Information Clause in Recruitment Processes
I. Data Controller
The controller of your personal data is one of the companies listed below:
- British American Tobacco Polska Trading sp. z o.o., with its registered office in Warsaw,
- CHIC sp. z o.o., with its registered office in Ostrzeszów,
- eSmoking Institute sp. z o.o., with its registered office in Poznań,
- BAT DBS Poland sp. z o.o., with its registered office in Warsaw,
- eSmoking Liquids sp. z o.o., with its registered office in Ostrzeszów,
- British-American Tobacco Polska S.A., with its registered office in Augustów,
hereinafter referred to as the BAT Group Companies.
You may contact our Data Protection Officer directly by email at: iod@bat.com.
II. Purposes and Legal Grounds for Data Processing
We process your personal data within the scope of recruitment processes conducted by us. Below we indicate the legal bases and purposes of the processing:
-
If you have applied for the position indicated in the job advertisement, the following applies:
- Article 6(1)(b) of the GDPR, i.e. processing is necessary for taking steps at the request of the data subject prior to entering into a contract – with regard to data provided in the recruitment process specified in Article 22¹ § 1 of the Polish Labour Code, and on the basis of your consent, i.e. Article 6(1)(a) of the GDPR, with regard to data exceeding the scope indicated in Article 22¹ § 1 of the Polish Labour Code,
- Article 6(1)(f) of the GDPR, i.e. for the purposes of the legitimate interests pursued by the controller – with regard to data generated in the recruitment process;
-
If you have applied for the position indicated in the job advertisement and you conduct a business activity, the following applies:
- Article 6(1)(b) of the GDPR, i.e. taking steps at the request of the data subject,
- Article 6(1)(f) of the GDPR, i.e. for the purposes of the legitimate interests pursued by the controller – with regard to data generated in the recruitment process;
-
If you have given your consent to participate in future recruitment processes, the following applies:
- Article 6(1)(a) of the GDPR – consent of the data subject;
- Your data may also be processed for the purposes of internal audits to verify whether the recruitment process was conducted properly in accordance with applicable law and our internal procedures, as well as for the purposes of establishing, pursuing or defending against claims, based on Article 6(1)(f) of the GDPR, i.e. for the purposes of the legitimate interests pursued by the controller.
III. Joint Controllers
The joint controllers of personal data within the recruitment process are:
- British American Tobacco Polska Trading sp. z o.o., with its registered office in Warsaw,
- CHIC sp. z o.o., with its registered office in Ostrzeszów,
- eSmoking Institute sp. z o.o., with its registered office in Poznań,
- BAT DBS Poland sp. z o.o., with its registered office in Warsaw,
- eSmoking Liquids sp. z o.o., with its registered office in Ostrzeszów,
- British-American Tobacco Polska S.A., with its registered office in Augustów.
The common purpose of the processing is to select the best candidates for employment, to place and store recruitment profiles in the candidate database so that each of the companies may consider your candidacy in their recruitment processes.
IV. Sources of Data
Your personal data is obtained:
- directly from you;
- from other sources indicated by you, e.g. a previous employer or an online service such as LinkedIn;
- generated during the recruitment process, e.g. recruiters’ opinions and competence assessments.
V. Principles of Data Collection
During recruitment processes, in order to create your recruitment profile, we may collect the following categories of your personal data:
- contact details: first name and surname, address, e-mail address, telephone number;
- information provided in the application: your professional career and employment history, date of birth, image, education, skills, foreign language proficiency and any other information included in your application;
- other data: any information that you choose to share with us during the recruitment processes and any data generated in connection with your application.
VI. Data Retention Period
Your personal data will be processed for the duration of the recruitment process and thereafter stored for the period during which potential claims by either party may be asserted, i.e. for 6 months from the date of submission of the application.
Likewise, if you withdraw from the recruitment process during its course, your personal data will be stored for the period during which potential claims by either party may be asserted, i.e. for 6 months from the date of submission of the application.
If you consent to the processing of your personal data for the purposes of future recruitment processes, your data will be processed for this purpose until the consent is withdrawn, however no longer than for 24 months from the date of submission of the application and granting such consent.
VII. Disclosure of Personal Data
Your personal data may be disclosed to the following categories of recipients:
- trusted subcontractors, in particular entities providing and servicing selected IT systems and solutions, including hosting, development and maintenance of IT systems and websites; providers of recruitment management systems and other IT systems supporting the recruitment process,
- entities providing postal and courier services, debt collection entities and law firms.
As a rule, personal data will not be transferred outside the European Economic Area (EEA) nor made available to international organisations.
However, if the controller uses service providers outside the EEA that have not been recognised by the European Commission as ensuring an adequate level of personal data protection, the transfer of personal data to such entities is based on standard data protection clauses adopted by the European Commission, thereby ensuring appropriate safeguards for the protection of privacy and the rights and freedoms of data subjects.
VIII. Your Rights
In connection with the processing of your personal data, you have the right to:
- request access to your personal data,
- request rectification of your personal data,
- request erasure or restriction of the processing of your personal data,
- object to the processing of your data,
- lodge a complaint with the supervisory authority, which in Poland is the President of the Personal Data Protection Office.
You may exercise your rights by submitting an appropriate request either by traditional mail to the registered office address of the Controller or by e-mail to: iod@bat.com.
IX. Additional Information
Providing personal data is voluntary, but necessary to obtain a response to your application.
Personal data is not subject to automated decision-making, including profiling.