PRIVACY POLICY FOR RECRUITMENT CANDIDATES
Thank you for your interest in the recruitment process. Protecting the privacy of our job applicant is very important to us. We make every effort to protect your personal data in an appropriate manner. This policy shows how your data will be processed as well as your rights in regard to the processing of your personal data.
Personal data controller
Your personal data controller, i.e. the entity deciding how your data will be used, is Panasonic Marketing Europe GmbH (Sp. z o.o.), branch in Poland (hereinafter: "Panasonic").
The data protection officer’s e-mail address: dataprotection@eu.panasonic.com
Data protection officer mailing address: The Data Protection Officer, Panasonic Marketing Europe GmbH, Hagenauer Strasse 43, 65203 Wiesbaden, Germany.
The purpose of personal data processing
The specific purposes for which Panasonic processes personal data may be as follows:
a) conducting the recruitment process including the negotiation of employment conditions;
b) counteracting discrimination in the recruitment process;
c) arranging the applicant’s travel and accommodation during the recruitment process;
d) handling complaints, requests and motions submitted in connection with pending recruitment process;
e) ensuring physical security at Panasonic, in particular with regard to video surveillance;
f) implementing an employee referral programme;
g) where applicable, for Panasonic internal reporting, including management reporting;
h) performing duties required by law, as well as tax and accounting regulations;
i) where applicable, for the purposes of judicial, arbitration or mediation proceedings;
j) statistics;
k) archiving;
l) ensuring accountability.
The legal basis of Personal Data Processing
Panasonic is authorized to process your personal data based on the rules of law in force in the country in which the job is offered (the Labour Code and other laws).
We also process your personal data when we must act at your request before entering into an employment contract (Art. 6 (1) (b) of the GDPR), e.g. during the negotiations of salary or other terms and conditions of employment.
In addition, we process your personal data for the purposes and to the extent necessary for the pursuit of our legitimate interests (Article 6 (1) (f) of the GDPR).
In cases other than described above, your personal data is processed on the basis of your consent. For instance, when your personal data goes beyond the scope of the data, the obligation to provide which arises from the provisions of applicable law, in the case of providing your data in the recommendation program of the candidate for work or when you accept our invitation to participate in the future recruitment processes. With your consent, we will also be able to share your data with other companies within our group for our internal reporting purposes and for recruitment carried out in these companies.
Sharing personal data by Panasonic
Panasonic may, for recruitment purposes, make the data of candidates in the recruitment database available in particular to the following Panasonic Group companies:
Panasonic Marketing Europe GmbH Belgrade, Serbia
Panasonic Marketing Europe GmbH Branch Office Slovenia, Podružnica Slovenija, Slovenia
Panasonic Marketing Europe GmbH Branch Office Zagreb, Croatia
Panasonic Marketing Europe GmbH Bulgaria Trade Representative Office, Bulgaria
Panasonic Marketing Europe GmbH organizační složka Česká Republika, Czech Republic
Panasonic Marketing Europe GmbH organizačná zložka Slovenská Republika, Slovakia
Panasonic Marketing Europe GmbH Representative Office Predstavništvo za BiH, Bosnia and Herzegovina
Panasonic Marketing Europe GmbH South-East Europe Branch Office, Hungary
Panasonic Marketing Europe GmbH Wiesbaden Germania, sucursala Bucuresti, Romania
Your personal data may also be transferred to other Panasonic companies to the extent indicated by corporate governance policy.
Due to Panasonic's corporate requirements, your personal data may be transferred to a third country (particularly to Japan).
Panasonic ensures that the transfer of data to third countries will have an appropriate legal basis (e.g. Standard Contractual Clauses adopted by the European Commission, corporate regulations). You can obtain a copy of the personal data transferred to a third country by requesting it at the following e-mail address dataprotection@eu.panasonic.com. The data will be sent in electronic form to the address you have provided us with.
In addition, Panasonic may transfer your personal data to third parties, such as business partners assisting Panasonic in carrying out and operating recruitment processes, outsourcers providing employment services (e.g. employment agencies, outsourcing companies, IT systems suppliers), and others. In our contracts with such entities, we require compliance with the applicable data protection regulations.
If required by the mandatory provisions of law, the Administrator may also make your personal data available to third parties, such as authorised state institutions.
Sharing your data with all these groups of recipients is carried out in compliance with applicable regulations.
Sources of personal data collection by Panasonic
Panasonic can obtain personal data of job candidates from the following sources:
a) From the candidates themselves, from their CVs and other documents submitted by them on-line or by e-mail;
b) From other entities affiliated with Panasonic;
c) During interviews with recruiters and job interviews with managers and other Panasonic employees or representatives, as well as from on-line searches performed by these employees, or job-seeking websites or professional networking sites (e.g. monster.com, LinkedIn, etc.) when a job candidate makes his or her data publicly available;
d) From previous employers;
e) From outsourced recruiters, temporary employment agencies or websites, when a job candidate is introduced to Panasonic through one of these parties. Panasonic does not accept unsolicited resumes from out-of-the-company recruitment agencies, but sometimes uses such agencies pursuant to a written agreement; and
f) Where appropriate, upon an in-depth examination of education and employment history. If permitted by law, Panasonic may enter into a contract with a third party to carry out such examination of the candidate's education and employment history before hiring the candidate. The information collected about the candidate's educational and employment history varies from country to country, and must be compliant with local requirements. It may also include information from publicly available sources, from the candidate's former employers or associates, from the candidate's schools, credit rating agencies and criminal records databases. You will receive more information about the nature of such an analysis of your education and employment history before the check is commenced. If required by applicable local law, you may be asked to provide certain information directly to Panasonic for the purpose of checking your education and employment history (and it may include sensitive data).
