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EMPLOYEES PRIVACY NOTICE
1. INTRODUCTION
Like most businesses, we hold and process a wide range of information, some of which relates to individuals who work for us. The notice focuses on individuals who work for us under employment or civil agreement. It also covers information on our former employ-ees/workers and candidates.
This Privacy Notice explains:
• what personal data we hold and why we process it;
• the legal grounds which allow us to process your personal data;
• where the data comes from, who gets to see it and how long we keep it;
• how to access your personal data and other rights;
• how to contact us.
2. PERSONAL DATA – WHAT WE HOLD AND WHY WE PROCESS IT
We process data for the purposes of our business including management, administrative, employment and legal purposes.
In particular we process the following type of information for you depending on your cat-egory:
Purpose of processing Categories of individuals Categories of personal data
Recruitment Job applicants Contact details
Qualifications
Employment history
Other information included in the CV, collected during the interview (incl. results) and documents at-tached to the CV
3. WHERE THE DATA COMES FROM AND WHO GETS TO SEE IT
Some of the personal data that we process about you comes from you. For example, you tell us your contact and banking details.
Other personal data about you is generated in the course of your work, for example, from your managers, colleagues and customers or others outside our organisation with whom you deal.
Your personal data will be seen internally by managers, HR and, in some circumstances, colleagues. We will where necessary and as set out in this privacy notice also pass your data outside the organisation, for example to people you are dealing with and payroll agencies.
4. HOW LONG DO WE KEEP YOUR PERSONAL DATA?
We do not keep your personal data for longer than is necessary for our purposes. In gen-eral, we will keep your personal data for the duration of your employment and for a cer-tain period afterwards.
Categories of individuals Categories of personal data Retention Period
Job applicants Contact details 3 years from the campaign
Qualifications
Employment history
Other information included in the CV, collected during the interview (incl. results) and documents at-tached to the CV
5. GROUNDS FOR PROCESSING
Under data protection law, there are various grounds on which we can rely when pro-cessing your personal data – such as Contract, Legal obligation, Legitimate Interests and Consent. We process your personal data in reliance on these legal grounds in accordance with GDPR and in compliance with data protection and civil law provisions. In some con-texts more than one ground for processing applies.
Term Ground for processing Explanation
Contract Processing necessary for perfor-mance of a contract with you or to take steps to enter an employment contract or civil with you This covers carrying out our con-tractual duties and exercising our contractual rights
Legal obligation Processing necessary to comply with our legal obligations Ensuring we perform our legal and regulatory obligations. For example, providing a safe place of work and avoiding unlawful discrimination.
Legitimate Interests Processing necessary for our or a third party’s legitimate interests We or a third party have legitimate interests in carrying on, managing and administering our respective business.
Consent You have given specific consent to processing your data In general processing of your data in connection with employment is not conditional on your consent. But there may be occasions where we do specific things and rely on your consent to our doing so.
6. TRANSFERS OF PERSONAL DATA OUTSIDE THE EEA
We will not transfer your personal data outside the European Economic Area.
7. YOUR DATA RIGHTS
We try to be as open as we reasonably can about personal data that we process. If you would like specific information, just ask us.
You also have a legal right to make a “subject access request”. If you exercise this right and we hold personal data about you, we are required to provide you with information on it, including:
• Giving you a description and copy of the personal data;
• Telling you why we are processing it.
If you make a subject access request and there is any question about who you are, we may require you to provide information from which we can satisfy ourselves as to your identity.
In addition to your subject access right, you may have a legal right to have your personal data rectified or erased, to object to its processing or to have its processing restricted. If you have provided us with data about yourself (for example your address or bank de-tails), you have the right to be given the data in machine readable format for transmitting to another data controller. This only applies if the ground for processing is Consent or Contract.
8. CONTACT DETAILS
In processing your personal data, we act as a data controller. Our contact details are:
LEONI Bulgaria EOOD, UIC 204970143
1000 Sofia, Triaditsa district, 56 Alabin Str., floor 2
Email: Galina.Toncheva@leoni.com
Telephone: +359 889 424 010
9. COMPLAINS
If you have complaints relating to our processing of your personal data, you should raise these with HR. You may also raise complaints with the Bulgarian Personal Data Protection Commission.
10. STATUS OF THIS NOTICE
This notice does not form part of your contract of employment and does not create con-tractual rights or obligations. It may be amended by us at any time. Nothing in this notice is intended to create an employment relationship between us and any non-employee providing services to us.
