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    Privacy Notice for the Recruitment Process

    Privacy notice for recruitment process - English

    Last updated: January 2020  See previous versions
    Last Updated: January 2020

    INTRODUCTION


    Your privacy is important to Signify.

     

    We have drafted this Privacy Notice (also referred to as “Notice”) in an easy and comprehensible way, in order to help you understand who we are, what Personal Data we collect about you, why we collect it, and what we do with it during our recruitment process. Keep in mind that ”Personal Data” (in this Notice also referred to as “Data” or “your Data”) means any information or set of information from which we are able, directly or indirectly, to personally identify you, in particular by reference to an identifier, e.g. name and surname, email address, phone number, etc.

    Please keep in mind that since Signify is an international company, this Notice may be replaced or supplemented in order to fulfil local requirements, as well as in order to provide you with additional information.
     

    We strongly encourage you to take some time to read this Notice in full.

    WHEN DOES THIS PRIVACY NOTICE APPLY?


    This Notice covers how we collect and use your Data in the context of our recruitment process. For example, when we contact you for job opportunities or when you apply for a job offered by us, use our recruitment channels, visit our career websites, join our recruitment events, or otherwise interact with us in your capacity as candidate or job applicant.
    By engaging in our recruitment process (where legally required), you expressly consent to our collection, storage, use, transfer, and disclosure of your Data, including any sensitive information you elect to submit (as described in this Privacy Notice).

    WHO IS SIGNIFY?


    As Signify, we are a global organization leader in the general lighting market with a unique competitive position and recognized expertise in the development, manufacturing, and application of innovative lighting products, systems, and services.  

     

    When this Notice mentions “we,” “us,” or the “Company,” it refers to the controller of your Personal Data under this Notice, namely the Signify Affiliate which may be interested in offering you a position or that otherwise decides which of your Data are collected and how they are used, as well as Signify Netherlands B.V. (Registration number 17061150 - High Tech Campus 48, 5656 AE, Eindhoven, The Netherlands). Please note that the Signify Affiliates include the subsidiary companies in which Signify N.V. has control, either through direct or indirect ownership. You may obtain a list of the Signify’s Affiliates by contacting the Signify Privacy Office (you will find the contact details in the below section “What are your choices?”).

    WHAT TYPES OF PERSONAL DATA DO WE COLLECT ABOUT YOU?


    Below you will find an overview of the categories of Data that we may process during the recruitment process:

     

    Information you provide to us directly

    Categories of Personal Data
    Examples of types of Personal Data We Collect
    Personal identification data
    Name, surname, title, gender, country, date and place of birth, military status (only in certain countries, such as US), nationality, language(s) spoken, marital/civil partnership status, domestic partners, dependents
    Contact information data
    Email, phone, address
    Network traffic data and other related data
    Identification numbers, location data, online identifiers, IP address, cookies, device ID, websites visited, language settings
    Account login information
    Login ID, password, other information used to access and/or secure Company systems and applications including the career website
    Images and/or videos from which you may be identified

    Pictures uploaded into CV or otherwise provided to us by you.

    Videos recorded during the optional video interview. Images or other Data captured by cameras and sensors when physically present on our premises and/or office locations.

    Data regarding qualifications and career development
    Any information contained in CVs and additional documents containing personal details (e.g. diplomas, certificates) as provided by applicants or any information - following from CVs or additionally - submitted by applicants as part of the application (for example confirmation(s) of employment history, relevant experience, academic achievements and GPA’s (for US interns only), assessment and/or test evaluation information, evaluations of interviews conducted with applicants, educational and employment background, job qualifications, jobs for which the applicant would like to submit an application, willingness to relocate, driver’s license information, any additional information such as transcripts, employment references and related information, compensation requests
    Information resulting from background or employment check and/or an employment reference
    Feedback, opinions
    Special categories of Personal Data

    When permitted by local law:

    -          Information about disabilities to the extent relevant for the performance of your work: for instance, where we would be required to make work or workspace adaptations, accommodations or adjustments,

    -          Racial or ethnic data: for instance where this would show from pictures, photographs and other visual images, but also where such data is processed for diversity related purposes.

