We, “Smartex Media”, take care of the privacy and protect the personal data of persons who wish to enter into an employment relationship or other legal relationship with us, therefore we provide you with information on the processing of your personal data during the recruitment process.
We provide you with information on the processing of your personal data in “Smartex Media”, i.e. any information which directly or indirectly concerns you, your right to privacy and the protection thereof, as well as your right to the availability of information.
You – applicant or trainee whose personal data we process.
Smartex Media or we – SIA “Smartex Media.
Processing – any activities we perform with your personal data, e.g. personal data collection, registration, retention, viewing, use, disclosure by sending, disseminating or otherwise making available thereof, harmonisation, deletion or destruction etc.
Document – information on the processing of your personal data during the recruitment process.
Personal Data – any information concerning you, e.g. your name, surname, personal identification number, address, phone number, e-mail address, information included in your CV, your interests.
Consent – any approval that you freely and intentionally give when agreeing to the Processing of your Personal Data for a particular purpose(s).
Regulation – Regulation (EU) 2016/679 of the European Parliament and 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.
Supervisory Authority – an independent authority supervising application of the Regulation in the respective country (in Latvia – Data State Inspectorate, in Estonia – Estonian Data Protection Inspectorate, in Lithuania – State Data Protection Inspectorate).
Your Personal Data are processed Smartex Media, with which you currently have or earlier had an employment or other legal relationship or if you intended to establish such a relationship by submitting a relevant application to Smartex Media.
According to the purposes and to the necessary extent specified in the Terms and Conditions, we process the following sets (categories) of your Personal Data.
Set of Personal Data (categories) |
Types and description of Personal Data |
Your identification data |
Your name, surname, personal identification code, date of birth, your photo. |
Your private contact information |
Address of place of residence, phone number, e-mail address. |
Information regarding your evaluation as an applicant |
Curriculum Vitae (CV), application letter and other documents required by legislation for particular position categories. Our written notes during a job interview, an audio recording or a video-conference during a remote job interview. Feedback from your previous employer(s). Information on you verified in publicly available registers (validity of an identity document, information on employment, in separate cases – data on debt history, absence of criminal records etc.). Information on a potential conflict of interest which may arise before entry into an employment relationship in Smartex Media, upon occupying a position in public administration (information on you and the status of a public officer of your relatives, degree of relatedness, positions in the status of a public officer during the last two (2) years, name of state or local authority, name of structural unit (division, unit, department), job title, date when duties were taken up and resignation date, date until which the position was occupied). Notification regarding recruitment results etc. |
Information regarding your professional activity and education |
Information included in your CV: work experience (employers), profession(s), position(s), occupation type(s), length of service; education, language skills, driving experience, additional education (training, courses, workshops, awarded certificates etc.) and other skills; participation in professional and other associations. |
Information regarding the provision of communication and effective work organization by Smartex Media |
The Personal Data included in correspondence (applications, Consent to data processing etc.) and information produced and retained during communication (via phone and e-mail) in both hard copy and electronic form. |
Personal Data of special categories |
Legislation specifies Personal Data of special categories which we will process if the Processing thereof for the respective purpose is permitted by legislation. It is data of special categories revealing race or ethnic origin, religious or other beliefs, political views, health data, participation in trade unions, criminal records. |
Before we begin the Processing of your Personal Data, we always assess the purposes for which your Personal Data needs to be processed. The Processing of your Personal Data is legitimate if we perform it according to one of the following grounds, i.e., we process your Personal Data:
· to fulfill statutory obligations imposed on Smartex Media;
· based on your Consent;
· to pursue legitimate interests of Smartex Media or a third party, assessing beforehand whether the interests to process your Personal Data are consistent with your right to privacy;
· for the protection of your vital interests or those of a third party;
· to fulfill a task in the public interest or to exercise official authority, which has been legally granted to Smartex Media.
Purpose of Processing of your Personal Data |
Grounds for the Processing of your Personal Data |
Set (categories) of Personal Data, which we process |
Recruitment (internal and/or external) and assessment of suitability for the vacancy |
Pursuing of your legitimate interests or those of Smartex Media or a third party. During the recruitment process, we select an applicant who is most suitable for Smartex Media and assess your suitability for the vacancy: Curriculum Vitae, application letters, job interviews, assessment of feedback from previous employer; assessment of potential conflicts of interest, prevention of fraud or other criminal offences against Smartex Media by the verification of your data in publicly available registers and reliable publicly available information sources according to the internal regulations of Smartex Media. Your Consent to request feedback from your previous employer(s). Fulfillment of statutory obligations imposed on Smartex Media. For specific position categories, to ensure a good reputation for Smartex Media, to prevent the involvement of Smartex Media in illegal activities, to identify and prevent other risks significant to Smartex Media, to keep the identity of the customer secret, his/her accounts, deposits and transactions, we assess your suitability for the vacancy in Smartex Media. |
Your identification data; your private contact information; information regarding your assessment as an applicant; information regarding your professional activity and education. |
Participation in a competition for another vacancy |
Your Consent to the repeated use of the Curriculum Vitae in another competition. |
Your identification data; your private contact information; information regarding your professional activity and education. |
Processing of received requests and complaints regarding recruitment |
Fulfillment of statutory obligations imposed on Smartex Media. |
Your identification data; your private contact information; information regarding the provision of communication and effective work organization by Smartex Media. |
Satisfaction of claims arising from the recruitment process |
Pursuing of your legitimate interests or those of Smartex Media or a third party. Smartex Media protects its rights if a dispute with you arises during the recruitment process. |
Your identification data; your private contact information; information regarding your assessment as an applicant; information regarding your professional activity and education; information regarding the provision of communication and effective work organization by Smartex Media; Personal Data of special categories. |
Processing of requests made by state/local/investigative and other law enforcement authorities, as well as other state authorities and public officers specified by legislation |
Fulfillment of statutory obligations imposed on Smartex Media. |
Your identification data; your private contact information; information regarding the provision of communication and effective work organization by Smartex Media. |
Archiving |
Fulfillment of statutory obligations imposed on Smartex Media. |
All sets (categories) of Personal Data specified in the Document. |
We obtain your Personal Data:
· when you submit your data:
· when your Personal Data is made available by job advertisement websites;
· when your data is submitted by third parties:
We transfer your Personal Data to:
· Smartex Media companies, e.g. based on agreements concluded as part of mutual cooperation;
· our partners (processors, controllers, common controllers) who are related to the Processing of your Personal Data and whom we have carefully examined before cooperation, e.g. partners who provide support during the recruitment process;
· providers of databases developed according to procedures specified by legislation (e.g., database of the Information Centre of the Ministry of Interior);
· in cases specified by legislation – state/local authorities, law enforcement authorities (investigative authorities, prosecutor’s office, subjects of operative activity), courts, Supervisory Authorities (Data State Inspectorate and other authorities), based on written requests or other obligations laid down by legislation, which are binding to the Company, as well as other persons defined by legislation;
· audit firms, providers of legal services.
