Applicants Privacy Policy

This Applicants Privacy Policy governs the processing of your personal data as part of your application for a job at a company of the Bosal group (hereinafter: Bosal Group) via the “Working at Bosal” website or any other websites of the Bosal Group (hereinafter: the “Websites”) or in any other way, and your subsequent communications with us via e-mail, telephone, fax and social media channels (such as LinkedIn) in relation to any job offers.
This Applicants Privacy Policy relates specifically and exclusively to the processing of personal data of applicants applying for a job at any Bosal Group company. For our general policy in relation to the use of our Websites and our communication with you in any other capacity than as a job applicant, please see our general Privacy Policy.
If you want information on how we process personal data via cookies and social plugins, please see our Cookie Policy.
By submitting your application via one of our Websites, you acknowledge that you have read this Applicants Privacy Policy carefully and that you agree with it without reservation.


1.    IN GENERAL

1.1    When you apply for a specific position at one of the companies of the Bosal Group or if you send a spontaneous application directly to a specific company of the Bosal Group, then that company of the Bosal Group to which the vacancy relates or to which you sent your application is responsible for the collection and processing of your personal data.
If you apply spontaneously via the “Working at Bosal” website, then the initial data controller of the processing of your personal data is Bosal Corporate Emission Control Systems, Dellestraat 20, 3560 Lummen, Belgium, with company number 0431.440.855. If Bosal Corporate Emission Control Systems subsequently shares your personal data with another company of the Bosal Group in view of possible employment at that company, then that company will be a data controller of its processing of your personal data.
1.2    The terms used in this Applicants Privacy Policy have to be interpreted in accordance with the Regulation (EU) 2016/679 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 (“GDPR”).
1.3    Any reference in this Applicants Privacy Policy to certain laws or regulations also includes any change, replacement or annulment of these laws or regulations, including any related executive decisions.
1.4    We reserve the right to modify this Applicants Privacy Policy from time to time at our own discretion. Such modification will be communicated via the Websites.

2.    TYPES OF PERSONAL DATA WE PROCESS

2.1    When you apply for a job at Bosal Group, we collect the following personal data about you:

  • Your contact details and basic identity information that you provide us with, such as your photo, name, postal address, e-mail address, phone number, date and place of birth, nationality, etc.;
  • Resume-related information, such as former and current employer, work experience, education, skills, references and any other personal data you choose to include in your resume;
  • Any other personal data you choose to provide us with as part of your application;
  • Publicly available information about you on social media channels (such as LinkedIn);

2.2    In principle we obtain the personal data mentioned above directly from you. However, if you choose to apply via an external recruitment company, we receive your personal data via the external recruitment company. It is that company’s responsibility to relay the information contained in this Applicants Privacy Policy to you.
Please refer to the privacy policy of your external recruitment company to ascertain which personal data it processes about you, what the conditions for that processing are and how you can exercise your rights vis-à-vis that company. We will not send any of the personal data you provide via the Websites or in any other way to external recruitment companies unless you explicitly consent to it.
2.3    If we offer you a position, our internal recruitment department may also keep personal data pertaining to your application in your personnel file.
2.4    Our application process is not meant to involve the processing of personal data which can be construed as special categories of data (sensitive data). Sensitive data are personal data that pertain to your race or ethnicity, political affiliations, religious convictions, membership of a trade union or your health or sex life. If such information becomes relevant as part of the application process, you will be specifically asked for it and be given the opportunity to consent to the processing of these sensitive data separately.
If you nevertheless choose to upload or otherwise provide sensitive data about yourself, your uploading or provision of these will constitute your freely given, specific, informed, explicit and unambiguous written consent to our processing of these data in line with this Applicants Privacy Policy.