    Note: We generally process these special categories of data in order to comply with legal obligations and internal policies, such as relating to diversity and anti‑discrimination.

    Criminal data
    Data relating to criminal behavior, criminal records or proceedings regarding criminal or unlawful behavior (only in certain countries, for certain roles and only upon request of Signify)
    Compensation and payroll
    Bank account information (to support expenses of certain applicants), desired salary, compensation, and benefits.
    Any other information that you decide to  voluntarily share with Signify
    Feedback, opinions, information provided in emails and letters, during telephone calls and conversations.

    We value diversity and inclusion. In order to ensure equal employment opportunities as permitted or required by local law we may also gather Data of a sensitive nature, including your nationality, racial and/or ethnic origin, gender and disability. Equal employment opportunities mean we offer equal treatment to all applicants. You can choose to provide this information on a voluntarily basis. Where we have a mandatory legal obligation to process aforementioned Data, the relevant job vacancy will indicate if it is mandatory or voluntary.
     

    If you provide us with personal data of a reference or any other individual as part of your application, it is your responsibility to obtain consent from that individual prior to providing the information to us. It is your responsibility to ensure that information you submit does not violate any third party’s rights
     

    Please note that your election not to provide any of your Data as required or requested in the context of the recruitment procedure, may have effect on your ability to participate in the recruitment process. Any information you share with us as part of your application procedure must be true, complete and not misleading to avoid the risk of a rejection of your application during the application process or disciplinary action including immediate termination of employment.

     

    Information we collect automatically

     

    When you apply for a job offered by us, use our recruitment channels, or visit our career websites, in addition to the information you provide to us directly, we may collect information sent to us by your computer, mobile phone or other access device.  For example, we may collect:

    •         Device information: such as your hardware model, IMEI number and other unique device identifiers, MAC address, IP address, operating system version, and settings of the device you use to access the Services;

    •         Log information: such as the time and duration of your use of our channel;

    •         Location information: for example, a location derived from your IP address or data that indicates where you are located, such as at a city or postal code level;

    •         Other information: about your use of our digital channels, such as the apps you use or the websites you visit.

     

    For more information on how we use cookies and other tracking technologies, read the Signify Cookie Notice which can be found in the website of the Signify Privacy Center, see “Legal information” section.

     

    Lastly, if you visit our premises, for security reasons we might also record your Data through video or other electronic, digital, or wireless surveillance system or device (e.g. CCTV).

     

    Information we may collect from other sources

     

    To the extent permitted by applicable law, in addition to our recruitment channels or career websites, we may also obtain information about you from other sources, such as through your interactions with Signify personnel or from third parties, such as recruiters. LinkedIn or other websites on the Internet (subject to such third party’s privacy notices), or from a background check report. For example, you may choose to provide us with access to certain data stored by third parties such as business and employment-oriented social media sites.

    HOW DO WE USE YOUR PERSONAL DATA?


    We may use your Data for the purposes of carrying out your application and the entire recruitment process. Below you will find an overview of the purposes for which we may process your Data during the recruitment process:
    Purposes for processing Personal Data
    Examples
    Business process execution and internal management
    Identifying and evaluating candidature, assessing skills, qualifications and interest against Signify career opportunities, to set up and conduct interviews and assessments, to evaluate, select and recruit applicants, to conduct background checks and assessments as required or permitted by applicable local law, to contact third party references provided by applicant to evaluate applicant’s previous performances or as otherwise necessary in context of recruitment activities, to better understand your use of our career website to improve your recruitment experience, to keep records related to Signify hiring process, informing the Signify employee that referred the applicant for the job about the progress of the application, making business travel arrangements, managing expenses and reimbursements
    Job Applicant support (upon your request)
    Assistance via talent acquisition teams and other communication channels.
    Relationship management
    To contact you by phone call, text (SMS), or email messaging, to inform applicants of available vacancies, to provide with information relating to application and to fulfill applicants’ requests, to offer applicants suitable opportunities for employment within Signify
    Security and protection of interests/assets of Signify or Signify employees
    Deploying and maintaining technical and organizational security measures, conducting internal audits and investigations, conducting assessments to verify conflict of interests, or potential violations of our Integrity code and/or relevant laws and regulations that could negatively impact your desired employment relationship with us. 
    Compliance with legal obligations
    Disclosing Personal Data to government institutions or supervisory authorities as applicable in all countries in which Signify operates, such as tax and national insurance deductions, record-keeping and reporting obligations, compliance with government inspections and other requests from government or other public authorities, responding to legal process such as subpoenas, pursuing legal rights and remedies, and managing any internal complaints or claims.
    Defense of legal claims
    Establishment, exercise or defense of legal claims to which Signify is or may be subject to.

