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Privacy Notice – Recruiting

August 26, 2024

This privacy notice (“Privacy notice”) informs you about how Retail Logistics Excellence – RELEX Oy (“RELEX Oy”) and its affiliated companies globally (jointly “RELEX”) process information about you during RELEX’s recruitment activities, including when you apply for an open position at the RELEX website, through recruitment agencies and other available channels and when RELEX on its own initiative contacts you as a potential candidate.

In this Privacy notice, “you” refers to the job applicant whose personal data is processed. “Personal data” refers to your personal data that is processed under this Privacy notice.

RELEX is committed to respecting your privacy and to complying with applicable data protection and privacy laws and regulations. In this Privacy notice, we explain what types of personal data we may come to process and for what purposes. We also explain the choices you have in relation to our processing of your personal data and how you can learn more about our processing and exercise your rights.

Data controller

RELEX Oy maintains and uses the RELEX website and other RELEX recruitment channels for its own recruitment purposes, but also for the purposes of the other RELEX affiliates globally. RELEX Oy and its affiliated companies are therefore considered and will act as joint data controllers for the personal data covered by this Privacy notice.

Below you can find a list of the relevant RELEX affiliates:

The contact details of the RELEX affiliates in different countries are here:
https://www.relexsolutions.com/contact/

RELEX Oy acts as the main data controller for personal data covered by this Privacy notice:
Retail Logistics Excellence – RELEX Oy
Business ID FI 1963444-1
Address: Postintaival 7, FI-00230 Helsinki, Finland
Email: Info@relex.fi
Website: www.relex.fi

Categories of personal data processed

During the recruitment process, RELEX collects personal data directly from you as well as from other available sources to the extent relevant and permitted by applicable local law. Your personal data that is processed under this Privacy notice includes the following:

Information that you submit to RELEXWhen you submit an application to RELEX or otherwise apply for an open position at RELEX (either directly or through an agency or other third party), you may be asked or you may choose to provide RELEX with your personal data, such as: your name, address, telephone number, email address, or other contact details. In addition:
·       Your nationality and date of birth.
·       Your photo (if you choose to include one, for example, in your application or resume).
·       Your competences, skills, experience and education (such as in your CV or resume), previous employments, educational details and qualifications, as well as possible third-party references.
·       Possible records relating to your previous employments and education and information contained in such records.
·       Proof of work / residence permits, including information contained therein.
Additional personal information that you may choose to provide, such as your hobbies and other interests, languages you speak, and your social media profiles (such as your LinkedIn profile) and the like.
Information RELEX gets from other sourcesOther information, such as information provided by the references you have nominated as well as information related to credit or background checks, may be processed, depending on the position you are applying for. Such information will be processed only when and to the extent permitted by applicable legislation. Sourcing passive candidates: RELEX obtains contact details from public sources (such as your LinkedIn profile) for the purpose of contacting potential candidates.
Cookies and other technical informationWhen you access the RELEX website, our web servers automatically create records of your visit. We have explained in the Privacy notice for the RELEX website how we process your personal data when you are using our website.

The purposes and legal basis for the processing

Your personal data is collected, used, stored, and otherwise processed for the purposes of handling your job application and for other recruitment activities by RELEX. Your personal data is not used for profiling or other automated decision-making nor direct marketing purposes – RELEX may however notify you of open positions in case you choose to subscribe to such notifications.

RELEX will process your personal data during the recruitment process for the following purposes:

Sourcing passive candidates: We use publicly-available contact details for the purpose of contacting you and inquiring about your interest in applying for a job at RELEX.

RELEX also performs statistical analysis of its recruitment-related processes. Such activity looks at processes rather than individuals. In this connection, limited information on all parties – including applicants – participating in recruitment may be processed in pseudonymous or anonymous format.   

What are the legal grounds for processing the data?

Applicants

When you submit your application or indicate your willingness to be considered for employment at RELEX, we need to process certain personal data on you as necessary for entering into a contract (more specifically, the activities of the recruitment process prior to entering into a potential employment relationship).

Some of the data collected in this phase may be subject to another legal basis. Examples are: data we are legally obliged to collect, such as the existence of a work / residence permit, and additional data, such as non-mandatory information outside your immediate application, which is processed based on consent.

Sourcing passive candidates

Processing is carried out based on legitimate interest. RELEX has the legitimate interest to search for and contact potential candidates and inquire about their interest to apply for a job at RELEX. At this phase we will process personal data that you have made publicly available.

You may also come to our attention if a person working at RELEX provides your information to our recruitment team. In such a case, we require that you are notified accordingly. At this phase, the data on you is also processed based on legitimate interest as we compare potential candidates with our needs.

Future job opportunities at RELEX

Even if we do not initially enter an employment relationship, with your consent, we may continue to store your information for future recruitment purposes at RELEX.

If you have subscribed to notifications of open positions at RELEX, the processing is carried out based on legitimate interest to provide you with information on open positions at RELEX.

After the recruitment process

After a conclusion of the active recruitment process, RELEX stores recruitment data for a limited time to safeguard its legitimate interests. See more information in the Retention section.

If you are hired, your data will be processed as set out in our internal notices.

We also collect some statistical information of our recruitment activities, to make the process smoother for future applicants. In this case, any personal data is removed or anonymized at the first feasible step.

