Recruitment Privacy Notice of the Mitsubishi Chemical Advanced Materials Group

  1. What is this Privacy Notice about?
  2. Who is the controller for processing your data?
  3. What data do we process?
  4. For what purposes do we process your data?
  5. On what basis do we process your data?
  6. With whom do we share your data?
  7. Is your personal data disclosed abroad?
  8. How long do we process your data?
  9. How do we protect your data?
  10. What are your rights?
  11. Do we use online tracking?
  12. What data do we process on our LinkedIn corporate pages?
  13. Can we update this Privacy Notice?

1. What is this Privacy Notice about?

The Mitsubishi Chemical Advanced Materials group (also «MCAM group», «we», «us») collects and processes personal data that concern you but also other individuals («third parties»). We use the word «data» here interchangeably with «personal data».

The «MCAM group» means the Mitsubishi Chemical Advanced Materials AG and its EEA, Swiss and UK subsidiaries and group companies. A list of these subsidiaries and group companies can be found here https://www.mcam.com/eu-en/contact/.

«Personal data» means data relating to identified or identifiable individuals, which means that the relevant data, in combination with additional data, make it possible to draw conclusions about the identity of these individuals. «Sensitive personal data» are a subset of personal data that is specially protected under applicable data protection law. These include, for example, data revealing racial or ethnic origin, health-related data, religious or philosophical beliefs, and information relating to trade union membership. In Section 3, you will find information about the data we process in accordance with this Privacy Notice. «Processing» means any operation that is performed on personal data, such as collection, storage, use, alteration, disclosure and erasure.

In this Privacy Notice, we describe what we do with your data when you use our job application form on the website https://jobs-eu.mcam.comrecruitment portal») or otherwise interact with us in relation with a job opening posted on our recruitment portal or on the LinkedIn corporate page of the individual MCAM group company, a job application or a potential employment contract.

This Privacy Notice does not apply to our employees, contractors or clients, visitors of its websites or to other personal data that the MCAM group collects for purposes other than those defined in this Privacy Notice. Our general website privacy policy is available here: https://www.mcam.com/eu-en/support/privacy-notice. This Privacy Notice does also not apply to the processing of personal data by LinkedIn Corp. and eAcru for their own purposes, which can be found at https://www.linkedin.com/legal/privacy-policy?trk=homepage-basic_footer-privacy-policy, respectively at: https://www.earcu.com/privacy.

If you disclose data to us or share data with us about other individuals such as family members, co-workers, supervisors, former employers, etc., we assume you are authorized to do so and that the relevant data is accurate. When you share data about others with us, you confirm that. Please make sure that these individuals have been informed about this Privacy Notice.

This Privacy Notice is aligned with the EU General Data Protection Regulation («GDPR») and the Swiss Data Protection Act («DPA»). However, the application of these laws depend on each individual case.

2. Who is the controller for processing your data?

The Mitsubishi Chemical Advanced Materials AG, Hardstrasse 5, 5600 Lenzburg, Switzerland (the «MCAM AG») is the main controller with respect to the collection and processing of your data on the recruitment portal and related systems insofar operated for the MCAM group. The individual MCAM group that advertises a particular job opening on the recruitment portal is a joint controller with regard to your data processed with regard to such job opening.

Once a particular job application is handed over to the individual MCAM group company for being processed for a particular job opening (in particular the one for which you apply), such MCAM group company becomes the sole controller of the further processing of your data with regard to such job opening.

The individual MCAM group company that posts job offers on its LinkedIn corporate page is the controller with respect to the collection and processing of your data on that page.

For each processing activity there are one or several parties that are responsible for ensuring that the processing complies with data protection law. This party is called the controller. It is responsible, for example, for responding to access requests (Section 10) or for ensuring that personal data is processed securely and not used in an unlawful manner.

Additional parties may be joint controllers for the processing set out in this Privacy Notice if they participate in determining the purpose or means of the processing. All group companies may act as joint controllers. If you wish to receive information about the controllers for a specific processing activity, you are welcome to ask us as part of your access right (Section 10). We remain your primary contact, even if there are other joint controllers.

In Section 3, Section 6 and Section 11, you will find additional information about third parties with whom we work together and who are controllers for their processing. If you have any questions for these third parties or if you wish to exercise your rights, please contact them directly.

A list of the MCAM group companies, with whom we may share your data or who may be joint controllers for the processing of your data can be found here https://www.mcam.com/eu-en/contact/.

Your primary point of contact for data protection concerns and to exercise your rights under Section 10 is as follows:

Mitsubishi Chemical Advanced Materials AG
Hardstrasse 5
CH- 5600 Lenzburg
dataprivacy@mcam.com

We have appointed a Data Protection Officer for MCAM AG according to article 37 et seq. GDPR:

Mitsubishi Chemical Advanced Materials AG
Data Protection Officer
Talstrasse 70
CH-8008 Zürich

T +41 44 213 66 87
dataprivacy@mcam.com

You can also contact our Data Protection Officer for privacy concerns.

