ION ΓΙΑ ΠΑΝΤΑ

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NOTIFICATION REGARDING THE PROCESSING OF PERSONAL DATA OF JOB APPLICANT

Introduction & General Terms


The company under the corporate name «ION SA COCOA & CHOCOLATE MANUFACTURERS», having its registered seat at Neo Faliro, Piraeus (address: Eleftheriou Venizelou str., no. 69, Postal Code: 18547), Greece (the “Company”) collects, stores and processes Personal Data (as defined below) of the individuals who apply to it for employment (“Applicants” and/or “you”), in accordance with the General Data Protection Regulation ΕU 2016/679 as in force (“GDPR”), as well as any local Data Protection legislation.

 

  1. Scope of this Notification

This Notification applies to all Personal Data (as defined below) of Applicants, which the Company collects, uses, discloses, or otherwise processes, and which is held electronically or in paper-based filing systems.
The Company is the data controller of your Personal Data.

 

  1. What is Personal Data?

Personal Data means any information which relates to an identified or identifiable individual, or which could be used to identify an individual (“Personal Data”).
The types of Personal Data that the Company may collect from or about you include, on a case by case basis:


(a) Personal and family information: first name; last name; father’s name, mother’s name, full name of any spouse, residence details (address and telephone number), date and place of birth, gender, residence and work permit, nationality, fulfillment of military obligations (excluding any grounds for discharge due to incapacity or deferment of service), social security number (AMKA), identity card number, date of issue and issuing authority thereof, passport number and date of issue/expiry, mobile phone number, email address, tax identification number and competent tax office, bank account details, marital status, and details of dependent family members. 


(b) Information on your education and professional experience: details of previous employers and references, other information related to your prior employment, namely job title and/or position and description of responsibilities/ duties, type of employment (fixed-term/ indefinite-term), working hours and shifts, location, duration of employment, contact details of previous employment (telephone, address, fax, and email address), start and end date (where applicable) of employment, name and contact details of supervisor, manager, or team leader, benefits details and related information, remuneration information, information regarding attendance of training programs and related certificates, academic background and education, professional training, licenses and certifications, foreign languages, activities and research, information relating to complaints and reports, and the grounds for any termination of employment.


(c) any other data included in your CV or otherwise submitted to us, even if not requested.

 

  1. Why does the Company collect, use, disclose or retain Personal Data?

The Company collects, uses, discloses, and retains Personal Data for the following purposes: (1) evaluating such data in order to assess whether you are suitable for employment by the Company or, where applicable and subject to your consent, for evaluation by another company belonging to the same group of companies as the Company, in order for such company to assess whether you are suitable for employment by it; (2) general administration; (3) preparation of the human  resources department’s financial budget; (4) compliance with legal requirements; (5) defense, preparation, participation in, and response to potential legal actions, as well as investigations by regulatory and other authorities; and (6) improvement of recruitment processes, talent management, and succession planning.

 

  1. Legal basis for processing Personal Data

The legal basis for the collection, processing and use of your Personal Data is established in article 6 para 1 letters a), b), c) and f) of GDPR. This means that we process your data on the basis of your consent, as expressed through the clear affirmative act of sending your CV to us, or in order to take steps at your request, prior to entering into a contract with you, or in order to be able to comply with our legal obligations as your employer, or for the legitimate interests pursued by the Company or by a third party, unless such interests are overridden by the interests or fundamental rights and freedoms of the Applicant.

 

  1. Does the Company share or transfer your Personal Data?

The Company may from time to time disclose your Personal Data to third parties for any of the purposes listed above. Examples of relevant third parties to whom the Company may disclose Personal Data include governmental agencies, courts, as well as third parties who render services in connection with (among other things) the evaluation of Applicants. Furthermore, where applicable and subject to obtaining your consent, the Company may disclose your Personal Data to another company belonging to the same group of companies as the Company, to the extent that such company has a vacant position to be filled that matches your qualifications.


When we disclose your Personal Data to third parties who perform services on our behalf, we ensure that such service providers use Personal Data only in accordance with our instructions, and we authorize them to use or disclose the Personal Data only to the extent necessary to perform those services on our behalf or to comply with any obligations arising from the law.


The Company may also disclose Personal Data to third parties:

  • belonging to the same group of companies as the Company, or
  • where such disclosure is required by law; or
  • for the purposes of, or in connection with, any legal proceedings to which it is a party, or otherwise for the purpose of establishing, exercising or defending its legal rights; or
  • who are law enforcement authorities or other government agencies and who have made a lawful request for such disclosure; or
  • where we believe that its disclosure is necessary in connection with an investigation of suspected or actual criminal activity; or

 

  1. International Transfers of Personal Data

When we disclose your Personal Data to third parties located outside the European Economic Area (EEA), except where the relevant country has been determined by the European Commission to provide an adequate level of protection, we require such recipients to comply with appropriate measures designed to protect Personal Data.

 

  1. Third-party Personal Data

Where you provide third-party Personal Data to the Company (ie. data from a spouse and/ or family members), you are required to inform these persons about their rights in connection with the processing of their Personal Data (for example, by presenting the present Notification to them).
Moreover, it is your responsibility to obtain the consent of these persons. At the time you provide the third-party Personal Data, the Company considers that the third-party consent as granted.

 

  1. Consequences in case of failure to provide Personal Data

If an Applicant does not wish to disclose the requested minimum necessary Personal Data for the evaluation of his application, then the Company will review whether, in view of the circumstances, such evaluation can be made.

 

  1. Applicant’s Rights

You have the right to request access to your Personal Data. You may receive a copy of the Personal Data that we hold about you.


Moreover, you have the right to:

  • request that your Personal Data is rectified or deleted, or that its processing is restricted;
  • object to the processing of your Personal Data;
  • receive your Personal Data in a portable format or request the transmission of your Personal Data to a third party in a structured format; or
  • withdraw your consent, at any time without affecting the lawfulness of processing based on consent before its withdrawal.


If you would like to discuss or exercise any of these rights, please use the contact details in section 12 below.


Finally, if you are not satisfied with the way in which the Company handles your Personal Data, you have the right to lodge a complaint to the Hellenic Data Protection Authority (www.dpa.gr).

 

  1. Origin of Personal Data

In principle any data relating to you is collected from you personally. The Company may also obtain your Personal Data from sources such as the following:

 

  • An employment or recruitment agency;
  • Previous employers;
  • Public registers that contain your Personal Data;
  • In the context of pre-employment screening, the Company may make use of public sources such as search engines and public sections of social media accounts to the extent that they are relevant to the job position of the Applicant and subject to the provisions of the applicable legislation;
  • Third parties (e.g. individuals that make a recommendation for you).

 

  1. Data retention

The retention period of your Personal Data (excluding the case of your employment, in which case your data will be retained in a file containing the Company’s employee data and the relevant Company notice on the processing of employees’ personal data will apply) is up to 12 months, unless the retention of such data is permitted or required by the applicable legislation and/or the applicable regulatory framework for a longer period.

 

  1. Contact Us

If you have any questions or concerns about this Notification, or would like to exercise any of your rights, please contact us exclusively at privacy@ion.gr, or send a letter to the mailing address mentioned above.

 

  1. Updates

The Company may update this Notification from time to time due to changes in laws and regulations or its internal procedures and systems and will notify the Applicants accordingly by any appropriate means. All changes are effective from the date of publication, unless provided otherwise.