Why are you required to provide the data?

Providing personal data is a requirement necessary to enter into a potential employment contract (in case you are selected) and therefore you will need to provide the personal data requested. In case you choose not to provide all the personal data requested by RELEX during the recruitment process, RELEX will not be able to process your application or continue the recruitment process with you any further, and may need to reject you as a candidate.

Access to personal data

Your personal data will be made available to those employees working at RELEX that are responsible for recruiting activities. When you apply for a position at a RELEX affiliate, your personal data will be shared with RELEX Oy and other RELEX affiliates only to the extent necessary for carrying out the recruitment activities.

In addition, your personal data may be made accessible to RELEX’s service providers or other vendors that RELEX uses in the recruitment activities (such as recruiting agencies, providers of the web/software services used by RELEX in recruiting, and hosting providers) for the purpose of providing such services to RELEX and assisting RELEX in the recruitment activities.

Merger and acquisitions (M&A) activities: Where RELEX takes steps to sell, buy, merge, or otherwise reorganize its businesses in certain countries, this may involve disclosing personal data to prospective or actual purchasers, sellers, or partners and their advisers. In such circumstances, RELEX will take all reasonable steps to ensure that appropriate measures to protect personal data are taken by such prospective or actual purchasers, sellers, or partners and their advisors.

Transfer and disclosures of your data

Where do we get your data from?

We may acquire your personal data from your application, your acquaintance or contact in RELEX referring you as a candidate, RELEX events where you have indicated your interest, via agencies helping us with the recruitment, or from publicly available profiles.  

Will your personal data be transferred to other countries?

The data of the applicants is stored primarily in the United States and accessed from the RELEX affiliates involved in processing your application.

RELEX may use service providers that are located outside the European Union/EEA and provide services relating to recruitment activities to RELEX. Also, some RELEX affiliates are located outside the European Union/EEA, and the employees of such affiliates may process your personal data for the purposes specified in this Privacy notice. This means that your personal data may be transferred to other RELEX legal entities and to countries other than the one where you are applying to as an applicant.

When transferring your personal data outside the European Union/EEA, we will ensure that the transfer is legal and safe by concluding an agreement based on the EU Commission’s standard contractual clauses or taking other measures permissible under applicable legislation. You can ask for additional details relating to the transfer and the appropriate safeguards put in place and obtain a copy of the related documents from the contact at the end of this Privacy notice.

Retention

Application for a specific position at RELEX

Your personal data will be processed for as long as it is necessary for the purpose of processing your application and carrying out the related recruitment activities.

After immediate activities relating to the recruitment process, RELEX stores the data for as long as it has a legitimate need to keep the data. The length of retention is based on specific statutory limitation periods (such as the capability to address recruiting-related claims) and other legal requirements pertaining to RELEX (such as undertaking of activities at the start of employment).

Under most jurisdictions, the above rules lead to data being stored for 13 months from the rejection of the application. In case of successful employment, we typically delete your application and interview data when it is no longer relevant for your evaluation or other regulatory needs.  

Notable exceptions to the above are Germany, where the data is stored for six months from rejection of the application, and the United States, where the data is stored for up to three years.

Future job opportunities at RELEX

With your consent, we may continue to store your information for future recruitment purposes at RELEX after the above retention periods have been exceeded.

Security

We are committed to keeping your personal data safe. RELEX will implement appropriate technical and organizational measures to ensure sufficient data security. Sufficient security measures are put in place to prevent unauthorized access to and manipulation of your personal data. This includes restricting access to your personal data to the persons described in this Privacy notice (see the Access to personal data section above) and hosting your personal data with a service provider that demonstrates an adequate level of data security.

We take appropriate steps to address online security, physical security, risk of data loss, and other such risks, taking into consideration the risk represented by the processing and the nature of the data being protected. Also, we limit access to our databases containing personal data to authorized persons having a justified need to access such information.

Exercising your Rights

For job applicants in EU/EEA countries:

You have the right to access your personal data processed under this Privacy notice. You have the right to request correction and removal of your personal data.

In addition, you have the right to request the restriction of processing of your personal data and to object to the processing on grounds provided by the applicable legislation. You also have the right to receive the personal data you have provided to RELEX and transmit it to another controller.

You can also withdraw consent at any time in relation to receiving e-mail notifications. To exercise this right, click the unsubscribe link at the bottom of a notification sent to you by email.

You also have the right to lodge a complaint with a supervisory authority in case you think that your rights have been violated. You may choose to lodge a complaint with a supervisory authority in the EU member state of your habitual residence, place of work, or place of the alleged infringement.

RELEX contact information

RELEX Oy is the controller that is mainly responsible for the maintenance of the RELEX website and will act as RELEX’s representative in all matters relating to this Privacy notice and the processing of your personal data.

Should you wish to exercise your rights under the applicable legislation or if you have other questions about this Privacy notice, contact recruitment@relexsolutions.com.

The contact details for topics relating to the open position you have applied for can typically be found in the respective job advertisement. 

Changes

To keep this Privacy notice up-to-date, we make changes and additions from time to time. We publish the updated notice on our website or on another channel where this notice has previously been made available. Any changes apply from the date that we publish the revised Privacy notice. 

Latest update: October 2023