3. What data do we process?

We process various categories of data about you, including current but also previous versions where information changes over time. The main categories of data are the following:

  • Technical data: When you use our recruitment portal, we collect the IP address of your terminal device and other technical data in order to ensure the functionality and security of these offerings. This data includes logs with records of the use of our systems. We generally keep technical data for 12 In order to ensure the functionality of these offerings, we may also assign an individual code to you or your terminal device (for example as a cookie, see Section 11). Technical data as such does not permit to draw conclusions about your identity. However, technical data may be linked with other categories of data (and potentially with your person) in relation with user accounts, registrations, access controls or pre-contractual steps in the context of an employment contract (for example the submission of your job application).

Technical data includes the IP address and information about the operating system of your terminal device, the date, region and time of use and the type of browser that you use to access our electronic offerings. This may help us to provide an appropriate layout of the website or, for example, to display a sub-page for your region. We know through which provider you access our offerings (and therefore also the region) because of the IP address, but usually this does not tell us who you are. However, this changes for example when you create a user account, because personal data can then be linked with technical data (for example, we can know the browser you use to access an account through our website). Examples of technical data include protocols («logs») that are created in our systems (for example the log of user logins to our website).

  • Registration data: Certain offerings on our recruitment portal can only be used with a user account or registration. In this regard, you must provide us with certain data, and we collect data about the use of the offering or service. We generally keep this for 12 months from the date the use of the service ceases or the user account is terminated.

Registration data includes the information you provide when you create an account on our recruitment portal (for example username, password, name, e-mail). In relation with access controls, we may need to register you with your data (access codes in badges, biometric data for identification) (see «other data»).

  • Communication data: When you are in contact with us via the contact or application form, by e-mail or telephone, by letter or other means of communication, we collect the data exchanged between you and us, including your contact details and the metadata of the communication. We generally keep this data for 12 months from the last exchange between us. This period may be longer where required for evidentiary purposes or to comply with legal or contractual requirements, or for technical reasons. E-mails in personal mailboxes and written correspondence are generally kept for at least 12

Communication data is your name and contact details, the means, place and time of the communication and usually also its contents (i.e. the contents of e-mails, letters, chats, etc.). This data may also include information about third parties. For identification purposes, we may also process your ID card number or a password set by you.

  • Job application data: When you apply for a position with us, we collect and process the data that you submit to us in your application materials along with your job application, for example, your name and contact details, information about your academic background, qualifications, and professional experience. We generally collect this data directly from you in your application materials, such as your curriculum vitae, cover letter, diplomas, certificates, academic transcript of records and recommendation letters. Depending on the type of position advertised, we may also receive this data from recruitment and placement agencies that you have provided to them in the context of a job search. If your application is successful and you accept an offer of employment from us, this data that we have collected from you during the pre-employment period will become part of your personnel file with us and will be kept and processed in accordance with the separate privacy notice for employees. If your application is unsuccessful, we generally keep this data for 6 months from the date of notification of the rejection decision. This period may be longer in certain circumstances, for example if you have consented to a longer retention period so that we can inform you of future employment opportunities with us. In that case, we will generally keep the data for 1 year from the notification of the rejection decision, and for a maximum of 2 years if you agree to an extension period.

Job application data includes data such as name, mailing address, e-mail address, telephone number and other contact details, photograph, gender, date of birth, nationality, passport number, immigration status, marital status, number of children, name of relatives working in the MCAM group, salary requirements, function, membership in professional associations; moreover, information on your academic background, diplomas, certificates, academic transcript of records, technical skills, language skills, employment history (including job titles, salary and working hours), reference information from third parties (to the extent permitted), and extracurricular activities.

Depending on the type of position, we may ask you to provide us with additional information for compliance purposes, such as a work permit, a clean criminal record, an extract from the debt collection register, a driving license and a medical certificate confirming your ability to work. The medical certificate is sensitive personal data, for which we will ask you for separate consent to obtain it. The criminal record may be only processed insofar local law permits us to do so.

  • Publicly available data: We may collect certain personal data about you online to the extent that you have made this information publicly available and it is relevant for the job opening at issue or otherwise your assessment as a professional. We generally obtain this information from public sources. For example, we may find your profile on professional social media websites (such as LinkedIn and Xing) and collect the information made available through this channel. We generally keep this data for 6 months from the end of the relevant recruitment process.

Publicly available data includes data such as professional connections on a social media platform, activity on the platform (posts, comments, «likes»), photographs, videos (for example attended or organized webinars, conferences), skills, endorsements, licenses, certifications, publications, and interests (pages, companies and people «followed» on the platform).

