.

We license the System from SAP SuccessFactors, 1 Tower Place, Suite 1100, South San Francisco, CA 94080, USA (“SAP SuccessFactors”). SAP manages the system on our behalf for the benefit of our entities globally. The servers which host the system are owned by SAP and located in Rot, Germany.

Categories of Personal Data

To be able to apply for our career opportunities, you need to create an account into the System. This “Candidate Profile” requires a valid e-mail address as a login, along with other information, some of which is mandatory. Mandatory information will be marked accordingly. Your e-mail address allows us to communicate with you if your qualifications and/or preferences match job opportunities, or if you opt to receive automated notifications of job postings at any of our entities. Your Candidate Profile also makes it possible for you to access the System to monitor the progress of your application or to amend your personal details should you wish to do so. 


During the different stages of the recruitment and selection process, we may process – to the extent necessary and permitted by local law - the following personal data:

  • Personal identification information such as your name, home address;
  • E-mail address and phone number;
  • Work-related information such as current job title and responsibilities, previous positions and professional experience, reason for leaving;
  • Position(s) previously applied for (at our company) and job preferences, how you heard about the position;
  • Compensation and benefits information such as (gross) salary and salary package expectations;
  • Educational and training information such as educational awards, certificates and licenses, in house training attendance;
  • Performance related data such as objectives, ratings, comments, feedback results, career and succession planning, skills and competences and other work-related qualifications;
  • Information needed for compliance and risk management such as disciplinary records, background check reports and security data;
  • Data relating to mobility (driving license, transport options);
  • Your willingness to travel if the applied position so requires;
  • Immigration, right to work and residence status;
  • Government-issued identification numbers such as national ID, social security number;
  • Family and emergency contact details;
  • Payment related information, including identification and bank account numbers;
  • Data resulting from professional competence and skills assessments;
  • Data obtained from a personality test.


In addition, we may need to collect special categories of personal information from you at a later stage in the recruitment process if local employment laws or regulations require us to do so, such as:

 

  • Health certificates for a specific function, a function with increased caution or an activity with a specific risk;
  • Criminal convictions and prosecutions (for certain safety functions and/or in certain countries);
  • Religious beliefs (in certain countries);
  • Bio-metric data such as photographs with the purpose to uniquely identifying a person

Purposes of processing

We will only collect and process your personal data to the extent necessary for the purposes of recruitment and selection.


Your personal information is processed in the System so that our recruitment teams can consider and manage your application for the advertised position and to contact you. Your personal information will be used by us to build the global talent pool database. This will include planning and monitoring recruitment campaigns and notifying you from time to time of current vacancies.

We do not collect or compile personal information obtained by this System for dissemination or sale to outside parties for consumer marketing purposes or host mailings on behalf of third parties.

Legal bases for processing

We process above stated personal data on the following legal bases:

1) You have expressly given your consent e.g. by providing us with your resume, certificates, etc.

2) The processing is necessary for the performance of the contract e.g. drawing up employment contract.
 

3) The processing is required by law e.g. recruitment for a safety function may require certain certificates by law. Specific cases will always be explained in a separate interview.

4) The processing of your data is necessary to protect the legitimate interests of our company with a view to a proper assessment of your application, provided that the interests or fundamental rights and freedoms of the applicant do not outweigh our legitimate interests e.g. forwarding your contact details to assessment centers for conducting additional tests, forwarding your data to other entities within the group that may be interested in your profile.

Applying for a job outside of your home country

If you wish to apply for a job in a country outside of your home country, we may need to ask you questions that are specific to the country where the job is located. This is because in certain countries, before we can offer someone a job, we have to ask certain additional questions. These questions will be relevant and necessary for the job advertised and consistent with our values. 

Referees

If you provide any information in relation to third parties or referees, you are responsible for obtaining their consent and ensuring they are aware that their details will be forwarded to, and used by, us.

Recipients of personal data

Access to your personal information is limited by need. All recruitment staff within the group worldwide have access to your profile on the database and are able to match your details to current vacancies.

 

SAP can access your personal information as is necessary to perform its functions but may not share any information without first obtaining permission from us. From time to time, in addition to SAP, we may need to share your personal information with other third parties. However we will only disclose your personal details for the following reasons:

 

  • When it is necessary to involve a third party service provider in order to facilitate or extend recruitment services, as we do today with SAP.
  • When explicitly requested by you.
  • As required by a court order or any other legal or regulatory requirement.

