Effective on May 25, 2018
Controller of this filing system is the Finnish company Paulig Ltd (business registration number: 0112563-0) and companies at the time belonging to the Paulig Group, all together hereinafter referred to as ”Paulig”.
Paulig Ltd / job applicant privacy matters
FIN – 00980 Helsinki
Tel: +358 9 319 81
Please do not hesitate to contact us if you have any questions, concerns or ideas related to Paulig’s personal data procedures.
Paulig has established electronic and administrative safeguards designed to make the information collected secure.
Only appointed personnel of Paulig and of organizations operating by Paulig’s assignment or on behalf of Paulig are entitled to use the personal data filing system. All persons processing the system have a personal right of use granted by Paulig or its co-operation partner. Different levels of access have been created based on the data a person needs according to his/her job description. The system is protected with a fire-wall which protects it from contacts outside of Paulig.
All personnel of Paulig and its subcontractors are obliged to keep the information of the personal data which they obtain in their work confidential.
Manually processed documents containing personal data are protected against unauthorized access.
Paulig may process your personal data directly necessary for your recruitment process and possible employment relationship (either with Paulig or with a private employment agency) which is connected with managing the rights and obligations of the parties to the relationship or with the benefits possibly provided by Paulig for you, or which arises from the special nature of the work concerned.
Processing of your personal data is based on the following grounds of the EU’s General Data Protection Regulation (one or more grounds may apply simultaneously):
a) Processing is necessary in order to take steps at your request prior to entering into a contract.
b) Processing is necessary for the purposes of the legitimate interests pursued by Paulig.
c) You have given consent to the processing of your personal data.
The legitimate interests of Paulig or third party referred to in point b) above may include amongst others the following matters:
Content of Paulig’s filing system may include the following types of data and changes made to these data types:
A. Personal information
B. Employment related information
Paulig gathers personal data directly from you, for example from:
Paulig may gather personal data from third parties based on your consent, for example from:
Paulig may gather personal data from third parties without your consent when:
Paulig may obtain and update the personal data in its filing system from officials and companies offering personal data services.
Paulig companies have a legitimate interest in transmitting personal data within the Paulig group for internal administrative purposes.
Paulig does not sell, lease or otherwise disclose your personal data to third parties outside of the Paulig Group unless otherwise stated below.
Paulig may share your personal data based on a valid order from a court or other official body with sufficient authority.
Paulig may share your personal data as part of any merger, acquisition, sale of company assets or transition of service to another provider. This also applies in the unlikely event of an insolvency, bankruptcy or receivership in which your personal data would be transferred to another entity as a result of such a proceeding.
Paulig’s services may be provided using resources and servers located in various countries around the world. Therefore Paulig may transfer your personal data outside the country where you use our services, including to countries outside the EU and EEA that do not have laws providing specific protection for personal data or that have different legal rules on data protection.
In such cases Paulig ensures that a legal basis for such a transfer exists and that adequate protection for your personal data is provided as required by applicable law, for example, by using standard agreements approved by relevant authorities (where necessary) and by requiring the use of other appropriate technical and organizational information security measures.
Paulig may process your data in its job applicant system for until the end of the second year following your application year (for example: application 1 August 2018 => 31 December 2020).
Based on your consent Paulig may process your personal data for as long as the consent describes.
Paulig may process your personal data based on legal requirements for as long as the applicable legislation allows.
All rights can be exercised by contacting Paulig’s privacy team by using the contact details issued at section 1 above. The team will then give further instructions on how to exercise a specific right. Where Paulig has reasonable doubts concerning the identity of the person making the request, Paulig may request the provision of additional information necessary to confirm your identity.
Paulig will provide information on action taken on a request to you within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests.
You have the right to obtain from Paulig confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, receive information about your personal data.
You have the right to obtain from Paulig without undue delay the rectification of inaccurate personal data concerning you.
You have the right to obtain from Paulig the erasure of personal data concerning you without undue delay where one of the following grounds applies:
a) your personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
b) you withdraw consent on which the processing is based and where there is no other legal ground for the processing;
c) you object to the processing and there are no overriding legitimate grounds for the processing;
d) your personal data have been unlawfully processed;
e) your personal data have to be erased for compliance with a legal obligation in Union or member state law to which Paulig is subject;
f) the personal data have been collected in relation to the offer of information society services.
However, you do not have the right or erasure if the processing is necessary:
a) for exercising the right of freedom of expression and information;
b) for compliance with a legal obligation which requires processing by Union or member state law to which Paulig is subject; or
c) for the establishment, exercise or defence of legal claims.
You have the right to obtain from Paulig restriction of processing where one of the following applies:
a) the accuracy of the personal data is contested by you, for a period enabling Paulig to verify the accuracy of the personal data;
b) the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
c) Paulig no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;
d) you have objected to processing pending the verification whether the legitimate grounds of Paulig override those of you.
You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on legitimate interests pursued by Paulig, including profiling. Paulig shall no longer process the personal data unless Paulig demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms for the establishment, exercise or defence of legal claims.
Where personal data are processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
Please be aware that you cannot opt out of receiving service messages from Paulig, including but not limited to security and legal notices.
You have the right to receive the personal data concerning you, which you have provided to Paulig, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller where:
a) the processing is based on consent or on a contract; and
b) the processing is carried out by automated means.
Where processing of your personal data is necessary for Paulig in order to take steps at your request prior to entering into a contract, it is mandatory for you to disclose the personal data needed for a recruitment process.
You may withdraw possible consent by contacting Paulig’s privacy team (contact information in section 1) or by using possible electronic means provided by Paulig.
Paulig does not make decisions based solely on automated processing which produces legal effects concerning you or similarly significantly affect you.
Paulig does not carry out job applicant profiling in a way meant in the GDPR.
In case the matter is not solved amicably between you and Paulig, you may contact the Data Protection authority of the country where the Paulig entity in question operates. Contact information of the competent authority of each Paulig’s operation country can be found here.
The processing of personal data in Paulig’s filing system is governed by the European Union’s applicable data protection legislation as well as national laws of countries where Paulig is established.