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Processing of (personal) data by the entity in charge of the online application process

1. General information

Thank you for your interest in SPICE P (Swiss Post Lisbon IT Campus Enterprise – Portugal) and its strategic subsidiaries (referred to below as Swiss Post). The protection of your personal data is of great importance to us. This Privacy Policy provides information about current Swiss data protection regulations and the ways in which your personal data is collected, the purposes for which it is used, and how we handle it. It also contains information about your rights relating to the processing of your personal data.


2. Scope

The information in this document applies to all natural persons whose personal data is processed in connection with an application process. Personal data means all information which relates to a specific or specifiable natural person. We use the terms “data” and “personal data” synonymously throughout this Privacy Policy.

The purpose of this Privacy Policy is to provide you with information; it does not constitute part of a contractual agreement between you and Swiss Post.

This Privacy Policy for Applicants is supplementary to existing privacy policies on our website. Separate privacy policies containing further information concerning data processing in relation to our websites can be found at:

The terms “we”, “us” and “our” refer to all companies and units which are responsible for the processing of data. In instances where a distinction has to be made, that will be indicated specifically.


3. Controller

The controller is the company which places the job ad. Along with Swiss Post, the company indicated in the job ad (see below) is the controller:

  • Post CH Ltd (Logistics Services)

  • Post CH Network Ltd (PostalNetwork)

  • Post CH Communication Ltd (Communications Services)

  • PostBus Ltd

  • Post Real Estate Management and Services Ltd (Real Estate)

  • PostLogistics Ltd

  • Presto Presse-Vertriebs AG (Presto)

For applications to PostFinance, PostFinance Ltd is the controller, and Swiss Post Ltd is the processor.

See section 10 for contact info.


4. Which types of personal data do we gather and process?

In principle, we only process personal data that relates to the application process. Primarily we obtain this data directly from you, for example if you apply for a job or submit documents relating to your application. This involves data which you make available as part of your application. Depending on the situation and purpose, we may also gather data from various sources, for example from public registers or other publicly accessible sources such as LinkedIn, Xing or Prospective, and with your consent from your former employer or recruitment agency.

By submitting your application, you assure that the information you provide is true and accurate. Please bear in mind that information which is untrue or inaccurate could constitute grounds for rejecting your application or for later dismissal.

By sending us data about other people (e.g. family members or former employers), you confirm that you are authorized to do so and that the data is correct. Before providing this data, please ensure that these third parties have been informed that we will process their data.

As part of the job application process, we gather and process personal data in the following categories in particular:

Human resources data and master data

We use the term “HR data and master data” to refer to information such as identification information, contact information or personal details, for example your name, telephone number, addresses, date of birth, marital status, or family information.


Registration data

This refers to data provided by you during the registration on our job portal.


Visitor and communication data

This refers to our communication with you (written, telephone and electronic). This data may also include our communication with third parties (e.g. when obtaining references). In order to verify your identity, we also obtain data on the basis of which you can be identified.


Behavioural and preference data

This includes data from our interactions in connection with the job application, e.g. application assessments. Using this and other data, we may perform statistical evaluations, for example, on the suitability for a particular job. Such analyses are based on data provided by you or collected directly from you in the application process. We may also combine this data with other information (e.g. from public sources) to improve the quality of our analyses This data is gathered and processed in particular in connection with assessment of qualifications, so that we can assess your competencies and suitability for a specific position.


Other data

This includes, for example, data on your career, such as education, employment history, professional qualifications and references. Insofar as necessary, we may collect these and similar data in pursuit of our business interests or other justifiable interests or to protect our company.


The personal data in question will be processed as part of your application for recruitment purposes on the following lawful grounds, under the terms of the General Data Protection Legislation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016): compliance with legal obligations, execution of pre-contractual procedures, our legitimate interests of the controller, as well as the candidate's consent where applicable.


5. What are the purposes for which we process your data?


Human resources management

The purpose of the data processing is to examine the possibility of employment with us (applicant selection) on the basis of your application documents (applicant information). To accomplish that, we process in particular your application data which you provide to us directly, and also additional data as described in section 4 above. This data is in particular: master data, communication data, and data about your education and employment history. To make hiring decisions, we process data from your candidate profile on our job platform, your application documents and data collected during the selection process. We use analytical procedures to compare your profile to our requirements profile, and if necessary, we may carry out further evaluations. No candidate shall be subject to a decision based solely on automated processing, as per section 6 below. The data may be used among other things to assess and improve our recruitment strategies.


