NOTICE REGARDING PERSONAL DATA PROTECTION IN CONNECTION WITH RECRUITMENT AND SELECTION PROCESS
This information note provides information regarding your rights as a data subject in relation to the processing of your personal data and describes why and how we process your personal data if you apply for a job at EDC as a candidate or, in case you agree, to keep your data in our database for the purpose of future employment opportunities, by accessing the Careers section available on www..edenred-digitalcenter.com or in any other way. It also describes how we will process this data and comply with various laws applicable to EDC to ensure that we treat your personal data in an appropriate manner.
Edenred Digital Center S.R.L., with registered office in Bucharest, 2nd Oltenitei Road, 2nd Floor, 4th District, Unique Identification Code RO RO41026768, registered with the Trade Register under no. J40/5640/2019, Share Capital 10,000 lei (hereinafter referred to as “EDC” / “Our Company” / “We” / “potential Employer”) acts as a personal data controller when processing the candidates’ personal data (including candidates to internship programs) (“Data Subjects”) as part of the recruitment and selection process. To this end, EDC processes your personal data in accordance with REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 (the Regulation) and the other applicable legal provisions regarding processing of personal data, as potential Employer.
When you fill in the form in the Careers section available on www..edenred-digitalcenter.com or in any other way, you will send us certain personal data about with you. Also, as part of the recruitment process, we may collect certain personal data about you from other sources (see below).
I. WHAT PERSONAL DATA WE CAN COLLECT ABOUT YOU?
Personal data means any information about a natural person that identifies him/her or can lead to his/her identification.
As part of your recruitment process, we may collect and subsequently process personal data, such as:
a. your identity and contact details, including signature, for example details from the application form, details on identity, etc.;
b. your professional, personal and social background, such as certificates, diplomas, professional qualifications mentioned in the CV, valid driving license, previous jobs, financial data, historical data available on recruitment or social platforms, as well as the image if your photo is available in the documents submitted or in the afore-mentioned platforms, other data found in CVs or exposed by you in public social media;
c. data resulting from the recruitment process carried out by us, such as abilities / skills / tested knowledge, psychological profile (in certain cases) etc.).
d. data resulting from EDC video surveillance, if you travel to EDC’s headquarters during the recruitment and selection process, such as your image, voice, CCTV recordings.
II. WHY DO WE COLLECT YOUR PERSONAL DATA AND JUSTIFICATION OF USES?
PURPOSE
LEGAL GROUND
Recruitment and selection of candidates for current vacancies
We process your personal data to assess the extent to which you are suitable for EDC’s vacancies, in order to invite you to an interview, to make you a job offer or to conclude an employment contract and in compliance with EDC legislation (e.g. requirements regarding minimum age, equal opportunities).
We also process your personal data for evaluation purposes during and after the interview, in order to decide if there is an EDC interest in concluding the individual employment contract.
We may also process your personal data on the basis of our legitimate interest in undertaking a thorough and comprehensive recruitment process (e.g. for the examination of skills and knowledge, verification of candidates on professional networks).
If you do not provide us with the required information, we may not be able to complete the recruitment and selection process (which will lead to the rejection of your application) or we may not be able to contact you.
Concluding the individual employment contract
Our legal obligations
Legitimate interest
Processing for future / potential jobs
When (i) you apply for a job at EDC without aiming a specific vacancy / position in our organization, or (ii) you have not been selected for the position for which you applied, if you agree (see below), EDC will keep your personal data for future vacancies or employment opportunities and we may further process your personal data based on your consent.
Consent
You can withdraw your consent at any time without affecting previous processing.
If EDC subsequently processes personal data for another purpose than that for which you have already been informed and which is not compatible with the purposes for which the data were originally collected / brought to your attention, EDC will provide you with information on that secondary purpose and any relevant additional information.
Types of processing: EDC processes personal data for the purposes set out in this information note, and for each purpose may be used one or more data processing operations such as collection, registration, organization, structuring, storage, extraction, consultation, use, disclosure by transmission, dissemination or otherwise made available, alignment or combination, restriction, deletion or destruction.
III. WHERE DO WE COLLECT YOUR PERSONAL DATA?
In addition to personal data obtained directly from the Data Subjects by accessing the Careers section available on www..edenred-digitalcenter.com or in any other way, we can obtain and process data relevant to our recruitment process from:
a. Recruitment agencies and online recruitment platforms (we obtain identity data and contact data, as well as data related to candidates’ professional, personal and social background);
b. Former employers (we obtain data on your professional history at the respective employer, such as the tasks performed and the duration of employment);
c. Recommendations of certain potential candidates made by EDC’s employees;
d. Professional networks (we obtain data regarding identity and contact data, as well as data on candidates’ professional, personal and social background);
e. Personnel leasing companies (we obtain identity data and contact data, as well as data related to professional background).
IV. TO WHOM DO WE TRANSFER YOUR PERSONAL DATA?
Depending on the respective position (such as management positions), we may transfer your data to companies from Edenred Group for the purpose of carrying out the selection and recruitment process.
