PRIVACY STATEMENT for Candidate Data

1.              Introduction

This is ZAMRO’s Privacy Statement for processing personal data of candidates or job applicants of ZAMRO B.V. and its group companies, hereafter ZAMRO, we or us.

At ZAMRO we take your privacy very seriously. We developed this ZAMRO Candidate Data Privacy Statement (“Privacy Statement”) to inform you of how we will use your personal data in relation to applications for roles with ZAMRO.

This Privacy Statement was last updated on 23-05-2018 and may be changed over time. You are advised to regularly review the Privacy Statement for possible changes.

2.              When does this privacy statement apply?

This Privacy Statement is applicable to ZAMRO’s processing of all personal data of potential candidates or job applicants (candidates) processed in relation to our recruitment activities.

This Privacy Statement does not apply to employee data or data of our customers. For information on how ZAMRO protects data of customers please visit www.zamro.nl. If you are an ZAMRO employee, you can find ZAMRO’ Data Privacy Statement on how ZAMRO uses employee data on the ZAMRO Intranet site.

3.              Who is responsible for your personal data?

ZAMRO based at Oosterdokstraat 80, 1011 DK, Amsterdam and its corporate affiliates (collectively, “ZAMRO”) and/or its group companies are the data controller for the processing of your personal data. You can contact our Privacy Officer at hrprivacy@zamro.com.

4.              For which purposes do we process your personal data?

4.1           To find suitable candidates

(a)           What does this purpose entail?

We collect your personal data from public profiles on LinkedIn or other social networks and other publicly-available websites if you reacted to the ZAMRO’ recruitment initiatives on such social networks and websites, or signed up via integrated functionality of such social networks, recruitment websites or our own websites. We also collect your personal data from such sources when you provided a link to your profile on any such site as part of your job application or curriculum vitae submitted with your job application.

We may also obtain your contact details from publicly available sources, including content that you have made public on LinkedIn or other social network sites or similar sites for professional purposes to make an initial contact with you for recruitment purposes. We will only contact you if you have made your contact details available to ZAMRO to contact you for recruitment purposes. We will provide you with a clear option to ask us to stop contacting you for career opportunities and remove your personal data from our systems.

(b)           On what legal basis do we process personal data for this purpose?

For this purpose, we process your personal data based on our legitimate interest. We process your personal data to find suitable candidates for vacancies at ZAMRO.

(c)            Which personal data do we process for this purpose?

For this purpose, we process the personal data you have made public through your public profiles on LinkedIn or other social networks and any correspondence between you and our internal recruiters. This includes your name, contact details if made available, current and past job titles, employment history, educational information, skills, recommendations, and curriculum vitae if you made it available.

(d)           How long do we retain your personal data for this purpose?

For this purpose, your personal data will be retained for as long as the purpose for which we collected it continues, unless a longer retention period is necessary to comply with legal requirements or protect our interests. If you submit a job application and become our employee, we will retain the information obtained during the recruitment process for the duration of your employment. If you applied for a job and were unsuccessful, ZAMRO may retain your personal data for a period of: 4 weeks from our final communication to you for future job opportunities. After this period, your personal data will be deleted from our systems.

4.2           To receive, review and reply to your job application

(a)           What does this purpose entail?

If you contact one of our internal recruiters, apply for a vacancy or register through ZAMRO careers website, we include the personal data you provide us in our recruitment database. We will also process your personal data to manage and update our recruitment database.

(b)           On what legal basis do we process personal data for this purpose?

We process your personal data for this purpose as a preparatory step to possibly entering into an employment contract with you. You are not obliged to provide us with any personal data for this purpose. However, if we don’t receive sufficient information from you to consider your eligibility and to communicate with you, we won’t be able to consider you for a role at ZAMRO.

(c)            Which personal data do we process for this purpose?

For this purpose, we process your name, contact details, address (optional), country of residence, citizenship status, the role you apply for, and any recruitment information you provide to us, such as a link to your public social media account (for instance, LinkedIn) (optional), your curriculum vitae, employment history, education history, skills, motivation, gender (optional), disability (optional), current compensation, and whether you are subject to a non-solicitation agreement. Also, we process your correspondence with ZAMRO with regard to job applications.

(d)           How long do we retain your personal data for this purpose?