    ON WHAT LEGAL BASIS WE USE YOUR PERSONAL DATA?


    In order to be able to process your Data, we may rely on different legal bases, including:

    •  Your consent (only when legally required or permitted). If we rely on your consent as a legal basis for processing your Personal Data, you may withdraw your consent at any time; or
    • The necessity to establish a contractual relationship with you; or
    • The necessity for us to comply with legal obligations and to establish, exercise, or defend our self from legal claims; or
    • The necessity to pursue our legitimate interests, including;

    - To ensure that our networks and information are secure;

    - To administer and generally conduct business within the Company and across Signify; and

    - To prevent or investigate suspected or actual violations of law, breaches of the terms of employment or non-compliance with the Signify Integrity code or other Signify policies; and

    • The necessity to respond to your requests (such as responding to your requests regarding the handling of, deletion of, or changes to your Personal Data);
    •  The necessity to protect the vital interests of any person; or
    •  Any other legal basis otherwise permitted by local laws.

    WHEN DO WE SHARE YOUR PERSONAL DATA?


    We do not share any of your Personal Data except in the limited cases described here.

     

    To fulfill the purposes for which your Personal Data has been collected (for details on these purposes, see above section “How do we use your personal information?”) we may disclose your Personal Data to the following entities. 

     

    1. Signify Affiliates: Due to our global nature, your Personal Data may be shared with certain Signify Affiliates. Access to Personal Data within Signify will be limited to those who have a need to know the information, for the purposes described in this Notice, and may include your interviewers, the relevant manager(s) of the respective job offer and other selected personnel within Signify.

    2. Service Providers: Like many businesses, we may outsource certain Personal Data processing activities to trusted third party service providers to perform functions and provide services to us, such as:

    -  ICT service providers

    - Recruitment- or assessment provider

    -  Consulting providers

    -  Background check provider

    - Travel-, security-and safety provider     

    3. Public and Governmental Authorities.  When required by law, or as necessary to protect our rights, we may share your Personal Data to entities that regulate or have jurisdiction over Signify.

    4. Professional advisors and others.  We may share your Personal Data with other parties including professional advisors, such as:

    -  Banks

    -  Insurance companies

    -  Auditors

    -  Lawyers

    -  Accountants

    -  Other outside professional advisors

    5. Other parties in connection with corporate transactions. We may also, from time to time, share your Personal Data in the course of corporate transactions, such as during a sale of a business or a part of a business to another company, or any reorganization, merger, joint venture, or other disposition of Signify’s business, assets, or stock (including in connection with any bankruptcy or similar proceeding). 

    WHEN DO WE TRANSFER YOUR PERSONAL DATA ABROAD?

     

    Due to our global nature, the Personal Data you provide to us may be transferred to or accessed by Signify Affiliates and trusted third parties from many countries around the world. As a result, your Personal Data may be processed outside the country where you live if this is necessary for the fulfilment of the purposes described in this Notice.

     

    If you are located in a country member of the European Economic Area, we may transfer your Personal Data to countries located outside of the European Economic Area.  Some of these countries are recognized by the European Commission as providing an adequate level of protection.  With regard to transfers from the European Economic Area to other countries that are not are recognized by the European Commission as providing an adequate level of protection, we have put in place adequate measures to protect your Data, such as organizational and legal measures (e.g. binding corporate rules and approved European Commission standard contractual clauses). You may obtain a copy of these measures by contacting the Signify Privacy Office. You will find the contact details in the below section “What are your choices?”

