Privacy notice applicants


We and our affiliated companies care about your privacy and are
committed to protecting your personal information in accordance
with fair information practices and applicable data privacy laws.

This Data Privacy notice is intended to describe the practices we
follow in relation to the Global Applicant Tracking System
(“System”) with respect to the privacy of applicants.

The Global Applicant Tracking System is a cloud-based applicant
tracking system. Our group uses this application globally to
conduct its recruitment activities and to provide job opportunities
in the country you are about to apply to as well as other countries
and regions. This notice will provide comprehensive information
about how we will use your personal information within this
System and to inform you about your rights in this regard. If you
have any questions regarding the processing of your personal
information in the System, please contact us using the email-
address displayed below.

If you are merely a visitor to our Careers site, we do not collect
any personal information about you, except to a limited extent
through the use of cookies as described in the relevant section.
However, if you are applying for an advertised position, we collect
information about you when you create a Candidate Profile in the

The provision of your personal information is optional at any time.
However, please be aware that your refusal to provide us with
your personal information or to process it in the System may
result in us not being able to carry out any activity related to your
recruitment in this online environment.


This privacy notice explains how we – regardless of nationality or
residence - handle the personal data of:
    - Any natural person who applies for an advertised job
    - Any natural person who applies spontaneously with the
    intention that his/her resume will be included in our database
    intended for recruitment and selection
    - Any natural person whose resume was passed on to us
    through a third party by a recruitment firm.

Personal data means any information relating to an identified or
identifiable natural person (‘data subject’). An identifiable natural
person is someone who can be identified, directly or indirectly, in
particular by reference to an identifier such as a name, an
identification number, location data, an online identifier or to one
or more factors specific to the physical, physiological, genetic,
mental, economic, cultural or social identity of that natural

Special categories of personal data means personal data in the
following categories: ethnic or racial origin, political opinions,
religious or philosophical beliefs, trade union membership,
physical or mental health, gender, sexual orientation, bio-metric
data where processed to uniquely identify a person, genetics,
criminal convictions.

Data controller

The data controller for your personal information is our entity
which is responsible for the advertised position and to whom you
address your application.

It is possible that entities may be jointly responsible for your
personal information if you submit applications to multiple entities
via the System.

We license the System from SAP SuccessFactors, 1 Tower Place,
Suite 1100, South San Francisco, CA 94080, USA (“SAP
SuccessFactors”). SAP manages the system on our behalf for the
benefit of our entities globally. The servers which host the system
are owned by SAP and located in Rot, Germany.

Categories of Personal Data

To be able to apply for our career opportunities, you need to
create an account into the System. This “Candidate Profile”
requires a valid e-mail address as a login, along with other
information, some of which is mandatory. Mandatory information
will be marked accordingly. Your e-mail address allows us to
communicate with you if your qualifications and/or preferences
match job opportunities, or if you opt to receive automated
notifications of job postings at any of our entities. Your Candidate
Profile also makes it possible for you to access the System to
monitor the progress of your application or to amend your
personal details should you wish to do so.

During the different stages of the recruitment and selection
process, we may process – to the extent necessary and permitted
by local law - the following personal data:

    - Personal identification information such as your name, home
    -E-mail address and phone number;
    -Work-related information such as current job title and
    responsibilities, previous positions and professional
    experience, reason for leaving;
    -Position(s) previously applied for (at our company) and job
    preferences, how you heard about the position;
    -Compensation and benefits information such as (gross)
    salary and salary package expectations;
    -Educational and training information such as educational
    awards, certificates and licenses, in house training
    -Performance related data such as objectives, ratings,
    comments, feedback results, career and succession
    planning, skills and competences and other work-related
    -Information needed for compliance and risk management
    such as disciplinary records, background check reports and
    security data;
    -Data relating to mobility (driving license, transport options);
    -Your willingness to travel if the applied position so requires;
    -Immigration, right to work and residence status;
    -Government-issued identification numbers such as national
    ID, social security number;
    -Family and emergency contact details;
    -Payment related information, including identification and
    bank account numbers;
    -Data resulting from professional competence and skills
    -Data obtained from a personality test.

In addition, we may need to collect special categories of personal
information from you at a later stage in the recruitment process if
local employment laws or regulations require us to do so, such as:

    -Health certificates for a specific function, a function with
    increased caution or an activity with a specific risk;
    -Criminal convictions and prosecutions (for certain safety
    functions and/or in certain countries);
    -Religious beliefs (in certain countries);
    -Bio-metric data such as photographs with the purpose to
    uniquely identifying a person

Purposes of processing

We will only collect and process your personal data to the extent
necessary for the purposes of recruitment and selection.

Your personal information is processed in the System so that our
recruitment teams can consider and manage your application for
the advertised position and to contact you. Your personal
information will be used by us to build the global talent pool
database. This will include planning and monitoring recruitment
campaigns and notifying you from time to time of current

We do not collect or compile personal information obtained by this
System for dissemination or sale to outside parties for consumer
marketing purposes or host mailings on behalf of third parties.

Legal bases for processing

We process above stated personal data on the following legal

1) You have expressly given your consent e.g. by providing us
with your resume, certificates, etc.

2) The processing is necessary for the performance of the contract
e.g. drawing up employment contract

3) The processing is required by law e.g. recruitment for a safety
function may require certain certificates by law. Specific cases will
always be explained in a separate interview.

4) The processing of your data is necessary to protect the
legitimate interests of our company with a view to a proper
assessment of your application, provided that the interests or
fundamental rights and freedoms of the applicant do not outweigh
our legitimate interests e.g. forwarding your contact details to
assessment centers for conducting additional tests, forwarding
your data to other entities within the group that may be interested
in your profile.

