Principles of personal data protection - general introduction
TAJCO respects privacy of all data subjects we are in contact with and regardless of the fact whether we process the data or they are processed by any other parties. It is important for everybody to comprehend which personal data about you we process and also why we do that and what your rights are. This is the reason we appeal to you for reading the following principles of personal data protection. The principles provide you with more information about the processing of your data by TAJCO.
We can process your personal data in various ways and in various situations depending on the fact if you are a customer, supplier, job applicant or an employee. We can also process personal data about visitors of our website/sites depending on how you decide to communicate with us. Regardless of the situation, we promise never to sell nor commercialize your personal data and we will never use them contrary to applicable regulations for personal data protection.
TAJCO respects your privacy - it is important for you to comprehend which personal data about you we process and also why we do that and what your rights are. And so, we appeal to you for reading these principles of personal data protection. They provide you with more information about the processing of your personal data by TAJCO.
Privacy Statement Client, Vendors and Others
The following principles apply to the processing of your personal data as a representative of our present or future client, supplier or a business partner.
Why Do We Have Access to Your Data? Why Do We Process Them?
It is necessary to process your personal data to be able to conclude and perform the contract with you or with the company you represent. We can also process personal data about visitors of our websites and real offices, depending on how you have decided to communicate with us.
We process your personal data only if we have the legal basis to do it. It means that the processing has to be necessary for the performance of the contract in which either you or the company you represent is a party. Or it has to be necessary to enable, on request, the performance of some steps even before the contract is concluded. In accordance with our legitimate interest we can also use your data to provide you with information about our services, prospects, analyses, events and trainings which could be in your best interest.
We can also do it to enable the performance of some needed or required tasks following the business relationship you represent.
We have the legal obligation to provide your personal data for an inspection by legitimate institutions and for a prevention, monitoring and giving evidence of any fraud as well as in the struggle against money laundering and any other criminal act.
Your personal data will be safely stored in accordance with legal regulations on data protection.
What Kind of Personal Data About Me Do You Process and Why?
We store information required for managing a contractual or business relationship. We need your name, the name of your position and some contact data like your address, telephone number and e-mail address to be able to communicate with you and ensure a safe and true identification.
We need to verify some other personal data such as your birth certificate number and the date of birth, identity card number or passport number or some similar identification data as well as some related information required by specific regulations. We have to do it to be able to perform our legal obligations relating to, for instance, the fight against money laundering.
We also use CCTV cameras in various places to ensure the safety of our employees and the protection of your personal data. And so, we ask you to provide us with, for instance, your name and telephone number in order to ensure your access to our places where some information characterised as also personal data are processed. Unless we have the legal obligation to store the data, we will erase them after 15 days.
Unless you arrange with us otherwise or unless it is necessary to establish, apply or defend legal claims, we will not include special categories of personal data (often called “sensitive personal data” such as data detecting racial or ethnic origin, political opinions, religious or philosophical belief, membership in trade unions as well as data relating to health or sexual life).
Will You Share My Personal Data with Other Parties?
We can share your personal data with our suppliers who arrange and/or ensure a part of our services, for instance, copy and post services (for the possibility of sending our offers) or with lawyers. We can also share your personal data with our clients if you represent a supplier who is included in services which we provide them and also legitimate institutions. The list of data processors is in our websites.
Our employees will also have access to your personal data. In that case the access will be enabled only if it is necessary for described purposes and only if the person is bound by confidentiality.
Will My Personal Data Be a Subject of Cross-Border Flow?
It is possible that your personal data will be transferred also to another country outside EU or EEA.
How Long Will You Store My Personal Data?
We will store your personal data for as long as it will be necessary for the purpose of the processing depending on specific regulations and the purpose for which they were obtained, if we have legitimate interest to store them, for instance, until the termination of the contractual relationship and/or until the expiration of period of limitation within which you should be able to defend yourselves against legal claims. We are legally obliged to store your personal data for a fixed period to prevent and uncover deceptions and to uncover and prove the fight against money laundering as well as for financial audits.
Regarding our data backup, your data will be deleted also from our storage sites, but only if and when the backup is obtained to data recovery by our rules of retention, BCM and DRP. If the backup is obtained to erasure according to our backup rules, your data will be completely deleted.