    HOW LONG DO WE KEEP YOUR PERSONAL DATA?


    We keep your Personal Data for the period necessary to fulfill the purposes for which it has been collected (for details on these purposes, see above section “How Do We Use Your Personal Data?”) and we may retain and use your Data to consider you for other positions.

    The criteria used to determine our retention periods include:
               - How long is the Personal Data needed to provide you with a job offer?

    - Do you have an account with us? In this case we will keep the Data while your account is active or for as long as needed to provide services to you.

    - Have you indicated that we can retain your Data to consider you for other positions?

    - Are we subject to a legal, contractual, or similar obligation to retain the Personal Data? Examples can include mandatory data retention laws in the applicable jurisdiction, government orders to preserve Data relevant to an investigation, or Data that must be retained for the purposes of litigation.

    If you have decided to participate in our optional live and/or on demand video interview during the recruitment process, videos of your interview will be retained for 90 days from their creation, after which they will be deleted unless local law requires differently and/or we have overriding company interest (e.g. the necessity for us to comply with legal obligations and to establish, exercise, or defend our self from legal claims or  to pursue our legitimate interests).

    Of course, if you do not want to be considered for other positions or would like to have your Data removed, you can contact us at: careers@signify.com.

    HOW DO WE SECURE YOUR DATA?

     

     To protect your Data, we will take appropriate measures that are consistent with applicable privacy and data security laws and regulations, including requiring our service providers to use appropriate measures to protect the confidentiality and security of your Personal Data. Unfortunately, no  data transmission or storage system can be guaranteed to be 100% secure. Depending on the state of the art, the costs of the implementation and the nature of the data to be protected, we put in place technical and organizational measures to prevent risks such as destruction, loss, alteration, unauthorized disclosure of, or access to your Data. If you have reason to think that your interaction with us or your Data is no longer processed in a secure manner, please reach out immediately in accordance with “WHAT ARE YOUR CHOICES?” as described below.

    WHAT ARE YOUR RESPONSIBILITIES?

     

    We would like to remind you that it is your responsibility to ensure, to the best of your knowledge, that the Data you provide us with are accurate, complete, and up-to-date. Furthermore, if you choose to share Personal Data of other people (such as dependents) with us, it is your responsibility to collect such Data in compliance with local legal requirements. For instance, you should inform such other people, whose Personal Data you provide to the Company, about the content of this Notice and obtain their consent (provided they are legally competent to give consent) for the use of that Personal Data by the Company as set out in this Notice (including transfer and disclosure).

    WHAT ARE YOUR CHOICES?


    We aim to provide you with access to your Data. Usually you can autonomously control your Personal Data (e.g. by logging to your account) and update, modify, or, if legally possible, delete it. In this case, we strongly encourage you to take control of your Personal Data.


    In any case, if you would like to review, change, restrict, or delete the Personal Data you have supplied to us (to the extent Signify is not otherwise permitted or required to keep such Data), if you wish to object to certain data processing operations (as permitted by applicable law), or if you would like to receive a copy of your Data (in a common machine readable format, to the extent such is required by applicable law), then you can contact: careers @signify.com.

    For any other questions or your reasonable inquiry related to the protection of your Personal Data by Signify or regarding this Notice in general, you can contact the Signify Privacy Office at:

    - Mail: Signify - Attn: Privacy Office – Herikerbergweg 102, 1101 CM Amsterdam Zuid Oost, The Netherlands; or

    - Online: Signify Privacy Center, “Privacy request” section.

     

    Please keep in mind that email communications are not always secure. Therefore, please do not include sensitive information in your emails to us.


    We will do our best to address your request in time and free of charge, except where it would require a disproportionate effort. In certain cases, we may ask you to verify your identity before we can act on your request.


    If you are unsatisfied with the reply received, you may then refer your complaint to the relevant regulator in your jurisdiction.

    CALIFORNIA PRIVACY DISCLOSURES

     

    The California Consumer Privacy Act (‘CCPA’) provides California consumer residents with specific rights regarding their personal information. In additional to the above this section describes your CCPA rights and explains how to exercise those rights.

