ST ENGINEERING IDIRECT
JOB CANDIDATE PRIVACY NOTICE
ST Engineering iDirect (Europe) CY NV (the “Company“) and our affiliated companies, ST Engineering iDirect (Europe) NV, ST Engineering iDirect (Luxemburg) Sarl, ST Engineering iDirect (Germany) GmbH, ST Engineering iDirect (France) Sarl, Turboconcept Sarl, ST Engineering iDirect, Inc. dba iDirect, and ST iDirect Soluções em Equipamentos para Satélites Ltda. (together, ” iDirect“, “we“, “our” or “us“) takes your data protection rights and our legal obligations seriously. The information that you provide to us in the course of your application for employment with us in Europe, as well as other information that relates to you or any other living individual (“Personal Data“) will be treated in a secure and confidential manner as set out in this Privacy Notice (“Notice“).
If you are a citizen of Cuba, Iran, North Korea or Syria seeking employment with us, an export license issued by the US Government will be required iDirect unless you have legal protection status or permanent work status in country other than the four (4) countries previously listed. We will review and evaluate written proof of such status prior to any employment offer.
In connection with apply for the US export license, we will collect Personal Data including, place of birth, schooling, prior employment and military service.
The Company and the ST Engineering iDirect, Inc. dba iDirect entity posting a position are the joint controllers of your Personal Data. For Germany, candidates may request information about the joint controller relationship between the Company and the iDirect group entity posting the position.
1. Personal Data
We may collect various types of Personal Data about you for the purposes described in this Notice, including:
- Data about you: forename and surname, gender, nationality, civil/marital status, date of birth, age, home contact details (e.g., address, telephone number, e-mail), national ID number, immigration and eligibility to work data, next-of-kin/dependent contact information.
- Data about your employment history and qualifications: qualifications, references, CV and application.
- Data about your application: CV and application, interview data, verification information.
- Legal and criminal records data: In compliance with the applicable laws and only in specific, limited circumstances.
2. Personal Data We Process
You may give us the Personal Data described above during the recruitment process, whether through your application, further communications, on the telephone or at interviews.
We may also receive Personal Data about you from third parties; for example, recruiters; references from a previous employer; business partners; sub-contractors providing recruiting or technical services; analytics providers; background check providers; search information providers; and from publicly available sources such as social media where such Personal Data is proportionate to the position for which you are applying. We may also retain that Personal Data after you have been employed (where this is relevant and to the extent permitted by applicable law).
We may also receive information which may include your Personal Data from our hiring manager, from Human Resources, from recruiters and, from time to time, from our other employees (for instance, in the course of conducting an interview).
3. Why We Process Your Personal Data
The Personal Data requested from you during the recruitment process is required by us in order to assess your application for employment with the iDirect group entity posting the position. There is no obligation to provide the Personal Data; however, if you do not provide some or all of this Personal Data it may affect our ability to process your application and therefore to enter into an employment agreement with you. In some cases, it may mean that we are unable to continue with your application for employment as the Company will not have the Personal Data we believe to be necessary for the effective and efficient management of the recruitment process.
We collect the Personal Data described in Sections 1 and 2 above for the purposes of managing the Company’s recruitment related activities. The Company may also use your Personal Data in relation to the evaluation and selection of applicants, including for example setting up and conducting interviews and tests, and conducting evaluations, assessments and otherwise as needed in the recruitment process, including if relevant, issuing employment offers.
We process your Personal Data for the purposes described above on at least one of the following legal bases:
- the processing is necessary for compliance with a legal obligation to which the Company is subject (notably verifying eligibility for employment or complying with obligations regarding non-discrimination); or
- the processing is necessary in order to take steps at your request prior to entering into an employment contract with you (notably verifying your qualifications and work history); or
- the processing is necessary for the legitimate interests pursued by the Company in hiring qualified and appropriate persons (notably by conducting interviews), except if in light of particular circumstances our interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data.
The processing of legal or criminal records data will be undertaken in compliance with applicable laws and in specific circumstances, where required or permitted by the applicable laws, national collecting bargaining agreements or binding resolutions of the relevant Data Protection Authority. The legal basis for such processing will be necessity for compliance with a legal obligation, or the Company’s legitimate interests in hiring, for roles involving the regular handling of significant assets, persons who have proven their reliability and probity.
4. With Whom Do We Share Your Personal Data?
As a global organisation consisting of businesses in various countries, the Company may hire for its sites, and use resources, located throughout the world. Your Personal Data may be shared with affiliated companies where it is reasonable and necessary to do so. Within the Company, your Personal Data can be accessed by or may be disclosed internally on a need-to-know basis to persons responsible for managing or making hiring decisions, Human Resources staff, system administrators and other support teams (such as IT and Finance).
Your Personal Data may also be accessed by third parties who provide us with services relevant to your recruitment, namely recruiters; companies that host, support and/or maintain the IT systems supporting our recruitment system; and companies that verify your references, undertake background checks or conduct vetting on our behalf.
If your application for employment with the Company is successful and you accept a job offer from us, your Personal Data may also be shared with HR information, payroll and benefits systems, and the Personal Data contained in such systems may be accessible by providers of those systems, their affiliated companies and sub-contractors; tax authorities; regulatory authorities; and our lawyers, auditors, investors, consultants and other professional advisors.
The Company expects all third parties to process any Personal Data disclosed to them in accordance with applicable law and contract terms, including with respect to Personal Data confidentiality and security. Where these third parties act as a “data processor” (for example, by verifying your references at our request), they carry out their tasks on our behalf and upon our instructions for the above mentioned purposes. In this case, your Personal Data will only be disclosed to these parties to the extent necessary to provide the required services.
