Applicant Privacy Notice
Dated 23 September 2019
1. INFORMATION REGARDING THE PROCESSING OF YOUR PERSONAL DATA
1.1 The purpose of this privacy notice is to provide you with information on how the Hexagon Autonomy and Positioning group of companies (“Hexagon Autonomy and Positioning”) process your Personal Data (defined below) in connection with managing the application(s) that you submit for consideration of job opportunities posted on our careers portal and in connection with our other general recruitment activities.
1.2 When we mention ‘we’, ‘our’ and ‘us’, we are referring to the relevant company in Hexagon Autonomy and Positioning responsible for the processing of your Personal Information. A list of all Hexagon Autonomy and Positioning companies can be found at the bottom of this privacy notice.
1.3 We respect your privacy and duly protect the Personal Data that you provide to us throughout the recruitment process and/or through interaction with our recruitment team. All processing of Personal Data is made in accordance with the General Data Protection Regulation (“GDPR”) and other applicable laws and regulations dependent on your location. The following describes how and why we collect, process, store and share your Personal Data during and after the application process.
1.4 By submitting an application for a job opportunity advertised on our careers portal, no obligation shall be imposed on any Hexagon Autonomy and Positioning Entity to offer you a position.
2. WHAT PERSONAL DATA WILL BE PROCESSED?
2.1 In connection with your application(s) and your interaction with us, we will collect, store and use the following categories of personal information about you:
2.1.1 Information that you have provided to us in your curriculum vitae and covering letter;
2.1.2 The information that you have provided in connection with registering on our recruitment website (careers
portal), including name, title, addresses, telephone number, personal email address, gender, employment
history, education and qualifications;
2.1.3 Any information that you provide to us during interviews;
2.1.4 Information about your salary expectations;
2.1.5 Information about your entitlement to work in the country of the relevant Hexagon Autonomy and Positioning
2.1.6 Special Categories of Personal Data to the extent that you have voluntarily provided this to us or we are
legally required to process such data (see Section 5.7), (All personal information referred above shall be
collectively referred to as your “Personal Data”).
3. HOW IS YOUR PERSONAL DATA COLLECTED?
3.1 We collect Personal Data about you from the following sources:
3.1.1 You, the applicant;
3.1.2 Recruitment agencies;
3.1.3 Third parties via our ‘email this job to a friend’ functionality, or a current Hexagon Autonomy and Positioning
Entity employee recommending you via our ‘refer a friend’ program; and
3.1.4 Other sources where you have made your Personal Data publicly available for the purposes of recruitment,
such as LinkedIn (or other publicly available social media networks and databases).
3.2 As a general rule, we will collect Personal Data from you directly. However, we may obtain Personal Data from the third parties referenced above and you may have already agreed that such third parties may share your information with us. In such circumstances, we rely on the relevant third party to obtain any relevant consent from you.
4. HOW WILL WE USE YOUR PERSONAL DATA?
4.1 We only process your Personal Data where we are lawfully permitted to do so for one or more of the purposes below. Not all of the purposes below will always apply to you all of the time.
4.2 We will use the Personal Data we collect about you to:
(a) Review your application and assess your skills, qualifications and suitability for the role that you have applied
(b) Communicate with you about the recruitment process;
(c) Determine, plan, administer and, potentially, initiate the employment relationship and fulfil the obligations set
out in an offer if made by us;
(d) Verify your suitability for the role by obtaining employment references from the referees provided by you;
(e) Confirm your eligibility to work for the company (where applicable) by using databases maintained by
third parties and governmental authorities in order to comply with legal or regulatory requirements;
(f) Retain your Personal Data for consideration in respect of future job opportunities that may arise with
Hexagon Autonomy and Positioning Entities;
(g) Send you job alerts relating to job opportunities in your chosen field if you request these alerts;
(h) Identify you as a suitable candidate and, thereafter, communicate with you about job opportunities that we feel
would be of interest;
(i) Keep records relating to our recruitment process;
(j) Conduct analyses and studies of data collected during the recruitment process to review and better understand
applicant engagement rates and the performance of our careers portal.
4.3 Generally, we do not make any recruitment decisions based solely on automated decision-making. We may employ automated decision-making to create a shortlist of candidates who fulfil a mandatory requirement for a particular role. For example, if you state that you do not have the right to work in the location of the role for which you are applying, your application will not proceed any further beyond the application. In the event that we do use automated decision-making that could have a significant impact on you, we will provide you with an opportunity to express your views and any other safeguards required by law. We may process your Personal Data by automated means to generate reports and compile statistics for or in the management of our recruitment exercises.
4.4 If you fail to provide Personal Data, when requested, which is necessary for us to consider your application, we will not be able to process your application successfully. For example, we will not be able to process your application if we require references for a role and you fail to provide us with relevant details.
5. WHAT ARE THE LEGAL BASES FOR PROCESSING YOUR PERSONAL DATA?
5.1 We will only use your Personal Data for our recruitment purposes. In this pursuit, there may be several legal grounds which justify our use of your Personal Data as described below.
5.2 The processing of your Personal Data for the purposes outlined in (c) and (d) of Section 4.1 above are necessary in order for us to prepare and enter into an employment contract with you.
5.3 The processing of your Personal Data for the purposes outlined in (e) of Section 4.1 above are necessary to comply with the company’s legal obligations.
