UAB “Travel Union” Candidate policy notice

Valid from: 2020-06-04

GENERAL PROVISIONS

This Candidate Privacy Notice (the “Notice”) applies to the processing of data from a candidate (“you” or the “Candidate”) that applies for job vacancies or corporate body duty offerings, including possible internships or contractual opportunities with UAB “Travel Union” (the “Company” ).

The Notice’s purpose is to explain how the Company collects, processes, and protects your personal data, as well as, give you instructions on how to exercise your rights. By doing so, the Company seeks to ensure the fair and transparent collection and use of your information, as well as, protection of your personal data and privacy.

Any personal data the Company gathers, uses, or shares about you is processed in accordance with the Regulation (EU) 2016/679 of the European Parliament, the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (the “GDPR” ), and other applicable laws.

This Notice may be changed, amended, or renewed at any time.

DEFINITIONS

Definitions of the concepts used in the Notice:

• Candidate, you – a person seeking employment or an internship in the Company, seeking to be elected to the corporate body of the Company, or seeking to enter into a contract for the provision of consulting services or any other civil contract with the Company;
• Company, we – data controller UAB “Travel Union”;
• data processing – any operation or set of operations which is performed with the Candidate’s personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction;
• GDPR – General Data Protection Regulation as defined in article 1.3 of this Notice;
• Notice – this Candidate Privacy Notice;
• personal data – any information relating to an identified or identifiable natural person (data subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person;
• Request – a request for the application of the data subject’s rights indicated in article 11.1. of this Notice, as well as any complaint, notice, or request directed to the Company.

PRINCIPLES OF PERSONAL DATA PROTECTION FOLLOWED BY THE COMPANY

The Company undertakes to ensure your personal data is:

• processed lawfully, fairly, and in a transparent manner in relation to you;
• collected for specified, explicit, and legitimate purposes (i. e. prevention of money laundering and terrorist financing, the performance of Services, etc.), and not further processed in a manner that is incompatible with those purposes;
• adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed;
• accurate and, where necessary, kept up-to-date;
• kept in a form which permits your identification for no longer than is necessary for the purposes for which the personal data was processed;
• processed in a manner that ensures appropriate security of your personal data.

The Company follows the above-indicated principles strictly during the processing of your personal data and requests the same from the data processors which it may use to process personal data on behalf of the Company.

PURPOSES FOR THE COLLECTION AND USE OF YOUR PERSONAL DATA

• To exercise the recruitment (selection) process:
  a) to assess your skills and qualifications in relation to a desired position;
  b) to carry out background and reference checks, if necessary;
  c) to communicate with you during the ongoing recruitment (selection) process;
  d) to keep records about ongoing recruitment (selection) processes;
• to administrate a Candidate database;
• to conclude employment, internship, consultancy services, or any other civil contract with you, or to elect you to the corporate body of the Company.

When you enter into an employment, internship, consultancy services or any other civil contract, or you are elected to the corporate body of the Company, the information you provide during your candidacy will be further processed for internal administration purposes on the basis of your employment, internship, consultancy services or any other civil contract, or based on grounds of election to the corporate body;

TYPES OF PERSONAL DATA THE COMPANY MAY PROCESS ABOUT CANDIDATES

The Company may process the following personal data of the Candidate:

• basic personal data such as name or date of birth;
• contact information such as phone number, e-mail address, residential address, or career social network profile address;
• identification data such as image;
• data on your education and qualification such as education, qualifications, competencies, work experience, as well as information provided on your career social network profile (i.e., Linkedin);
• economic data such as your other past or present employments or economic-commercial activities if you are self-employed;
• candidate evaluation information such as a summary of your job interview, comments, tests, tasks performed, and the results of any of the aforementioned evaluations;
• as well as other information provided in your resume (CV), cover letters, and other documents provided to the Company or while in communication with the Company’s representatives.

