SD Worx Recruitment – privacy notice

What about my personal data?

Hi there! When you apply for a job vacancy with us, we will collect your personal data throughout the recruitment process. In this privacy notice, we will explain what personal data we process about you throughout your recruitment process, and why. Other details will include who has access to your personal data, and how long we keep it. We’ll also point out what your individual rights over your personal data are and how you can exercise them, as well as other important information.

By ‘we’, we mean the SD Worx company you’re applying to. This SD Worx entity qualifies as the controller of your personal data for your recruitment process.  

We have also appointed a Data Protection Officer (DPO). If you have any questions about SD Worx’ privacy and data protection practices, we invite you to contact our DPO by email or otherwise:

SD Worx Group NV
Attn.: Data Protection Officer
Brouwersvliet 2
2000 Antwerpen
Belgium
Via email: dataprotectionofficer@sdworx.com

1. What personal data do we process?

During your application to SD Worx, we will collect and process your personal data during our selection and recruitment process. In this section, we provide an overview of that personal data:

  • Identification data like your first name, last name, gender, address, email address, phone number, date of birth, and photo (if you choose to upload or otherwise provide it);
  • Your CV, motivational letter, information from your LinkedIn profile (to the extent you applied with your Linkedin profile and/or that information was publicly available);
  • Actual and historic job information, like your current and past employers, your current and previous positions and functions, and locations of employment, current and expected wage and salary information;
  • Information and/or recommendations we may receive about you from the references you provided us with;
  • Information we may access and verify during pre-employment screening activities (per applicable law).
  • Information about your formal education, any certifications you may have, and other information about courses you may have followed;
  •  Information about your skills, competences, and language proficiency;
  • Reports from your interviews with us and other information our recruiters and interviewers may create about you;
  • Information about and results of tests and assessments you may have taken during your application;
  • As applicable, other information you may provide or we may collect or generate during the selection and recruitment process.

Except where required or permissible under applicable law, we do not collect or store sensitive personal data and ask that you don’t provide it to us. This is information about your race or ethnic origin, religious or philosophical beliefs, your health or disabilities, sex life or sexual orientation, political opinions, trade union memberships, or other information qualified as sensitive as per applicable law.

2. Where do we collect your personal data from?

Throughout your application process, we will collect your personal data from various sources:

  • Directly from you: when you submit your profile and/or provide us with further information during interviews with our recruiters and hiring managers;
  • From previous employers or other individuals whom you provided to us as professional references;
  • Online sources (for example professional network websites like Linkedin), up to the extent that you have made that information publicly available;
  • Third party recruiters.

3. What we use your personal data for

We will process your personal data for the following purposes:

  • Selection and recruitment: Throughout the selection and recruitment process, we will use your personal data to evaluate if you are a good candidate for the position you’re applying for. This means we will screen and manage your profile, communicate with and interview you, and assess your fit with the vacancy. We do this in our legitimate interest to make sure we make the right choices when recruiting new employees.
  • Building a talent pool: if your application has not been successful, we will include your candidate profile into our talent pool for another year. This way, you remain on our radar in case another or new position opens that fits your profile. We do this in our legitimate interest to ensure we are able to recruit individuals fit for our vacancies, especially where we already know candidates from previous selection efforts.
  • Recruitment marketing: with your consent, we will email you recruitment-related updates and messages, like job alerts and invitations for our recruitment events.
  • Reporting and analytics: to get a broader view on who applies for our vacancies and what recruitment channels work best, we create anonymous reports. Similarly, we perform anonymized analytics on our applicant pool to better understand who applies with us so that we can learn out of those insights. We perform these activities for our legitimate interest in improving our recruitment process.
  • Access management and IT security: a limited amount of your personal data (like your platform login details) will be used to manage and monitor access to, and overall security of, our recruitment platform. This way, we protect our legitimate interest in making sure our IT environments, as well as your personal data, remain secure.
  • Legal and compliance purposes: where necessary, we will also use your personal data to comply with applicable legal obligations or to respond to legal or judiciary process.

4. Who has access to my personal data?

In this section, we want to make explain who can have access to your personal data, and why. As a strict rule, we make sure people, our suppliers, or other third parties only receive or have access to what is really necessary. For clarity’s sake, we distinguish between two kinds of recipients: those within SD Worx, and those outside of our organization.

If we transfer your personal data outside of the European Economic Area, we ensure that that transfer will based on an adequacy decision by the European Commission, or governed by EU standard contractual clauses. If you want to receive a copy of these clauses, you can contact us at dataprotectionofficer@sdworx.com. If neither of these apply, we ensure the international transfer of your personal data is supported by the appropriate safeguard per applicable law.