Applying for a job outside of your home country

If you wish to apply for a job in a country outside of your home
country, we may need to ask you questions that are specific to the
country where the job is located. This is because in certain
countries, before we can offer someone a job, we have to ask
certain additional questions. These questions will be relevant and
necessary for the job advertised and consistent with our values.


If you provide any information in relation to third parties or
referees, you are responsible for obtaining their consent and

ensuring they are aware that their details will be forwarded to,
and used by, us.

Recipients of personal data

Access to your personal information is limited by need. All
recruitment staff within the group worldwide have access to your
profile on the database and are able to match your details to
current vacancies.

SAP can access your personal information as is necessary to
perform its functions but may not share any information without
first obtaining permission from us. From time to time, in addition
to SAP, we may need to share your personal information with
other third parties. However we will only disclose your personal
details for the following reasons:

    -When it is necessary to involve a third party service provider
    in order to facilitate or extend recruitment services, as we do
    today with SAP.
    -When explicitly requested by you.
    -As required by a court order or any other legal or regulatory

International transfers

Because we are a global company with locations in many different
countries, we may transfer your Personal Information from one
legal entity to another or from one country to another in order to
accomplish the purposes listed above. We will transfer your

Personal Information consistent with applicable legal requirements
and only to the extent necessary for the purposes set out above.

Within the group of companies, Personal Information is transferred
subject to the same rules and levels of security. If required, data
processing agreements will be in place to ensure the necessary
level of protection.

We rely on available legal mechanisms to enable the legal transfer
of Personal Information across borders. To the extent that we rely
on the standard contractual clauses (also called the model
clauses) to authorize transfer, we will comply with those
requirements, including where there may be a conflict between
those requirements and this Notice.

We will not sell or otherwise share your Personal Information
outside the group of companies, except to:

    -service providers we retained to perform services on our
    behalf. We will only share your Personal Information with
    service providers whom we have contractually restricted
    from using or disclosing the information except as necessary
    to perform services on our behalf or to comply with legal

    -comply with legal obligations, including but not limited to, in
    response to a legitimate legal request from law enforcement
    authorities or other government regulators;
    -investigate suspected or actual illegal activity;
    -prevent physical harm or financial loss; or
    -support the sale or transfer of all or a portion of our business
    or assets (including through bankruptcy).


We will retain your personal information as long as necessary to
achieve the purposes for which it was collected.

If you are given and accept an offer of employment by us,
personal data collected during your pre-employment period will
become part of your personnel records, to be retained throughout
and for a period after your employment. You will be further
informed of the processing of your personal data by us within the
framework of personnel management and payroll administration
at the time of employment.

If we do not employ you, we may nevertheless continue to retain
and use personal data collected during the recruitment process in
order to consider you for new positions, and, if appropriate, to
refer back to an earlier application if you submit a resume or other
information to us again in the future, as well as for system
administration and to perform research and analysis.

We determine the retention period of your information based on
the following retention criteria:

    -We retain your personal data as long as we have an ongoing
    relationship with you;
    -We retain your personal data where it is required to do so by
    a legal obligation to which we are subject;
    -We retain your personal data where this is advisable to
    safeguard our legal position (for instance in relation to
    statutes of limitations, litigation, or regulatory

Applicant’s rights

In addition to our commitment to transparency and this notice to
applicants in order to respect the right to be informed, we also
respect the following rights:

    -You have the right to obtain without constraint at reasonable
    intervals and without excessive delay or expense a copy of
    all data relating to you that are processed.
    -You have the right to obtain the rectification or update of
    inaccurate or out-of-date personal information. You have a
    responsibility to ensure you submit accurate information into
    the System and keep it up to date. This can be done via the
    "Candidate Profile".
    -You have the right to erasure of personal data.
    -You have the right to object to the processing of your
    personal data, unless that processing is required by law.
    Where the objection is justified, the processing must cease.
    -You may have the right to request data portability. Data
    portability is the provision of your personal information in a
    structured, commonly used and machine-readable form so
    that it may be transferred to another company easily. The
    right to data portability is subject to restrictions i.e. data
    portability does not apply to paper records and must not
    prejudice the rights of others or sensitive company
    -You have the right not to be subject to decisions based solely
    on automated decision making if those decisions produce
    legal effect or significantly affect you.
    -You have the right to withdraw any consent previously
    granted for a specific purpose, if consent is the legal basis
    for the processing of your personal information.
    -We respect these rights and have processes in place to
    recognize and respond to individuals wishing to exercise
    these rights. You may request to exercise any of these rights
    through your local human resources contact or by using the
    email-address displayed below.


We are committed to ensure that your personal information
processed in the System is kept secure and have implemented
appropriate technical measures and security policies that protect
the information we have under our control from:

    -Unauthorized access.
    -Improper use or disclosure.
    -Unauthorized modification.
    -Unlawful destruction or accidental loss.
    -All our personnel and any third parties which we engage to
    process your personal information are obliged to respect the
    confidentiality of your information.

Privacy concerns and how to contact us

If you are concerned about an alleged breach of privacy law or
any other regulation by us, you can contact us using the email-
address displayed below.

A Privacy Officer will be made available to investigate your
complaint and give you information about how it will be handled.

If we do not address any of your requests, or fail to provide you
with a valid reason why we are unable to do so, you have the right
to contact supervisory authority to make a complaint. You can find
your local supervisory authority through this link: EU   Authorities

Changes to our privacy notice

We may change this data privacy statement, should it become
necessary to do so. This notice may also be supplemented by
other statements as needed to comply with local requirements in
the country where you live or where employee representation
agreement exists.