Important Information for Future Employees
On How We Collect, Use and Store Information About You
By this notice the Company, which has provided you with the job offer, and/or by your decision and with your consent, providing you with information about career opportunities within the Company (“the Company” or “we”), following the requirements of the European Union General Data Protection Regulation (EU) 2016/679 (GDPR) and other laws protecting information about you informs you on the most important aspects of the processing of your personal data within our organization. A more detailed information on the processing of your personal data will be provided at a later stage following our internal procedures.
If you have any questions, comments or complaints regarding how we collect, use and store information about you, or if you want to assert any of your rights under the GDPR please refer to the contact information provided in our job offer.
| No | Why do you collect information about me? | When this is relevant for me? | Which information about me do you collect? | Why are you legally allowed to collect my information? | How long do you use or keep information about me? |
|---|---|---|---|---|---|
| 1.1. | To conclude and perform employment contract with you, and formalize the end of the employment contract, carry out Company’s, as employer’s, obligations provided in the laws | When you are employed with us | Name, surname, personal code, address, remuneration, position, e-mail address, IBAN / BIC, birthdate, telephone number, family members (including number of children, their names and birthdates), marital status, bonuses, allowances, other wage-related benefits, payment date, payroll taxes, holidays (duration, start), declarations to public authorities, date of employment, date of dismissal, period of employment, e-mail communication Information about disability (including your children’s disability), information about incapacity, information about diseases, personal medical certificate data, information on accidents at work, health status | We conclude and perform employment contract with you (Art. 6(1)(b), Art. 88 of the GDPR) We must collect and process information in accordance with the law (Art. 6(1)(c) of the GDPR) We implement provisions of labor / social security laws (Art. 9(2)(b) of the GDPR) | 50 (fifty) years following the termination of your employment with us: employment contracts, their annexes and amendments 10 (ten) years following the termination of your employment with us: all other data |
| 1.2. | Because we use information technology tools for communication between our employees and performance of work functions | When you use and post via internal forums, accounts, applications and other information technology and communication tools allocated by us or under our directions installed by yourself | Username, full name, position, telephone number, names of employees’ teams you are a part of, names of products that you work on, your supervisor, your subordinates, locations of offices you work at, date of employment, birthdate, holiday requests, performance reviews, description about you, posts, comments, posts you liked, other information you provided in the forum, date of the post, uploaded files, e-mail address, communication, date and time of the communication, information in work accounts, other information in communication tools | During your employment: we conclude and perform an employment contract with you (Art. 6(1)(b) of the GDPR) After the end of your employment: we have a legitimate interest to ensure communication between employees, performance of work functions and business continuity (Art. 6(1)(f) of the GDPR) | 10 (ten) years following the termination of your employment with us |
| 1.3. | Because we perform video surveillance in our premises | When you work at or enter parts of our premises under video surveillance | Video surveillance footage | We have a legitimate interest to protect your and others’ security, health, life and property and the Company’s property (Art. 6(1)(f) of the GDPR) | 10 (ten) days |
| 1.4. | Because we control access to our premises by way of access badges | When you are allocated a badge to access our premises | Name, surname, date and time of entrance to the Company’s premises, badge activation date and time | We have a legitimate interest to protect your and others’ security, health, life and property and the Company’s property (Art. 6(1)(f) of the GDPR) | 6 (six) months |
| 1.5. | To represent the Company and its internal culture at social media and traditional media | When we post a photo or video of you via our social media accounts and traditional media | Full name, position, email address, phone number, photos of you, videos of you, comments on photos or videos | We have a legitimate interest to increase publicity of our Company at social media and traditional media (Art. 6(1)(f) of the GDPR) | 10 (ten) years (unless you object to such use of your data) |
| 1.6. | To defend our rights and interests in legal processes | When you are employed with us - only in case we become a party to court or other legal processes which you are related to | All information mentioned under other purposes, documents and attachments sent to you, documents and attachments submitted by you, procedural documents, court rulings, resolutions, decisions, information about criminal offenses and convictions | We have a legitimate interest to defend Company's rights in legal proceedings (Art. 6(1)(f) of the GDPR) | 10 (ten) years following the termination of your employment with us In case of legal processes: 3 (three) years following the day the court or institution decision came into force or complete enforcement of the legally binding decision |
| 1.7. | If necessary, to check or monitor work tools and property provided by us as an employer and/or your personal tools and property used for the work | In case we decide this is necessary in order to identify and investigate violations of law and work discipline, to control data security breaches, to ensure continuity of the Company's activities, to protect the Company's information and communication technologies and other legitimate interests of the Company | Work-related information in work tools and/or property | We have a legitimate interest to do that (as described in the third column) (Art. 6(1)(f) of the GDPR) | 3 (three) years (in case we need to identify infringement) 10 (ten) years (in case we need to ensure continuity of the Company's activities) In case of an identification of an infringement: Until the end of the investigation |
| 1.8. | To provide you with relevant information about new career opportunities and offers for vacant positions within the Company. | When you are interested in career opportunities at our Company, and choose to subscribe to email newsletters about new job openings. | Name, surname, email address, and the specific field of interest for new job opportunities. | We have your consent (Art. 6(1)(a) of the GDPR | For the duration of 2 (two) years (unless you withdraw your consent earlier) |
2. Which information do I have to provide you with and why?
Please refer to Section 1 above - you have to provide us with the information which we need: (i) to conclude and perform employment contract with you, and formalize the end of the employment contract, carry out Company’s, as employer’s, obligations provided in the laws; (ii) to use information technology tools for communication between our employees and task management.
In case you do not provide us with this information, we will not be able to conclude and perform the employment contract, carry out our duties as an employer, you will not be able to perform your duties in the Company.
3. Where do you get my information from?
Generally, we collect the information directly from you. However, some of the information we obtain from other group companies, recruitment agencies, LinkedIn, state social security institutions, state tax institutions, courts, law enforcement and other state institutions.
4. Do you share the information about me?
We share the information about you only where necessary and permitted by applicable laws and for the reasons listed under Section 1 above. We share the information about you with (i) other group companies providing services to us; (ii) attorneys, attorney’s assistants, notaries, bailiffs, auditors, tax, business, personnel management and other consultants, IT service providers, electronic communications service providers, travel agencies, insurance companies, archiving services providers, accounting service providers, organizers of health checks for employees and other service providers; (iii) state institutions, including labour, social security and tax authorities; (iv) police, prosecutors, courts, law enforcement, regulatory and other state authorities; (v) potential or actual acquirers of the Company's business or its part or their authorized consultants or representatives.
5. Do you disclose information about me outside the European Economic Area?
In most cases, personal data are processed and transferred in the territory of the European Union and the European Economic Area, but when necessary, the data may be transferred and processed beyond those territories. In case we will transfer your personal data to such territories, we will take all the necessary and in the legal acts indicated measures (including where appropriate, signing Model Contractual Clauses for transfer of data.
You may download a copy of the Model Contractual Clauses at: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?uri=CELEX:32021D0914&locale=en .
6. What rights do I have?
GDPR and other laws provide you with certain rights, establish procedures for implementation of and exceptions to these rights. At your request we can confirm what information we hold about you and how it is processed. If we do hold personal data about you, you can request to have your information corrected, deleted and to restrict or object to the information processing activities as well as to receive information on your right to receive (transfer) your data in a generally used electronic form. You may also withdraw any consents given to us regarding information used about you. Upon your inquiry, we would also advise how to lodge a complaint with the supervisory authority.