Applicant Privacy Notice
Dated 1 October 2020
1. INFORMATION REGARDING THE PROCESSING OF YOUR PERSONAL DATA
1.1 The purpose of this privacy notice (“Privacy Notice”) is to provide you with information on how the Hexagon Autonomy and Positioning division (“Hexagon Autonomy and Positioning”) processes 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 in the division can be found at the bottom of this privacy notice.
1.3 Hexagon Autonomy and Positioning is the data controller of the processing of your Personal Data. This means that we are responsible for deciding how we hold and use your Personal Data and for ensuring that it is processed correctly and in accordance with applicable laws. If you have any questions concerning this Privacy Notice, please contact the Data Privacy Officer by emailing email@example.com
1.4 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.
1.5 This Privacy Notice does not form part of any contract of employment or any other contract. We may update this Privacy Notice at any time but, if we do so, we will provide you with an updated copy of this Privacy Notice as soon as reasonably practical by publishing an updated version of this Privacy Notice on our career portal.
1.6 It is important that you read and retain this Privacy Notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing your Personal Data, so that you are aware of how and why we are using your Personal Data and what rights you may have under applicable data protection laws and regulations.
1.7 With respect to your Personal Data, we will ensure that it is:
1. Used lawfully, fairly and in a transparent way;
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
3. Relevant to the purposes we have told you about and limited only to those purposes;
4. Accurate and kept up to date;
5. Kept only as long as necessary for the purposes we have told you about; and,
6. Kept securely.
1.8 By submitting an application for a job opportunity advertised on our career portal, no obligation shall be imposed on any Hexagon Autonomy and Positioning entity to offer you a position of employment.
2. WHAT PERSONAL DATA WILL BE PROCESSED?
2.1 In connection with your application(s) and your interaction with us, we will collect, process, 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, resumé, references, covering letter and other background information as part of the application process;
2.1.2 The information that you have provided in connection with registering on our recruitment website (career portal), including name, title, addresses, telephone number, personal email address, gender, employment history, veteran and disability status, 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 Entity; (All personal information as described in this clause 2 shall be collectively referred to as your (“Personal Data”) and
2.1.6 Special Categories of Personal Data to the extent that you have voluntarily provided this to us or where we are legally required to process such data as defined (see Section 5.7),
3. HOW IS YOUR PERSONAL DATA COLLECTED?
3.1 We may collect Personal Data about you from the following sources:
3.1.1 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).
3.1.2 You, the applicant;
3.1.3 Recruitment agencies;
3.1.4 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
3.2 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. WHAT ARE THE PURPOSES OF PROCESSING 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 may collect about you to:
(a) Review your application and assess your skills, qualifications and suitability for the role that you have applied for;
(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 but only 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 may not be able to process your application successfully. For example, we may 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) and (i) 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), (f), (g), (h), (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 therefore 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 the limited circumstances that we use it.
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, or which is made publicly available by you or can be inferred from information provided by you on 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 to ensure meaningful employment equity, equal opportunity monitoring and reporting or for making reasonable adjustments).
5.7.3 We may use information about your disability status and any medical limitations or restrictions specific to assess your ability to perform your job, to ensure your health and safety in the workplace or to assess your fitness to work
5.7.4 Where appropriate, we may collect information about criminal convictions as part of the hiring process but only where we are legally able to do so. This information will be used only to assess suitability for employment with respect to the applied position and for the purposes of administering the employment relationship as well as to obtain the necessary government security clearance.
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 data security 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: hosting 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 or Switzerland 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, UK and the USA 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: http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm.
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 you are no longer identifiable, 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. FOR CALIFORNIA RESIDENTS ONLY
9.1 As used in this Section 9, ‘personal data’ means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. ‘consumer’ means a natural person who is a Californian resident, ‘processing’ means any operation or set of operations that are performed on personal data or on sets of personal data, whether or not by automated means. ‘sell’ means selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing or by electronic or other means, a consumer’s personal data by the business to another business or a third party for monetary or other valuable consideration.
9.2 While processing ‘personal data’ that you, a ‘consumer’, supply or is collected by us in connection with you, we agree to comply with all applicable data protection laws, including the California Consumer Privacy Act of 2018 (“CCPA”).
9.3 To the extent that we receive from you any ‘personal data’ for ‘processing’ on your behalf pursuant to your employment with us, we shall:
a. not ‘sell’ your ‘personal data’;
b. retain, use and disclose the ‘personal data’ only as permitted by the CCPA;
c. not retain, use or disclose the ‘personal data’ for any purpose other than specified under Section 9.3(b); and
d. promptly, and, in any case within ten (10) days of receipt, comply with any written instructions in connection with responding to requests of consumer’s exercising their rights under the CCPA.
9.4 If we authorise any third party to process ‘personal data’ received from you, we shall ensure that such third party is legally bound by provisions no less stringent than set out in this Privacy Notice when processing ‘personal data’ received or collected.
10.1 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 career portal. Please keep us informed if your Personal Data changes during the application process.
10.2 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 career’s portal. We might also notify you in other ways, from time to time, about the processing of your Personal Data.
List of Hexagon Autonomy and Positioning Entities
Autonomous Stuff LLC
Novatel America Inc.
Terrastar GNSS Limited
Veripos (Australia) Pty Ltd
Veripos Brasil Ltda
Veripos (Mexico) S.R. de R.L. de C.V.
Veripos (Singapore) Pte Ltd
Veripos (US) Inc.