[Company] (with regard to job applicants applying a position in [insert here the name of the Uponor Company])
The [Company], [Company] and [Company] hereinafter together “Uponor”.
2. Contact Person
Telephone:[telephone number with country code]
E-mail: [first name].[surname]@uponor.com
3. Name of Personal Data Register
Uponor [Country] Job Applicant Personal Data Register.
4. Group of Data Subjects
Persons participating in recruitment processes at Uponor in [Country].
5. Purpose and Legal Basis of Processing Personal Data
The purpose of this personal data register is the management of Uponor’s employee recruitment processes including the processing of job applicant personal data. In case the job applicant has applied through a web portal service provided by a third party, the privacy policies of such third party service providers shall apply. The processing described above may include processing and evaluating the personal data in order to fill vacant positions and to inform the job applicants of the outcome of the recruitment process. The processing may also include sifting of job applicants by automated tools (based on search words).
Uponor has legitimate interest to process the personal data for the abovementioned purposes.
The job applicant personal data may be stored after the end of the recruitment process as long as Uponor need it for the performance of their obligations related to the recruitment process or in future recruitments, however not longer than 1 year.
6. Content of the Personal Data Register
In the personal data register, Uponor may process especially the following information:
- Basic information, such as: name, date of birth, e-mail address, telephone number, home address, position;
- Qualification data, such as: education, work experience, permissions and permits, diplomas, certificates, CV’s, application letters, language skills;
- Compensation data: salary request;
- Photo (if uploaded by the job applicant);
- References and basic information on the referee (such as name, title, e-mail address, telephone number);
- Links to personal profiles, e.g. in social media applications such as LinkedIn (if uploaded by the job applicant);
- Videos recorded during possible video interviews; and
- Assessment data: evaluation and comments made by Uponor Group’s recruiting personnel.
7. Regular Sources of Information
The data is primarily collected from each data subject him/herself. As allowed by applicable legislation, personal data may, in some situations, be collected from other sources than directly from the data subject.
Uponor informs each data subject of the data processing, including of any third party data sources and data collected from such sources, in accordance with applicable legislation.
The data is entered into the personal data register by the data subject, Uponor Group’s Human Resources personnel and the recruiting manager during the recruitment process.
8. Disclosure and Transfer of Personal Data Outside the EU/EEA Area
Uponor may disclose and transfer personal data outside EU/EEA in accordance with and subject to the limitations imposed by applicable legislation as follows:
- to companies belonging to the Uponor Group in accordance with a contract entered into between the relevant Uponor entities, incorporating the European Commission’s Standard Contractual Clauses, which ensure that adequate data protection arrangements are in place as well as to authorized third parties to the extent they participate in the processing of personal data for the purposes stated in this personal data register. The personal data may be processed by such authorized third parties also outside EU or EEA in accordance with a contract entered into between Uponor and such authorized third party, incorporating the European Commission’s Standard Contractual Clauses, which ensure that adequate data protection arrangements are in place. Uponor shall oblige such third parties to keep confidential and adequately secure any such transferred personal data; or
- based on consent; or
- as otherwise permitted by applicable legislation.
For technical reasons and for reasons related to the use of data, the personal data may be stored on servers of external service providers who may process the data on behalf of Uponor.
Any transfers of personal data shall be made in accordance with the General Data Protection Regulation (2016/679) and any applicable mandatory legislation, as amended.
9. Rights of Data Subjects
Unless any limitations apply, each data subject has the right to access all personal data Uponor has on him/her. Each data subject also has the right to request that Uponor corrects, erases or stops using any erroneous, unnecessary, incomplete or obsolete personal data. Each data subject may also withdraw any consent previously provided by him/her, and object to all direct marketing.
Any requests should be sent to the contact person mentioned in Section 2 above. Uponor processes all requests as soon as possible. If dissatisfied with the decision or actions of Uponor, each data subject has the right to lodge a complaint with his/her country's data protection authority.
10. Principles of Securing Personal Data – Technical and Organizational Controls
Uponor shall ensure that sufficient technical and organizational personal data protection measures are implemented and maintained throughout its own organization. Further, Uponor shall ensure that any transfer or disclosure of personal data described in this personal data register to any third party is subject to Uponor having ensured an adequate level of data protection by agreements or by other means required by law.
Physical material is stored in locked spaces with restricted access. Any IT systems are secured by means of the operating system’s protection software. Access to the systems requires entering a username and a password and data transfers happen via high encryption channels.
Within the organization of the controller, the use of the personal data is instructed, and access to IT systems including personal data is limited to such persons who are entitled to access them on the basis of their work assignments or role and who are subject to confidentiality obligations regarding the personal data.