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DATA PROTECTION NOTICE FOR CANDIDATES

1. General

With this Data Protection Notice ("Data Protection Notice”) “we”, as Swisscom DevOps Center Rotterdam, under the legal entity of NGT International B.V. (hereafter "SDC") registered at the address of Beursplein 37, 3011 AA Rotterdam, the Netherlands, inform you about how we process your personal data in relation to your job application process and/or during the career events you attend.   



2. Scope

This Data Protection Notice applies to all candidates who have applied to one of SDC’s job openings through our SDC Career Site or through other job boards such as LinkedIn, Indeed, RelocateMe, etc. Thus, this Data Protection Notice describes in which we process personal data concerning candidates (“Candidate Data” or "Data”).

This Notice also applies to all persons (i.e.university students, possible candidates, etc.) who are participating in internal career events SDC hosts either in our offices in the above mentioned address or in external locations, as well as in external events hosted by third-parties career (i.e. job fairs, career events held by universities such as student fairs, etc.) where SDC is a participant.

As the processing of Candidate Data listed in this Data Protection Notice takes place in many different business processes, it is quite possible that you will not always be personally affected by such processing especially if you have not completed your application process to have an offer or if you are a participant at a career event and have not applied for a job with us.

3. Collection of Candidate Data

If you are applying to a position with us, we may collect Candidate Data directly from you (e.g. documents you submit via your job application such as CV or other information disclosed by you during interviews and assessments). However, we may also receive data from third parties (e.g. from references in an application or from recruitment agencies). Especially when you provide us information about other people, such as information about your reference persons, we assume that you are authorized to do so and that you provide accurate information.

 If you are a participant in one of our career events, we may collect personal data directly from you through the registration forms you fill out in order to register for an event hosted by the SDC or through obtaining your data to hear about future job opportunities in external career events hosted by third-parties during your participation. We will obtain your contact information in case you voluntarily provide us your data during the event manually or by electronic means, to be contacted for future job opportunities as well as correspondence on future career events hosted by SDC.

We may also obtain your personal data from third parties (such as job agencies, career fair organizers, etc.) as part of our agreements with them. These third parties may collect your personal to connect you with potential job opportunities in various companies, consequently they may share your information with us for this purpose. We will use your data to invite you to our career events and to provide you job opportunities that you might be interested. We encourage you to review Privacy Policies of such third parties to understand how your data is processed and shared. In case you do not wish to be contacted, you can always exercise your rights towards the third party as well as the SDC. For more information, please refer to Section 9.

With regard to the data mentioned above, we will only process this data in accordance with Section 5 if you voluntarily disclose them to us. You may also refuse or restrict the disclosure of these data as a general matter in accordance with your rights under Section 10. We will then draw your attention to the consequences of refusing or restricting disclosure.

 

4. Categories of Candidate Data processed 

We process the following categories of Candidate Data for the purposes specified in Section 5.  

  • Identification Data: In particular, your name,home address, personal email address, telephone number, photo, date of birth and age, gender, marital status, residence country, nationality, emergency contact(s), work and residence permit information, visa information, family status and number of children, and similar data.

    Educational and Professional Background Data: In particular, your CV, your educational background including information about the university and program you attended/attending to, (expected) year of graduation (especially if you are applying for an internship), information on certificates, diplomas, information on trainings, skills, abilities, and qualifications (“skills”), professional interests (e.g. specific projects or tools), information on languages, information about previous workplaces, positions, years of experience, personal references and their contact details, data from publicly available profiles on platforms including direct links to social media profiles (to the extent they are intended for business or professional use, e.g. LinkedIn, GitHub, etc.), hobbies and interests, and similar data.