5. Security of Personal Data
We implement what we determine to be reasonable physical, technical and administrative security standards designed to protect your Personal Data from loss, misuse, alteration, destruction or damage.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our recruitment portal, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
The transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our recruitment portal any transmission is at your own risk. Once we have received your Personal Data, we will use strict procedures and security features to try to prevent unauthorised access.
6. Where we Process and Store your Personal Data
From time to time your Personal Data will be transferred outside your country for the purposes described in this Notice and the Appendix. For example, your Personal Data may be transferred, among other purposes, to conduct the review of your application, the processing of your details and the provision of support services.
We may share your Personal Data (i) with colleagues within the Company; (ii) with colleagues at iDirect; and (iii) with third parties as described in this Notice and the Appendix. Your Personal Data may be transferred to Canada and the United States (“U.S.”). Canada has been determined by the European Commission to grant adequate protection to Personal Data, while the U.S. has not. The iDirect group has entered into European Commission-approved Standard Contractual Clauses to safeguard transfers of Personal Data among iDirect group companies, including transfers outside the EU/EEA or the UK.
Transfers to third parties outside the EU/EEA or UK may be made pursuant to the European Commission-approved Standard Contractual Clauses, Binding Corporate Rules, or other legally acceptable mechanisms that ensure an adequate level of protection, unless such are not required due to an exception under the General Data Protection Regulation (cf. Art. 49 of the General Data Protection Regulation, e.g. transfer necessary for contract performance). In addition to this, we intend to, where necessary, agree on additional measures with recipients to ensure an adequate level of data protection.
Where applicable, you are entitled, upon request sent to the recruitment manager or at email@example.com, to receive a copy of the relevant contract (such as Standard Contractual Clauses or Binding Corporate Rules) showing that appropriate safeguards have been taken to protect your Personal Data in connection with such transfer. Please note that such copy may be redacted to the extent necessary to protect business secrets or other confidential information.
7. Retention of your Personal Data
Our general approach is to retain candidate Personal Data for a period of six months following the closure of the recruitment process relating to the role for which you applied. You may request deletion of your Personal Data. We will not keep your details on file for future job openings unless you expressly consent that we may do so. In certain cases, legal or regulatory obligations require us to retain specific records for a set period of time.
If you accept employment with the Company, your Personal Data related to the recruitment process will be held on the basis set out in our Employee Privacy Notice, which is provided to all employees.
8. Your Rights
8.1 Right to Access and Correct your Personal Data; Right to Withdraw Consent
The Company aims to ensure that all Personal Data is correct. You can see and update most of your Personal Data yourself via our recruitment portal.
You have the right to request access to any of your Personal Data that the Company may hold, and to request correction of any inaccurate Personal Data relating to you. You can see and update most of your Personal Data yourself via our recruitment portal available here.
If we are processing your Personal Data on the basis of your consent (for example, if we keep your details on file for future job openings), you have the right to withdraw such consent at any time. You can do this by (i) in some cases deleting the relevant Personal Data from our recruitment portal (although note that in this case it may remain in back-ups and linked systems until it is deleted in accordance with our data retention policy) or (ii) contacting the recruitment manager.
8.2 Additional rights
You also have the following additional rights:
- Data portability – where we are relying (as the legal basis for processing) upon your consent, or the fact that the processing is necessary to perform a contract to which you are party or to take steps at your request prior to entering a contract, and the Personal Data is processed by automated means, you have the right to receive all such Personal Data which you have provided to the Company in a structured, commonly used and machine-readable format, and also to require us to transmit it to another controller where this is technically feasible.
- Right to erasure – you are entitled to have your Personal Data erased under specific circumstances, such as where you have withdrawn your consent, where you object to processing based on legitimate interests and we have no overriding legitimate grounds (see below) or where Personal Data is unlawfully processed.
- Right to restriction of processing you have the right to restrict our processing of your Personal Data (that is, allow only its storage) where:
- you contest the accuracy of the Personal Data, until we have taken sufficient steps to correct or verify its accuracy;
- where the processing is unlawful but you do not want us to erase the Personal Data;
- where we no longer need your Personal Data for the purposes of the processing, but you require such Personal Data for the establishment, exercise or defence of legal claims; or
- where you have objected to processing justified on legitimate interest grounds (see below), pending verification as to whether the Company has compelling legitimate grounds to continue processing.
Where your Personal Data is subject to restriction, we will only process it with your consent or for the establishment, exercise or defence of legal claims.
- Right to object to processing justified on legitimate interest grounds – where we are relying upon legitimate interest to process Personal Data, you have the right to object to that processing. If you object, we must stop that processing unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or we need to process the Personal Data for the establishment, exercise or defence of legal claims. Where we rely upon legitimate interest as a basis for processing, we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis.
- You also have the right to lodge a complaint with the supervisory authority of your habitual residence, place of work or place of alleged infringement, if you consider that the processing of your Personal Data infringes applicable law.
9. How to Contact Us; How to Exercise Your Rights
To obtain further information regarding your rights, to exercise any of your rights, or to ask any questions regarding the processing of your Personal Data, please contact firstname.lastname@example.org.
10. Changes to this Notice
If we still have your email on file, as described in Section 7 above, we will notify you in advance of any changes to this Notice and the Appendix that are material or may impact you. For other changes, please check back frequently to see any updates or changes to this Notice and the Appendix (if relevant to you).