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Enreach

Recruitment privacy statement

In this statement "Enreach", "we" or "us" refers to the Enreach entity that you are applying to work for. In addition, you will see a number of references to the "Enreach Group", which includes all other Enreach entities globally.

Details of these can be obtained by contacting us using the details provided below.

When you apply for a position at Enreach, we receive and process personal data about you relating to the application. This means that we are the data controller for the personal data that we process about you. If we process your personal data to offer you a position in one of the Enreach Group companies, we will always inform you which group entity is the data controller for the processing of your personal data.

CONTACT INFORMATION

You can find our contact information here:

Enreach Holding B.V.

Address: Verlengde Duinvalleiweg 102, 1361 BR Almere

Email: info@enreach.com 

Phone: +31 088 889 0889

Data Protection Officer

We have a Data Protection Team and a Data Protection Officer (DPO). If you have any questions relating to the processing of your personal data or want to contact our DPO, feel free to contact our Data Protection Team using the details provided below.

Enreach Data Protection Team

Email: dataprotectionteam@enreach.com 

PURPOSE

The purpose of collecting personal data about you in the recruitment process is to evaluate you for the specific position at Enreach that you have applied for, or in relation to recruitment for another position in the Enreach Group, that we have assessed may be relevant to you.

If we receive personal data due to our contact with you, we process your personal data for the purpose of assessing whether your profile is relevant for a position at Enreach, which we have judged could be suitable for you. Additionally, we exercise the right to process your personal data in order to ensure compliance with the accountability requirements in the Data Protection Regulation (henceforth “GDPR”) which requires controllers to ensure documentation of the recruitment processes in the event of a complaint or dispute.

In connection with our recruitment process, we will process ordinary personal data about you, but it may also happen that we process information about criminal matters or sensitive information related to your health if you actively provide us with this in your application.

In this statement you can read more about what information we process about you when you apply for a position with us.

Categories of personal data

When you apply for a position with us, we collect personal data that are necessary for us to process your application. The categories of personal data will typically be:

 

  • Mandatory contact information: We process personal data such as your name, address, email, and telephone number in order to communicate with you during the recruitment process.
  • Mandatory application material: We also process the personal data that you submit to us in the application material, it will typically be your; application, CV, grade sheets, certificates, references, and other supporting documents that you choose to attach to your application.
  • Information processed in connection with the job interview: We process personal data collected during the job interview, it will typically be notes from your interview with us as well as test results if applicable.
  • Information from background checks: We process personal data collected in connection with the check of references and validation of your educational background, information collected from social media and previous employment relationships, as well as information relating to criminal records, if applicable.
  • Information necessary to comply with applicable law: We process personal data such as residence- and work permits to ensure that you are entitled to work in the specific country that the position is located in.
  • Information collected through tests or assessments: We process information from tests or assessments we may ask you to complete prior to calling for a job interview.

We evaluate your application

We specifically assess each candidate´s qualifications in relation to the vacancy that you have applied for. Once we have read the applications, we select candidates for the recruitment interview(s). Candidates who have not been invited to an interview will be informed at the end of the recruitment process.

We rely on legitimate interest under art. 6(1)(f) GDPR as the legal basis for this processing, as this is personal data that you have provided to us for the purpose of seeking employment with us.

Enreach can receive additional information that you actively submit to us on your own initiative as part of your application that cannot be assessed to be processed on the basis of legitimate interest. Our processing of this information will be deemed to be carried out with your consent under art. 6. (1)(a) or art. 9(2)(a) GDPR, for the remainder of the recruitment process. You can read more about this in the section “Sensitive information”.

Once we have selected you for an interview

In connection with the interview(s), we will receive additional information about you that we store with your application for further use in the recruitment process.

We rely on legitimate interest under art. 6(1)(f) GDPR as the legal basis for this processing, as this is personal data that you have provided to us for the purpose of seeking employment with us.

Enreach can receive additional information that you actively submit to us on your own initiative during your job interview that cannot be assessed to be processed on the basis of our legitimate interest. Our processing of this information will be deemed to be carried out with your consent under art. 6(1)(a) or art. 9(2)(a) GDPR, for the remainder of the recruitment process. You can read more about this in the section “Sensitive information”.