These sources are treated as private sources of information unless the source is clearly identified as “public”. Please note that these sources may store candidates' personal data both within and outside the EU.
Retention of personal data by Panasonic
The Data Controller makes every effort to process your personal data in an appropriate manner and as long as it is necessary for the purposes for which the data was collected. With this in mind, in connection with the recruitment procedure, we distinguish two areas of data processing:
a) active data processing, i.e. processing in any manner that is necessary taking into account the purpose for which the data was collected,
b) processing “inactive” data, when active data processing is not performed and the data is only stored in case any potential claims may arise.
We actively process your personal data collected exclusively for the purposes of certain recruitment procedures and only in the course of the recruitment process. After the procedure is completed, the data is only processed in an “inactive” mode for the period in which you can assert claims related to the recruitment procedure. After the expiry of this period, your personal data is deleted.
If you agree for the processing of personal data for future recruitment procedures, the data is actively processed by Panasonic for two years and then processed “inactively” for a period during which you can submit a claim in connection with the recruitment procedure. After the expiry of this period, your personal data is deleted.
If a candidate receives an offer of employment from Panasonic and accepts such offer, the candidate’s personal data collected prior to the employment date with Panasonic will become part of Panasonic's personnel file, and will be kept for the entire period of the candidate’s employment at Panasonic and also for a certain period after its termination.
The retention of data by Panasonic shall be determined in line with the following criteria:
- Panasonic retains candidates' personal data for the entire duration of the relationship with the employment candidate;
- Panasonic retains candidates' personal data if it is required by law;
- Panasonic retains candidates' personal data when it is recommended for the protection or improvement of the company’s legal situation (e.g. in connection with statutes of limitations, court proceedings or regulatory authorities’ investigations).
Voluntary provision of personal data
Types of information that you are required to provide and the way in which it is collected and shared depends on the specific requirements of the country in which the job is offered and not of the country of residence of the candidate for work.
Panasonic may collect the following categories of data:
a) Personal data;
b) Data provided in CVs and cover letters;
c) Data generated by interviewers and recruiters on the basis of their interaction with the job applicant or as a result of a key internet search;
d) If applicable, data provided by outsourced recruitment companies, out-of-company recruiters or job websites;
e) Job referrals;
f) Documentation required by immigration law;
g) Information regarding the candidate's previous employment, education and, where appropriate, criminal record and other data disclosed during the analysis of their education and previous employment;
h) Information regarding the candidate's health condition or disability, where relevant for working ability or availability, or for workplace amenities, subject to legal restrictions on the time such data may be collected and other relevant restrictions.
It is not mandatory to provide Panasonic with any required information, but a lack of information may prevent the candidate from continuing to apply for the selected position.
By providing us with your details, you confirm that any statements made by you are true and correct to the best of your knowledge and belief, and that you have not knowingly omitted any related adverse information. Providing inaccurate information may result in the candidate being ineligible for employment.
Job Candidate's rights against Panasonic regarding data processing
You have the right to request access to data, rectify data, delete data, restrict data processing, transfer data, not have your data subjected to automatic decision making, including profiling, and have the right to object to the processing of your personal data.
You can exercise these rights in the following situations:
a) With regard to a request for rectification: when the data is incorrect or incomplete;
b) With regard to a request to delete data ("right to be forgotten"): when the data is no longer required for the purposes for which it was collected by Panasonic; you withdraw your consent for data processing (within the scope of your consent); you object to the processing of data in advance; the data is processed unlawfully; the data should be deleted in order to comply with the requirement stipulated by the law;
c) With regard to a request to restrict the processing of data: the data is inaccurate - for a period allowing Panasonic to verify the accuracy of the data; the data is processed unlawfully but you do not want the data to be deleted; the data is no longer needed by Panasonic, but may be needed for your defence or redress; or you object to the processing until it is established that the legitimate grounds take precedence over the grounds for objection;
d) With regard to a request for the transfer of data, i.e. the receipt of personal data from the Controller in a structured, commonly used and machine-readable format: the data processing takes place on the basis of your consent or under a contract concluded with you and the processing takes place automatically.
You are entitled to object to the processing of personal data when it is processed on the basis of a legitimate interest and/or for statistical purposes and the objection is justified by your particular situation.
In regard to your consent for personal data processing, you can withdraw your consent at any time. The withdrawal of consent does not affect the lawfulness of data processing carried out on the basis of this consent prior to its withdrawal.
You have the right to lodge a complaint on your personal data processing by Panasonic to the data protection supervisory authority.
Profiling and Automated Personal Data Processing
Profiling means any form of automated processing of personal data consisting in the use of personal data to evaluate certain personal aspects, in particular, to analyse or predict aspects of your performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or relocation.
Your personal data will not be used for automated decision making, and no profiling will be made on the basis of your personal data received by Panasonic.
Final Provisions
This Policy is available in various language versions.
In case of conflict between the English version and other language versions of this Policy, the English version prevails.