Recipients within SD Worx
During your application process, several SD Worx stakeholders will be provided with, or have access to, your personal data. This may include people across our global organisation, who work for another SD Worx entity and possibly in another country. This will only be the case where these people justifiably need that access because of their role during your recruitment process or for purposes of IT support. These people include our recruiters, HR managers and advisors, and our hiring managers, who can be located in Belgium, the Netherlands, France, Germany, Luxembourg, the United Kingdom, Ireland, Austria, Switzerland, and Mauritius.

Recipients outside of SD Worx
Your personal data may be shared with or accessible to third parties, including service providers, but only to the extent necessary for them to perform their services to us. Where required, we have strict contracts in place to make sure that they protect any personal data they receive or have access to.

  • HR recruitment partners, with whom, in limited cases, we may exchange your name to verify if you have also applied to our vacancy with them;
  • SAP, the company that hosts and supports our recruitment platform, and our reporting and analytics platform;
  • Governmental agencies in case of legal reporting or other requirements, or law enforcement authorities and/or private parties in the context of legitimate legal and judicial process.

 

5. How long do you keep my personal data?

We take care not to hold on to your personal data for longer than necessary. To determine this, we take a number of criteria into account. These include any legal obligations we may have to retain your data, where we need to retain your data to safeguard or legal position and interests (e.g. in the context of litigation or statutes of limitation), or our recruitment relationship with you.

When your application with SD Worx has been successful and you join our team, your personal data we collected during the recruitment phase will become part of your personnel records. Those records are retained during your employment and for a limited time after. If your application has not been successful, we will include your information into our talent pool for one year, unless you object to this.  

When a retention period has expired, we will either securely delete or safely anonymize the personal data it applies to.

6. Your rights over your personal data

What are my rights?

Data protection law provides you a number of rights. Here, we want to explain what those rights entail, and how you can exercise them. Subject to applicable law, you have the following rights:

The right of access
This right allows you to request a number of things from us. You can ask us to confirm if we process personal data about you and if so, more details like the information we provide in this privacy notice (for example, what personal data and why, how long it is retained and who it is shared with, etc.). This right also allows you to ask us to provide you with a copy of the personal data we process about you. Where you request such a copy (even if you ask for just a specific set of data), we have the right to withhold some data if providing it would infringe on the rights of others.

The right to rectification
You can always ask us to rectify any personal data about you that is incorrect. If your personal data is incomplete or if something is missing, you can provide us with the missing information so that we can complete it. In some cases, you may be able to complete it yourself (e.g. through your profile pages).

The right to erasure
Under specific circumstances, you can ask us to erase all or some of your personal data. By way of example, you can ask us to delete your personal data if a national or EU law obligates us to do so, where you successfully objected, or if it is no longer necessary for the purpose we originally collected it for. We will be able to refuse a request to delete personal data if, for example, we are under a legal obligation to retain it.

The right to restriction
This right allows you to, in some cases, request we temporarily restrict your personal data from being processed. For example, you can ask us to restrict the processing of your personal data until we have corrected your data, if you claimed it was inaccurate.

The right to data portability
T
his right only applies under specific circumstances, and may not include all the personal data we process about you. You can ask for a copy of, in a commonly used and machine-readable format, the personal data you provided to us which we process with your consent or because we need it to perform a contract. Alternatively, you can ask us to provide the same personal data directly to a third party.

The right to object
You have the right to object to any processing we carry out in pursuit of a legitimate interest, where you provide us with arguments specific to your situation. We will stop that processing, unless we can for example demonstrate that legitimate interest still overrides your specific interests, rights and freedoms.

The right to withdraw consent
If and where we process any of your personal data with your consent, you can always withdraw it. Any processing that took place prior to your withdrawal of consent will remain lawful. Your profile settings will allow you to opt out or to opt in to our recruitment marketing communications we described above.

How can I exercise these rights?

If you want to exercise any of the rights above, we ask you to reach out to our Data Protection Officer via email to dataprotectionofficer@sdworx.com.

It helps both of us if you make your request as specific as possible. In some cases, we may reach out to you to verify your identity. This way, we avoid any personal data ending up in the wrong place. We will respond to your request within a month of receipt after having verified your identity. If your request is complex, this may take up to an additional two months.

You also have the right to submit a complaint with your local supervisory authority. You can find an overview of the EU authorities via this website, which will allow you to find the relevant contact details.

7. Version control

We want to be transparent about our processing of your recruitment data. If there are substantial changes to  our recruitment practices, we will update this privacy notice accordingly and let you know that it has been updated.

This version of our privacy notice was published on 1 january 2020