  • Reference data: If, in your application, you mentioned persons with whom or for whom you have worked in the past, such as former supervisors, co-workers, we can contact them by e-mail, telephone, letter or other means of communication, or meet with them in person, in order to obtain references about you. We will only contact these persons if you have specifically provided us with their names and contacts details for the purpose of your application. Again, we assume you are authorized to do so and that the relevant data you have provided us is accurate. If you are already employed by us and apply for another internal position, we may request references from your current supervisors and co-workers. We generally keep this data for 6 months from the end of the relevant recruitment process, except in the event of an internal application, where the data is already known to us and kept in accordance with the separate privacy notice for employees.

Reference data includes data such as information about your relationship with the referral person, your personality, abilities, qualifications, contributions to the company, work ethics and job performance.

  • Candidate assessment data: During the recruitment process, we collect data that serves to determine your suitability for the employment position, in addition to the job application data, the publicly available data and reference data. This includes the notes we take during and after our interviews with you, as well as our internal exchanges and discussions about your suitability for the position. If you are already employed by us and apply for another internal position, we may use information from your personnel file to supplement the information you provide to us with your application in order to assess your suitability for the new internal position. We generally keep this data for 6 months from the end of the relevant recruitment process, except in the event of an internal application, where the data is already known to us and kept in accordance with the separate privacy notice for employees.

Candidate assessment data includes data such as information on the personal impressions you made during your interviews with your interlocutors (for example personality traits, engagement in the discussion), your ability to communicate and express yourself, your ability to react to fictitious situations and propose creative solutions, as well as information on your analytical and writing skills.

Depending on the type of position, we may also require that you undergo a medical examination to assess the suitability for the position in question.

  • Behavioral and preference data: Depending on our relationship with you, we try to get to know you better and to tailor our services and offers to you, for example on the recruitment portal. For this purpose we collect and process data about your behavior and preferences. We do so by evaluating information about your behavior in our domain, and we may also supplement this information with third party information, including from public sources. Based on this, we can for example determine the likelihood that you will be interested in certain job openings. The data processed for this purpose is already known to us (for example where and when you apply for job openings), or we collect it by recording your behavior (for example how you navigate our recruitment portal). We anonymize or delete this data when it is no longer relevant for the purposes pursued, which may be – depending on the nature of the data – between 2-3 weeks and 24 months (for job preferences). This period may be longer for evidentiary purposes or to comply with legal or contractual requirements, or for technical reasons. We describe how tracking works on our recruitment portal in Section 11.

Behavioral data is information about certain actions, such as your response to electronic communications (for example if and when you have opened an e-mail) or your location, as well as your interaction with our social media profiles.

Preference data tells us what your needs are, which services or job openings might be of interest to you or when and how you will likely respond to messages from us. We obtain this information from the analysis of existing data, such as behavioral data, so that we can get to know you better, tailor our offers more precisely to you and generally improve our offers. To improve the quality of our analyses, we may combine this data with other data that we also obtain from third parties such as publicly available sources such as the Internet, for example with information about your professional qualifications, publications and anonymous information from statistical offices.

Behavioral and preference data may be analyzed on a personally identifiable basis (for example to show you personalized advertising), but also on a non-identifiable basis (for example for market research). Behavioral and preference data may also be combined with other data (for example, motion data may be used for contact tracing as part of a health protection concept).

  • Other data: We also collect data from you in other situations. For example, data that may relate to you (such as files, evidence, etc.) is processed in relation with administrative or judicial proceedings. We may obtain or create photos, videos and sound recordings in which you may be identifiable (for example in an assessment test, with security cameras etc.). We may also collect data about who enters our premises, certain buildings, and when, or who has access rights (including in relation with access controls, based on registration data or lists of visitors, etc.), and who uses our infrastructure and systems and when. The retention period for this data depends on the purpose and is limited to what is necessary. This ranges from a few days for most the security cameras to usually a few weeks in the case of data for contact tracing and visitor data that is usually kept for 3 months, to several years or longer for reports about events with images.

Much of the data set out in this Section 3 is provided to us by you (through application forms, your application documents, in relation with communication with us, when you use the recruitment portal, etc.). You are not obliged or required to disclose data to us except in individual cases (legal obligations). If you wish to enter into an employment relationship with us or use our services (in particular on the recruitment portal), you must also provide us with certain data, in particular job application data, reference data and – as may be the case on the recruitment portal – registration data, in order to be able to submit your application and be eligible as a candidate for the advertised position. Application to certain positions may be available only through the recruitment portal. When using our recruitment portal, the processing of technical data cannot be avoided. Depending on the job position at issue, we will also insist on collecting publicly available data, reference data and candidate assessment data if you want us to proceed with your job application. If you wish to gain access to certain systems or buildings, you must also provide us with registration data. However, in the case of behavioral and preference data, you generally have the option of objecting or not giving consent.

