INFORMATION ON PROCESSING OF PERSONAL DATA
FOR TRANS.EU GROUP
JOB CANDIDATES
The protection of candidates’ personal data at Trans.eu Group is a particularly important part of our DNA. In order to ensure the lawful, reliable and transparent processing of your personal data, we have prepared the following information for you. This document outlines how we handle your personal information and explains your rights when participating in our recruitment processes.
1. Terms used in the document
GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation)
Trans.eu – Trans.eu Group S.A., ul. Racławicka 2-4, 53-146 Wrocław
Trans.eu Group – The list of companies in the group is available at www.trans.eu/pl/o-nas
Controller – Trans.eu or entities belonging to Trans.eu Group
Our – Jointly or separately each of the Trans.eu Group companies
2. Who is the Controller of your personal data and how can you contact us?
The Controller of your personal data is Trans.eu or entities belonging to Trans.eu Group, respectively, in accordance with the content of the job advertisement or other information provided to candidates before they send their recruitment application.
If you agree to participate in future recruitment processes conducted by Trans.eu Group companies, the Controller of your personal data, in addition to Trans.eu, will also be entities belonging to Trans.eu Group (in accordance with the content of the consent and to the extent that your personal data will be processed in recruitment processes conducted by a given company).
If you have any questions regarding the processing of your personal data and your rights, please contact us:
- by sending an e-mail to the following address: taat@trans.eu or by mail to the following address: ul. Racławicka 2-4, 53-146 Wrocław
- by sending an e-mail to our Data Protection Officer: iod@trans.eu
3. What personal data do we process?
We process personal data provided by you in your recruitment application (e.g. data indicated in your CV, application form in the Traffit system), in particular we may process the following information: name, surname, date of birth, contact details (e.g. e-mail address, telephone number, address of residence), information about your education, professional qualifications, professional experience, as well as your image (if you include your photo, e.g. in your CV or make it available during an online meeting).
If competency tests are carried out and you have expressed your willingness to take such tests, we also process information about your knowledge, skills or personality traits (e.g. information about your language skills or aptitude to a specific position).
4. For what purposes do we process your personal data?
We process your personal data for the following purposes:
- Conducting recruitment process for the position indicated in the job advertisement for which you send us your recruitment application, including the selection of candidates for the conclusion of a civil law contract/specific work/cooperation (if such a form of employment is indicated in the job advertisement);
- Carry out future recruitments for different positions, if you have given separate consent;
- Surveying the experience (satisfaction) of participating in our recruitments (candidate experience survey);
- In the case of a positive result of the recruitment, for drafting an employment contract or a civil law contract (e.g. cooperation or specific work contract), as well as to provide you with the necessary information regarding the start of work at Trans.eu Group (e.g. information about training for new employees – our WelcomeDays);
- Pursuing or defending against claims related to the recruitment process.
5. On what legal basis do we process your personal data?
We process your personal data on various legal bases depending on the purpose of their processing:
- We process your personal data indicated in the Labor Code or other relevant national regulations of the law (e.g. your name, surname, date of birth, contact details, education, professional experience) or data necessary to take action before concluding an employment contract or a civil law contract (e.g. your financial expectations, date of commencement of work/provision of services) in order to fulfill a legal obligation to which we are subject (Article 6(1)(c) of the GDPR) or because they are necessary to take action at your request before entering into an employment contract or a civil law contract (Article 6(1)(b) of the GDPR) and providing them will be necessary to take part in the recruitment process;
- We process your e-mail address (required in the Traffit system for recruitment management) on the basis of our legitimate interest (Article 6(1)(f) of the GDPR) consisting in, among others, the possibility of conducting recruitment by electronic means, efficient communication with candidates and ensuring the correct identification of the candidate in the system;
- We process other personal data (e.g. your image, interests, other data) on the basis of your consent and providing them does not affect the possibility of participation in the recruitment process (Article 6(1)(a) of the GDPR).