Compliance and risk management

We may use your data for security reasons and access control. For those purposes, we use master data in particular. Access controls involve managing access to electronic systems (e.g. log-ins to user accounts) or in our buildings (entry control).

As a financial institution, PostFinance Ltd is subject to additional obligations. For that reason, additional personal data has to be processed (e.g. criminal records data or debt collection data), inter alia to combat fraud or money laundering, to prevent market abuse, and to fulfil inspection and reporting obligations. This helps protect PostFinance and the integrity of financial markets and may be necessary to assess whether an employment could potentially lead to a security risk. In addition, we are subject to statutory and supervisory-law obligations, and since we work in conjunction with supervisory, judicial and other authorities and bodies, there may be further processing of your data as a result.


Surveys

As part of the application process, you will receive one or more surveys about your experiences during the application process and preboarding/onboarding. The survey(s) are anonymous, and do not allow any conclusions to be drawn about you as an individual. The data is used to improve the application process. Participation in these surveys is voluntary.


Other purposes

In order to send you information or messages or respond to your enquiries, we may also process data collected in connection with communications with you and third parties. We use your master and communication data in particular for this. In addition, we may display targeted job ads on various social media platforms by defining target groups.


6. Do you use automated decision-making procedures?

As a general rule, we do not use automated decision-making procedures during the application process. If we do use such procedures, you will be notified about this separately.


7. Will data be forwarded?

The subsidiary to which you submit your application for a particular position will receive your data. As our work processes are handled collaboratively, your data may be processed by different departments within the Swiss Post Group, for the purposes described above (see section 5). Aside from that, your personal data may also be processed by third parties on our behalf (processors). Our processors process data to the extent that Swiss Post itself and its subsidiaries are allowed to and follow our instructions. This takes place as part of the outsourcing of data processing, in particular by providers of systems for applicant management and selection procedures.

Other third parties in this context may include recruiting partners, HR service providers and recruiters. Data may further be disclosed to comply with legal provisions, i.e. when we are subject to obligations to clarify, report or provide information to the authorities. In all such cases, we take appropriate measures to ensure that the entities involved process your data only to the extent permitted by law and/or contract.


8. Is data disclosed abroad?

As we have explained in section 7, in certain situations processing is carried out by processors; these third parties may in some cases be located in other countries. Therefore, your data may also be forwarded to recipients to countries without a level of data protection equivalent to the European Union. When data is disclosed to recipients in countries without an equivalent level of data protection, we ensure an appropriate level of data protection by Standard Contractual Clauses, in accordance with the applicable data protection legislation.


9. For how long do we store your data?

In principle, we only store your personal data for the time necessary to fulfil the purpose.

Candidate profiles (i.e. CV, references, and master data) will be kept for one year. As a general rule, data such as application documents relating to spontaneous applications for jobs at Swiss Post is deleted within one year.

Personal data regarding successful applicants will be subject to the privacy policy for employees, which will be made available when the successful applicant starts work. The new employee’s job application will be kept on file in their HR file.


10. What are your rights?

You have the right to request information about your personal data and how we process it (right to information). You can, for example, request that we rectify incorrect data or supplement incomplete data (rectification). Furthermore, you can also object to processing your data for specific purposes or revoke any separate consent that you have given (with an effect for future processing). You may also request that we delete data, subject to the provision that the relevant purpose has been fulfilled, no longer applies or is no longer achievable, and that, there are no statutory retention obligations or other grounds for further processing.

In order to exercise one of the aforementioned rights, you may contact the address at the company indicated in the job ad (see below):


Company

Contact address

E-mail address

SPICE-P, S.A.

Swiss Post IT Campus Portugal S.A.