We provide certain services to you only if you provide us with registration data, because we or our contractual partners wish to know who uses our services, including our recruitment portal, because it is a technical requirement or because we wish to communicate with you. Additionally, we can only consider your application if you provide us with the requested job application data. If you do not provide us with the data necessary for the position you apply for, this may result in our inability to consider your candidacy. In this case, however, before rejecting your candidacy, we will give you the opportunity to provide us with the missing information or documents within a set period of time. Further during the process of assessing you as a candidate for a particular position, we will depending on the position also have to assess your suitability for the position by collecting publicly available data (e.g., to verify your statements made and understand your qualifications), reference data or have you undergo a further assessment resulting in the collection of assessment data and other data. Similarly, we can only submit a response to a request from you if we process communication data and – if you communicate with us online – possibly also technical data. Also, the use of our website is not possible without us receiving technical data.

As far as it is not unlawful we also collect data from public sources (for example the internet, including professional social media websites) or receive data from other companies within the MCAM group, and from other third parties (such as credit agencies, background check agencies, internet analytics services, etc.).

The categories of personal data that we receive about you from third parties include, in particular, information that we receive in relation with administrative and legal proceedings, information regarding the validation of the information you have provided us in your job application data (for example, university degrees, former employments), other background check information (for example, your debt collection status or sanctions listing status, where relevant), what you have been posting on the internet or what other people did (for example, appraisals of you on your professional social media profile), information from other contractual partners of us about your use of our services (for example job applications submitted on the job portal), and other socio-demographic data (especially for research purposes).

4. For what purposes do we process your data?

We process your data for the purposes explained below. Further information is set out in Sections 11 and 12 for online services. These data processing purposes and their objectives represent interests of us and potentially of third parties. You can find further information on the legal basis of our processing in Section 5.

We process your data for purposes related to communication with you, in particular in relation with responding to inquiries and with the exercise of your rights (Section 10) and to enable us to contact you in case of queries. For this purpose, we use mostly communication data and registration data in relation with our recruitment portal. We keep this data to document our communication with you, for quality assurance and for follow-up inquiries.

The above includes all purposes in relation with which you and we communicate, whether in the context of your application, authentication where the recruitment portal is used, or for quality assurance. We further process communication data in order to be able to communicate with you by e-mail and telephone, as well as other means of communication. Communication with you usually takes place in relation with other processing purposes, for example to enable us to arrange an interview with you, to inform you of the outcome of your application or to respond to an access request. Our processing also serves to document the communication and its contents.

We process your data in order to determine whether you are a suitable candidate for the position you have applied for and to decide whether we would like to enter into an employment relationship with you. For this purpose, we mostly use job application data, publicly available data, reference data, and candidate assessment data. We process this data to progress your application through the different recruitment stages, to verify the qualifications information you have provided, to document our recruitment process and maintain employment records, as well as to document our decision-making process and make an informed recruitment decision.

The above include all purposes in relation with the pre-contractual steps necessary for the purposes of entering into an employment contract with you, such as informing the competent persons at the individual MCAM group company of your application (for example the hiring manager, hiring team members, the employees of the human resources department, etc.), making an informed decision to shortlist you for an interview, arranging interviews with you, obtaining relevant references about you, verifying the qualifications information you have provided and, if you application is successful, to enter into an employment relationship with you.

Most of the data we process is directly obtain from you in your application documents. Certain data, however, is obtain from third parties (for example, referees, supervisors, co-workers) or from public sources (for example, professional social media networks, such as LinkedIn and Xing). Again, we process this data to assess your suitability for the position you have applied for.

We further process your data for market research, to improve our services on the recruitment portal, for developing our hiring processes and internal statistical purposes.

We wish to continuously improve our services on the recruitment portal and to be able to react quickly to changing needs. We therefore analyze, for example, how you navigate through our recruitment portal and how new layouts of such recruitment portal might look (for further details see Section 11). This helps us understand the market acceptance of existing services on the recruitment portal and the market potential of new services on the recruitment portal. We therefore process mostly behavioral data and preference data, but also communication data and other information, for example from social media, the Internet and other public sources. We also want to understand the employment market and we want to improve the way how we identify and employ new workers. This may require us to use job application data, publicly available data and candidate assessment data to analyze it and create statistics. We also create Key Performance Indicator (KPI) statistics that enable, for example, to determine the duration of the vacant position and the gender composition of candidates. We use pseudonymized or anonymized data for these purposes, where possible.

We may also process your data for security and access control purposes.

