This HR Privacy Notice was created by W.Y., S.A. (hereinafter referred to as “WYgroup”, “we”, “us”, and “our”) to inform you as to how we look after your personal data with regards to Human Resources (HR) activities and should be read in conjunction with our General Privacy Notice.
Data Controller
WYgroup is the Data Controller of your personal information.
WYgroup manages its own HR operations and of its subsidiaries (please visit www.wygroup.net), including processing personal information about the employees and job applicants.
Our registered office is Av. Marginal, Edifício Parque Oceano, 4º andar, 2780-322 Oeiras – Portugal. We are registered in Portugal under company number 508561752. We have appointed a Data Protection Officer, registered in the Portuguese data protection authority – Comissão Nacional de Proteção de Dados (www.cnpd.pt). We provide details of how to contact us at the bottom of this HR Privacy Notice.
Definitions
In this HR Privacy Notice:
“Third party” means someone who is not you or us or a part of WYgroup; and
“WYgroup” means WY, S.A., and any company or other organization in which WYgroup owns 50% or above of the share capital.
The Basics
Personal information we collect about you
WYgroup will process your personal information based on:
WYgroup’s legitimate business interest – when you apply for a role at WYgroup you provide us with your personal information and agree that we can use this information to assess your application, progress your application through the recruitment process, make a decision about your suitability for the role and contact you throughout the recruitment process;
Necessary to perform a contract – we may ask you to provide personal information that is required to enter into an employment or outsourcing contract with us;
Consent you provide – where WYgroup does not rely on another legal basis or in addition to reliance on our legitimate business interests, we may ask you to provide information voluntarily, including for example your date of birth and gender. You can withdraw your consent at any time by sending an email to dpo@wygroup.net;
Compliance with the law – where certain information is necessary to satisfy a legal or regulatory requirement.
How we collect personal information about you
We collect personal information about you when you register a general interest (spontaneous application) or apply for a specific role at WYgroup. Some of the information we collect about you is required to make an assessment of your application to WYgroup and contact you as you progress through the recruitment process (for example your telephone number, email address, and CV). If you do not provide this information, we will be unable to assess your application or contact you to invite you for an interview or make you an offer.
We may collect information about you from third parties (including but not limited to, recruitment consultants or agencies and previous employers) and from the public internet where you have made this information publicly available, or from professional and recruiting networks on the internet (for example, LinkedIn or Indeed) and contact you about suitable roles.
Types of information we may collect about you
Personal details – such as name, personal email address, current address, home and mobile phone number;
Recruitment information – such as application form, CV, resumes, interview notes, references from previous employers, nationality and immigration status, passport and other identification and immigration details (where applicable), and criminal records information checks (where applicable);
Internal candidate information – such as interview notes and internal transfer;
Identification information – such as proof of identity.
We may also collect and process sensitive personal information about you whenever necessary – or when this information is provided on a voluntary basis (for example, information you provide to us on your CV).
How we use information about you
We may process the personal information that we collect about you for the following purposes:
Recruiting – the information you provide to us will be used to assess and progress your job application and to make any verifications required;
Resourcing for jobs – if you register a general interest in pursuing a career with WYgroup, the information that you provide will be retained by us and searched by people who are employed by WYgroup to help us fill future vacancies. If you apply for a specific vacancy and you are unsuccessful, the information you provide to us will be retained so that we can consider you for future suitable vacancies – but only where we have collected your consent to do so;
Creating an employee record – if your job application is successful, the information you give during the application process will form part of your employee record and will be used to administer your employment and manage your career at WYgroup;
Analytics – we may use some of the personal information you provide for various reporting purposes including, for example, to report on our diversity targets or the type of candidates and volumes of applications made to WYgroup and related trends – you will not be personally identified from these reports;
Screening – in certain circumstances we will make an automatic decision on the suitability of your application based on certain criteria. For example, you will be asked if you are proficient in a specific language and if you have good academic performance – we will bring this to your attention wherever we collect information to make an automatic decision about you.
Who we share information about you with
We may share personal information about you with:
Companies in the WYgroup, which will process your personal information solely and only where we have collected your consent to do so;
Third parties, such as recruitment consultants and employment agencies, security check providers, test providers, and others who help us fill vacancies and assess the suitability of candidates and progress applications. Where we use third parties, WYgroup ensures that they meet the same privacy and security standards as WYgroup;
Law enforcement agencies, government bodies, regulatory organizations, courts, or other public authorities if we have to, or are authorized to, by law;
A third party or body where such disclosure is required to satisfy any applicable law or other legal or regulatory requirement.
Where we process information about you
In doing the above, we may need to transfer personal information about you to other companies in the WYgroup (please visit www.wygroup.net) or third parties located (or whose servers may be located) in countries outside of the country where you have applied, including countries outside of the European Economic Area (EEA).
If we send personal information about you to a country that is not in the EEA, we will make sure that there is a legal basis for such transfer and that your personal information is adequately protected as required by applicable law (for example, by using standard agreements approved by relevant authorities and by requiring the use of other appropriate technical and organizational measures to protect your personal information).
Please contact our Data Protection Officer at dpo@wygroup.net if you would like to find out more about the way we comply with our legal obligations concerning international data transfers.
How long we keep information about you
We will keep your information for as long as it is necessary for the recruitment process and under our Data Retention Policy – a copy is available on request by sending an email to dpo@wygroup.net.
If you are successful at the end of a recruitment process, we will keep your information for the duration of your employment, should you wish to apply for other roles within WYgroup and its companies. If we aren’t able to offer you a role, we will keep your information for 5 years to contact you about future roles that may interest you, but only where we have collected your consent to do so – you can withdraw your consent at any time by sending an email to dpo@wygroup.net. Every 5 years, we will send you an email alert about the retention period expiration. If you don’t respond, your personal data will be deleted.
We will anonymize your information in accordance with our retention policy and may retain those anonymized records to monitor the effectiveness of our recruitment process. For example, we may create reports to understand what nationalities have applied for roles with WYgroup in the last 12 months – you will not be identifiable in these reports.
Your rights
Right to correct or update information: you have the right to have information we keep about you corrected if it is not accurate. If the information we keep about you needs updating, or you think it may be inaccurate, you can contact dpo@wygroup.net at any time to update this;
Right to access: you have the right to receive a copy of the personal information we hold on you. You can apply for a copy of your personal information by contacting dpo@wygroup.net;
Right to object: in certain circumstances, you have the right to object to WYgroup processing your personal information. This includes, for example, where we make an automatic decision about you for screening purposes. If you wish to object to processing, you can make an objection request or contest an automatic decision we have made about you by contacting dpo@wygroup.net;
Right to deletion: in certain circumstances, you have the right to request that we erase the personal information we hold about you. You can request for your information to be deleted by contacting dpo@wygroup.net;
Right to restrict use of your information: if you feel the personal information we hold about you is inaccurate or believe we shouldn’t be processing your personal information, you may have the right to ask us to restrict processing that information. You can request to restrict processing by contacting dpo@wygroup.net;
Right to data portability: in certain circumstances you will have the right to take the personal information you have provided to us with you. You can request a copy of your personal information by contacting dpo@wygroup.net.
If we don’t take action based on any of the above requests, we will inform you of the reasons why.
Changes to this HR Privacy Notice
This HR Privacy Notice gets updated from time to time, so we encourage you to check it regularly.
How to contact us
If you have any further questions about this HR Privacy Notice or how we process your information, please contact our Data Protection Officer at dpo@wygroup.net or by sending a registered letter to the following address:
DPO WYgroup Av. Marginal, Edifício Parque Oceano, 4º andar 2780-322 Oeiras – Portugal