Information obtained from social media platforms

When recruiting for positions with a focus on partner-, customer-, and collaborative relationships, it may be relevant that we perform a search on your social media platforms. It will typically be search on LinkedIn and other SoMe-platforms.

We rely on legitimate interest under art. 6(1)(f) GDPR as the legal basis for the processing of information about candidates obtained from social media platforms. We do this to assess whether you have a public profile that fits in with the company and the specific position you have applied for.

Performance information and tests

In connection with recruitment for some positions, we may ask you to complete a test, such as the development of a piece of source code, the processing of a case or a personality assessment. We always assess whether the specific test or assessment is relevant to the position in question. The purpose of the test is to assess your skills and qualifications as a potential employee and to assess whether your profile fits in with the company and the specific position.

We rely on your consent under art. 6(1)(a) GDPR as the legal basis for processing this information and you will therefore be asked to give your consent before the test is carried out. You may withdraw your consent at any time. You can do this by contacting us via the contact information.

If you withdraw your consent, the withdrawal will only take effect from the date of withdrawal. Therefore, it does not affect the legality of our processing of the data up until the time you withdraw your consent.

Driver’s license

In some positions it will be necessary to see a valid driver’s license. We always assess whether it is necessary for the specific position for us to be presented with such a license. The purpose is to ensure, if your work function requires the use of a car, that you can perform this work function.

We will not store a copy of your driving license, but note whether during the recruitment process, you can present a valid driving license.

We rely on legitimate interest under art. 6(1)(f) GDPR as the legal basis for the processing of information relating to driving licenses.

Criminal record

In some positions it is necessary for us to be presented with clean a criminal record. We always assess whether seeing criminal records is relevant to the position in question. The purpose for the processing is to ensure that you can for example, obtain security the clearances necessary to perform work related activities in data centers.

We will only ask to see this criminal record when you have been offered a position with us, and in doing so, we will ask you for consent to the processing.

We rely on your consent as a legal basis when obtaining criminal records in accordance with art. 10 GDPR and the applicable national legislation of the Enreach entity that you are applying to. You may withdraw your consent at any time. You can do this by contacting us via the contact information.

If you withdraw your consent, the withdrawal will only take effect from the date of withdrawal. Therefore, it does not affect the legality of our processing of the data up until the time you withdraw your consent.

Information from former employers

In some positions it is necessary to obtain references from previous employers. If we obtain references from one or more of your former employers, we will record the information we receive.

We rely on your consent under art. 6 (1)(a) GDPR as the legal basis to process this information and you will therefore be asked to give your consent before we contact one or more of your former employers. You may withdraw your consent at any time. You can do this by contacting us via the contact information.

If you withdraw your consent, the withdrawal will only take effect from the date of withdrawal. Therefore, it does not affect the legality of our processing of the data up until the time you withdraw your consent.

Residence and work permit

It is a condition of employment that you have a valid work and residence permit. To ensure this, we may ask for a copy of your passport in connection with your employment.

If, because of your citizenship, you need a work- and residence permit to work legally for the Enreach entity you are applying for, we will also obtain a copy of your work and residence permit.

We rely on art. 6 (1)(c) GDPR as the legal basis when obtaining a copy of your passport and, where appropriate, work and residence permits, as we can be obliged to ensure this in accordance with national law.

Sensitive information

If you suffer or have suffered from an illness that will have a significant impact on your ability to work in the position for which you are a candidate, you must inform us accordingly at the latest during the job interview process and in accordance with applicable law. If we determine that the health information is relevant to the position in question, we will register the information as part of the recruitment process.

We use legitimate interest art. 6(1)(f) GDPR and art. 9 (2)(b) GDPR (compliance with labor law obligations) as double legal basis for the processing of health data and medical conditions.