We will retain your personal data for this purpose as long as the application procedure for this position is open, unless a longer retention period is necessary to comply with legal requirements or to protect our interests. If you submit a job application and become our employee, we will retain the information obtained during the recruitment process for the duration of your employment.

If you applied for a job and were unsuccessful, ZAMRO may retain your personal data for a period of: 4 weeks from our final communication to you for future job opportunities, unless you gave us permission to keep your data for a longer period in order to match your skills with future job opportunities with ZAMRO. In this case we will keep your data for a period of 1 year. After this period, your personal data will be deleted from our systems.

4.3           To verify your job application information, check your references and assess your suitability for the role you applied for and to make you a job offer.

Depending on the role you apply for, the job application process may include virtual or phone interviews, online assessments, on site interviews and/or psychological assessments, a language test, or system screenings to screen your fit for the job and ZAMRO’ culture. We will process your personal data to manage and execute this process and to process the feedback received about you. Our internal recruiter will inform you about the specific job application process for the role you have applied for. In addition, with your consent, our internal recruiters will check your references.

If you have successfully completed a job application procedure, we will prepare and email you an offer letter. This letter will include the employment conditions we would like to offer you at ZAMRO. This offer is still conditional on a satisfactory background check.

(b)           On what legal basis do we process personal data for this purpose?

We process your personal data for this purpose as a preparatory step to possibly entering into an employment contract with you.

You are not obliged to take part in any element of the job application process or otherwise provide us with any personal data for this purpose. However, if you do not engage in our job application process, we are not able to consider or offer you for a role at ZAMRO.

(c)            Which personal data do we process for this purpose?

For this purpose, we process the information you provided to us following 4.24.1, feedback received from the interviewers who spoke with you, the outcomes of any test you completed and any communications between us.

(d)           How long do we retain your personal data for this purpose?

For this purpose, your personal data will be retained for 4 weeks. After this period, your personal data will be deleted from our systems.

4.4           To check your background

If you have accepted a conditional offer at ZAMRO, we will do a background check. Depending on your role with us, these background checks may be for verification of information provided by you to us and/or to verify information about criminal convictions.

(b)           On what legal basis do we process personal data for this purpose?

We process your personal data for this purpose as a preparatory step to possibly entering into an employment contract with you. You are not obliged to provide us with any personal data for this purpose. However, if we cannot perform a satisfactory background check, we are not able to consider you for a role at ZAMRO. We only perform background checks to the extent permitted by applicable law in your country.

(c)            Which personal data do we process for this purpose?

You will be approached by the ZAMRO recruiter to explain what information should be submitted for the background check procedure.

If we have any concerns following your background check, we will liaise with you directly.  If something on your background check indicates that we cannot hire you, we will notify you and provide you with a copy of your background check report, where required by applicable law. We will also provide you a reasonable period of time to dispute, correct, explain or otherwise respond regarding the information disclosed in the background check report, where required by applicable law.

(d)           How long do we retain your personal data for this purpose?

If you become our employee, we will retain the results of your background check for the duration of your employment. If you applied for a job and were unsuccessful, ZAMRO may retain your personal data for a period of: 4 weeks. After this period, your personal data will be deleted from our systems.

4.5           If you have been rejected for a particular role at ZAMRO, we process your personal data to inform you and communicate with you about vacancies that you may be interested in if you choose to.

Sometimes, we just do not have the right role available for you yet. If you choose, we will keep information about you in our database and contact you if we have a new vacancy that may be of interest to you. We may also invite you for recruitment activities or communicate with you about job opportunities.

(b)           On what legal basis do we process personal data for this purpose?

For this purpose, we process your personal data based on your consent.

If you give us your consent to process your personal data for this purpose, you have the right to withdraw your consent at any time by sending an email to adriaan.van.der.heijden@zamro.com. Please note that this will not affect the lawfulness of any processing based on your consent before the withdrawal.

(c)            Which personal data do we process for this purpose?

For this purpose, we process your contact details (such as your address and email address), the information you submitted to us in the course of previous job applications (for example, your resume) and a summary of how you performed during previous job applications with us.

(d)           How long do we retain your personal data for this purpose?

Your personal data will be retained for 1 year in our recruitment database for this purpose.  After this period, your personal data will be deleted from our systems.