  • Application Data: In particular: 

    • Information concerning the position and the job offer, including hire date, contract sign date, starting salary, seniority level, title and position names at SDC;

    • information you provide in your cover letter;

    • information you provide during interviews with Talent Acquisition and with the team;

    • information about the personality test and its results including snapshots of your test duration;

    • information about the technical projects done throughout the recruitment process and its results;

    • information about the team (superiors, coaches and mentors, subordinates, and other team members);

    • information related to your expected salary;

    • information related to your bank account including IBAN number;

    • information in connection with our security systems (e.g. information from access control systems including World Trade Center Rotterdam systems for access and exit information through the visitor QR code)

    • information in connection with your correspondence with us (e.g. with Talent Acquisition team members or your possible team members through interviews, etc.) and with third parties (e.g. business emails, but also private emails that you receive or send via your email address and all written correspondence) and similar data.    

  • Visual and/or audio data: In particular pictures and/or videos taken at the time of the career event.

  • Interaction and usage data: Information related to the usage of our systems specifically for challenges we host in career events or other forms of activities where you use our systems with your as e-mail address (specifically for certain activities such as coding challenges) and similar data.    

  • Information relating to data that is processed with your consent (‘Consent Data’): the data we process with your consent (we will inform you of this separately when we ask you for your consent); in addition, the date and time of your declarations of consent, the subject matter and if applicable, the withdrawal of consent (if applicable).

  

5. Purposes and Legal Basis of Processing Candidate Data  

 

We process your personal data mainly to perform the employment relationship with you. Thus, we process the following categories of personal data for the following purposes and under the following legal bases:

Table 1 for candidate
Table 2 Candidate

6. Categories of External Recipients of Candidate Data 

We may disclose or make available your personal data (Section 4) to the following recipients within and outside SDC, provided these recipients require the relevant data which is necessary for the purposes stated above ("need-to-know” principle). In particular, these recipients will be as follows: 

    Employees of HR (including external HR consultants) and Talent Acquisition: in relation to the preparation of the employment contract in case the application process is successful, and an offer has been made by Talent Acquisition team; or in case there is a communication for possible job opportunities related to the purposes set out in Section 5;

  • Future line managers and possibly your potential future team colleagues: in relation to and as a part of the application process in order to select the best candidate for the vacancy; 

  • Former employers or references: if we obtain information from them in relation to your application process. If we reach out to your references, we will let you know separately that we will contact them.  

  • Swisscom internal employee who referred you to the position: in order to provide information about your application process (e.g. candidate rejected or offer made) in relation to referral bonus subjected under their own company (if applicable). 

  • Service providers including ATS within Netherlands or abroad: for operational, maintenance and support services of candidate application management. Please check Section 6 for detailed information on the transfer of your personal data beyond European Union (EU). 

  • Third parties in the performance of legal obligations: to the extent and if deemed necessary or appropriate in order to comply with, or verify compliance with, applicable laws and regulations and to respond to enquiries from competent authorities.  

  • Swisscom (Switzerland) Ltd and other Swisscom Group companies: in connection with your application and application management. Please check Section 6 for detailed information on the transfer of your personal data beyond European Union (EU). 

7. Processing of Candidate Data in the Netherlands and abroad 

Candidate Data may be processed by us, in the Netherlands, but the processing may also take place other European Union (EU) countries or European Economic Area (EEA). As a group company in the Swisscom Group, the processing of your personal data may take place in Switzerland or abroad, if necessary.

 For the transfers made to Switzerland for our business with Swisscom (Switzerland) Ltd, under Article 45 GDPR, the European Commission has recognized Switzerland to have adequate level of data protection with the Commission Decision 2000/518/EC. These adequacy decisions are periodically reviewed, the last review took place on January 15, 2024, concluding Switzerland’s adequacy in data protection.

 It is also possible to process data outside the EU or the EEA (e.g. in the UK, USA, Australia). Many countries outside the EU and the EEA or Switzerland do not currently have laws that guarantee an adequate level of data protection. If Candidate Data is disclosed to a recipient in such a country, the protection of your data is ensured with the legally prescribed precautions, such as in particular the conclusion of contractual agreements such as Standard Contractual Clauses (SCCs) and appropriate technical and organisational measures. 

