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LPP SA Privacy Policy Recruitment

LPP SA Privacy Policy Recruitment

This privacy policy sets out the principles and scope of the processing of your personal data as well as your rights and our obligations as the Controller. With state-of-the-art technical and organisational measures, we seek to ensure a high level of protection for the personal data we process to safeguard them against unauthorised access.

In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (hereinafter RODO), please note as follows:

Data controller (hereinafter DC):

LPP S.A. with its registered office in Gdańsk, ul. Łąkowa 39/44, entered in the National Court Register kept by the Gdańsk-Północ District Court in Gdańsk, 7th Commercial Division of the National Court Register under KRS number 0000000778, share capital PLN 3,708,482 (paid in full), REGON 190852164, NIP 583-10-14-898 (hereinafter: “LPP”).

Contact with the Data Protection Inspector (hereinafter: DPI) and in matters concerning personal data:

You can send any notification or request regarding your personal data to us by the following choices:

by e-mail to: dataprivacy@lpp.com
by post to: LPP S.A., Dział Personalny (Personnel Department), ul. Łąkowa 39/44, 80-769 Gdańsk.

Purposes of processing

To recruit employees
To recruit for usability tests
To conduct usability tests

1. To recruit employees

Purposes and bases of personal data processing:

a) to carry out the recruitment procedure within the scope of data provided for in the Labour Law (Article 22¹ of the Labour Code) and to take the necessary actions to conclude a contract with the selected candidate pursuant to Article 6 (1)(b) of the GDPR;
b) to carry out the recruitment, on the basis of consents granted by you, including personal data provided other than those resulting from the provisions of the law, pursuant to Article 6(1)(a) of GDPR (ordinary data) or pursuant to Article 9 (2)(a) of GDPR (special category data, e.g., data concerning health condition or degree of disability);
c) to conduct analyses and occupational aptitude tests in order to check skills and abilities for selected job positions through dedicated tools pursuant to Article 6(1)(a);
d) o participate in future recruitment processes, under the consent granted pursuant to Article 6(1)(a) of the GDPR.

Scope of data required: provision of data resulting from Article 22¹ of the Labour Code is required to participate in the recruitment. The scope of necessary data includes: full name, date of birth, contact data (i.e., phone number, e-mail address, contact via social networking site such as LinkedIn); education, professional qualifications or course of previous employment.

Voluntary data: other personal data included in the application documents and the application form are voluntary and may include:
a) other data usually not prescribed by law, e.g., photo (image of the candidate), interests and additional skills;
b) special category data (specified in Article 9 of the GDPR, such as concerning health or disability certificates.

Source of data: We received your data directly from you or from our employee who suggested your candidacy in the recruitment process within the employee referral programme, in particular the data contained in your CV (first name, surname, e-mail address or telephone number).

The recipients of the personal data may include:
a) entities of the LPP S.A. Group, including in particular SilkyCoders Sp. z o.o., DockIT Sp. z o.o., LPP Retail Sp. z o.o. or LPP Logistic z o.o.;
b) entities providing legal services;
c) entities providing correspondence;
d) entities providing archiving services and destroying documentation;
e) entities providing service and technical maintenance of devices used by the controller;
f) entities providing IT services for the controller;
g) entities (web portals) publishing the announcement of the commenced recruitment process in case you submit your application via this portal or providers of recruitment management systems.

The controller may entrust personal data to providers of services or products acting on its behalf on the basis of an entrustment agreement for the processing of personal data, requiring such entities to perform activities upon documented instructions, while maintaining confidentiality and protecting the privacy and security of the entrusted personal data.

Period of data processing: the data will be processed until the end of the recruitment process, for no longer than 12 months from the date of submission of the application or for the period indicated in the possible consent for future recruitment, for no longer than one year from the end of the recruitment process. Your data for the purposes of future recruitment will be processed for 12 months from the date of consent.

Your rights:
a) to access your personal data and request a copy of it;
b) to rectify your personal data;
c) to request the restriction of the processing of his/her personal data;
d) to exercise data portability;
e) to withdraw consent at any time, whereby withdrawal of consent shall not affect the lawfulness of processing carried out on the basis of consent before its withdrawal;
f) to erase the data if no other purpose of the processing is pursued and there are no grounds excluding this right, as per Article 17 (3) of the GDPR;
g) object to the processing of personal data in the scope of the legitimate interest of the administrator;
h) to file a complaint with the President of the Office for Personal Data Protection (https://uodo.gov.pl).