3.    PURPOSES FOR WHICH WE USE YOUR PERSONAL DATA

3.1    We process your personal data to allow you to apply for employment with us and to allow us to process, assess and decide on your application.
3.2    We also process your personal data to provide you with relevant and personalised information regarding future opportunities for employment at Bosal Group.
3.3    We process your personal data to be able to defend ourselves in case of a dispute regarding your application (such as related to our refusal of your application).
3.4    If an application process for a particular position leads to a successful outcome, the personal data you provided will be used for human resources purposes during your employment with us.
3.5    We process your personal data to perform statistical analyses to improve our application and recruitment process and our service offering in general. Such processing will take place in a pseudonymised manner where possible.
3.6    We process your personal data to comply with our legal obligations or to comply with any reasonable request from law enforcement agents or representatives, judicial authorities, governmental agencies or bodies, including supervisory authorities.
3.7    We process your personal data to inform any third party and its advisors in the context of a possible merger with, acquisition by/of, demerger by, or other share or asset purchase deal with that third party, also if that third party is located outside the European Union.
3.8    We also process your personal data for the preservation of our legitimate interests  or those of our affiliates, partners or a third party if your application-related use of the Websites or your application in general can be considered: (a) a violation of any applicable terms of use of the Websites or the intellectual property rights or any other right of a third party, (b) a danger or threat to the security or integrity of our Websites, social media channels or other communication channels or any of our or our affiliates’ subcontractors’ underlying IT systems due to viruses, Trojan horses, spyware, malware or any other form of malicious code, or (c) in any way hateful, obscene, discriminating, racist, slanderous, spiteful, hurtful or in some other way inappropriate or illegal.

4.    LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

4.1    We process your personal data for the purpose outlined in Article 3.1 because that processing is necessary in order to take steps at your request prior to entering into a contract.
4.2    The processing of your personal data for the purpose outlined in Article 3.2 is based on your consent.
4.3    The processing of your personal data for the purpose outlined in Article 3.3 is necessary for the protection of our legitimate interest of being able to defend ourselves in case of a dispute.
4.4    The processing of your personal data for the purpose outlined in Article 3.4 is necessary for the protection of our legitimate interest to save time and resources in order to run a more efficient business by re-using already available information where permitted.
4.5    The processing of your personal data for the purpose outlined in Article 3.5 is necessary for the protection of our legitimate interest to continuously improve our Websites, social media channels, products and services to ensure that you have the best experience possible.
4.6    The processing of your personal data for the purpose outlined in Article 3.6 is necessary to allow us to comply with our legal obligations.
4.7    The processing of your personal data for the purpose outlined in Article 3.7 is necessary for the protection of our legitimate interest of being able to explore or conduct normal corporate or merger and acquisition transactions.
4.8    The processing of your personal data for the purpose outlined in Article 3.8 is necessary for the protection of our legitimate interest to keep our Websites, social media channels, products and services safe from misuse and illegal activity.

5.    TO WHOM WE SEND YOUR DATA

5.1    We rely on third-party processors to provide you our Websites and social media channels, including the job application parts thereof, and to process your personal data on our behalf. These third-party processors are only allowed to process your personal data on our behalf and upon our explicit written instruction.
5.2    We share your personal data with other entities within the Bosal Group. We will ensure that all companies of the Bosal Group will take due care that all processing of your personal data is in line with what is set out in this Applicants Privacy Policy.
5.3    Your personal data may be shared upon our own initiative with the police or the judicial authorities as evidence or if there are justified suspicions of an unlawful act or crime committed by you in the context of your application.

6.    LOCATION AND TRANSFER

6.1    We process your personal data first and foremost within the European Economic Area (EEA). However, in order to process your personal data for the purposes outlined in Article 3 of this Applicants Privacy Policy, we may also transfer your personal data to other companies of the Bosal Group or to third parties who process on our behalf outside the EEA. Should such transfer take place, Bosal Group will ensure that there are safeguards in place to ensure the safety and integrity of your data as well as all rights with respect to your personal data you might enjoy under applicable mandatory law.
6.2    Each company of the Bosal Group or third party outside the EEA that processes your personal data will be bound to observe adequate safeguards in order to ensure the safety and integrity of your data. Such safeguards will be the consequence of:

  • The country of the recipient having legislation in place which is considered equivalent to the protection offered within the EEA; or
  • A contractual arrangement between us and that entity. All companies of the Bosal Group are parties to a contractual agreement based on the European Commission’s Standard Contractual Clauses (controller-to-controller) (Commission Decision C(2004)5721) or any update thereof.
     