5.              Who has access to your personal data?

5.1           Access to your personal data within ZAMRO

Your personal data can be accessed by relevant ZAMRO departments such as recruiters, hiring managers, ZAMRO employees directly involved in your job application process, employment counsel or other HR functions involved, and legal, compliance, data protection or integrity officers to the extent strictly necessary to fulfil their respective tasks. If your application indicates interest in working internationally, we may provide your personal data to our global affiliates, in connection with possible opportunities at those affiliates. If ZAMRO employs you within any of its affiliates, it will retain your personal data and may use it and disclose it to others for personnel, administrative, or other purposes related to your job application or employment with ZAMRO.

5.2           Access to your personal data by third parties

The following third parties have access to your personal data where relevant for the provisioning of their products or services to ZAMRO:

  • Travel agencies
  • External assessment consultants
  • IT suppliers
  • Financial, tax or legal advisors

If the ownership or control of all or part of ZAMRO changes, we may transfer your personal data to the new owner.

We may also provide your personal data to federal, state, local, or other government agencies that have jurisdiction over matters related to employment. ZAMRO will not provide your personal data to other third parties unless it is required to do so by a valid court order, governmental agency order or information request, or unless it has a legitimate business purpose for doing so and the third party agrees to similar restrictions on disclosure and use of your personal data.

5.3           The use of your personal data by data processors

When a third party processes your personal data solely following ZAMRO’ instructions, it acts as a data processor.  We enter into agreements with such data processors, relating to the processing of personal data.  In this agreement we include obligations to safeguard that your personal data are solely provided to the data processor to provide services to us,

5.4           Transfers of your personal data outside of your home country

Your personal data may be processed by ZAMRO, its affiliated companies and ZAMRO’ trusted third party suppliers anywhere in the world, including in countries where data privacy laws may not be equivalent to, or as protective as, the laws in your home country.

We will implement appropriate measures to ensure that your personal data remains protected and secure when it is transferred outside of your home country, in accordance with applicable data protection and privacy laws.

6.              How are your personal data secured?

ZAMRO has taken adequate safeguards to ensure the confidentiality and security of your personal data.  ZAMRO has implemented appropriate technical, physical and organisational measures to protect personal data against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorised disclosure or access, and against all other forms of unlawful processing (including, but not limited to unnecessary collection) or further processing consistent with applicable data protection and privacy laws.

For example, when we share your personal data with external suppliers, we may put in place a written agreement which commits the suppliers to keep your information confidential, and to put in place appropriate security measures to keep your information secure.

7.              Your rights

Under applicable data protection and privacy laws, you may have rights to:

·       Access your personal data

You may ask us whether we process any personal data that relates to you. If this is the case, you may ask us to provide you with a copy of the personal data we process of you insofar as required by applicable data protection laws.

·       Correct and erase your personal data

You may request us to correct any inaccurate personal data we process of you. Also, you may ask us to erase the personal data that relate to you if they are no longer necessary for the purposes for which we processed them, if you have withdrawn your consent and we do not have another legal ground for processing your personal data, if your personal data have been unlawfully processed, if your personal data have to be erased following applicable EU or EU member state laws, or if it concerns a child’ personal data processed in relation to offering information society services.

·       Request the restriction of processing

You may request the restriction of the processing of your personal data if you have contested the accuracy thereof, if the processing is unlawful and you prefer restriction over erasure, if we no longer need your personal data for a purpose but you need them for the establishment, exercise or defence of legal claims, or while your exercised your right to object is being reviewed.

·       Object to processing your personal data

You may object to our processing of your personal data based on our legitimate interest. We will then no longer process your personal data for this purpose, unless we have an overriding legitimate interest to do so. You may also ask us to erase your personal data, unless there is an overriding legitimate interest for the processing.

You may also opt out from processing your personal data for direct marketing purposes.

·       Withdraw your consent to processing your personal data

You may withdraw your consent to the processing of your personal data (where ZAMRO is processing your personal information based on your consent).

·       Data portability

You may request receipt or transmission to another organisation, in a machine-readable form, of the personal information that you have provided to ZAMRO.

·       Lodge a complaint with supervisory authority

If you feel that we do not comply with the applicable privacy laws, you have the right to lodge a complaint with your local supervisory authority.

8.              Contact information If you have any questions regarding the processing of your personal data, send a request relating to any of your data protection rights, please contact our Privacy Officer at privacy