Will I Be The Subject of An Automated Decision-Making?
Your personal data will not be used in automated decision-making.
What Rights Do I Have?
It is important for you to understand that those are your personal data we process and that we want you to be aware of the fact. Even if we do not need your consent to process your personal data, you have a lot of rights in connection with the processing of them.
Your Rights and What Does It Mean?
Right to access
You can require to be informed how we process your personal data including the information about:
- the reason why we process your personal data.
- what categories of personal data we process.
- with whom we share your personal data.
- how long we store your personal data or what criteria we exercise to determine the time limit.
- what rights you have.
- from where we obtain your personal data (if we have not obtained them from you).
- if processing includes automated decision-making (so called profiling).
- if your personal data have been transferred to a country outside EEA, how we ensure your personal data protection.
All the information mentioned above is available in these Principles of personal data protection.
You can also ask for a copy of your personal data which we process. However, additional copies will be chargeable.
Right to remedy
It is important for us to have correct information about you and we request you to inform us if any of your personal data is incorrect, for instance, if you have changed your name or if you have moved.
Right to be forgotten
If we process your personal data in an illegal way, for instance, if we process them longer than it is necessary or if we do it groundlessly, you can ask us for their erasure.
Right to restriction
From the moment you have asked for remedy of your personal data, or if you have objected processing and until we can look into the problem or confirm the accuracy of your personal data (or change them according to your instructions), you are entitled to restricted processing. It means that we can process your personal data only in accordance with your consent (with the exception of their storage), if it is necessary in connection with legal claims to the protection of somebody else‘s rights or if there exists a significant public interest in processing.
You can also require restriction of the processing of your personal data if the processing is illegal, but you do not want us to erase your personal data.
Right to object
If you suppose that we do not have the right to process your personal data, you can object our processing. In such cases we can continue to process them only if we are able to prove persuasive legitimate reasons which prevail your interests, rights and freedoms. But we can always process your personal data if it is necessary for determination, exercise and defence of legal claims.
Right to data portability
You can demand your personal data, which you have provided us for processing based on your consent or for the contract performance, to be provided in structured commonly used and computer-readable format. You also have the right to require portability of the information to another data controller.
Right to withdraw your consent
You have the right to withdraw your consent and subsequently we will stop our processing activities based on this legal ground.
We will also inform other parties we might have provided your data, about your request.
In case of any doubts you have the right to lodge a proposal for initiation of the procedure under Art. 77 of GDPR.
How Can I Lodge A Complaint Regarding the Use of My Data or How Can I Exercise My Rights?
If you want to lodge a complaint about the way how we process your personal data, also in relation to the aforesaid rights, you can address our Data Protection Officer and your complaints and requests will be inspected.
If you are not satisfied with our reply or if you suspect that we process your personal data unfairly or illegally, you can complain to the supervisory body which is the Data Protection Commission.
For further information about the Data Protection Commission and their procedures how to lodge a complaint visit website of the competent supervisory authority.
In case of any further questions considering the processing of your personal data, you can contact our Data Protection Officer
Privacy Statement Job Applicants
Since you have decided to apply for job in the company belonging to TAJCO Group, after submission of job application, resp. after starting of the selection process to fill the vacancy job as chosen by you, this Privacy Statement – Job Applicants (hereinafter only “Privacy Statement”) will apply to you and your personal data. TAJCO Group includes various companies and entities operating in many countries of the world.
For the purposes of this Privacy Statement, entity of TAJCO Group, to which you have submitted your job application and in which you are applying for the job will be responsible for the protection of your personal data (hereinafter only “data controller”).
This Privacy Statement explains, how we will use your personal data obtained directly from you or from third parties during the selection process to fill the concrete vacancy job.
If you are interested in obtaining more detailed information than stated in this Privacy Statement, please contact local data protection officer (see below).
We can update this Privacy Statement from time to time without any notice. Therefore, we kindly ask to regularly check its wording in our General Introduction section.. This version of the Privacy Statement was issued on 25th May 2018.
