Since 25 May 2018, 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 (referred to as “GDPR” and “General Data Protection Regulation”) has been in force.
In view of the above, we would like to inform you about the processing of your personal data during the recruitment process.
1. WHO IS THE CONTROLLER OF YOUR PERSONAL DATA AND HOW CAN YOU CONTACT THEM?
Quad/Graphics Europe Sp. z o.o., with its registered office in Wyszków (address: ul. Pułtuska 120, 07‑200 Wyszków), entered into the Register of Entrepreneurs of the National Court Register kept by the District Court in Białystok, 12th Commercial Department of the National Court Register, under KRS number: 0000029585, REGON number: 570775337, Tax Identification Number (NIP): 7642085674, with a share capital of PLN 160,857,000.00 (hereinafter referred to as “QGE”), is the controller of your personal data in connection with your participation in the recruitment process.
In the case of any questions regarding the processing of your personal data and your rights, please contact our Data Protection Officer by email at email@example.com or by post to the following address: Quad/Graphics Europe Sp. z o.o., ul. Pułtuska 120, 07-200 Wyszków, with a note, “Concerns the personal data protection”.
2. WHAT KIND OF PERSONAL DATA DO WE PROCESS, FOR WHAT PURPOSES AND ON WHAT LEGAL BASIS?
- In order to enable you to apply for a QGE’s job offer, we process the personal data you provide in your application; legal basis: Art. 221 of the Labour Code, which lists the personal data that an employer may require from a person applying for a job; your consent (Art. 6[a] GDPR).
- In order to enable you to contact us and receive answers to your questions, we process the personal data that you provide in your application, i.e. your name, telephone number, email address and correspondence address; legal basis: Art. 221 of the Labour Code, which lists the personal data that an employer may require from a person applying for a job; your consent (Art. 6[a] GDPR).
- We process your personal data in order to carry out activities in response to requests made by you prior to the conclusion of a contract, as well as to enable its conclusion and execution.
- We process your personal data in order to be able to comply with QGE’s legal obligation arising from specific employment legislation.
- In order to enable us to assert claims or defend ourselves against them, we may process certain personal data provided by you to the extent that is necessary to prove the existence of a claim (or lack thereof) and the severity of the incurred damage.
- We process your personal data in order to prove our compliance with the obligations arising from GDPR;
- We process your personal data for tax, accounting and social security purposes.
3. ARE YOU OBLIGED TO PROVIDE YOUR PERSONAL DATA?
Your participation in the recruitment process is voluntary. Pursuant to Article 221 of the Labour Code, an employer has the right to request personal data from a person applying for a job, including his/her:
- name(s) and surname;
- date of birth;
- contact details;
- professional qualifications;
- work history.
If you believe that the provision of any personal data other than those listed above (e.g. information on your interests, etc.) will enable us to better assess your application, you are welcome to do so. However, please note that provision of said data is entirely voluntary – it is neither a statutory or contractual requirement nor a condition for the conclusion of an employment contract. In this case, please include a statement in your recruitment documents expressing your consent to the processing of such additional personal data in the recruitment process.
4. HOW CAN YOU WITHDRAW YOUR CONSENT?
You are entitled to withdraw any consent given to QGE in relation to the processing of your personal data without any consequences until the day of commencement of your employment with QGE. To do so, use the “withdrawal of consent” feature available on our website, send an email to firstname.lastname@example.org or submit a letter with your request by post to: Quad/Graphics Europe Sp. z o.o., ul. Pułtuska 120, 07-200 Wyszków, with a note “Concerns the personal data protection”. You can express your wish to withdraw your consent in any way you choose, with the only condition being that your request must reach us. The withdrawal of consent does not affect the lawfulness of the processing of your data prior to such withdrawal (i.e. the processing of your data by QGE is legally valid until your consent is withdrawn).
5. WHO ARE THE POSSIBLE RECIPIENTS OF YOUR PERSONAL DATA?
We transfer your personal data to the recipients of the following categories:
- our parent company, i.e. Quad Graphics INC, with its registered office in the United States (address: N61 W23044 Harry’s Way, Sussex, WI 53089):
our parent company Quad Inc. is based outside the European Economic Area (EEA); due to the fact that we share IT systems and that some of our IT infrastructure (e.g. servers) is located in the USA, we cannot avoid transferring your data outside the EEA; moreover, your personal data may be transferred to our parent company in connection with our recruitment activities; therefore, we have ensured that the recipients of your personal data provide guarantees of a high level of personal data protection; such guarantees are based in particular on the application of binding corporate rules or standard contractual clauses adopted by the European Commission;
- IT companies which supply us with software:
we transfer your personal data to the providers of IT services and software used by us during recruitment activities; such providers process your personal data exclusively at our request and for the sole purpose of supporting the recruitment process; we only cooperate with suppliers who guarantee the full security of the processed personal data;
- state authorities:
we make your personal data available if we are requested to do so by relevant state authorities, in particular the organisational units of the public prosecutor’s office, the police, the President of the Personal Data Protection Office or the President of the Office of Electronic Communications.