At no time do we process sensitive personal data about you during the recruitment process, except for the abovementioned. We therefore request that you exclude such sensitive information from your application material, i.e., information on:

 

  • data concerning health other than the abovementioned.
  • racial or ethnic origin;
  • political opinions;
  • religious or philosophical beliefs;
  • trade union membership;
  • genetic and biometric data;
  • data concerning sexual orientation

 

Additionally, we request that you blur national identification numbers, e.g., Social Security number, in the submitted application material, as national identification numbers are not necessary information in the recruitment process.

STORAGE AND RETENTION

If you are rejected, we will delete the information we have registered about you within 2 to 6 months.

If you are hired, we will store the information that has been part of the recruitment process in our HR system.

If we have obtained a copy of your criminal record in connection with recruitment, we will delete it as soon as we have registered that we have seen your criminal record.

In some situations, we would like to save your application, even if you have been rejected, for later recruitment. If we would like to save your application longer than our standard retention period, we will ask for your consent.

RECIPIENTS

If we deem it necessary for the abovementioned processing purposes, your recruitment information may be shared with one or more third parties, regardless of whether it is affiliated with the Enreach Group, for the purpose of processing personal data in accordance with relevant instructions.

Within the Enreach Group

As the Enreach entity that you are applying to work for is part of a wider group with headquarters in the Netherlands, and entities located in the EEA and the UK, Enreach may transfer your personal data to, or otherwise allow access to such data by, other entities within the Enreach Group, which may use, transfer, and process your personal data for the purposes described within this statement.

Data processors

Data processors- such as recruitment agencies, hosting and IT service companies are contractually obliged to implement appropriate technical and organizational measures to ensure that your personal data is processed in accordance with our instructions.

If you would like to see a full list of the third parties with which we may share your personal data with, you can contact us via the contact information.

Regulators, authorities, and other third parties

Where necessary for the processing purposes described above, personal data may be transferred to regulators, courts and other authorities, independent external advisors, insurance providers, pensions and benefits providers, and internal or external compliance and investigation teams.

On application via Social Media (SoMe) platforms

SoMe platforms collect personal data in the form of your conduct on our SoMe pages, etc., and will be able to compare the information from your profile with these providers. In this context, each provider is the data controller for certain data and for others, providers may have been joint data controllers with Enreach.

We therefore refer to the privacy policies and terms of service of the provider of your SoMe profile.

SECURITY

Enreach has implemented generally accepted standards of technology and operational security in order to protect Personal Data from loss, misuse, alteration or destruction. Only authorized Enreach personnel are provided access to Personal Data and these employees are contractually or statutory obliged to ensure confidentiality of this data.

Enreach will implement appropriate technical and organizational measures to ensure that the Processing of your Personal Data is performed in accordance with data protection law, in particular ensuring an appropriate level of security.

YOUR RIGHTS

Under GDPR, you have a number of rights regarding our processing of your personal data. To exercise these rights, please contact us via our contact information.

Right of access

You have the right to access the information we process about you.

Right to rectification

You have the right to have incorrect or outdated information about yourself corrected.

Right to be forgotten

In exceptional cases, you have the right to have information about you deleted before the time of our retention period.

Right to restrict processing

In some cases, you have the right to have the processing of your personal data restricted. If you have the right to have the processing restricted, we may only process your personal data - except for storage - with your consent, or for the purpose of establishing, asserting, defending, protecting, a significant public- or private interest.

Right to object

In certain cases, you have the right to object to our otherwise lawful processing of your personal data.

Right to receive your information (data portability)

In certain cases, you have the right to receive your personal data in a structured-, commonly used- and machine-readable format and to have that personal data transferred from one controller to another without hindrance.

COMPETENT SUPERVISORY AUTHORITY

You can lodge a complaint about our processing of your personal data with a competent supervisory authority, which in the Netherlands is Autoriteit Persoonsgegevens.

If you have any questions regarding which supervisory authority is applicable to your recruitment process at Enreach, please contact us via our contact information.

CHANGES

Enreach reserves the right to modify or amend this statement at any time. The effective date will be displayed below the statement. It is the user's responsibility to check this document regularly for changes.

“Guarding your privacy is our privilege”

Version 1.0; Sept 2021