This Summary Applicant Privacy Statement (“Summary Statement”) will provide you with a summary of the accompanied, detailed Applicant Privacy Statement (hereafter “Full Statement”) on our data processing activities with respect to individually identifiable information about applicants for positions at LMW S.A. (ΑΕΠΑ) (i.e., the entity identified in the vacancy for which you are applying or to which you are sending an unsolicited application) or at a third party employer (i.e. a client of LMW S.A.) (“Personal Data”). LMW S.A. acts as data controller and has its registered offices in 208 Kifisias Avenue, Halandri 152 31, Greece (“LMW” or “we” or “us” or “our”).
Scope of applicability
This Summary Statement applies to you if you are applying for a position at LMW or via LMW for a position at a third party employer.
Processing of your Personal Data (categories of Personal Data)
We process the following Personal Data collected during the application and job interview process from yourself, or authorized third parties (e.g. recruitment agencies), as applicable: name, contact details, information related to your education and professional experience, language skills, your eligibility to work in Greece, information about the reason for your application at LMW, information from your LinkedIn profile (if you decided to use your LinkedIn profile for your CV/resume) and any other information you provide. For more details see I. 1. of the Full Statement or click here.
We process your Personal Data for the following purposes: determine your suitability for the position you are applying for as part of the application process, provide you with offers for potential other positions that may be of interest for you, protect the legal interests of LMW (e.g. as required to defend against legal claims), comply with legal or regulatory obligations under laws applicable to LMW. For more details see I. 2. of the Full Statement or click here.
Legal justifications for the processing of your Personal Data
One of the key privacy law requirements is that any processing of Personal Data has to have a legal justification. We generally use the following legal justifications: the processing is (i) necessary to determine whether an employment contract will be entered into [Art. 6(1)(b) GDPR and the corresponding provisions in local data protection law relating to the (pre-)employment relationship], (ii) necessary for compliance with a legal obligation [Art. 6(1)(c) GDPR], (iii) necessary for realizing a legitimate interest [Art. 6(1)(f) GDPR], or (iv) based on your consent [Art. 6(1)(a) GDPR]. For more details see I. 3. of the Full Statement or click here.
Data transfers and recipients and legal justification for such transfers
We may transfer your Personal Data to our service providers, external advisors, and, in accordance with applicable law, governmental authorities, courts, and similar third parties, some of the aforementioned recipients located in jurisdictions outside the EU. For more details see II. of the Full Statement or click here.
Retention periods for and deletion of your Personal Data
Your Personal Data will be deleted once they are not any longer needed for the purposes of their original collection or as required by applicable law. For more details see III. of the Full Statement or click here.
Your statutory rights
You have a number of rights with regard to the processing or your Personal Data, each as per the conditions defined in applicable law, such as the right to have access to your data, to have them corrected, erased or handed over. Please refer any of your questions to LMW at [email protected] For more details see IV. of the Full Statement or click here.
Changes of this Summary and the Full Statement as well as further notices
Both this Summary and the Full Statement are subject to change. You will be notified adequately of any such changes. Further, you will be notified adequately through further relevant privacy notices (e.g. for specific purposes, systems used by LMW) in case such is not covered by this Summary and the Full Statement.
How to contact us
If you wish to exercise your data subject rights or if you have any other questions concerning this Statement, please address your request at [email protected]
FULL APPLICANT PRIVACY STATEMENT
I. YOUR PERSONAL DATA / PURPOSES AND LEGAL BASIS OF THE PROCESSING
We will process Personal Data about you we collected during the application and job interview process from yourself, or authorized third parties (i.e. recruitment agencies).
1. Categories of Personal Data
As needed, we may collect the following Personal Data categories when you apply at LMW.
Identification data, such as name, date of birth, nationality;
Contact details, such as address, phone number, email address;
Recruitment-related information, such as professional experience (including references from previous employers), education, language skills, qualifications, talents, professional memberships;
Communication details, such as email content;
Eligibility to work in Greece;
Information about the reason for your application at LMW or via LMW at a third party employer;
Information from your LinkedIn profile (if you decided to use your LinkedIn profile as CV/resume); and
Any other information you provide in your CV/resume, cover letter and/or the documents you upload or provide to us by any other means.
The provision of Personal Data is necessary for the decision whether an employment contract with you will be concluded (hiring decision). The provision of Personal Data by you is voluntary. However, if you do not provide your Personal Data, the application process may be delayed and/or we may not be in a position to properly evaluate your applications and essentially need to reject it.
2. Processing Purposes
We process your Personal Data, to the extent permitted or required under applicable law, for the purposes to
determine your suitability for the position you are applying for as part of the application process;
provide you with offers for potential other positions that may be of interest for you (if you have provided your consent);
protect the legal interests of LMW (e.g. as required to defend against legal claims); and
comply with legal or regulatory obligations under laws applicable to LMW.
3. Legal Basis
The processing of your Personal Data is mainly necessary to determine whether an employment contract will be entered into and is based on Art. 6 para. 1 lit. b) General Data Protection Regulation [Regulation (EU) 2016/679] (“GDPR”) and the corresponding provisions in Greek data protection law relating to the (pre-)employment relationship.