6. HOW LONG DO WE RETAIN YOUR PERSONAL DATA?
Provided that you have not previously exercised your rights, as described in section 7 below, we will process your personal data for the duration of the recruitment and for two years thereafter. However, solely in specific cases, your personal data may be stored for a longer period, e.g. in relation to QGE’s compliance with any legal obligation incumbent on it as the Controller (in such a case, your personal data will be stored for the time necessary to comply with a given obligation).
7. WHAT ARE YOUR RIGHTS IN RELATION TO THE PROCESSING OF YOUR PERSONAL DATA?
We ensure that you can exercise the rights indicated below. In order to do so, submit a request to our Data Protection Officer – by email to: email@example.com or by post to: Quad/Graphics Europe Sp. z o.o., ul. Pułtuska 120, 07-200 Wyszków, with a note, “Concerns the personal data protection”.
- THE RIGHT TO OBJECT TO THE USE OF YOUR PERSONAL DATA
You have the right to object to the use of your personal data at any time. If your objection proves to be valid and we have no other legal basis for the processing of your personal data, we will delete the data in question.
Legal basis: Art. 21 GDPR
- THE RIGHT TO ERASURE OF PERSONAL DATA (“THE RIGHT TO BE FORGOTTEN”)
You have the right to request the erasure of all or some of your personal data provided that:
- you have withdrawn the consent on the basis of which your personal data were processed;
- your personal data are no longer necessary for the purposes for which they were initially collected/processed;
- you have objected to the use of your data;
- you have objected to our use of your data to keep website traffic statistics;
- your personal data are being processed unlawfully.
Notwithstanding your request for deletion of your personal data (following the abovementioned objection or withdrawal of consent), we may retain certain personal data to the extent required by applicable law (e.g. to the extent necessary for us to fulfil our obligations under labour law, to establish claims or to defend ourselves against them).
Legal basis: Art. 17 GDPR
- THE RIGHT TO RESTRICT DATA PROCESSING
You have the right to request the restriction of the processing of your personal data. If you make such a request, you will not be able to access the functionalities and services the use of which requires the processing of the data covered by the request, until it is considered. We will also cease to send you any correspondence, including marketing communication. You are entitled to exercise this right in the following cases:
- if you question the accuracy of your personal data;
- if your data are processed unlawfully, but you decide to request the restriction of their use rather than their erasure;
- if your personal data are no longer necessary for the purposes for which they were initially collected or used by us, but you need them in order to establish, assert or defend any claims;
- where you have objected to the use of your data, in which event, the restriction shall apply for the period of time necessary to assess whether the protection of your interests, rights and freedoms outweighs the interests we pursue by means of processing your personal data (in view of your particular situation).
Legal basis: Art. 18 GDPR
- THE RIGHT OF ACCESS TO YOUR DATA
You have the right to request us to provide confirmation as to whether we process your personal data. If we do, you are entitled to:
- gain access to your personal data;
- obtain information about the purposes of the processing, the categories of the processed personal data, their recipients (or categories of recipients), the intended retention period (or the criteria for determining that period), your rights under GDPR, your right to lodge a complaint with a supervisory authority, the source of the data, the automated decision‑making (including profiling) and the safeguards applied in relation to the transfer of the data outside the European Union;
- receive a copy of your personal data.
Legal basis: Art. 15 GDPR
- THE RIGHT TO RECTIFICATION
You have the right to rectify the personal data you have provided (if they are incorrect) and to complete them (if they are incomplete).
Legal basis: Art. 16 GDPR
- THE RIGHT TO DATA PORTABILITY
You have the right to obtain the personal data that you have provided to us and send them to any other data controller of your choice. You are also entitled to request us to send your personal data directly to such other controller, insofar as this is technically feasible.
We will send your personal data in the form of a file in a commonly used, machine-readable format that allows the received data to be transferred to another controller.
Legal basis: Art. 20 GDPR
8. HOW DO WE ENSURE THE SECURITY OF YOUR PERSONAL DATA?
We make every effort to ensure the security of your personal data. As we treat this issue very seriously, we use, for instance, the encrypted data transmission (SSL) during your registration and login to the User’s account, which ensures the protection of your personally identifiable data and makes it significantly more difficult for unauthorised systems or individuals to intercept access to your account.
Your personal data are stored based on cloud hosting, under relevant data entrustment agreements. A backup copy of your data is made periodically and stored on the disks of the server located at our head office.
Your data can be accessed solely by our authorised employees, who have been granted appropriate rights – other employees of QGE do not have access to your data.
9. WITH WHOM CAN YOU LODGE A COMPLAINT ABOUT THE PROCESSING OF YOUR PERSONAL DATA BY QGE?
You can lodge a complaint with the President of the Personal Data Protection Office.
10. HOW TO CONTACT OUR PERSONAL DATA PROTECTION OFFICER?
You can contact our Data Protection Officer by email at firstname.lastname@example.org or by post at the following address: Quad/Graphics Europe Sp. z o.o., ul. Pułtuska 120, 07-200 Wyszków, with a note, “Concerns the personal data protection”.