7.    QUALITY ASSURANCES

7.1    Your personal data are only processed for as long as needed to achieve the purposes listed under Article 3 above or, regarding the purposes in Article 3.2, up until such time where you withdraw your consent for processing them. We will de-identify your personal data when they are no longer necessary for the purposes outlined in Article 3 above, unless there is:

  • An overriding interest of Bosal Group or any other third party in keeping your personal data identifiable;
  • A legal or regulatory obligation or a judicial or administrative order that prevents us from de-identifying them.

7.2    You understand that an essential aspect of assessing your application for employment with Bosal Group or sending you relevant and personalised information regarding future opportunities for employment with Bosal Group involves assessments of your professional and relevant personal characteristics. This means that we build and use a profile of you based on these characteristics. Please note, however, that these assessments are never fully automated and require human intervention.
7.3    We will take appropriate technical and organisational measures to keep your personal data safe from unauthorised access or theft as well as accidental loss, tampering or destruction. Access by our personnel or our third-party processors will only occur on a need-to-know basis and will be subject to confidentiality obligations. You acknowledge, however, that safety and security are best-efforts obligations which can never be guaranteed.

8.    YOUR RIGHTS

8.1    You have the right to request access to all personal data pertaining to you that we process. We reserve the right to charge an administrative fee for multiple subsequent requests for access that are clearly submitted for the purpose of causing nuisance or harm to us. Each request has to specify for which processing activity you wish to exercise your right of access and which data categories you wish to gain access to.
8.2    You have the right to request that any personal data pertaining to you that are inaccurate, be corrected free of charge. If you submit a request for correction, such request has to be accompanied by proof of the flawed nature of the data for which correction is asked.
8.3    You have the right to withdraw your earlier given consent for the processing of your personal data.
8.4    You have the right to request that personal data pertaining to you be deleted if these data are no longer required in the light of the purposes outlined in Article 3 above or if you withdraw your consent for processing the data. However, we will evaluate a request for deletion against:

  • Overriding interests of Bosal Group or any other third party;
  • Any legal or regulatory obligations or administrative or judicial orders which may contradict such deletion.

Instead of deletion you can also ask that we limit the processing of your personal data if (a) you contest the accuracy of the data, (b) the processing is illegitimate, or (c) the data are no longer needed for the purposes mentioned in Article 3.
8.5    You have the right to object to the processing of personal data, unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims. However, if the intended processing qualifies as direct marketing, you have the right to object to such processing free of charge and without justification.
8.6    You have the right to receive from us in a structured, commonly used and machine-readable format all personal data you have provided to us, where the processing of your personal data is based on your consent or on the necessity to perform a contract or enter into a contract at your request.
8.7    If you wish to submit a request to exercise one or more of the rights mentioned above, you can send a letter or e-mail to the Bosal Group company to which the vacancy relates or to which you sent your application. If you applied spontaneously via the “Working at Bosal” website, you can send a letter or e-mail to Bosal Emission Control Systems. In any case, you can also send an e-mail to info@bosal.com.

A request to exercise a right will not be construed as consent with the processing of your personal data beyond what is required for handling your request. Any request has to clearly state which right you wish to exercise and the reasons for it if such is required. It should also be dated and signed, and accompanied by a digitally scanned copy of your valid identity card proving your identity. Regardless of the manner you choose to contact us with your request, the circumstances may require that we need to take additional verification and authentication measures in order to protect your personal data.

We will promptly inform you of having received your request. If your request proves valid, we will honour it as soon as reasonably possible and at the latest thirty (30) days after having received your request.
If you have any complaint regarding our processing of your personal data, please feel free to contact the Bosal Group via the e-mail address mentioned above. You also have the right to file a complaint with the competent supervisory authority.