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What is the purpose with this Privacy Notice?
1.1 ASSA ABLOY is committed to protecting your personal data. This Privacy Notice describes how ASSA ABLOY processes and uses the personal data that we receive from you in connection with your application and how you can contact us if you have additional questions regarding our processing of your personal data.
It is important for you to know that you have certain rights when it comes to our use of your personal data. These rights include:
· To access your personal data;
· To object to the processing of your personal data;
· The restriction of our processing of your personal data;
· To have your personal data rectified;
· Deletion of your personal data; and
· The right to data portability.
If you are dissatisfied with how we process your personal data, you have a right to lodge a complaint with a data protection authority. Your rights are further explained below.
What is "personal data" and "processing of personal data"?
1.2 The term "personal data" as used in this Privacy Notice is any piece of information that, either on its own or together with any other pieces of information, can be traced back to a living individual, and any other data that qualifies as personal data in accordance with the law applicable to ASSA ABLOY. This Privacy Notice covers all personal data that is in any form considered processed under the relevant law in relation to you as a job applicant, including personal data that is kept, stored, collected, transferred, disclosed or otherwise handled.
What personal data will ASSA ABLOY use, for what purposes and on what legal ground?
1.3 What personal data will ASSA ABLOY collect? When you
· apply for an open position within ASSA ABLOY, we will collect your contact details such as name, email address and telephone number. We will also collect the personal data that you voluntarily submit via the registration form when applying for an open position, such as a picture of you, your gender, link to LinkedIn profile and other information you may include in your CV or any other information you provide to us in connection with your application;
· register to subscribe to open positions within ASSA ABLOY, we will collect your name and email address.
For what purposes and on what legal grounds will the personal data be collected?
We will collect the personal data set out above to process your application and/or subscription and we base this processing on your consent. You are free to, at any time and without cause, revoke your consent to ASSA ABLOY's processing of your personal data (please see section 2 for contact details). However, please note that if you revoke your consent to ASSA ABLOY's processing of your personal data, it means that ASSA ABLOY cannot process your application. We may also when you apply for a position use your personal data for statistical analysis on candidate demographics, background checks and candidate assessment, if applicable, based on ASSA ABLOY's legitimate interest. We have concluded that our legitimate interest to do so is not overridden by your interests or fundamental rights and freedoms. You are welcome to contact us to receive more information in this respect (please see section 2 for contact details). You can object to our processing of personal data for these purposes. However, please note that if we cannot conduct background checks or make an assessment of a candidate, this will result in that we cannot offer an open position to such candidate.
For how long will ASSA ABLOY store your personal data?
The personal data that has been collected and stored for recruitment purposes in connection with registration of an application will be deleted after 6 months, or for such longer period during which a claim can be lodged against ASSA ABLOY, except in the following cases:pplications for positions in US will not be deleted due to US regulations.
Please note that if you become employed by ASSA ABLOY, we will also store and process your personal data in accordance with ASSA ABLOY's Employee Privacy Notice. The personal data that has been collected and stored for the purpose of job subscription will be deleted after 12 months, unless you choose to actively postpone the deletion.
Transfer of personal data
1.4 For the purposes set out above and as a part of the recruitment process to be able to assess how well suited a job applicant is for a specific position with an ASSA ABLOY group company, personal data may be transferred to companies within the ASSA ABLOY group. We may also transfer personal data, such as name and email address, to selected third party providers for processing activities related to the recruitment process; e.g. for assessments, background checks, if applicable.
1.5 The personal data that is collected and stored is exclusively used for a) processing your application for the specific job you have applied for within the ASSA ABLOY group; b) processing your request to receive information about published vacancies.
1.6 Your personal data may also be transferred to and processed by third party providers and suppliers which perform services for ASSA ABLOY (data processors), to enable these companies to perform the services requested by us. Services which may be requested include recruitment firms, head hunters and assessment providers. Only personal data that is necessary to fulfil the purposes stated in this Privacy Notice will be provided to these companies. All third party providers and suppliers that we have engaged as data processors must follow our instructions and the applicable written data processor agreement and any other agreements that are in place between ASSA ABLOY and its third party providers/suppliers, and must implement appropriate technical and organizational measures for the protection of the personal data of our job applicants.
1.7 ASSA ABLOY will take measures to protect all personal data transferred to such third parties in accordance with applicable data protection laws.