Within the Processing of your Personal Data, access to your Personal Data is only provided to employees authorized by us and our partners who require it for the fulfillment of their work duties and process your Personal Data solely for the purpose and on the grounds of Personal Data Processing specified in this Document, complying with technical and organizational requirements of Personal Data Processing defined by Personal Data protection legislation and internal regulations of Smartex Media.
When we process your Personal Data for the purposes specified in this Document, we do not adopt automated individual decisions, including profiling. If we begin such Processing of your Personal Data, we will inform you about it.
We ensure the retention of your Personal Data within the territory of the European Union and the European Economic Area.
Taking into account the global nature of business and the technological solutions used to provide the Processing of your Personal Data for the purposes specified by the terms and conditions, your Personal Data may be transferred for Processing to Personal Data recipients outside the territory of the European Union and the European Economic Area, e.g. if services are provided by a partner (processor, separate controller, common controller). Any such international transfer of Personal Data is performed in compliance with the requirements of the Regulation, and in such cases we provide the procedure for Personal Data Processing specified by legislation, as well as a level of protection equivalent to the one established by the Regulation.
The period of retention of your Personal Data without the deletion thereof depends on the Processing purposes and the criteria according to which we consider the period of retention of your Personal Data.
When we determine the period of retention of your Personal Data, we assess the need for the retention of your Personal Data:
· within different document retention periods established for Smartex Media by legislation;
· for pursuing your legitimate interests and those of third parties, after the recruitment process Smartex Media retains documents submitted by you as a rejected applicant for 6 months, taking into account the potential filing of claims against Smartex Media according to the procedures laid down by labor legislation;
· if the Processing of your Personal Data is performed on the basis of Consent, Smartex Media will retain this Document and the related information for 5 years after the withdrawal of Consent to provide proof of legitimate Personal Data Processing in the previous period.
When considering Personal Data retention periods, we take into account the requirements set out by legislation and guidelines developed by industry associations, if such are applied in the respective country, to determine retention periods of different documents. If during this process, we identify different grounds for the determination of the retention period of your Personal Data, e. g. differences between a retention period specified by legislation and period specified for the protection of our rights exist, these will be sufficient grounds for the retention of your Personal Data for the longest of both periods.
If at least one of the specified criteria applies, we will ensure the deletion or anonymisation of your Personal Data.
We request you to provide Personal Data, only because we require it for any of the purposes specified in this Document. If you do not provide us with your Personal Data, it might restrict or prevent Smartex Media’s cooperation with you, e.g. Smartex Media will be unable to fully assess your suitability for the vacancy, which could prevent you from entering into an employment relationship with Smartex Media.
We process your Personal Data solely for the respective purpose and to the extent required according to the requirements established by legislation. We do not request you to submit more Personal Data than we require. We also guarantee non-disclosure and safety of your Personal Data.
Within compliance with the requirements established by legislation governing the protection of privacy and Personal Data, we provide you with the following rights upon your written request:
· to access your Personal Data;
· to rectify your Personal Data if you have reason to believe that your Personal Data is inaccurate or incomplete;
· to delete your Personal Data (“right to be forgotten”) if:
· to restrict the Processing of your Personal Data, including the deletion of Personal Data, if:
· to transfer your Personal Data if there are no obstacles to such Personal Data transfer;
· to object to the Processing of your Personal Data justified by the legitimate interests of Smartex Media;
· to refuse the automated individual adoption of decisions, including profiling – during the Processing of your Personal Data for the purposes specified by these terms and conditions we do not adopt automated individual decisions. If we begin such Processing of your Personal Data, we will inform you about it;
· to withdraw Consent to the Processing of your Personal Data for the specific purpose for which it was provided at any time.
However, you must take into account that such withdrawal of Consent will not affect the legitimacy of Processing of your Personal Data before the withdrawal.
Smartex Media certifies that it provides the Processing of your Personal Data according to the requirements of the Regulation, other requirements specified by European Union and national legislation, and this Document. However, if you believe that we have breached your right to privacy by processing your Personal Data, you are entitled to protect your interests by filing a complaint to be handled by Smartex Media or Supervisory Authority, or by bringing an action before court.
If you have any questions regarding the Processing of your Personal Data, you may contact us by writing to the e-mail address of Smartex Media and contact the Personal Data protection officer – you will be provided with all the necessary information regarding the Processing of your Personal Data, including answers to your questions. All the information will be communicated to the responsible employee who will respond to your request.