PRIVACY POLICY FOR THE RECRUITMENT PROCESSES
This Privacy Policy regulates the processing of personal data of the job applicants that use the Careers Portal (hereinafter “Careers Portal”) of Naturgy Group, and are involved in the process of admission, assessment and management of candidatures to job positions as well as internships (hereinafter the ”Recruitment Process”) posted by Naturgy Group.
This Policy is approved in compliance with the legal requirements set forth in:
- REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL, of 27 April 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation)
- Organic Law 3/2018, of 5 December, for the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD).
NATURGY is committed to protecting the privacy of your personal data, which will be processed as described in this Policy and under to the required measures to ensure their confidentiality, integrity and availability. To that end, the risk arising from the data processing have been analyzed and appropriate controls have been implemented, both technical and organizational.
NATURGY may change the information given in this Policy to meet new legal requirements or reflect changes in the way of processing data. You can check this Policy at any time at [X]. In any case, your personal data will not be processed for a different purpose or in a manner that is incompatible with the purposes described in this Policy.
- DATA CONTROLLER
Naturgy Energy Group, S.A, CIF: A08015497, with address at Avenida San Luis nº 77, 28033, Madrid (hereinafter the “Company”), is the data controller of your personal data gathered through the Careers Portal.
To ensure the proper management in the processing of your personal data, Naturgy Group, to which the Company belongs, has appointed a Data Protection Officer, whose contact details are:
- Postal address: Plaça del Gas, 1 - C.P. 08003, Barcelona
- E-mail address: dpd-dpo@naturgy.com
- PURPOSES OF THE PROCESSING
The personal data collected from the applicants through the Careers Portal are processed to manage their applications in any Recruitment Process posted by Naturgy Group.
This consists of:
- The inclusion of the applicant in a data base of applicants for job positions or internships posted by Naturgy Group.
- The analysis of the professional profiles of the applicants and their accommodation to the positions posted.
- Inform the applicants of the positions offered that may fit to their profile.
- In general, manage the relationship with the applicant during the Recruitment Process.
- For those who succeed, make the required arrangements to enter into their employment contract or inscription in the relevant internship program.
The personal data will never be processed for a different purpose or in a manner that is incompatible with the purpose described above.
Applicants are informed that, if they do not provide the required personal data, we will not be able to manage their participation in the Recruitment Process.
The applicants shall not be subject to a decision based solely on automated processing, including profiling.
III. LEGAL BASIS FOR THE PROCESSING
The processing of personal data for the purposes abovementioned is based on the consent given by the applicant while filling and sending the form of inscription in the Recruitment Process.
Applicant’s submission of his/her personal data means accepting such processing.
The Applicant can withdraw the consent given for such purposes whenever he/she deems it fit, in which case he/she will be deemed to have given up the Recruitment Process. To withdraw the consent, the applicant must prove his/her identity by sending a copy of his/her National identity Card (DNI), NIE, Passport or alike, and notify his/her will through any of the following channels:
- Postal address: Plaça del Gas, 1 - C.P. 08003, Barcelona, marking as reference “Protección de Datos- Procesos de Selección’’.
- E-mail address: dpd-dpo@naturgy.com, marking as reference “Protección de Datos- Procesos de Selección’’.
The disclosure of your personal data to other companies within Naturgy Group described in Section IV of this Privacy Policy shall be based on the legitimate interest since the Careers Portal is a tool used for the Recruitment Processes of all Naturgy Group, and therefore it is necessary to disclose some personal data of certain applicants to those companies within Naturgy Group that are posting the relevant job position or internship.
- RECIPIENTS OF PERSONAL DATA
The personal data processed in the Recruitment Process may be disclosed to the companies within Naturgy Group that have posted the relevant job position or internship, always with the purpose described in Section II of this Privacy Policy, that is to say, manage the applications in the Recruitment Process.
The Company can engage processors to assist him to manage the applications and maintain the Careers Portal of Naturgy Group. Processing by a processor shall be governed by a contract to guarantee that personal data processing will meet all legal requirements.
On the other hand, your personal data may be disclosed to the authorities by the Company when legally compelled to do so.
The Company has no intention to transfer personal data of the applicants to any third country or international organization. Notwithstanding the foregoing, should for the purposes described personal data need to be sent to any country out of the European Economic Area (“EEA”), such transfers shall be made under a Privacy Shield scheme, in case the transfer is made to US companies, or using standard data protection clauses adopted by the Commission when the transfer is made to other companies outside the EEA.
- PERIOD FOR WHICH PERSONAL DATA WILL BE STORED
NATURGY will store applicant’s personal data for 1 year. We understand that such information becomes obsolete when such period elapses. Then, the personal data will be blocked unless the relevant applicant is involved in an active Recruitment Process, in which case his/her personal data will be stored until the Recruitment Process ends.
Once the abovementioned term has elapsed, the personal data may be kept blocked until the relevant statute of limitations expires. Then, the personal data will be deleted.
- RIGHTS REGARDING THE PROCESSING OF PERSONAL DATA
You have the following rights:
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RIGHT
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CONTENT
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Access
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You can ask which of your personal data are being processed by the Company
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Rectification
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You can ask for your personal data to be rectified when they are nor accurate or complete.
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Erasure
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You can ask the erasure of your personal data.
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Object
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You can object the processing of your personal data when such processing is based on legitimate interest (except in case of compelling legitimate grounds for the processing, or for the establishment, exercise or defence of legal claims).
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Restriction of processing
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You can ask the restriction of processing of your personal data:
- While the accuracy of the personal data is verified in case it has been contested.
- When the processing is unlawful and you oppose the erasure of the personal data and requests the restriction of their use instead.
- When the Company no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims.
- When you have objected to processing based on legitimate interest, pending the verification whether the legitimate grounds of the Company override yours.
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Portability
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You can ask to receive, in a machine-readable format, the personal data you provided to us, and you have the right to transmit those data to another controller.
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You can exercise the abovementioned rights through any of the following channels:
- E-mail address: dpd-dpo@naturgy.com
- Postal address: Plaça del Gas, 1 - C.P. 08003, Barcelona. Att. DELEGADO DE PROTECCIÓN DE DATOS.
In your notice, we recommend you to clearly state “Solicitud Protección de Datos – Procesos de Selección”. Since these are individual rights, the Company must check that they are exercised by the data subject or a person duly authorized by the data subject. For this reason, we ask you to prove your identity by sending a copy of both sides of your National identity Card (DNI), NIE, Passport or alike. Should the rights be exercised by a person duly authorized by the data subject, a copy of the authorisation and the ID document of the authorised person have to be submitted additionally.
The Company shall answer within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests.
Should you think your personal data have not been properly processed, you can contact the Data Protection Officer through the aforesaid channels.
In any case, should you think the processing of your personal data has not been made according to the applicable regulations regarding personal data protection, you have the right to lodge a complaint before the relevant supervisory authority (eg. Spanish Data Protection Agency - www.aepd.es)
December 2019