You can exercise the above rights by contacting the DC or the DPI in writing or by e-mail.

2. To recruit for usability tests

Purpose of processing

Recruitment of persons willing to participate in a website usability study.

Data type

Full name, telephone number, e-mail address, place of residence, age, gender and employment data.

Legal basis for processing

Your personal data is processed under Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC and the Data Protection Act of 10 May 2018.

LPP processes your personal data with your consent. Giving your consent to the processing of your personal data is completely voluntary; however, the lack of consent prevents you from sending your application and participating in the recruitment process.

You have the following rights in the processing of your personal data:

You may withdraw your consent at any time – without giving any reason. The request may relate to the purpose of processing which you submitted. The withdrawal of consent will not affect the activities performed to date.
You may request that your data be erased, without giving reasons. The request to erase your data will not affect the activities performed to date.
At any time you can object to the processing of your data, both in its entirety and for the purpose of your choice. The objection will not affect the activities already carried out. Our fulfilment of the above request will result in the removal of your application from the group of candidates for employment and your personal data will not be processed by LPP.
You may request that LPP restrict the processing of your personal data, either for a specific period or within a specific scope. This request will not affect the activities performed to date.
You may request that your personal data be corrected or rectified.
You may request that your personal data held by LPP be transferred to another entity. To this end, please contact us stating the name and address of the entity to which we are to transfer your data and their scope; that is, which of your data we are to transfer. The transfer will take place electronically once you have confirmed this request. The request has to be confirmed to keep your data secure and to ensure that the request comes from an authorised person.
You may request information on the extent of our processing of your personal data if you wish.
You have the right to lodge a complaint with the President of the Office for Personal Data Protection.

You will hear from us concerning the measures we have taken within a month of filing a request.

Duration of keeping personal data

If you have consented to the processing of your data for the purposes of current and future recruitment, we will continue to process your data for 3 years.
If you have consented to us processing your data only for the purposes of the current recruitment, we will erase your data within 3 months from the end of the recruitment in question – regardless of the method of termination.

Contact about personal data

You can send any notification or request regarding your personal data to us by the following choices:

by e-mail to: dataprivacy@lpp.com
by post to: LPP S.A., Dział Personalny (Personnel Department), ul. Łąkowa 39/44, 80-769 Gdańsk.

Entrusting data processing

LPP may entrust your personal data to LPP group companies for the purposes of recruitment for website usability studies and for conducting or supporting the recruitment process. Your personal data will not be transferred outside the European Union.

3. To conduct usability tests

Purpose of processing

To conduct website usability studies and to analyse the results of these studies for the own needs of LPP.

Data type

Full name, telephone number, e-mail address, place of residence, age, gender and employment data, image and voice. The image and voice will be processed only as an ordinary recording without the possibility of biometric analysis.

Legal basis for processing

You have the following rights in the processing of your personal data:

You may withdraw your consent at any time – without giving any reason. The request may relate to the purpose of processing which you submitted. The withdrawal of consent will not affect the activities performed to date.
You may request that your data be erased, without giving reasons. The request to erase your data will not affect the activities performed to date.
At any time you can object to the processing of your data, both in its entirety and for the purpose of your choice. The objection will not affect the activities already carried out. Our fulfilment of the above request will result in the removal of your application from the group of candidates for employment and your personal data will not be processed by LPP.
You may request that LPP restrict the processing of your personal data, either for a specific period or within a specific scope. This request will not affect the activities performed to date.
You may request that your personal data be corrected or rectified.
You may request that your personal data held by LPP be transferred to another entity. To this end, please contact us stating the name and address of the entity to which we are to transfer your data and their scope; that is, which of your data we are to transfer. The transfer will take place electronically once you have confirmed this request. The request has to be confirmed to keep your data secure and to ensure that the request comes from an authorised person.
You may request information on the extent of our processing of your personal data if you wish.
You have the right to lodge a complaint with the President of the Office for Personal Data Protection.

You will hear from us concerning the measures we have taken within a month of filing a request. Time of keeping personal data:

The Controller will keep your data for 1 year.
The Controller may keep the results of the research and material produced during the research, including the image and voice recorded during the research for an indefinite period.

Entrusting data processing