8. Retention Period of Candidate Data and Storage 

For the job applications; the Candidate Data is stored in databases located in the EU. We will keep your Candidate Data for a maximum of 1 year following your application date. If you request your data to be deleted during this time, your Candidate Data will be automatically deleted within 14 days.

 After the retention period is over, unless you provide your additional consent, your Candidate Data will be anonymized or deleted from our database.

 For career events; as a general principle, we do not store your personal data we directly collect from you and delete all records immediately after the end of the career event and/or after we conduct all our communications to you for the purposes stated in Section 5.

 We do not keep a copy any of your personal data we receive from third-party companies mentioned in Section 3. We will receive your personal data and use it according to our agreement with the third-party under our legitimate interests and delete all personal data.

 

9. Rights of Candidates 

You have certain rights in relation to your personal data processed by us so that you can control or influence our processing.  

  1. Right to Information: With this Data Protection Notice, we provide transparent information in relation to how we process your personal data under Article 13-14 GDPR. You always have the right to receive information about your personal data processed by us in writing or where appropriate by electronic means at any time and as a general principle, free of charge.

  2. Right of Access: Under Article 15 GDPR, you have the right to obtain confirmation if we process your personal data or not, and where it is the case, you have the right to access the personal data and the following information: purposes of processing, categories of personal data, recipients of your personal data including recipients in third countries, retention periods and your rights in relation to the processing of your personal data (mentioned in this Section). You have the right to obtain a copy of the personal data undergoing processing. For additional copies requested by you, we may charge a reasonable fee based on administrative costs.

  3. Right to Rectification: Under Article 16 GDPR, you may request us to rectify, complete or update your personal data at any time and free of charge, if your personal data is inaccurate. Depending on the purposes of the processing, you have the right to have incomplete personal data, including by means of providing a supplementary statement.

  4. Right to Erasure ('right to be forgotten'): Under Article 17 GDPR, you may also request us to erase your personal data without undue delay if your personal data is no longer needed, if you withdraw your consent (if applicable), if you object to the processing (mentioned in detail in this Section), if your personal data has been unlawfully processed or your personal data has to be deleted for a legal obligation.

  5. Right to Restriction of Processing: Under Article 18 GDPR, you have the right to request the restriction of processing your personal data if the accuracy of the personal data is contested by you; the processing is unlawful but you do not want the personal data to be erased, if the data is no longer needed but required for legal obligations, if your objection is pending. In this case, the respective data will be marked and may only be processed by us for certain purposes.  

  6. Right to Data Portability: Under Article 20 GDPR, you have the right to receive the personal data concerning you which you have provided to us in a structured, commonly used and machine-readable format and you have the right to transmit those Personal Data to another entity without hindrance from us.Data Protection Officer

  7.  Right to Object: Under Article 21 GDPR, you have the right to object at any time to the processing of your personal on grounds relation to the particular situation, in certain processing purposes. If you exercise this right, the data will no longer processed unless we can demonstrate compelling legitimate grounds for processing of personal data.

  8. Withdrawal of Consents: If we process your personal data based on your consent (please see Section 4), you may withdraw this consent at any time.

  9. Right to lodge a complaint with a supervisory authority: Under Article 77GDPR, you have the right to lodge a complaint with the supervisory authority against how we process your Candidate Data in relation to your job application.

  10. 

     10. Contact

    If you have any questions about this Data Protection Notice or if you want to know more about the processing of your data as well as exercise your above-mentioned rights, please do not hesitate to contact us. We may be contacted at: compliance.sdcNL@swisscom.com   

     

    Data Protection Officer

     Attn: Aylin Zainea

    Aylin.Zainea@swisscom.com   

     

    11. Amendments to the Data Protection Notice 

    We reserve the right to amend this Data Protection Notice at any time. The version published in the Career Site shall apply.

    Date: December 2024

    Version: 1.2