5.4 The processing of your Personal Data for the purposes outlined in (a), (b), (i) and (j) of Section 4.1 above are based on the legitimate interests of the company (or those of a third party) in order to manage and carry out the business operations of the company.
5.5 The processing of your Personal Data for the purpose outlined in (f), (g) and (h) of Section 4.1 shall only be undertaken upon your request and where you have given your consent for the company to do so.
5.6 Special Categories of Personal Data (as defined in Section 5.7 below) require higher levels of protection. We have implemented appropriate policies, technological, organisational and legal safeguards to ensure the secure collection, processing, storage and sharing of such Special Categories of Personal Data in limited circumstances.
5.7 We may collect, store and use the following sensitive personal information (“Special Categories of Personal Data”) and use it as follows:
5.7.1 Information about your race or ethnicity, religious beliefs, trade union membership, sexual orientation and political opinions, as voluntarily disclosed by you, made publicly available by you or can be inferred from your CV; and
5.7.2 Information about your health, including any medical conditions, health and sickness records, all of which shall only be processed where we have either obtained your explicit consent or where we are permitted under applicable laws (for example, in the context of diversity monitoring, restricted party screening or making reasonable adjustments).
6. WHO HAS ACCESS TO YOUR PERSONAL DATA?
6.1 We have implemented appropriate technical, legal and organisational measures to protect your Personal Data against loss or unlawful access etc. The number of persons with access to your Personal Data is limited. Only employees involved in the recruitment process and within the human resources function for the relevant Hexagon Autonomy and Positioning Entity who process Personal Data in accordance with this privacy notice will have access to your Personal Data.
6.2 We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
6.3 We may share your Personal Data with other Hexagon Autonomy and Positioning Entities who form part of the recruitment process and only insofar as is necessary for the purpose of processing your application. When transferring Personal Data to other Hexagon Autonomy and Positioning Entities which are situated in countries outside the EU/EEA, we use intra-company agreements which ensure protection of your Personal Data.
6.4 We may share your Personal Data with third parties where permitted by law or where we have legitimate interest in doing so. “Third parties” includes third party service providers (including contractors and designated agents). The following activities are carried out by third party service providers: administration of our recruitment website, restricted party screening and legal regulatory bodies (where applicable). The specific details about our third-party service providers and their processing activities are available by contacting firstname.lastname@example.org.
6.5.1 For EU/EEA Applicants: Your Personal Data may be transferred to a country outside of EU/EEA such as Canada, New Zealand, Switzerland and the USA (limited to the Privacy Shield Framework) which offer similar levels of protections as within the EU/EEA. The transfer to these countries is based on the adequacy decisions of the European Commission.
6.5.2 Your Personal Data may be transferred to a country outside of the EU/EEA such as Australia, Brazil, China, India, Mexico, Singapore and the USA (to the extent not covered by the Privacy Shield Framework) which may have a lower level of protection than within the EU/EEA. When transferring Personal Data to countries outside the EU/EEA, we use standard contractual clauses approved by the European Commission (“EU Standard Contractual Clauses”) which contractually ensure the protection of your Personal Data. The EU Standard Contractual Clauses can be found via the following link:
7. FOR HOW LONG IS YOUR PERSONAL DATA STORED?
7.1 We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal or reporting requirements. Details of retention periods for different aspects of your Personal Data are available by contacting email@example.com. To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
7.2 We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
7.3 In some circumstances we may anonymise your Personal Data so that it can no longer be associated with you, in which case we may use such information without further notice to you.
8. WHAT ARE YOUR RIGHTS?
8.1 In the context of your application, the Hexagon Autonomy and Positioning Entity to whom you are addressing the application (usually this is the Hexagon Autonomy and Positioning Entity which is stated in the job overview) is the controller of the processing of your Personal Data. This means that such Hexagon Autonomy and Positioning Entity is responsible for your Personal Data being processed correctly and in accordance with applicable laws. A list of all Hexagon Autonomy and Positioning Entities can be found at the bottom of this privacy notice. The Data Privacy Officer can be contacted at firstname.lastname@example.org.
8.2 You are entitled to know what Personal Data we are processing about you and you can request a copy of such data. You are entitled to have incorrect Personal Data regarding you corrected and in some cases you may request that we delete your Personal Data. You also have the right to object to certain processing of your Personal Data (such as automated decision making) and request that the processing of your Personal Data be limited. Please note that limitation or deletion of your Personal Data may result in us not being able to fulfil our obligations under the employment agreement. You are also entitled to extract your Personal Data in a machine-readable format and to transfer the Personal Data to another controller/employer.
8.3 If you have questions regarding how we process your Personal Data, you are most welcome to contact us at email@example.com or by mail to the office at which the Hexagon Autonomy and Positioning Entity resides.
8.4 If you have any objections or complaints with the way in which we process your Personal Data, you have the right to lodge a complaint with the relevant data protection supervisory authority where applicable laws provide for such remedy. If you would like help establishing your applicable supervisory body for data privacy, please request assistance from firstname.lastname@example.org.
9.1 It is your responsibility to keep the Personal Data we hold about you accurate and current. You can manage your applicant data via the Hexagon Autonomy and Positioning careers portal. Please keep us informed if your Personal Data changes during the application process.
9.2 We reserve the right to update this privacy notice at any time. If any changes are made concerning the processing of your Personal Data, we will inform you by publishing an updated version of this privacy notice on our careers portal. We might also notify you in other ways, from time to time, about the processing of your Personal Data.
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