International transfers

Because we are a global company with locations in many different countries, we may transfer your Personal Information from one legal entity to another or from one country to another in order to accomplish the purposes listed above. We will transfer your Personal Information consistent with applicable legal requirements and only to the extent necessary for the purposes set out above.


Within the group of companies, Personal Information is transferred subject to the same rules and levels of security. If required, data processing agreements will be in place to ensure the necessary level of protection.

We rely on available legal mechanisms to enable the legal transfer of Personal Information across borders. To the extent that we rely on the standard contractual clauses (also called the model clauses) to authorize transfer, we will comply with those requirements, including where there may be a conflict between those requirements and this Notice. 


We will not sell or otherwise share your Personal Information outside the group of companies, except to:

 

  • service providers we retained to perform services on our behalf. We will only share your Personal Information with service providers whom we have contractually restricted from using or disclosing the information except as necessary to perform services on our behalf or to comply with legal
        requirements;
  • comply with legal obligations, including but not limited to, in response to a legitimate legal request from law enforcement authorities or other government regulators;
  • investigate suspected or actual illegal activity;
  • prevent physical harm or financial loss; or
  • support the sale or transfer of all or a portion of our business or assets (including through bankruptcy).

Retention

We will retain your personal information as long as necessary to achieve the purposes for which it was collected. If you are given and accept an offer of employment by us, personal data collected during your pre-employment period will become part of your personnel records, to be retained throughout and for a period after your employment. You will be further informed of the processing of your personal data by us within the framework of personnel management and payroll administration at the time of employment.


If we do not employ you, we may nevertheless continue to retain and use personal data collected during the recruitment process in order to consider you for new positions, and, if appropriate, to refer back to an earlier application if you submit a resume or other information to us again in the future, as well as for system administration and to perform research and analysis. 


We determine the retention period of your information based on the following retention criteria:

  • We retain your personal data as long as we have an ongoing relationship with you;
  • We retain your personal data where it is required to do so by a legal obligation to which we are subject;
  • We retain your personal data where this is advisable to safeguard our legal position (for instance in relation to statutes of limitations, litigation, or regulatory investigations).

Applicant’s rights

In addition to our commitment to transparency and this notice to applicants in order to respect the right to be informed, we also respect the following rights:

  • You have the right to obtain without constraint at reasonable intervals and without excessive delay or expense a copy of all data relating to you that are processed.
  • You have the right to obtain the rectification or update of inaccurate or out-of-date personal information. You have a responsibility to ensure you submit accurate information into the System and keep it up to date. This can be done via the "Candidate Profile".
  • You have the right to erasure of personal data.
  • You have the right to object to the processing of your personal data, unless that processing is required by law. Where the objection is justified, the processing must cease.
  • You may have the right to request data portability. Data portability is the provision of your personal information in a structured, commonly used and machine-readable form so that it may be transferred to another company easily. The right to data portability is subject to restrictions i.e. data portability does not apply to paper records and must not prejudice the rights of others or sensitive company information.
  • You have the right not to be subject to decisions based solely on automated decision making if those decisions produce legal effect or significantly affect you.
  • You have the right to withdraw any consent previously granted for a specific purpose, if consent is the legal basis for the processing of your personal information.
  • We respect these rights and have processes in place to recognize and respond to individuals wishing to exercise these rights. You may request to exercise any of these rights through your local human resources contact or by using the email-address displayed below.

Security

We are committed to ensure that your personal information processed in the System is kept secure and have implemented appropriate technical measures and security policies that protect the information we have under our control from:

  • Unauthorized access.
  • Improper use or disclosure.
  • Unauthorized modification.
  • Unlawful destruction or accidental loss.
  • All our personnel and any third parties which we engage to process your personal information are obliged to respect the confidentiality of your information.

Privacy concerns and how to contact us

If you are concerned about an alleged breach of privacy law or any other regulation by us, you can contact us using the email-address displayed below.

A Privacy Officer will be made available to investigate your complaint and give you information about how it will be handled. 


If we do not address any of your requests, or fail to provide you with a valid reason why we are unable to do so, you have the right to contact supervisory authority to make a complaint. You can find your local supervisory authority through this link: EU   Authorities

Changes to our privacy notice

We may change this data privacy statement, should it become necessary to do so. This notice may also be supplemented by other statements as needed to comply with local requirements in the country where you live or where employee representation agreement exists.