Information clause on the processing of your personal data as a potential
Who is the controller of your personal data?
The personal data controller is Alten Polska spółka z ograniczoną odpowiedzialnością with its registered office in Warsaw (00-844), ul. Grzybowska 87, entered in the register of entrepreneurs kept by the District Court for the Capital City of Warsaw, XIII Commercial Division of the National Court Register under KRS number 0000340221 (Administrator).
Contact form: https://www.altenpolska.pl/contact/
What are the contact details of our Data Protection Officer
If you have any questions regarding the processing of your personal data, you can contact the Data Protection Officer at the following email address [email protected]
or in writing to the Controller address adding an annotation "IOD".
For what purposes is your personal data processed?
We process your personal data for the following purposes: to carry out the recruitment process; to assess whether you are a suitable person for the position we are recruiting for; if you have given your consent, also to carry out future recruitment processes; to market our own services; to conduct our business; to establish, assert or defend against claims relating to recruitment; to satisfaction with the recruitment process.
What are the legal bases and purposes for processing your personal data
Your personal data will be processed in accordance with the Data Protection Act of 10 May 2018 (Journal of Laws 2018, item 1000) and the Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation) (GDPR).
The legal bases for processing your personal data are as follows
- Article 22¹ §1 of the Labour Code and the processing needed to conclude the employment contract - with regard to the following data: name and surname, date of birth, contact details, education, professional qualifications, previous employment history or other legal provisions (as required in the job advertisement);
- Article 6(1)(b) of the GDPR - the necessity of the processing for the conclusion of the employment contract (e.g. information about the expected salary and your availability to start work, information about recruitment meetings);
- Article 6(1)(a) GDPR - processing on the basis of your consent given by submitting a recruitment application. This applies to personal data beyond that specified in the Labour Code (i.e. other than: name, date of birth, contact details, education, professional qualifications, previous employment history. This is data that you voluntarily include in your CV or cover letter (e.g. your image, interests, data contained in references from former employers)
- Article 6(1)(a) of the GDPR - processing based on your consent for the purpose of future recruitment for various positions
- Article 6(1)(f) GDPR - processing on the basis of a legitimate interest. The administrator has a legitimate interest to verify your skills and abilities in order to assess whether you are a suitable person for the position for which it is recruiting, e.g. based on the results of your competency tests, information collected from
professional and business portals such as Linkedln. The legitimate interest is also the Administrator's own marketing of its services; the conduct of its business activities (including the execution of contracts with its contractors (business partners/customers and suppliers); the establishment, investigation or defence of possible claims related to recruitment; the transfer of data for internal administrative purposes within the Alten Group; the examination of satisfaction with the recruitment process.
If necessary, we may ask for your consent to process your personal data for purposes other than those indicated above.
As a general rule, we ask you not to indicate any sensitive data during the recruitment process such as information about your health or other data indicated in Article 9 of the DPA. However, if you deem it necessary to provide such data during the recruitment process, e.g. due to your particular situation, we will ask you to consent to our processing of such sensitive data.
To whom can we pass your personal data?
Your personal data may be transferred to entities that process it on behalf of the Administrator, e.g. providers of job advertisement publication services, providers of recruitment management systems, providers of IT services such as hosting, providers of IT systems, whereby such entities process data on the basis of a contract with the Administrator and only in accordance with the Administrator's instructions.
Your personal data may be made available to entities entitled to obtain them on the basis of applicable legislation, e.g. law enforcement agencies.
Your personal data with your consent in terms of name, employment history, professional qualifications may also be shared with the Administrator's business partners/clients to the extent necessary to assess your qualifications and the feasibility of the project for which you are being recruited.
We analyse candidates in the eRectuiter system using various search filters and assess them according to their qualifications, skills and work experience for a specific position. We do this based on our legitimate interest in finding and grouping candidates who are the best fit for a specific position.
How long will we keep your personal data?
Your personal data will be kept for the duration of the recruitment process, i.e. from the moment you submit your application/cd until the end of the recruitment process for the position for which you are applying, but for no longer than 6 months from the date they are obtained
If you have given separate consent to process your data for future recruitment purposes, your personal data will be retained for 36 months from the date it was obtained or until you withdraw that consent - whichever comes first.
What are your rights?
You have the following rights in relation to the processing of your personal data:
- the right to withdraw consent to the processing of personal data;
- the right of access to your personal data (including obtaining a copy of your data)
- the right to request the rectification of your personal data;
- the right to request the deletion of your personal data;
- the right to request restriction of processing
- The right to object to the processing of your personal data on the grounds of your particular situation - in cases where we process your data on the basis of a legitimate interest;
- The right to portability of your personal data, insofar as it is technically possible to send your data. You have this right as regards those data that the Administrator processes on the basis of your consent or contract.
Notwithstanding the above rights, if you believe that your data is being processed unlawfully, you also have the right to lodge a complaint with the supervisory authority competent for the processing of personal data, i.e. the President of the Office for Personal Data Protection.
Please remember that you have the right to withdraw your consent to data processing at any time. The withdrawal does not affect the lawfulness of the processing carried out on the basis of consent prior to its withdrawal. Withdrawal of your consent means that the current recruitment process is terminated and your application will not be considered for future recruitment.
Is the provision of your data voluntary?
Your provision of your personal data is voluntary, however, failure to provide such data to the extent indicated in the Labour Code or other legislation (if indicated above) (name, date of birth, contact details, education, professional qualifications, previous employment history) prevents the recruitment process from commencing. Likewise, failure to provide the data indicated above necessary to take action at your request prior to the conclusion of the contract and necessary in our legitimate interest. The provision of the remaining data is voluntary.
What should you do if you want to exercise your rights?
To exercise your rights, contact: [email protected]
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Clause dated February 2025