EMPLOYEES PRIVACY NOTICE
1. INTRODUCTION
Like most businesses, we hold and process a wide range of information, some of which relates to individuals who work for us. The notice focuses on individuals who work for us under employment or civil agreement. It also covers information on our former employ-ees/workers and candidates.
This Privacy Notice explains:
• what personal data we hold and why we process it;
• the legal grounds which allow us to process your personal data;
• where the data comes from, who gets to see it and how long we keep it;
• how to access your personal data and other rights;
• how to contact us.
2. PERSONAL DATA – WHAT WE HOLD AND WHY WE PROCESS IT
We process data for the purposes of our business including management, administrative, employment and legal purposes.
In particular we process the following type of information for you depending on your cat-egory:
Purpose of processing Categories of individuals Categories of personal data
Recruitment Job applicants Contact details
Qualifications
Employment history
Other information included in the CV, collected during the interview (incl. results) and documents at-tached to the CV
3. WHERE THE DATA COMES FROM AND WHO GETS TO SEE IT
Some of the personal data that we process about you comes from you. For example, you tell us your contact and banking details.
Other personal data about you is generated in the course of your work, for example, from your managers, colleagues and customers or others outside our organisation with whom you deal.
Your personal data will be seen internally by managers, HR and, in some circumstances, colleagues. We will where necessary and as set out in this privacy notice also pass your data outside the organisation, for example to people you are dealing with and payroll agencies.
4. HOW LONG DO WE KEEP YOUR PERSONAL DATA?
We do not keep your personal data for longer than is necessary for our purposes. In gen-eral, we will keep your personal data for the duration of your employment and for a cer-tain period afterwards.
Categories of individuals Categories of personal data Retention Period
Job applicants Contact details 3 years from the campaign
Qualifications
Employment history
Other information included in the CV, collected during the interview (incl. results) and documents at-tached to the CV
5. GROUNDS FOR PROCESSING
Under data protection law, there are various grounds on which we can rely when pro-cessing your personal data – such as Contract, Legal obligation, Legitimate Interests and Consent. We process your personal data in reliance on these legal grounds in accordance with GDPR and in compliance with data protection and civil law provisions. In some con-texts more than one ground for processing applies.
Term Ground for processing Explanation
Contract Processing necessary for perfor-mance of a contract with you or to take steps to enter an employment contract or civil with you This covers carrying out our con-tractual duties and exercising our contractual rights
Legal obligation Processing necessary to comply with our legal obligations Ensuring we perform our legal and regulatory obligations. For example, providing a safe place of work and avoiding unlawful discrimination.
Legitimate Interests Processing necessary for our or a third party’s legitimate interests We or a third party have legitimate interests in carrying on, managing and administering our respective business.
Consent You have given specific consent to processing your data In general processing of your data in connection with employment is not conditional on your consent. But there may be occasions where we do specific things and rely on your consent to our doing so.
6. TRANSFERS OF PERSONAL DATA OUTSIDE THE EEA
We will not transfer your personal data outside the European Economic Area.
7. YOUR DATA RIGHTS
We try to be as open as we reasonably can about personal data that we process. If you would like specific information, just ask us.
You also have a legal right to make a “subject access request”. If you exercise this right and we hold personal data about you, we are required to provide you with information on it, including:
• Giving you a description and copy of the personal data;
• Telling you why we are processing it.
If you make a subject access request and there is any question about who you are, we may require you to provide information from which we can satisfy ourselves as to your identity.
In addition to your subject access right, you may have a legal right to have your personal data rectified or erased, to object to its processing or to have its processing restricted. If you have provided us with data about yourself (for example your address or bank de-tails), you have the right to be given the data in machine readable format for transmitting to another data controller. This only applies if the ground for processing is Consent or Contract.
8. CONTACT DETAILS
In processing your personal data, we act as a data controller. Our contact details are:
LEONI Bulgaria EOOD, UIC 204970143
1000 Sofia, Triaditsa district, 56 Alabin Str., floor 2
Email: Galina.Toncheva@leoni.com
Telephone: +359 889 424 010
9. COMPLAINS
If you have complaints relating to our processing of your personal data, you should raise these with HR. You may also raise complaints with the Bulgarian Personal Data Protection Commission.
10. STATUS OF THIS NOTICE
This notice does not form part of your contract of employment and does not create con-tractual rights or obligations. It may be amended by us at any time. Nothing in this notice is intended to create an employment relationship between us and any non-employee providing services to us.