PCDC (hereinafter referred to as the “Company“), being a Personal Data Controller within the meaning of the General Data Protection Regulation (EU) 2016/679 (“GDPR“), may collect and process job applicants’ personal data during the recruitment process.
The Company is committed to being transparent and to protecting and respecting job applicant’s privacy in compliance with the provisions of GDPR and the Greek legislation on data protection, as in force. This Privacy Notice (hereinafter referred to as the “Notice”) explains how the Company collects job applicant’s personal data, how it uses them, the conditions under which it may disclose them and how it keeps them secure.
What information does the Company collect and how?
- The Company may collect a range of information about the job applicant including: name, address and contact details, including email address and telephone number;
- details of qualifications, skills, experience and employment history;
- information from interviews and phone-screenings the job applicant may have;
- information about job applicant’s current level of remuneration, including benefit entitlements;
- information about job applicant’s entitlement to work in Greece; and
- equal opportunities monitoring information, including information about job applicant’ ethnic origin, sexual orientation, health and religion or belief.
The Company may collect this information in a variety of ways. For example, personal data might be contained in application forms or CVs (including those sent to the Company as part of speculative applications or queries). Personal data might be also obtained from the job applicant’s passport or other identity documents, or might be collected through interviews or other methods of assessment.
The Company may also collect job applicant’s personal data from third parties, such as references supplied by former employers.
The job applicant’s personal data will be stored in a range of different places, including job applicant’s application record in the Company’s or in its affiliated companies’ HR management systems and/or email systems.
Why does the Company process the job applicant’s personal data?
The Company collects and processes the job applicant’s personal data on a legal basis provided by the Company’s legitimate interests, as follows.
The Company has a legitimate interest in processing personal data during the recruitment process and in keeping records of the personal data. Processing the job applicant’s personal data allows the Company to manage the recruitment process, assess and confirm the candidate’s suitability and ultimately decide to whom the job position shall be offered. The Company may also need to process the job applicant’s personal data so that the Company exercises or defends its legal rights and/or ensure that it complies with its legal obligations deriving from the Law and especially from the employment legislation.
The Company may process information about whether or not job applicants are disabled so it can make reasonable adjustments for candidates who have a disability. The Company’s processing of other special categories of personal data, such as information about ethnic origin, sexual orientation, health or religion or belief, aims at serving equal opportunities monitoring purposes. The Company’s processing of these types of personal data will be carried out to ensure that the Company is able to meet its obligations arising from an employment agreement or (where applicable) to exercise or defend its legal claims.
The Company will not use the job applicant’s personal data for any purpose other than the recruitment process which he/she takes part in.
How does the Company protect job applicant’s personal data?
The Company has internal policies and controls in place to ensure that the requirements of the GDPR are met and takes appropriate technical and organizational measures against unauthorised, unfair or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data or disclosure thereof to any unauthorized party.
For how long does the Company keep job applicant’s personal data?
If the job applicant’s application for employment is unsuccessful (including when he/she has speculatively applied to the Company in respect of a position which is not available), the Company will keep record of the job applicant’s personal data for 36 months. At the end of that period, the job applicant’s personal data are deleted or destroyed (unless the keeping of record for a longer time is required so that the Company exercises or defends any legal claims).
If the job applicant’s application for employment is successful, personal data gathered during the recruitment process will be kept in the job applicant’s personnel file and retained during his/her employment and even thereafter for a period of 20 years (unless the keeping of record for a longer time is required so that the Company exercises or defends any legal claims).
The job applicant’s rights
Being a data subject the job applicant is entitled to:
- access and obtain a copy of the personal data undergoing processing;
- obtain the rectification of inaccurate his/her personal data;
- obtain the erasure of the personal data especially in cases where such data are no longer necessary in relation to the purposes for which they have been collected and processed;
- obtain restriction of processing or object to the processing;
- transmit his/her personal data to another controller without hindrance
If the job applicant wishes to exercise any of the aforementioned rights or if he/she has any questions about this Notice or the Company’s processing of his/her personal data more generally, he/she may contact the Company’s Data Protection Officer Mr. Stathis Mastorakis (Tel. +(30) 210 4099000 (ext. 007), Email Stathis.email@example.com .If the job applicant believes that the Company has not observed his/her data protection rights, he/she can lodge a complaint before the Hellenic Data Protection Authority (HDPA) (firstname.lastname@example.org.).
What if the job applicant does not provide his/her personal data?
The job applicant is under no statutory or contractual obligation to provide his/her personal data to the Company during the recruitment process. However, if the job applicant does not provide them the Company may not be able to process the job applicant’s application.
Who has access to the job applicant’s personal data?
The job applicant’s personal data may be shared internally within the Company for the purposes of the recruitment process. The persons who shall have access to the job applicant’s personal data may be members of the HR team, interviewers involved in the recruitment process and managers in the relevant department.
The Company will not share the job applicant’s personal data with third parties, unless a job position is offered to him/her. The Company may share the job applicant’s personal data with the Company’s affiliated companies for business performance purposes and for management purposes and, if the job applicant is applying for a senior management position with the Company, the latter may share the job applicant’s personal data with the Company’s investors.
In addition, the Company may be required to share the job applicant’s personal information with a regulator, so that the Company complies with any applicable law.
Please indicate your acceptance with the terms set out hereunder either by return e–mail stating that you agree and accept the terms of the Notice or by signing this Notice at the bottom thereof and returning a signed copy thereof by e-mail within 2 days from receipt thereof, otherwise the Company will proceed with the deletion of your job application and will not process it.
The job applicant
[full name and signature]