     

    The following is not applicable to de-identified or aggregated personal information or data publicly available.

    INFORMATION WE COLLECT

     

    In the execution of our services and/or when visiting our Website we collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (defined as “data”). In particular, we have collected the following categories of data from our consumers within the last twelve (12) months:

    Category
    Examples
    Collected
    A. Identifiers.
    A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
    YES
    B.Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

    A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

    Some personal information included in this category may overlap with other categories.

    YES
    C.Protected classification characteristics under California or federal law.
    Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
    YES
    D.Commercial information.
    Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
    NO
    E.Biometric information.
    Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
    YES
    F. Internet or other similar network activity.
    Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
    YES
    G. Geolocation data.
    Physical location or movements.
    YES
    H. Sensory data.
    Audio, electronic, visual, thermal, olfactory, or similar information.
    NO
    I. Professional or employment-related information.
    Current or past job history or performance evaluations.
    YES
    J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
    Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
    YES
    K. Inferences drawn from other personal information.
    Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
    YES

    We disclose your data for a business purpose to the following categories of third parties:

    • Signify Affiliates.
    • Service providers.
    • Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

    DO NOT SELL?

     

    We do not respond to “Do Not Sell” requests as we do not track your data across third party websites, nor do we sell your data to third parties to provide targeted advertising. Nonetheless, we aim to make your online experience and interaction with our websites as informative, relevant and supportive as possible. One way of achieving this is to use cookies or similar techniques, which store information about your visit to our site on your computer. For more information on how we use cookies and other tracking technologies, read our Cookie Notice (see section “How do we use cookies and other tracking technologies”)
     

    Your Rights?

    “Right to Know”: You have the right to request that we disclose to you what personal information of yours that we collect, use, and/or disclose.

    “Right to Delete:” You have the right to request the deletion of your personal information collected or maintained by us.
     

    If you have questions about the foregoing or how to execute your Right to Know and/or Right to Delete in our Privacy Notice or specifically with regard to categories and specific pieces of data processed, categories of sources from which your data is collected by us, categories of third parties with whom we share your data in the preceding 12 months of its collection and the business or commercial purpose for collecting please contact our Privacy Office (see section “What are your choices?”). You may also make a verifiable request to exercise your rights by contacting us via the contact details in the vacancy.
     

    If we cannot verify if you are the California consumer making the request is the consumer about whom we have collected information (or is authorized to act on your behalf) we have the right to deny requests. While verifying your identity we shall generally avoid requesting additional information from you for purposes of verification. If, however, we cannot verify your identity from the information already maintained by us, we may request additional information from you, which shall only be used for the purposes of verifying your identity while you are seeking to exercise your rights under the CCPA, and for security or fraud-prevention purposes. We shall delete any new personal information collected for the purposes of verification as soon as practical after processing your request, except as required to comply with applicable legislation.
     

    An “Authorized agent” means a natural person or a business entity registered with the Secretary of State that a consumer has authorized to act on your behalf and conditioned you have
     

    1. Provided the authorized agent written permission to do so and we could verify this; and

    2, Verified your own identity directly with the business.
     

    Subsection 1 does not apply when you have provided the authorized agent with a valid power of attorney.
     

    We endeavor to timely respond to a verifiable individual, free of charge and in a portable format unless it is excessive, repetitive or material unfounded. If we require more time, we will inform you of the reason thereof and extension period in writing.
     

    Non-Discrimination

    We will not discriminate against you for exercising your rights under the CCPA. Unless permitted by applicable regulations, we will not charge different prices or rates, deny products or services, provide different products or services or level of quality and/or suggest you may receive the foregoing mentioned.
     

    However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your data’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

    WHEN WILL THERE BE UPDATES TO THIS PRIVACY NOTICE?


    This Notice might change from to time.

    The most current version of this Notice will govern our use of your Personal Data and can be found in the website of the Signify Privacy Center, see “Legal information” section.
     

    - Signify -

    Version history

    Date

    May 2018
    January 2019
    May 2019