Rua Castilho 2-4

1250-096 Lisboa

DPOITcampus@swisspost.pt

Processing of (personal) data by the operator of the recruitment website

General information

This recruitment website is operated by Personio SE & Co. KG, which offers a human resource and candidate management software solution (https://www.personio.com/legal-notice/). Data transmitted as part of your application will be transferred using TLS encryption and stored in a database. The sole controller of this data within the meaning of article 24 of the GDPR is the enterprise carrying out this online application process. Personio’s role is limited to operating the software and this recruitment website and, in this context, being a processor under article 28 of the GDPR. In this case, the processing by Personio is based on an agreement for the processing of orders between the controller and Personio. In addition, Personio SE & Co. KG processes further data, some of which may be personal data, to provide its services, in particular for operating this recruitment website. We will refer to this in more detail below.

The controller

The controller under data protection law is:
Personio SE & Co. KG
Seidlstraße 3
80335 München
Tel.: +49 (89) 1250 1004
Entry in the commercial register
Commercial register entry number: HRA 115934
Registration Court: Amtsgericht München
Data Protection Officer contact: privacy@personio.com

Access logs (“server logs”)

Each access to this recruitment website automatically causes general protocol data, so-called server logs, to be collected. As a rule, this data is a pseudonym and thus does not allow for inferences about the identity of an individual. Without this data, it would, in some cases, be technically impossible to deliver or display the contents of the software. In addition, processing this data is absolutely necessary under security aspects, in particular for access, input, transfer, and storage control. Furthermore, this anonymous information can be used for statistical purposes and for optimizing services and technology. In addition, the log files can be checked and analyzed retrospectively when unlawful use of the software is suspected. The legal basis for this is §25 subsection 2 Sentence 2 TDDDG. Generally, data such as the domain name of the website, the web browser and web-browser version, the operating system, the IP address, as well as the timestamp of the access to the software is collected. The scope of this log process does not exceed the common log scope of any other site on the web. These access logs are stored for a period of up to 7 days. There is no right to object to this.

Error logs

So-called error logs are generated for the purpose of identifying and fixing bugs. This is absolutely necessary to ensure we can react as quickly as possible to possible problems with displaying and implementing content (legitimate interest). As a rule, this data is a pseudonym and thus does not allow for inferences about the identity of an individual. The legal basis for this is §25 subsection 2 Sentence 2 TDDDG. When an error message occurs, general data such as the domain name of the website, the web browser and web-browser version, the operating system, the IP address, as well as the timestamp upon occurrence of the respective error message and/or specification is collected. These error logs are stored for a period of up to 7 days. There is no right to object to this.

Use of cookies

So-called cookies are used on parts of this recruitment website. They are small text files which are stored on the device with which you access this recruitment website. As a general rule, cookies serve the purpose of ensuring secure access to a website (“absolutely necessary”), implementing certain functionalities such as standard-language settings (“functional”), improving the user experience or the performance of the website (“performance”), or placing targeted advertisements (“marketing”). On this recruitment website, we generally use only cookies that are absolutely necessary, functional or performance-related, in particular for implementing certain default settings such as language, for identifying the job advertising channel, or for analyzing the performance of a job advert via which a user accessed this recruitment website. The use of cookies is absolutely necessary for providing our services and thus for the performance of the contract (article 6 (1) b) of the GDPR). Period of storage: up to 1 month or until the end of the browser session Right to object: You can determine via your browser settings whether you allow or object to the use of cookies. Please note that deactivating cookies may result in limited or completely blocked functionalities of this recruitment website.

Rights of data subjects

If Personio SE & Co. KG as the controller processes personal data, you as the data subject have certain rights under Chapter III of the EU General Data Protection Regulation (GDPR), depending on the legal basis and the purpose of the processing, in particular the right of access (article 15 of the GDPR) and the rights to rectification (article 16 of the GDPR), erasure (article 17 of the GDPR), restriction of processing (article 18 of the GDPR), and data portability (article 20 of the GDPR), as well as the right to object (article 21 of the GDPR). If the personal data is processed with your consent, you have the right to withdraw this consent under article 7 III of the GDPR. To assert your rights as a data subject in relation to the data processed for the purpose of operating this recruitment website, please refer to Personio SE & Co. KG’s Data Protection Officer (see item B).

Concluding provisions

Personio reserves the right to adjust this data privacy statement at any point in time to ensure that it is in line with the current legal requirements at all times, or in order to accommodate changes in the services offered, for example when new services are introduced. In this case, the new data privacy statement applies to any later visit of this recruitment website or any later job application.