Also, depending on the respective position, we may transfer your data to certain professional skills assessment service providers for the purpose of recruitment and promotion (internal recruitment).
Where reasonably necessary or required to do so, we may disclose such data to third parties (authorities, consultants, etc.) in connection with investigations of law enforcement bodies or regulatory authorities.
Also, the service providers, our company’s processors, may obtain access to your data to allow us to carry out the recruitment and selection process, for security and safety purposes, video monitoring, IT&C services related to applications and hardware terminals. or for the organization of the interview, archiving or administrative assistance services.
V. WHEN DO WE TRANSFER YOUR PERSONAL DATA ABROAD?
We keep your personal data mainly in Romania.
However, sometimes it is necessary to provide details regarding your application to other member companies from Edenred Group, within the European Economic Area, depending on the concerned position (such as management positions).
VI. HOW LONG DO WE KEEP YOUR PERSONAL DATA?
We keep records of your data only for as long as it is necessary for the purpose for which we obtained it and for any other permitted purposes.
If you are employed in the position for which you have applied, we will generally keep your recruitment data for as long as you are employed by us, plus a reasonable period depending on the circumstances (normally 3 years - limitation period).
If you are not employed by us, we will keep your data in the archive for a period of 1 year from the end of the recruitment process, unless a longer period is required.
We will ask you if you want to keep your data for other employment opportunities, if you are not employed in the position for which you applied. In this case, we will use your data for this purpose for a period of maximum 1 year.
VII. WHAT ARE YOUR RIGHTS?
EDC is responsible for facilitating the exercise of any of your rights listed below.
If you submit a request in electronic format for the exercise of your rights, the information will also be provided by us in electronic format where possible, unless you request another format. If we receive a request from you regarding the exercise of any of the rights below, we may ask you for additional information to verify your identity before acting on your request.
In the event that, as a result of the application of certain legal provisions, we are unable to comply, in whole or in part, with a request from you, then the applicable exceptional situations will be communicated to you by means of the answer we will send you in in connection with the respective application.
We will try to respond to your request within 30 days. However, the deadline may be extended depending on various issues, such as the complexity of the request, the large number of requests received or the inability to identify you in a timely manner.
If we are unable to identify you in the context of an application, although we have made efforts to do so, and you do not provide additional information to identify you, we may not be able to process your request.
· Access: You have the right to be confirmed that EDC processes your personal data, as well as to obtain information on the specific nature of this processing, such as the purpose, the categories of processed personal data, the recipients of the data / third parties who have access to your data, the period for which the data is kept, your specific rights. You can also request a free copy of your personal data that we process.
· Correction: You may ask us to modify or complete incorrect or incomplete Personal Data.
· Deletion ("right to be forgotten"): You can ask us to delete Personal Data in certain circumstances listed in Article 17 of the GDPR, within the limits and with the exceptions provided in the GDPR, and we will take reasonable steps to inform other controllers who process the data whose deletion you have requested in connection with any links to, copies or reproductions of such data.
· Consent Withdrawal: You may withdraw your consent to the processing that you have given us and you may prevent further processing in the future, if there is no other reason based on which EDC may process your Personal Data.
· Restriction: You may request that certain Personal Data be marked as restricted during the resolution of complaints, as well as the restriction of processing in other specific circumstances. If, following your request, we restrict the processing of your personal data, EDC will store your personal data and process it otherwise only with your consent; for the establishment, exercise or defense of a right in court; for the protection of the rights of another natural or legal person; or for public interest important reasons. We will also inform you before lifting the processing restriction.
· Opposition: You have the right to object to the processing of your personal data when the legal basis for the processing is EDC’s legitimate commercial interests. We will stop processing such data if the following situations do not apply: (i) there are legitimate and compelling grounds for processing which prevail over your interests, rights and freedoms; or (ii) EDC must continue to process your personal data in order to establish, exercise or defend a right in court.
· Portability: You can ask us to transmit, to you or to a third party, the personal data we hold about you, in electronic form (in a structured format, commonly used, automatically processable), or whenever we process your data on the basis of a contract / consent basis and by automated means.
· Filing a complaint: You can file a complaint about how we process Personal Data to the data protection authority:
The National Supervisory Authority For Personal Data Processing
- B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, postal code 010336, Bucharest, Romania
- www.dataprotection.ro; E-mail: anspdcp@dataprotection.ro; Phone: 40.318.059.211/ +40.318.059.212.
VIII. CONTACT PERSON FOR ANY QUESTIONS
EDC has appointed a Data Protection Officer at Edenred Group level, as well as a local correspondent whom you can contact if you have any questions regarding the Internal Privacy Policy or this Notice (including the guarantees that we apply in connection with the export of your Personal Data).
Contact details are as follows:
• Attention: The local correspondent of the Data Protection Officer
Address: Edenred Digital Center S.R.L., 2nd Olteniței Road, 2nd floor, 4th district, Bucharest, Romania
Tel: +40 742 239 170
E-mail: gdpr-ro@edenred.com
Attention: Data Protection Officer
Tel: +33 6 29 94 48 93
Email: dpo.romania@edenred.com