Candidate Privacy Policy

OEC European Union Candidate Privacy Notice

Scope and Overview

OEConnection (“OEC”) respects your privacy and is committed to protecting the security of your personal data. This Privacy Notice describes how OEC and its subsidiaries, affiliates, and related entities (collectively, "we," or "us") collect and process personal data about you during the application and recruitment process. This Privacy Notice applies to job applicants located in the European Union.

This Privacy Notice is issued on behalf of the OEConnection group of companies so when we mention OEConnection, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the OEConnection group of companies responsible for processing your data. This Privacy Notice describes the categories of personal data that we collect, how we use your personal data, how we secure your personal data, when we may disclose your personal data to third parties, and when we may transfer your personal data outside of your home jurisdiction. This Privacy Notice also describes your rights regarding the personal data that we hold about you including how you can access, correct, and request erasure of your personal data.

We will process your personal data in accordance with this Privacy Notice unless you consent, or as otherwise required by applicable law. OEC takes all reasonable steps to ensure that the personal data that we collect about you is adequate, relevant, not excessive, and processed for limited purposes.

It is important that you read this privacy notice, together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data.

PLEASE NOTE: This website is not intended for children and we do not knowingly collect data relating to children.

THE DATA WE COLLECT ABOUT YOU

For purposes of this Privacy Notice, personal data means any information about an identifiable individual collected in connection with the recruitment process. OEC may collect personal data directly from you, as a job applicant, or may receive personal data from third parties, for example, in connection with a background, employment, or reference check, subject to your consent where required by law. Personal data excludes anonymous or de-identified data that is not associated with a particular individual. We may collect, store, and process the following categories of personal data, which are required in connection with our recruiting activities:

· Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.

· Work history and other relevant experience including information contained in a resume, CV, cover letter, or job application.

· Education information including degrees awarded, transcripts, and other information provided in support of the job application.

· Compensation history.

· Information collected during phone screenings and interviews.

· Details regarding the type of employment sought, desired salary, willingness to relocate, job preferences, and other information related to compensation and benefits.

· Reference information and information received from background checks, where applicable, including information provided by third parties.

· Information related to previous applications to OEC or previous employment history with OEC.

The personal data listed in this notice is voluntary, but mandatory in connection with our recruiting activities. Failure to provide or allow us to process mandatory personal data may affect our ability to accomplish the purposes stated in this Privacy Notice.

HOW WE WILL USE YOUR PERSONAL DATA

We only process your personal data where applicable law permits or requires it in connection with carrying out our application and recruitment process, to take steps necessary to enter into an employment contract with you, when necessary to comply with a legal obligation applicable to us, for our legitimate interests or the legitimate interests of third parties, to protect your vital interests, or with your consent if applicable law requires consent. We may process your personal data for the following purposes:

· Identifying and evaluating job applicants, including assessing skills, qualifications, and interests.

· Verifying your information and carrying out employment, background, and reference checks, where applicable, subject to your consent where required by applicable law.

· Communicating with you about the recruitment process and your application.

· Keeping records related to our hiring processes.

· Creating and submitting reports as required by applicable laws or regulations.

· To comply with our legal, regulatory, or other corporate governance requirements.

· Analyzing and improving our application and recruitment process.

· Complying with applicable laws, regulations, legal processes, or enforceable government requests.

· To protect the rights and property of OEC, other job applicants, employees, or the public, as required or permitted by law.

In addition to using your personal data for the position for which you have applied, we may retain and use your personal data to inform you about and consider you for other positions that may be appropriate for you. If you do not want us to consider you for other positions or would like us to remove your personal data, you may contact us as specified below under Contact Us.

We will only process your personal data for the purposes we collected it for or for compatible purposes. If we need to process your personal data for an incompatible purpose, we will provide notice to you and, if required by law, seek your consent. However, we may process your personal data without your knowledge or consent where required by applicable law or regulation.

We may also process your personal data for our own legitimate interests, including for the following purposes:

· To prevent fraud.

· To ensure network and information security, including preventing unauthorized access to our computer and electronic communications systems and preventing malicious software distribution.

· To support internal administration with our affiliated entities.

· To conduct data analytics analyses to review and better understand the operation of our recruitment process.

You will not be subject to hiring decisions based solely on automated data processing without your prior consent.

COLLECTION AND USE OF SPECIAL CATEGORIES OF PERSONAL DATA

The following special categories of personal data may be considered sensitive under the laws of your jurisdiction and may receive special protection:

· Racial or ethnic origin.

· Political opinions.

· Religious or philosophical beliefs.

· Trade union membership.

· Genetic data.

· Biometric data.

· Data concerning health.

· Data concerning sex life or sexual orientation.

· Data relating to criminal convictions or offenses.

We may collect and process the following special categories of personal data when you voluntarily provide them or we receive them from a third party with your consent, when relevant for a particular position and to carry out our obligations under employment laws, or as applicable law otherwise permits:

· Physical or mental health condition or disability status to determine appropriate workplace accommodations and evaluate fitness for a particular position.

· Race or ethnic origin, religious affiliation, health information, and sexual orientation to ensure meaningful equal opportunity monitoring and reporting.

· Criminal convictions and offenses to evaluate fitness for a particular position.

Where we have a legitimate need to process special categories of personal data for purposes not identified above, we will only do so only after providing you with notice and, if required by law, obtaining your prior, explicit consent.

HOW WE MAY SHARE YOUR PERSONAL DATA

We will only disclose your personal data to third parties where required by law or to our employees, contractors, designated agents, or third-party service providers who require such information to assist us with administering the recruitment process, including third-party service providers who provide services to us or on our behalf. We may use third-party service providers for various purposes, including, but not limited to, obtaining employment verification and background checks, and data storage or hosting. These third-party service providers may be located outside of the country in which you live or the country where the position you have applied for is located.