If you provide consent allowing LMW to provide you with offers for potential other positions that may be of interest for you, the processing of your Personal Data is based on your consent [pursuant to Art. 6 para. 1 lit a) GDPR].
Your Personal Data may also be processed where LMW reasonably considers it necessary for complying with legal or regulatory obligations [pursuant to Art. 6 para. 1 lit c) GDPR] or to pursue the following legitimate interests [pursuant to Art. 6 para. 1 lit f) GDPR]: protect the legal interests of LMW (e.g. as required to defend against legal claims or to take precautions against liability).
II. DATA TRANSFERS AND RECIPIENTS
We may transfer some of your Personal Data to other parties, as permitted pursuant to Art. 6 para. 1 lit. f) GDPR, for the legitimate interests of LMW, i.e. in order to be able to support our recruiting processes. We may use externally provided IT systems or services provided by third party vendors as a support in the recruitment process and third party providers of recruiting software services.
We may also transfer of your Personal Data to public authorities, if legally required to do so under applicable local law, based on Art. 6 para. 1 lit. c) GDPR.
If you provide consent allowing LMW to provide you with offers for potential other positions that may be of interest for you, the transfer of your Personal Data is based on this consent (pursuant to Art. 6 para. 1 lit. a) GDPR).
To the extent that, in the context of and for the needs of the above-mentioned purposes, your Personal Data need to be transferred outside the EU/EEA, such data transfer will take place in accordance with applicable law and LMW will ensure an adequate level of data protection.
By way of entering into appropriate data transfer agreements based on Standard Contractual Clauses (2010/87/EC and/or 2004/915/EC) as referred to in Art. 46 (5) GDPR or other adequate means, which are accessible upon request at [email protected], we have established that all other recipients located outside the EEA will provide an adequate level of protection for the Personal Data and that appropriate technical and organizational security measures are in place to protect Personal Data against accidental or unlawful destruction, accidental loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing. Any onward transfer is subject to appropriate onward transfer requirements as required by applicable law.
III. RETENTION PERIODS
The main principle is that Personal Data pertaining to a job application will be deleted as soon as a decision has been made in respect of the job and any applicable period to appeal or otherwise dispute the decision has expired. In other words, Personal Data processed for the purposes hereunder will be stored only as long as necessary during the application process and a following reasonable period (taking into account statutory limitation periods) as required or permitted under applicable law (e.g., as necessary to defend against claims in relation to the application process, or to comply with LMW’s obligations regarding data retention as established in the applicable laws). If a judicial or disciplinary action is initiated, the Personal Data may be stored until the end of such action, including any potential periods for appeal, and will then be deleted or archived as permitted by applicable law.
If you provide consent allowing LMW to provide you with offers for potential other positions that may be of interest for you, your Personal Data will be stored for 24 months or until you withdraw your consent.
LMW may keep anonymized data – i.e. data that does not allow you to be identified – for internal statistics purposes and for purposes to improve our recruitment process.
IV. YOUR STATUTORY RIGHTS
You normally have the following rights, under the conditions set out under the GDPR:
(i) Right of access: You have the right to obtain from us confirmation as to whether or not Personal Data concerning you is being processed, and, where that is the case, to request access to the Personal Data. The access information includes – inter alia – the purposes of the processing, the categories of Personal Data concerned, and the recipients or categories of recipients to whom the Personal Data have been or will be disclosed. You have the right to obtain a copy of the Personal Data undergoing processing. For additional copies requested by you, we may charge a reasonable fee based on administrative costs.
(ii) Right to rectification: You have the right to obtain from us the rectification of inaccurate Personal Data concerning you. Depending on the purposes of the processing, you have the right to have incomplete Personal Data completed, including by means of providing a supplementary statement.
(iii) Right to erasure (right to be forgotten): You have the right to ask us to erase your Personal Data.
(iv) Right to restriction of processing: You may have the right to request the restriction of processing your Personal Data. In this case, the respective data will be marked and may only be processed by us for certain purposes.
(v) Right to data portability: You have the right to receive the Personal Data concerning you which you have provided to us in a structured, commonly used and machine-readable format and you have the right to transmit those Personal Data to another entity without hindrance from us.
(vi) Right to object: You have the right to object, on grounds relating to your particular situation, at any time to the processing of your Personal Data by us and we can be required to no longer process your Personal Data. If you have a right to object and you exercise this right, your Personal Data will no longer be processed for such purposes by us. Exercising this right will not incur any costs. Such a right to object may not exist, in particular, if the processing of your Personal Data is necessary to take steps prior to entering into a contract or to perform a contract already concluded.
Please note that the aforementioned rights might be limited under the GDPR or other applicable data protection legislation.
If you have provided your consent for any Personal Data processing activities (e.g. in order to contact you in case of a new opening), you can withdraw this consent at any time with future effect. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal.
If you wish to exercise your data subject rights or if you have any other questions concerning this Statement, please submit your request at [email protected]
In case of complaints you also have the right to lodge a complaint with the Greek Data Protection Authority.