We continuously review and improve the appropriate security of our IT and other infrastructure (for example buildings). Like all companies, we cannot exclude security breaches with certainty but we do our best to reduce the risks. We therefore process data, for example, for monitoring, inspecting, analyzing and testing our networks and IT infrastructures, for system and error checks, for documentation purposes and as part of backups. Access controls include controlling access to electronic systems (for example logging into user accounts on the recruitment portal), as well as physical access control (for example building access when you are invited for an interview or take a job readiness tests). For security purposes, we also keep access protocols and visitor lists and use surveillance systems (for example security cameras). We will inform you about surveillance systems at the relevant locations through appropriate signage.

We process personal data to comply with laws, directives and recommendations from authorities and internal regulations Compliance»).

This includes implementing security concepts to prevent fraud and other criminal offences. We may also be required to make certain clarifications about you or to report to authorities in certain cases. Disclosure, information or reporting obligations, for example, in connection with supervisory authorities and archiving obligations and the prevention, detection and investigation of criminal offenses and other violations. This includes receiving and processing complaints and other reports, monitoring communications, disclosing documents to an authority if we have sufficient reason or are legally obliged to do so. For these purposes we process mostly your job application data and communication data, but also, under certain circumstances, behavioral data and data from the category of «other data». The legal obligations may arise under European, English and Swiss law or other regulations that apply to us, as well as self-regulations, industry standards, our own «corporate governance» and instructions and requests from authorities.

We may further process your data for our internal processes and administration and for protecting our rights.

These purposes include administrative purposes (such as managing job application data, reference data, and data archiving, and testing, managing and improving IT infrastructure), protecting our rights (for example to enforce claims in and out of court and before authorities in the EEA, the United Kingdom, Switzerland and abroad, and to defend us against claims, for example by keeping evidence, by conducting legal assessments and by participating in court or administrative proceedings) and evaluating and improving internal processes. This also includes safeguarding other legitimate interests that cannot be named exhaustively.

5. On what basis do we process your data?

Where we ask for your consent for certain processing activities (for example for processing sensitive personal data and behavior analysis on the recruitment portal), we will inform you separately about the relevant processing purposes. You may withdraw your consent at any time with effect for the future by providing a notice to us in writing (by mail) or, unless otherwise specified or agreed, by e-mailing us; see our contact details in Section 2. For withdrawing consent for online tracking, see Section 11. Where you have a user account on our recruitment portal, you may also withdraw consent or contact us through such recruitment portal. Once we have received notification of the withdrawal of your consent, we will no longer process your information for the purpose(s) you originally agreed to, unless we have another legal basis to do so. The withdrawal of your consent does not, however, affect the lawfulness of the processing based on the consent prior to its withdrawal. If you withdraw the consent for us processing personal data we require for assessing or employing you for a particular position, your will no longer be able to continue with your application for such position.

Where we do not ask for your consent, the processing of your personal data relies on the basis of processing for initiating the necessary steps to enter into an employment contract with you or on our or a third-party legitimate interest in the particular processing operation, in particular in pursuing the purposes and objectives set out in Section 4 and in implementing related measures. This includes compliance with legal regulations, where compliance is not a legal basis under the applicable data protection law (for example under the laws in the EEA, the United Kingdom and Switzerland).

Where we receive sensitive personal data (for example health-related data, data about political opinions, religious or philosophical beliefs, and biometric data for identification purposes), we may process your data on other legal basis, for example, in the event of a dispute, as required in relation with a potential litigation or for the enforcement or defense of legal claims. In some cases, other legal basis may apply, which we will communicate to you separately as necessary.

6. With whom do we share your data?

In relation with the potential employment relationship between you and us, the recruitment portal, our legal obligations or otherwise in relation with the protection of our legitimate interests and the other purposes set out in Section 4, we may disclose your personal data to third parties, in particular to the following categories of recipients:

  • MCAM group companies: A list of our group companies can be found here https://www.mcam.com/eu-en/contact/. When you apply for an open position with us on our recruitment portal, we share your application and, with it, your job application data with the individual MCAM group company that advertised the job opening in question on the recruitment portal, for the purposes of being processed by that group company for that particular job opening. That MCAM group company becomes the sole controller of the further processing of your data with regard to such job opening. Additionally, with your consent, we may share your data with MCAM group companies so that they can contact you in the event of future job opportunities with them that may be of interest to you, with those MCAM group companies acting as sole controllers for such purposes.

The group companies have access particularly to your job application data, publicly available data, reference data, candidate assessment data, and registration data.

  • Service providers: We work with service providers in the EEA, the United Kingdom, Switzerland and abroad who process your data on our behalf or as joint controllers with us or who receive data about you from us as separate controllers (for example IT providers, talent acquisition service providers). This may include health-related data. For the service providers used for our recruitment portal, see Section 11. Our key service provider for talent acquisition is eArcu.