The Company does not process any special categories of personal data from Candidates except in cases where the Company is required or permitted by law to process such data, or in cases where such consent has been obtained from the data subject. The Company also does not process records of convictions or criminal activities of Candidates, except in cases where it is necessary to verify that the person complies with the legal requirements for the performance of duties or work.

If you provide the Company with other persons’ details, you should inform these persons and introduce them to the provisions of this Notice.

PROVISIONS GIVING US THE RIGHT TO ACCESS AND USE YOUR PERSONAL DATA

We obtain and use your personal data under at least one of the following conditions:

• You have given consent explicitly (i.e., confirming that you “Agree”) or implicitly (i.e., when you send your CV or other documents necessary for your application for a desired position). Such initiatives or actions from your side are treated as your consent for the processing of your personal data by the Company for the purpose of participating in the Candidate recruitment (selection) procedure. You can revoke your given consent at any time by contacting the Company in accordance with article 11.2 of this Notice;
• In order to conclude a respective contract with you when you have been selected for a desired position;
• or other grounds under Article 6(1) of GDPR, if applicable.

If you do not provide the Company with the personal data necessary for recruitment (selection) purposes or later for the conclusion and / or execution of a contract, or election to the corporate body, the Company will not be able to consider your candidacy for the respective position, to conclude contract with you, elect you to the corporate body of the Company, or perform other related functions.

METHODS OF PERSONAL DATA COLLECTION USED BY THE COMPANY

The Company uses personal data that you provide to the Company during the recruitment (selection) process (i.e. in an application form, questionnaires, your CV, cover letter, references, information received while corresponding with you or during interview meetings, assessments, or other means).

The Company may also obtain your personal data from other sources, such as:

• your named referees;
• recruitment agencies;
• job search portals, specialized career social networks and / other job search and / or intermediary services providers;
• the State Social Insurance Fund Board, law enforcement agencies, other registers, and state authorities, if applicable;

The Company may combine available information about you obtained from various sources.

When the Candidate’s CV and / or other candidacy documents are received directly by the Company from job search portals, career social networks (i.e., Linkedin), and / or other job search, and / or intermediary services providers (referred to as the “Service provider”), the Company presumes that the Candidate has already received all information regarding his / her data processing and has already expressed consent to the data processing performed by a particular Service provider, which also informs the Candidate about its right to provide the respective Candidate’s personal data to potential employers, including the Company, and also grants a right to the potential employer to process a Candidate’s personal data to exercise its recruitment (selection) processes or to perform the assessment of his / her candidacy.

The Company may contact a Candidate’s former employer(-s) in order to collect information relating to a Candidate’s qualification, professional abilities, and expertise. If the Company wants to contact a Candidate’s current employer regarding the aforementioned matter, it could act so only with the written confirmation of the Candidate.

DISCLOSURE OF PERSONAL DATA TO OTHER PARTIES

We disclose your personal data in accordance with legal requirements, only if there is a legal ground for the transfer. Your personal data may be transferred to:

• third parties assisting in the selection and evaluation of Candidates;
• public authorities if such transferring is requested under the applicable laws, or if the Company in cases specified in the legislation seeks to lodge a claim or defend its rights and legal interests;
• other data recipients, if necessary.

The Company may also invoke the following data processors to process the personal data specified in this Notice: companies developing, providing, and maintaining personnel software, companies providing information technology infrastructure services, including cloud computing services, companies providing communication services, consultancy companies, and others which would also be obliged to comply with the requirements of GDPR, laws, and other mandatory legal requirements.

The Company does not transfer personal data outside the European Union / European Economic Area.

