Information Memorandum for Job Applicatns | KPMG | CZ

Information Memorandum for Job Applicants on the processing of personal data

Information Memorandum for Job Applicants

Last updated on the 24th of May, 2018

Dear Applicant,

Thank you for your interest in working at our companies:

KPMG Česká republika, s.r.o., Id. No.: 00553115, with its registered office at Pobřežní 648/1a, 186 00 Prague 8 – Karlín, Czech Republic registered in the Commercial Register kept by the Municipal Court in Prague, Section C, File 326;

KPMG Česká republika Audit, s.r.o., Id. No.: 49619187, with its registered office at Pobřežní 648/1a, 186 00 Prague 8 – Karlín, Czech Republic, registered in the Commercial Register kept by the Municipal Court in Prague, Section C, File 24185;

KPMG Legal, s.r.o., Id. No.: 24733598, with its registered office at Pobřežní 648/1a, 186 00 Prague 8 – Karlín, Czech Republic, registered in the Commercial Register kept by the Municipal Court in Prague, Section C, File 169791;

KPMG Advisory, s.r.o., Id. No.: 27570193, with its registered office at Pobřežní 648/1a, 186 00 Prague 8 – Karlín, Czech Republic, registered in the Commercial Register kept by the Municipal Court in Prague, Section C, File 113192 (hereinafter “we”);


In this information memorandum, you will find information about how we process your personal data in relation to the selection procedure, in particular about categories of the processed personal data, the scope and purpose of the processing, the resources from which your personal data are collected and the persons to whom your personal data are transferred. In this document, you will also find information about your rights in the area of personal data processing. If you succeed in the selection procedure, we will also provide you with an information memorandum on the processing of personal data for employees along with the offer to enter into an employment contract.

We process personal data in compliance with the legal regulations governing personal data protection, in particular with 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 (the General Data Protection Regulation) (hereinafter the “GDPR”), and in compliance with our internal regulations and policies.

We are fully aware of the importance of protection of the job applicants’ personal data and privacy. Therefore, when processing personal data, we always proceed in order to:


a) Process up-to-date and accurate data only in the scope necessary for the fulfilment of the purpose of processing,
b) only process personal data for the period necessary for the fulfilment of the purpose of processing,
c) secure your personal data to the maximum extent possible, in particular by taking appropriate measures that will protect your personal data against any unauthorised access,
d) preserve your privacy to the largest extent possible, and therefore we always properly consider whether any particular processing is necessary and whether it does not unreasonably interfere with your rights and freedoms.

You will receive more information about the processing of personal data in the selection procedure from the HR Department. You can contact us:


By e-mail: kpmg@kpmg.cz
By telephone: +420 222 123 111
By regular mail: Pobřežní 648/1a, 186 00 Prague 8 – Karlín, Czech Republic

1. Categories of personal data

We process the following categories of your personal data:

  • Identification and address data: academic degree, first name, surname, address, date of birth, nationality, and other relevant personal data,
  • contact data: e-mail, telephone number, delivery address and other relevant personal data,
  • data related to the job offer: job title and qualification requirements for the given job,
  • professional data: previous employers, work experience and positions, highest education attained, certificates, diplomas, personal characteristics, other data included in your CV and gained during your job interview,
  • image: all personal data identifiable from a photograph (if included in your CV),
  • camera recordings from cameras located on the premises of our sites (if visited by the job applicant during the selection procedure),
  • health data: information about disability and other relevant personal data.
2. Categories of personal data
 
We collect your personal data particularly from you for the purpose of selecting a suitable job applicant and preparing an employment contract or an agreement to work outside the scope of regular employment. In such cases we always inform you whether providing certain personal data is a legal or contractual requirement or a requirement that must be specified in the contract, and whether you are obliged to provide the personal data, as well as about potential consequences of your failure to provide the personal data (you are usually not obliged to provide the data but if you fail to do so, the employment contract or agreement cannot be executed properly).
In some cases we obtain personal data from third parties (e.g. our employees, your previous employers or an HR agency), or from publicly available sources, in particular from:
  • The Commercial Register,
  • the Trade Register,
  • the jobs.cz portal,
  • professional/social networks like Facebook or LinkedIn,
  • search engines like Google.
3. For which purposes and on what grounds do we process your personal data?
 
Please note that we only process your personal data in the scope necessary for the given purpose and for the period necessary for the fulfilment of the given purpose, i.e. usually for the duration of the selection procedure unless you give us consent to further processing.
 
We process your personal data:

a) For the purposes of selecting a suitable applicant and making an employment contract or an agreement to work outside the scope of regular employment (contract negotiations),
b) for the purposes of our legitimate interests.
 
Ad a) Contract negotiations
 
We process your personal data in order to assess whether your profile fits the job you are applying for, to inform you about our employment terms and to be in touch with you during the selection procedure. In other words, we process your personal data for the purposes of negotiating and potentially entering into an employment contract, an agreement to work or an agreement to complete a job. The provision of personal data is therefore a contractual requirement. The following categories of personal data are processed for these purposes: identification and address data, contact data, data related to the job offer, professional data, image, and health data.
 
We process your personal data for the above purpose for the duration of the selection procedure for the given job. If we enter into an employment contract or an agreement to work outside the scope of regular employment with you, we process your personal data for the duration of the given contract or agreement in the scope and under the terms specified in the information memorandum for employees.
 