In order to be able to reach out to and receive applications from new candidates, deliver our services (including our services on the recruitment portal) efficiently and focus on our core competencies, we procure services from third parties in various areas. These include IT services, talent acquisition services, information transmission, communication services, fraud prevention measures and services from recruiting agencies. We disclose the data that these providers require for their services, which may also concern you. These providers may also use such data for their own purposes, for example anonymized information to improve their services. In addition, we enter into contracts with these providers that include provisions to protect data, where such protection does not follow from the law.

  • Former and future employers, other organizations referred to in your CV: We may also disclose your data to former employers when you apply for a job with us (for example, reference information) or to future employers when you apply for a new job. These former and future employers act as separate controllers. The same applies with other organizations we may contact for validating your job application data.

We will particularly disclose data related to your reference data, your identity and, eventually, the information we want to have verified. However, we will only do so with your prior consent.

  • Authorities: We may disclose personal data to agencies, courts and other authorities in the EEA, the United Kingdom, Switzerland and abroad, if we are legally obliged or entitled to make such disclosures or if it appears necessary to protect our interests. This may include health-related data. These authorities act as separate controllers.

Examples are criminal investigations, police measures (for example health protection concepts), social security and regulatory requirements, judicial proceedings, reporting obligations and proceedings in and out of court as well as legal information and cooperation obligations.

  • Other persons: This means other cases where interactions with third parties follows from the purposes set out in Section 4. Where these other persons determine the purposes and means of the processing and process your data for their own purposes, they act as separate controllers.

Other recipients are, for example, persons involved in administrative or legal proceedings.

All these categories of recipients may involve third parties, so that your data may also be disclosed to them. We can restrict the processing by certain third parties (for example IT providers), but not by others (for example public authorities).

We reserve the right to make such disclosures even of secret data (unless we have expressly agreed with you that we will not disclose such data to certain third parties, except if would are legally required to do so). Notwithstanding the foregoing your data will continue to be subject to adequate data protection in the EEA, the United Kingdom and Switzerland, even after disclosure. For disclosure to other countries, the provisions of Section 7 apply. If you do not wish certain data to be disclosed, please let us know so that we can review whether and to what extent we can accommodate your concern (Section 2).

In many cases, disclosure of secret data is necessary in order to provide or receive services (for example from insurance, HR service providers). However, depending on the sensitivity of the data and on other circumstances we take care that these third parties deal appropriately with data. Where disclosure is necessary for our activities we cannot comply with your objection to the disclosure.

In addition we enable certain third parties to collect personal data from you on our recruitment portal (for example providers of job tools on our recruitment portal, etc.).

7. Is your personal data disclosed abroad?

As explained in section 6, we disclose data to other parties. These other parties are not all located in the EEA, the United Kingdom and Switzerland. Your data may therefore be processed abroad; in exceptional cases, in any country in the world.

If a recipient is located in a country without adequate statutory data protection, we require the recipient to undertake to comply with data protection (for this purpose, we use the European Commission’s standard contractual clauses, which can be accessed here: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02010D0087-20161217), unless the recipient is subject to a legally accepted set of rules to ensure data protection and unless we cannot rely on an exemption. An exception may apply for example in case of legal proceedings abroad, but also in cases of overriding public interest or if the performance of a contract requires disclosure, if you have consented or if data has been made available generally by you and you have not objected against the processing.

Many countries outside of the EEA, the United Kingdom and Switzerland currently do not have laws that ensure an adequate level of data protection under the GDPR or the DPA. The contractual arrangements mentioned compensate to some extent for this weaker or missing legal protection. However, contractual precautions cannot eliminate all risks (namely of government access abroad). You should be aware of these remaining risks, even though they may be low in an individual case, and we take further measures (for example pseudonymization or anonymization) to minimize them.

Please note that data exchanged via the internet is often routed through third countries. Your data may therefore be sent abroad even if the sender and recipient are in the same country.

8. How long do we process your data?

We process your data for as long as our processing purposes, the legal retention periods and our legitimate interests in documentation and keeping evidence require it or storage is a technical requirement. You will find further information on the respective storage and processing periods for the individual data categories in Section 3, and for cookies in Section 11. If there are no contrary legal or contractual obligations, we will delete or anonymize your data once the storage or processing period has expired as part of our usual processes.

Documentation and evidence purposes include our interest in documenting the recruitment processes and our decision-making process in relation to the recruitment processes, as well as our interactions and other facts in view of legal claims, inconsistencies, IT and infrastructure security requirements and demonstrating good corporate governance and compliance. Retention may be a technical requirement if certain data cannot be separated from other data and we therefore need to keep it with it (for example in case of backups or document management systems).

9. How do we protect your data?

We take appropriate security measures, commensurate with the level of known risk, in order to maintain the required security of your personal data and ensure its confidentiality, integrity and availability, and to protect it against unauthorized or unlawful processing and to mitigate the risk of loss, accidental alteration, unauthorized disclosure or access.