LENGTH OF TIME PERSONAL DATA IS STORED BY THE COMPANY

Your personal data is processed in accordance with the applicable laws and the Company’s internal rules for no longer than it is necessary to achieve the purposes for which the personal data is collected:

• A Candidate’s personal data collected for the recruitment (selection) purpose shall be actively processed until the recruitment (selection) and hiring procedure for the specific position (that the Candidate has applied for) ends (i.e. the Company selects the preferred Candidate and concludes a contract with him / her or elects him / her to the relevant corporate body), except in cases where the Candidate gives separate consent for the purpose of administration of Candidate database for another 12 (twelve) months from the date when the consent was given in order to receive future job offers for which he / she could be a suitable Candidate for the Company. However, the Company shall be able to demonstrate that the Candidate has consented to the processing of his / her personal data (Article 7(1) of GDPR) and also in case of need be able to establish, exercise, or defend legal claims (e.g., in the event of a legal claim the Company shall be able to show that Candidate’s recruitment (selection) procedure was conducted in a lawful and transparent way), once the aforementioned terms expire your personal data will be stored by the Company for an abridged 3 (three) year prescription under the applicable laws and deleted after the expiration of this term;
• If you’ve been selected by the Company as suitable for a position, the information you provided for the recruitment (selection) purposes will be further processed by the Company for internal administration purposes on the basis of concluded employment, internship, consultancy services or any other civil contract, or grounds of election to the corporate body of the Company.

The Company has a right to process your personal data longer than described in article 9.1.1. of the Notice, if there is a reasonable suspicion that illegal activity has been executed and the personal data is necessary for further investigation, or personal data is necessary in order to properly solve an occurring dispute, or in the case of other legitimate grounds mentioned in relating legislation.

SECURITY MEASURES TAKEN BY THE COMPANY TO ENSURE SECURITY OF YOUR DATA

The Company uses a variety of security technologies and procedures to protect your personal information from unauthorized access, use, or disclosure. The Company’s service providers are carefully selected and required to use appropriate measures to protect your confidentiality and the security of your personal data. However, the security of communications by e-mail or mobile communication maybe unsecure for reasons beyond the Company’s control, and you should exercise caution and not transfer your personal data under conditions which you find suspicious and / or to unknown recipients allegedly acting on behalf of the Company.

YOUR RIGHTS AND HOW TO EXERCISE THEM

You have the following rights:

• the right to know (be informed) about the processing of your personal data;
• the right to request the Company to access your personal data;
• the right to request to correct inaccurate personal data as well as to complete or supplement incomplete personal data;
• the right to request the erasure of your personal data, except in cases where further processing is necessary;
• the right to request a restriction of the processing of your personal data for the period it is necessary for the data controller to verify the legitimacy of its processing;
• the right to request the transfer of your personal data to another data controller (if there are technical possibilities) or to provide it directly to you in a convenient form (applicable to personal data provided by you / yourself and processed automatically by consent or on the basis of the conclusion and execution of a contract);
• the right to revoke your consent, without prejudice to the use of your personal data prior to revocation;
• the right to file a complaint with the State Data Protection Inspectorate (more information can be found at https://vdai.lrv.lt/)

The Company shall make all possible efforts to exercise your rights and to answer any questions you may have regarding the information contained in the Notice. You may submit a Request for the exercise of your rights indicated in article 11.1 of the Notice via the e-mail address provided below.

In order to exercise his / her rights the Candidate must be successfully identified by the Company, therefore the Company may ask you to provide a copy of your identification documents or use other legitimate means of identification.

The Company will respond to your Request no later than 1 (one) month from the date of receipt of the Request. In exceptional cases, where additional time is required, the Company will notify you and will have the right to extend the deadline for the submission of requested personal data or investigation of other requirements specified in your Request for 2 (two) more months.

The Company may refuse to comply with your Request only on reasonable grounds if the circumstances specified in the GDPR and other applicable laws have been established by informing you in writing.

COMPANY’S CONTACT DETAILS

If you have a Request, you may contact the Company via e-mail at dpo@travelunion.eu

Other contact details: UAB “Travel Union”, address Saulėtekio alėja 17, Vilnius, the Republic of Lithuania, tel. no. +370 521 40121.