For the purposes of this Privacy Statement, the abbreviation "GDPR Regulation" means General Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data.
Types of Personal Data
- When you apply for a job, we will get the following information from you:
Contact information – e.g. your name, address, e-mail address, phone number, and the legal basis for the processing of such data is Art. 6 sec. (1) (a), (b) and (f) of the GDPR Regulation.
- Information from your CV – e.g. information about your previous work experience, education, skills, language skills and any other information that you decide to mention in your CV, and the legal basis for the processing of such data is Art. 6 sec. (1) (a) and (f) of the GDPR Regulation.
- Motivation letter – any information that you decide to mention in your motivation letter, and the legal basis for the processing of such data is Art. 6 sec. (1) (a) and (f) of the GDPR Regulation.
- Eligibility for work – information related to possible obligation to prove legal eligibility for performance of respective job, and the legal basis for the processing of such data is Art. 6 sec. (1) (b), (c) and (f) of the GDPR Regulation.
- Declaration of Integrity – depending on the nature of the job and the country in question, we may request you to provide us with declaration from relevant public authority confirming that you have not been convicted of any crime, which would disqualify you from the selection process of applicant for the respective job, and the legal basis for the processing of such data is Art. 6 sec. (1) (b), (c) and (f) of the GDPR Regulation.
- Video – based on your decision, it is possible that you will provide us with abovementioned information in form of video, and the legal basis for the processing of such data is Art. 6 sec. (1) (a) and (f) of the GDPR Regulation.
Additionally, depending on the position you are applying for, we may also obtain information from third parties as follows:
- Internal requests. If you are already employed in TAJCO Group and you apply for another internal position, we can use information from your personal file in order to supplement information that you provide to us in job application. Legal basis for the processing of such data is Art. 6 sec. (1) (b) and (f) of the GDPR Regulation.
- Assessment. We may ask you to undergo an assessment of your skills, personality or cognitive aptitude. Such assessments are usually performed using third-party software or a third-party company, who will share the results with us. Prior to undergoing such an assessment, we will provide you with further information relevant to your specific situation. Legal basis for the processing of such data is Art. 6 sec. (1) (a) and (f) of the GDPR Regulation.
- Pre-employment screening. Depending on the nature of the job and country in question, we may ask a pre-employment screening expert to determine whether there are any circumstances which would disqualify you as a candidate from that job. Whether or not a screening will occur, as well as the scope and purpose will be discussed with you prior to the start of the screening. Legal basis for the processing of such data is Art. 6 sec. (1) (a) and (f) of the GDPR Regulation.
- References. We may decide to obtain references from individuals who have worked with you in the past. Generally, we will only contact those individuals if you have provided us with their names and contact details. If you are already an employee in some entity of TAJCO Group, we may ask for references from your manager and/or co-workers, without your knowledge. Legal basis for the processing of such data is Art. 6 sec. (1) (a) and (f) of the GDPR Regulation.
Purposes of Data Processing
Data controller will process your data for the following purposes:
- Recruitment. We process your information in order to ascertain whether you are a qualified candidate for the job you have applied for.
- Dispute resolution. We may process personal data for the purposes of resolving disputes, complaints or legal procedures.
- To comply with the law. We may have to process your personal data to comply with the law or a decision of the competent public authority or court order.
Parties Who May Access to Your Data
Data controller might share your data with third parties under the following circumstances:
- If we obtain information from third parties (as described above), we will provide them with your name and any other information necessary for them to provide us with relevant information about you.
- We may share your personal data with other third parties acting on our behalf, such as a service provider. In such cases, these other third parties may only use your personal data for the purposes described above and only in accordance with our instructions.
- Our employees will have access to the personal data. In such a case, access will be granted only if necessary for the purposes described above and only if the employee is bound by an obligation of confidentiality.
- We may share your personal data if required to do so by law a decision of the competent public authority or court order, for example with law enforcement agencies or other governmental agencies.
Location of Your Personal Data
Your personal data will be accessed by authorized employees of TAJCO Group within the European Union and European Economic Area. Further, your data will be accessed by authorized employees of TAJCO Group in USA and People´s Republic of China in case you apply for job in these countries and so in accordance with the legal requirement to provide appropriate safeguard - based on the standard privacy contractual clauses.