Technical and organizational security measures may include encryption and pseudonymization of data, logging, access restrictions, keeping backup copies, giving instructions to our employees, entering confidentiality agreements, and monitoring. Specifically, we take appropriate organizational measures to ensure that our employees have access to your data on a need-to-know basis, to extent necessary for the purposes described in this Privacy Notice and the activities of the employees concerned. This includes, in particular, the hiring manager and the hiring team members at the individual MCAM group company, the employees of the human resources department and support areas, such as the administrative and IT departments. Our employees act in accordance with our instructions and are bound to confidentiality and discretion when processing your data.

We protect your data that is sent through our websites in transit by appropriate encryption. However, we can only secure areas in our control. We also require our data processors to take appropriate security measures by entering into the necessary data processing agreements with them. However, security risks can never be excluded completely, residual risks are unavoidable.

10. What are your rights?

Applicable data protection laws grant you the right to object to the processing of your data in some circumstances, in particular for processing activities on the basis of legitimate interest.

To help you control the processing of your personal data, you have the following rights in relation with our data processing, depending on the applicable data protection law:

  • The right to request information from us as to whether and what data we process from you;
  • The right to have us correct data if it is inaccurate;
  • The right to request erasure of data («right to be forgotten»);
  • The right to request that we provide certain personal data in a commonly used electronic format or transfer it to another controller;
  • The right to withdraw consent, where our processing is based on your consent;
  • The right to receive, upon request, further information that is helpful for the exercise of these rights.

If you wish to exercise the above-mentioned rights in relation with us or with one of our group companies, please contact us in writing, at our premises or, unless otherwise specified or agreed, by e-mail; you will find our contact details in Section 2. In order for us to be able to prevent misuse, we need to identify you (for example by means of a copy of your ID card, unless identification is not possible otherwise).

You also have these rights in relation with other parties that cooperate with us as separate controllers – please contact them directly if you wish to exercise your rights in relation with their processing. You will find information on our key service providers in Section6 and additional information in Section 11.

Please note that conditions, exceptions or restrictions apply to these rights under applicable data protection law (for example to protect third parties or trade secrets). We will inform you accordingly where applicable.

In particular, we may need to continue to process and keep your personal data in order to enter into and perform an employment contract with you (in such case, your data will become part of your personnel file with us), to protect our own legitimate interests, such as the assertion, exercise or defense of legal claims, or to comply with legal obligations. To the extent legally permitted, in particular to protect the rights and freedoms of other data subjects and to safeguard legitimate interests, we may also reject a subject request in whole or in part (for example by redacting content that concerns third parties or our trade secrets).

If you do not agree with the way we handle your rights or with our data protection practices, please let us or our Data Protection Officers (Section 2) know. If you are located in the EEA, in the United Kingdom or in Switzerland, you also have the right to lodge a complaint with the competent data protection supervisory authority in your country. You can find a list of authorities in the EEA here: https://edpb.europa.eu/about-edpb/board/members_en. You can reach the UK supervisory authority here: https://ico.org.uk/global/contact-us/. You can reach the Swiss supervisory authority here: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html.

11. Do we use online tracking?

We use various techniques on our recruitment portal that allow us and third parties engaged by us to recognize you during your use of our recruitment portal, and possibly to track you across several visits. This Section informs you about this.

In essence, we wish to distinguish access by you (through your system) from access by other users so that we can ensure the functionality of the website and carry out analysis and personalization. We do not intend to determine your identity, even if that is possible where we or third parties engaged by us can identify you through a combination with registration data. However, the technologies we use are designed in such a way that you will be recognized as an individual visitor each time you access the recruitment portal, even without registration data, for example by our server (or third-party servers ) which assign a specific identifier to you or your browser (so-called «cookie»).

Cookies are individual codes (for example a serial number) that our server or a server of our service providers transmits to your system when you connect to our website, and that your system (browser, cell phone) accepts and stores until the set expiration time. Your system transmits these codes to our server or the third-party server on each additional access. That way, you are recognized even if your identity is unknown.

Other technologies may be used to recognize you with some likelihood (i.e. distinguish you from other users), such as «fingerprinting». Fingerprinting combines your IP address, the browser you use, screen resolution, language settings and other information that your system tells each server), resulting in a more or less unique fingerprint. This makes it possible to go without cookies.

Whenever you access a server (for example when you use our recruitment portal or related apps, or because an e-mail includes a visible or invisible image), your visits can therefore be «tracked». If we integrate offers from a provider of an analysis tool on our recruitment portal, it may track you in the same way, even if you cannot be identified in a particular case.

We use these technologies on our recruitment portal and may allow certain third parties to do so as well. However, depending on the purpose of these technologies, we may ask for consent before they are used. You can access your current settings here:
Edit Settings
You can also set your browser to block or deceive certain types of cookies or alternative technologies, or to delete existing cookies. You can also add software to your browser that blocks certain third-party tracking. You can find more information on the help pages of your browser (usually with the keyword «Privacy») or on the websites of the third parties set out below.