Ad b) Our legitimate interests
 
Using your personal data is often not necessary for the contract negotiations as such. Nevertheless, we process such personal data e.g. for security reasons or to protect our other legitimate interests. On the basis of these legitimate interests, we only process your personal data under the assumption that your interests and fundamental rights do not override our legitimate interests. Before we start processing, we always thoroughly assess and compare your interests with our interests. If you do not agree with the processing, you are entitled to object and we will perform a new assessment or we cease to process your personal data (if applicable). The following categories of personal data are processed for these purposes: identification and address data, contact data, camera recordings and data on records in the Criminal Register.
 
Our legitimate interests are the following:
  • Protection of property, lives and health of persons entering our buildings or sites. For these purposes, camera systems have been installed within the premises of our sites and records on the monitoring of visits are kept. You are always informed of the location of the cameras by a pictogram sign at each entrance to the monitored premises. The camera recordings are kept for a maximum period of 3 weeks. If necessary, the camera recordings may be provided to the law enforcement authorities. Apart from that purpose, the camera recordings are not processed or otherwise utilised in any manner. We keep the records of visits for the period of 2 years.
  • Screening of information and documents provided by you, defence of our legal claims. We keep the said personal data no longer than for the duration of the respective limitation or prescription time limits and subsequently for a maximum period of one year so that we have time to become aware of any possible initiation of a dispute by a job applicant. If court or any other proceedings are initiated, we process the personal data further for the duration of these proceedings.

4. To whom do we disclose your personal data?

We process your personal data as a personal data controller. This means that we determine the purposes for which we collect your personal data and select means for the processing of the same. If your job interview has been intermediated by the Employment Office of the Czech Republic, we send information back to it about whether a contract has been made with you or not. If your job interview has been intermediated by an HR agency, it is usually this HR agency that is the processor of your personal data. In such case, we execute a contract with the HR agency on the processing of personal data in order to guarantee protection of your personal data to the maximum extent possible.

We also use other external processors’ services for the processing of your personal data. We use the following categories of processors: website operators; operators of mailing instruments. We have executed contracts on the processing of personal data with all these processors in order to guarantee protection of your personal data to the maximum extent possible.

In rare cases, we might be obliged to provide your personal data to third parties for the performance of our legal duties. These cases include in particular provision of personal data to the law enforcement authorities in criminal, administrative violation or administrative proceedings if we are asked to cooperate (e.g. to provide recordings from our camera system).

5. How do we process your personal data?

We are fully aware of the importance of protection of the job applicants’ personal data and privacy. When processing personal data, we always proceed so that your personal data are safeguarded to the maximum possible extent and so that your personal data cannot be misused.

Your personal data may be processed both manually and automatically. Automated processing is performed in our information systems or in information systems of our processors. Your personal data are processed particularly by our authorised employees and by the processors specified in the previous section. We have taken these measures so that only the employees and the processors who are involved in the processing of your personal data have access to your personal data and so that those employees and processors maintain confidentiality about any facts, information and (personal or any other) data of which they have learned during the performance of their work.

We execute written contracts regulating the processing of personal data, which contain the same guarantees in respect of the processing of personal data that are applied within our firm, with all our processors of your personal data.

We would also like to inform you that we do not make any decisions based solely on automated processing, including profiling.

6. Which rights do you have in the area of personal data protection?

We process your personal data in an entirely transparent manner. At all times during the processing of your personal data, you may exercise the following rights:

a) Right of access to your personal data and right to obtain a copy of your personal data processed by us.
b) Right to rectification and completion of your personal data if you find out that we process any incorrect or inaccurate personal data concerning you.
c) Right to erasure of your personal data (‘right to be forgotten’). Upon your request, we can erase your personal data under certain conditions stipulated by legal regulations. However, please note that your personal data cannot be erased if the processing of your personal data is necessary.
d) Right to restriction of processing of your personal data. Upon your request, we can restrict our processing of your personal data under certain conditions set out by legal regulations. If you exercise your right to the restriction of processing and if any such condition is met, we will make a record in our systems that the particular data are subject to restriction, and we will usually not continue to actively process such data. If the reasons for the restriction of processing cease to exist, we will cancel the restriction of processing of your personal data. Nevertheless, we will inform you of this in advance.
e) Right to portability. If we process your personal data on the basis of your consent or for the purposes of the performance of a contract and if, at the same time, the processing is automated, you have a right to obtain such personal data of yours in a structured, commonly used and machine-readable format and to transfer the data to another controller.
f) If you believe that any of the obligations stipulated by the legal regulations governing the protection of personal data, in particular by the GDPR, have been breached, you have the right to lodge a complaint with the Office for Personal Data Protection or with any other authority of a Member State of the European Union that is authorised to supervise the compliance with the obligations laid down by the GDPR.

You also have the right to object to the processing of your personal data, if your personal data are processed for the purpose of the controller’s or a third party’s legitimate interests. If you object, we will not process your personal data until we prove serious grounds for the processing that will prevail over your interests or your rights and freedoms, or for the determination, filing or defence of legal claims.

If you exercise any of the rights specified above, we will inform you about the manner of settlement of your request in writing without undue delay.

7. Updates

We regularly check this information memorandum and may modify it from time to time (in particular, in order to comply with the legal regulations and procedures regarding the personal data protection). Updated versions will always be available on our website.

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