Providing this data is voluntary. Consent may be withdrawn at any time. The withdrawal of consent does not affect the lawfulness of data processing up to the time of withdrawal of consent;
- We process your personal data for the purposes of future recruitment based on your consent (Article 6(1)(a) of the GDPR), which you express by ticking a specific box under the application form in the Traffit system or in another way indicated by us for a given recruitment process;
- We process your personal data for the purposes of surveying the experience (satisfaction) of participation in our recruitment processes (candidate experience survey) based on our legitimate interest in collecting your assessment of participation in our recruitment processes so that they meet the expectations of candidates and build a positive image of Trans.eu Group (Article 6(1)(f) of the GDPR);
- In the event of a positive result of the recruitment process, we process your personal data to the extent necessary to draft an employment contract or a civil law contract (e.g. a cooperation/specific work contract) (Article 6(1)(b) of the GDPR), as well as to provide you with information necessary before you start working in Group Trans.eu based on our legitimate interest in providing you with information which will help you and us to best prepare for your start at Trans.eu Group (Article 6(1)(f) of the GDPR);
- In the event of misunderstandings between you and Trans.eu Group in connection with the recruitment process, we process your personal data based on our legitimate interest in pursuing claims or defending against claims against Group Trans.eu before courts or state authorities (Article 6(1)(f) of the GDPR).
6. Who do we share your personal data with?
The data may be shared with other recipients in order to carry out the recruitment process based on your explicit consent, to comply with legal obligations, to fulfill contractual obligations or for the purposes of the legitimate interests of Trans.eu Group.
The recipients of your data may be in particular: authorized employees and associates of Trans.eu, other entities statutorily authorized to receive your data on the basis of relevant provisions of law (state authorities, if they request us to do so, e.g. law enforcement authorities), as well as entities belonging to Trans.eu Group (if you have consented to the processing of your personal data by Trans.eu Group companies for the purposes of future recruitment).
Your data may also be made available to entities cooperating with Trans.eu who carry out activities on our behalf and for Trans.eu Group under separate agreements (service providers who support us in conducting recruitment processes), e.g. providers of job advertisement publication services, providers of recruitment management systems, providers of competence testing tools, providers for the transcription of online recruitment interviews, IT service providers (hosting), IT system providers. Your data may be transferred to entities processing personal data at the request of Trans.eu Group and their authorized employees, whereby such entities process data on the basis of an agreement with the Controller and only in accordance with instructions and provided that business secrets are maintained. Access to the data is transferred to those data recipients who need the data in question to fulfill contractual and legal obligations.
7. Where do we get your data from?
We have most of the data we process directly from you as a candidate. In certain cases, some of your data may come from, among others: entities performing activities for and on behalf of our Company under separate agreements, e.g. employment agencies, or from entities to which you have given your consent to their transfer. From these sources, we have data such as: identification data, contact details, sociodemographic data (i.e. about employment, education).
8. How long do we process your personal data?
We will process your personal data for the period necessary to achieve the purposes indicated in section 4:
- To the extent that it is necessary to achieve the objectives of the recruitment process, i.e. for the duration of the recruitment process or, depending on your additional voluntary consent, future recruitments or until the consent is withdrawn, unless the law obliges us to process this data for a longer period or we store them longer in the event of potential claims, for the period of limitation specified by law, in particular the Labor Code or other regulatory provisions (in each case, the longer processing period is decisive).
- For the purposes of surveying the experience (satisfaction) from participation in our recruitment processes (candidate experience survey), for the period of processing personal data for the purposes of recruitment in accordance with letter a above;
- In the event of a positive result of the recruitment, we further process your personal data on the basis of the rules and periods of data processing provided for employees/associates of companies belonging to Trans.eu Group, which will be provided to you after starting work in a specific Trans.eu Group company.
9. Will we transfer your personal data outside the European Economic Area (EEA)?
Your data will not be transferred to recipients in countries outside the European Union (“third countries”). Any transfer of data to a third country may only take place with your consent.
10. What rights do you have?
You have the following rights related to the protection of your personal data. You can submit any requests, dispositions, and queries related to the exercise of your rights by sending an inquiry through the channels indicated in section 2.
You have the right to access the content of your data and the right to rectify, delete, limit processing thereof, the right to data portability, and the right to withdraw consent at any time.
In addition, you have the right to object to the processing of your data at any time.
If you find that the processing of your personal data violates the provisions of the GDPR, you have the right to lodge a complaint with the supervisory authority.
11. Is providing your data voluntary?
Providing personal data indicated in the provisions of law, necessary to take action at your request before concluding a contract or necessary in our legitimate interest, is mandatory to take part in the recruitment process. Providing other data is voluntary. Failure to provide the necessary data will prevent you from participating in the recruitment process.
12. Do we use automated decision-making and profiling?
We do not use any fully automated processes or profiling for the processing of your personal data.