We may also disclose your personal data for the following additional purposes where permitted or required by applicable law:

  • To other members of our group of companies (including outside of your home jurisdiction) for the purposes set out in this Privacy Notice and as necessary to administer the application and recruitment process.
  • As part of our regular reporting activities to other members of our group of companies.
  • To comply with legal obligations or valid legal processes such as search warrants, subpoenas, or court orders. When we disclose your personal data to comply with a legal obligation or legal process, we will take reasonable steps to ensure that we only disclose the minimum personal data necessary for the specific purpose and circumstances.
  • To protect the rights and property of OEC.
  • During emergency situations or where necessary to protect the safety of persons.
  • Where the personal data is publicly available.
  • If a business transfer or change in ownership occurs.
  • For additional purposes with your consent where such consent is required by law.

We require all our third-party service providers to implement appropriate security measures to protect your personal data consistent with our policies and any data security obligations applicable to us. We take all reasonable measures to ensure that our third-party service providers do not use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We may also disclose your personal data for the following additional purposes where permitted or required by applicable law:

  • To other members of our group of companies (including outside of your home jurisdiction) for the purposes set out in this Privacy Notice and as necessary to perform our employment contract with you.
  • As part of our regular reporting activities to other members of our group of companies.
  • To comply with legal obligations or valid legal processes such as search warrants, subpoenas, or court orders. When we disclose your personal data to comply with a legal obligation or legal process, we will take reasonable steps to ensure that we only disclose the minimum personal data necessary for the specific purpose and circumstances.
  • To protect the rights and property of OEC.
  • During emergency situations.
  • Where the personal data is publicly available.
  • If a business transfer or change in ownership occurs and the disclosure is necessary to complete the transaction. In these circumstances, we will limit data sharing to what is absolutely necessary and we will anonymize the data where possible.
  • For additional purposes with your consent where such consent is required by law.

INTERNATIONAL TRANSFERS

Where permitted by applicable law, we may transfer the personal data we collect about you to the United States and other jurisdictions that may not be deemed to provide the same level of data protection as your home country, as necessary to perform our employment contract with you and for the purposes set out in this Privacy Notice.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
  • We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe;
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US; or
  • Where we transfer your personal data between the OEC Group of companies, we have implemented adequate safeguards in the form of an Intra Group International Data Transfer Agreement, including the Standard Contractual Clauses for processors approved by European Commission Decision C(2010)593, among all of the OEC Group of companies to secure the transfer of your personal data to the United States and other jurisdictions.

Please contact us at privacy@oeconnection.com if you want further information on the specific mechanism used by OEC when transferring your personal data out of the EEA.

HOW DO WE ENSURE THE SECURITY OF YOUR DATA?

OEC has put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have also put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

HOW LONG WE WILL USE YOUR PERSONAL DATA?

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, accounting, or reporting requirements or as necessary to resolve disputes.

If you are offered and accept employment with OEC, the personal data we collected during the application and recruitment process will become part of your employment record, and we may use it in connection with your employment consistent with our employee personal data policies.

For unsuccessful candidates, we will typically retain personal data collected during the recruitment process for a maximum period of three (3) months from the end of the process, unless the circumstances warrant a longer retention period or applicable law or regulation requires a different retention period. We may retain select personal data for a period longer than three (3) months to inform you about and consider you for other positions.

If you do not want us to consider you for other positions, or would like us to remove your personal data, you may contact us as specified below under Contact Us.

In some circumstances you can ask us to delete your data: see the Request erasure section below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing of your personal data based on your consent before it was withdrawn. If you withdraw your consent, we may not be able to process your application . We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at privacy@oeconnection.com.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. Reasonable access to your personal information will normally be provided at no cost.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

If for some reason access is denied, we will provide an explanation as to why access has been denied.

CHANGES TO THIS PRIVACY NOTICE

We reserve the right to update this Privacy Notice at any time. If we would like to use your previously collected personal data for different purposes than those we notified you about at the time of collection, we will provide you with notice and, where required by law, seek your consent, before using your personal data for a new or unrelated purpose.

CONTACT US

If you have any questions about our processing of your personal data or would like to make an access or other request, please contact us at:

privacy@oeconnection.com

Below is a list of the Companies within the OEC Group. This Notice shall be read to refer to the company that you are applying to:

UK

OEC International Limited

Springfield Lyons House Chelmsford Business Park

Chelmsford

Essex CM2 5TH

England

OEConnection Limited

Springfield Lyons House Chelmsford Business Park

Chelmsford

Essex CM2 5TH

England

OEC Europe Holdings Limited

Springfield Lyons House Chelmsford Business Park

Chelmsford

Essex CM2 5TH

England

OEC Athoris Limited

Springfield Lyons House Chelmsford Business Park

Chelmsford

Essex CM2 5TH

England

Poland

OEC Sp. z o.o

UI Sw. Jana 20, 31-018

Krakow

Poland

Germany

OEConnection GmbH

Siegfried-Leopold-Str. 58

53225 Bonn

Germany

OEConnection AutoConsult GmbH

Landshuter Allee 43,

80637 Munich

Germany

France

OEC S.A.R.L.

52 Boulevard de Sebestopol

75003 Paris

France

OEC’s Data Protection Representative:

Scott Christie

OEC International Limited

Springfield Lyons House Chelmsford Business Park

Chelmsford

Essex CM2 5TH

England

You have the right to make a complaint at any time to with the data protection authority in your jurisdiction We would, however, appreciate the chance to deal with your concerns before you approach the data protection authority, so we hope that you will please contact us in the first instance.

Effective Date: May 25, 2018