The categories of cookies (including other technologies) used in connection with the recruitment portal may be:

  • Necessary cookies: Some cookies are necessary for the functions of the website or for certain features. For example, they ensure that you can move between pages without losing information that was entered in a form. They also ensure that you stay logged in. These cookies exist temporarily only («session cookies»). If you block them, the website may not work properly. Other cookies are necessary for the server to store options or information beyond a session (i.e. one visit to the website) if you use this function (for example language settings, consents, automatic login functionality etc.). These cookies have an expiration date of up to 24
  • Performance cookies: In order to optimize our website and related offers and to better adapt them to the needs of the users, we use cookies to record and analyze the use of our website, potentially beyond one session. We use third party analytics services for this purpose. We have listed them below. Before we use such cookies, we ask for your consent. You can withdraw consent at any time through the cookie settings here:
    Edit Settings
    Likewise, performance cookies have an expiration date of up to 24 Details can be found on the websites of the third party providers.

We currently use offers from the following service provider (where it uses data from you or cookies set on your computer for advertising purposes):

  • Google Analytics: Google LLC is the provider of the service «Google Analytics». For the purposes of the GDPR and the DPA, Google Ireland Ltd. is the controller (both «Google»). Google tracks the behavior of visitors to our website (duration, page views, geographic region of access etc.) through performance cookies (see above) and on this basis creates reports for us about the use of our website. We have configured the service so that the IP addresses of visitors are truncated by Google in Europe before forwarding them to the United States and then cannot be traced back. Google provides us with reports and may therefore be considered our processor, but it also processes data for its own purposes. Google may be able to draw conclusions about the identity of visitors based on the data collected, create personal profiles and link this data with the Google accounts of these individuals. You should assume that this processing takes place if you consent to the use of performance cookies. Information about data protection with Google Analytics can be found here: https://support.google.com/analytics/answer/6004245 and if you have a Google account, you can find more details about Google's processing here: https://policies.google.com/technologies/partner-sites?hl=en.

12. What data do we process on our LinkedIn corporate pages?

We may operate corporate pages on the professional social media network LinkedIn Corp. and collect the data about you described in Sections 3 and below. We receive this data from you and from LinkedIn when you apply directly to a job offer or when you share your LinkedIn profile in response to a job offer published by the individual MCAM group company on its LinkedIn corporate page. At the same time, the platforms analyze your use of our online presences and combine this data with other data they have about you (for example about your behavior and preferences). They also process this data for their own purposes, in particular for marketing and market research purposes (for example to personalize advertising) and to manage their platforms (for example what content they show you) and, to that end, they act as separate controllers.

We receive data about you when you visit the LinkedIn corporate page of an MCAM group company and communicate with it through this page, when you view the job offers that an MCAM group company publishes on its corporate page, when you apply directly to a job offer published by an MCAM group company using the "easy apply" button and thereby provide it with the job application data (such as your name, email address, phone number and curriculum vitae), and when you share your LinkedIn profile with an individual MCAM group company, including the job application data contained therein, by using the "apply" button provided on the LinkedIn job post. LinkedIn also collects technical data, registration data, communication data, behavioral data and preference data from you or about you, among other things (see Section 3 about these terms). In principle, LinkedIn also performs statistical analysis of the way you interact with us, how you use our LinkedIn corporate pages and our content or other parts of the platform (what job post you viewed, applied to, «saved» on your user account, etc.) and combine this data with other information about you (for example information about your age and your gender and other demographic information). That way, LinkedIn creates profiles about you and statistics on the use of our corporate pages. LinkedIn uses this data and pages to display to you our or other advertisements and other personalized content on the platform and to manage the behavior of the platform, but also for market and user research and to provide us and other parties with information about you and the use of our corporate pages. We can control the analysis that LinkedIn generates regarding the use of our corporate pages to some extent.

We process this data for the purposes set out in Section 4, in particular for communication purposes and for the purpose of initiating the necessary steps to enter into an employment relationship with you. You will find information about the applicable legal basis in Section 5. We may disseminate content published by you (for example comments on a particular job post. We or LinkedIn may also delete or restrict content from or about you in accordance with its terms of use (for example inappropriate comments).

For further information on the processing of the LinkedIn platform operator, please refer to its privacy information, which is available here: https://www.linkedin.com/legal/privacy-policy?trk=homepage-basic_footer-privacy-policy. On that link you can also find out about the countries where they process your data, your rights of access and erasure of data and other data subjects rights and how you can exercise them or obtain further information. Some of your data will be transferred to the United States.

13. Can we update this Privacy Notice?

This Privacy Notice is not part of a contract with you. We can change this Privacy Notice at any time. The version published on this website is the current version.

Last updated: February 9th, 2021