TAJCO uses third-party service providers to store your data, which may be located outside of the European Union and European Economic Area, including, but not limited to, the United States. These countries generally do not have laws which protect your personal data to the same extent as is the case in the European Union. For that reason, respective company from TAJCO Group will ensure that there is a contract in place with that third party which safeguards the protection of your personal data. If you would like to obtain a copy of such a contract, please use the contact details below to get in touch with us.
We may also rely on the Privacy Shield program, which is a program where US companies can commit to a higher level of privacy protection than is required by US law. Please use the contact information below if you’d like to know more.
Retention of Personal Data
We retain your personal data for a limited amount of time and will delete your personal data after it is no longer necessary for the purposes of the processing as mentioned in this Privacy Statement. This means that we will retain your data during the selection process and delete it after we have found a suitable candidate. If we have selected you to fill the position, we will retain your personal data in your personnel file in accordance with our HR privacy guidelines.
We may process your personal data for a longer period after the selection process has ended, if there is a pending legal dispute or similar proceeding or if you have given us permission to keep your personal data on record for a longer period of time.
Legal Basis for Processing Your Data
Concrete legal basis for the processing of individual types of data is set out above. Generally, we process your personal data on the ground that the processing is necessary for purposes of legitimate interest pursued by us. Our legitimate interest in this case is to recruit qualified candidates for respective positions. In some cases we will also be required to process your personal data due to fulfilment of legal obligation.
Your Rights under Act on Personal Data Protection
As a data subject, you have certain rights under valid legislation.
1. Right to Access
You are entitled to a copy of the personal information we hold about you and certain details of how we use it.
Your personal data will usually be provided to you in writing in paper form, unless otherwise requested, or where you have made the request by electronic means, in which case the information will be provided to you by electronic means where possible.
2. Right to Rectification
We take reasonable steps to ensure that the information we hold about you is accurate and complete. However, if you consider data, which we hold, are inaccurate, incomplete, or non-actual, please do not hesitate to ask us to correct, update or amend them.
3. Right to Erasure
In certain circumstances, you have the right to ask us to erase your personal information, for example where the personal data we collected are no longer necessary for the original purpose or where you withdraw your consent to processing. However your right need to be assessed from all relevant perspectives. For example, we may have legal and regulatory obligations which mean we cannot comply with your request.
4. Right to Restrict Processing
In certain circumstances, you are entitled to ask us to stop using your personal information, for example where you think that the personal information we hold about you may be inaccurate or where you think that we no longer need to use your personal information.
5. Right to Data Portability
In certain circumstances, you have the right to ask that we transfer personal information that you have provided to us to another third party of your choice.
6. Right to Object
You have the right to object to processing which is based on our legitimate interests (which is the case here, when we process your personal data as applicant for employment). Unless we have a compelling legitimate ground for the processing we will no longer process the personal data on that basis when you file an objection.
Note however that as a consequence of such an objection, you will be excluded from the selection process for concrete position, since we will not be able to process your data as a candidate for this position.
7. Rights Related to Automated Decision-Making
You have the right not to be subjected to automated decision-making, including profiling, which produces legal effect for you or has a similar significant effect. TAJCO generally does not use automated decision-making or profiling in the recruitment process, but if you have been subject to an automated decision and do not agree with the outcome, you can contact us using the details below and ask us to review the decision in a non-automated manner.
8. Right to Withdraw Consent
In most cases, we do not base the processing of your personal data on your consent. However, it may happen that we ask for your consent in specific cases. Where we do this, you have the right to withdraw your consent to further use of your personal information.
9. Right to Initiate Procedure for Protection of Personal Data
If you believe that your privacy rights have been infringed or that the applicable law has been violated, you have the right to initiate procedure before the respective Data Protection Authority.
If you would like to contact Data Protection Office in regard to the processing of your personal data, please send an e-mail to our Data Protection Officer
If you want to inform us about a breach of the use of personal data or if you want to send us a request regarding the rights of a data subject, click on the appropriate link on this website, or please send an e-mail to our Data Protection Officer