Transfer of personal data to third countries
1.8 Due to the fact that ASSA ABLOY is part of a group of companies with business activities in several different countries, personal data may, in case you apply for a job outside the EU/EEA, also be transferred to companies in the group located outside the EU/EEA that may not ensure as strict data protection legislation as in the EU/EEA. Such transfer is based on model clauses that have been approved by the European Commission https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en. Furthermore, also other recipients of personal data as described above may be located in third countries. Transfers of personal data to such companies are either based on the relevant companies being privacy shield certified (USA) (https://www.privacyshield.gov/welcome) or on the model clauses as referred to above.
Who has access to my personal data?
1.9 Personal data will only be available to authorized employees holding a position that requires them to process personal data to perform their work. These employees will only be granted access in accordance with the principles of "least privilege", meaning that they will only have access to personal data that is strictly necessary for the purpose of the processing to perform their work. Therefore, personal data will only be accessible to employees working with recruitment and, in some cases, the managers within the department/division where the job applicant is applying for an open position.
What are my rights with regards to my personal data?
Right to access and rectification
1.10 You have the right to request access to your personal data. This includes the right to be informed whether or not personal data about you is being processed, what personal data that is being processed, and the purpose of the processing. You also have the right to rectify or add personal data if the personal data is inaccurate or incomplete. As soon as we become aware of any inaccurate personal data about you being processed, we will always rectify such personal data without undue delay and notify you accordingly.
Right to erasure
1.11 You may also request that your personal data be erased if e.g. the personal data is no longer necessary for the purposes for which it was collected, if the processing is based on your consent and you withdraw your consent for a specific process and there is no other legal ground for processing your personal data, if you object to the processing of personal data where we do not have an overriding legitimate interest, the processing is unlawful, or the personal data has to be erased to enable us to comply with a legal requirement. If you have any questions about your right to erasure, please contact ASSA ABLOY (please see section 2 for contact details). Please note that we may reject your request if the processing is permitted or required according to law or any other relevant legal ground.
Right to object
You are also entitled to object to our use of your personal data that we base on our legitimate interest. If you object, we will no longer process your personal data unless we can show that we have compelling legitimate grounds for the processing that overrides your interests or rights and freedoms, or if we need it to establish, exercise or defend legal claims.
Right to restriction
You can request us to restrict the processing of your personal data in the following situations:
· if the processing is no longer necessary for the purposes it was collected or otherwise processed,
· if you believe the personal data may not be correct,
· if you believe that the processing is unlawful, and/or
· if you have objected to processing based on our legitimate interest.
Right to data portability
If you request access to personal data about you that you yourself have provided and if the personal data is being processed automatically and/or in accordance with a contract between you and ASSA ABLOY, you may request that the data is provided in a structured, commonly used and machine-readable format and you may also request that the personal data is transmitted to another controller, if this is technically feasible.
How do I make use of my rights?
2. ASSA ABLOY Group, registration number 556059-3575, is responsible for the processing of your personal data. Requests to exercise your rights as stated above shall be addressed to “ASSA ABLOY AB, BOX 70340, 107 23 STOCKHOLM” in an envelope marked with “Attn.: ASSA ABLOY DPM”.
2.1 If you are not satisfied with how we processes your personal data, you may contact ASSA ABLOY. Please see who you can contact above if you should have any requests in relation to the processing of your personal data. Please note that we may contact you and ask you to confirm your identity to ensure that we do not disclose your personal data to any unauthorized person, and that we may ask you to specify your request before we perform any actions. Once we have confirmed your identity, we will handle the request in accordance with applicable law.
You always have the right to lodge a complaint with the relevant authority in particular where you live, apply for a job or where an alleged personal data infringement has occurred. You can find details about relevant European authorities here: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm
Updates to this Privacy Notice, and non-compliance with this notice
2.2 In order to ensure that we comply with data protection law, this Privacy Notice may be changed by us at any time. We will inform you of any changes made. Any breach of this Privacy Notice should be reported to ASSA ABLOY (please see section 2 for contact details). Any breach of this Privacy Notice, including any processing or transfer of personal data for any purpose other than as stated in this Privacy Notice, will be taken seriously and will result in necessary actions being taken (including a data breach notification being sent to the relevant data protection authority if required under applicable law). Please notify us of any changes to the personal data relating to you to enable us to process personal data accurately and securely.