JUST ALIGNER PRIVACY NOTICE FOR APPLICANTS
Mac Dental Dis Protez Laboratuvarlari A.S. (hereinafter referred to as “Just Aligner“, “ Company” or “we”), pays the utmost attention to the lawfulness of the processing of personal data of its applicants. The Just Aligner Privacy Notice for Applicants (“Privacy Notice”) herein has been prepared in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”) to ensure that your personal data, as applicants, is processed in a transparent manner.
This Privacy Notice describes how we handle and protect your personal data in connection with our recruiting processes. This Notice applies to the personal data of job applicants and potential candidates for employment.
It is important that you understand who we are, how we use your personal data and that we take our obligations in this regard very seriously. The purpose of this Notice is therefore to give you information about how we collect, process, store and otherwise use your personal data and your rights in relation to that data.
We need to process your personal data in order to process your application for employment. There may also be statutory requirements we have to comply with in relation to your application. If we are not able to carry out the processing activities, we describe in this Privacy Notice we may not be able to continue with your application.
Table of Contents
- Data Protection Principles. 2
- Who is your personal data collected from?. 2
- What categories of personal data do we collect about you?. 2
- Our Purposes and Legitimate Basis for Collecting and Processing. 3
- Why we will share your personal data with third parties?. 4
- Data security. 5
- Data retention. 5
- Complaints. 7
- Changes to the privacy notice. 7
- Contact us. 7
- Data Protection Principles
We will comply with data protection law, which says that the personal data we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about (i.e. in relation to the recruitment exercise)
- Kept securely and protected against unauthorised or unlawful processing and against loss or destruction using appropriate technical and organisational measures.
We will typically collect, process, and use your personal data from the following sources:
- You, the applicant (when you apply to us directly for a job);
- Recruitment agency (recruiters that share your CV with us);
- Your named referees (referees or pre-employment screening service providers); or
- Publicly accessible sources, such as business and employment oriented social networking platforms (e.g., LinkedIn).
In connection with your application for work with us, we will collect, store, and use the following categories of personal data about you:
- Personal identification: including your name, date and place of birth, photo, and where applicable, information required to assess the eligibility of foreign duties (e.g. visa information, residence permit, work permit) information, immigration status).
- Contact details: including home address, telephone number, email address.
- Application data: including your CV, cover letter, employment history, education history, certifications, qualifications and skills, reference contact information, references, position preferences, willingness to relocate, desired salary, interests and aspirations and background screening information if relevant.
- The information you have provided on our application form.
- Any information you provide to us during the interview process.
- background check or other applicable screening information, such as information obtained through reference checks and confirmation about your work/educational background (as permitted by applicable laws).
This may involve us collecting, storing and using the sensitive personal data about your health and disabilities where we need to make any reasonable adjustments to the workplace in order to facilitate job interviews.
We collect and use applicant personal data for a variety of reasons linked to managing your application for a role with us. However, we can only collect and use this data if we have a valid legal ground for doing so, and we are required to explain the various legal bases that we rely on to you.
We will only request your personal data if we have a valid legal basis to do so, as outlined below:
To take the necessary steps before entering into an employment contract with you:
- To determine your eligibility for the role you applied for, including identification data, contact details, education and work experience, information obtained during your interview and information contained in your CV.
Where necessary to comply with a legal obligation
- Complying with applicable laws, policies and procedures, including employment and immigration laws and employment-related policies and procedures, which involves the processing of identification data and contact details.
- To comply with legal or regulatory requirements and protect our legal rights, including immigration and/or employment laws and regulations, right-to-work checks, diversity and inclusion requirements and practices, and legal claims data (including disclosure of information in connection with legal process or litigation). If you are successful, this will include verifying whether you have the right to work in the country in which you are applying for a job with the Company and checking whether the information you have provided in the application is correct.
Where necessary for our legitimate interest:
- Administering and processing your application (including processing a job offer should you be successful), including identification data, contact details, education and work experience, information obtained during your interview and information contained in your CV.
- Assessing your skills, qualifications, and suitability for the role, including identification data, contact details, education and work experience, information obtained during your interview and information contained in your CV.
- Communicating with you and third parties regarding your application and recruitment process, including informing you of future opportunities with the Company, which involves the processing of identification data and contact details.
- To carry out background, reference and other applicable screening checks as part of your application (where applicable), including identification data, contact details, information about your qualification(s) and employment history (to the extent permitted under applicable law).
If we need your consent, we will notify you of the personal data we intend to use and how we intend to use it. You do not have to give us consent. Where you have given us consent to collect, use or disclose your personal data in a certain way, you may withdraw your consent at any time. If you wish to withdraw any consent that you have given us, please contact us using the details set out below (Contact us).
Under certain circumstances, we may transfer your personal data to third parties in accordance with applicable laws. The categories of third parties that we may transfer your data to can be listed as follows:
- Regulators, authorities, business partners and other third parties. We may need to share your personal data with regulators, courts, and other authorities (e.g., tax and law enforcement authorities), independent external advisors (e.g., lawyers and consultants).
- In the event that business to which you are applying is sold or transferred in whole or in part (or such a sale or transfer is being contemplated), your personal data may be transferred to the acquiring entity as part of the transfer itself or as part of an initial review for such transfer limited to what is necessary.
- Third-party service providers. As necessary for the purposes of processing listed above, your personal data may be shared with third parties to process under appropriate instructions and on behalf of us, including, where applicable, external recruitment agencies, or video conferencing social media platforms (as permitted by applicable law) and other activities.
All our third-party service providers are required to take appropriate security measures to protect your personal data in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
Where information is transferred from inside the EEA to outside the EEA (Turkey), and where this is to a stakeholder in a country that is not subject to an adequacy decision by the EU Commission, data is adequately protected by EU Commission approved standard contractual clauses (SCCs), equivalent mechanisms including derogations, to protect your data and ensure its security.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
- If you are successful, we will retain your personal data for the purposes of the recruitment process and, once this process is finished, for an appropriate period so as to be able to deal with any legal claims linked to the application process and for any periods we are required to keep your personal data under applicable law. After this period which we will take steps to delete your personal data or hold it in a form that no longer identifies you. If you become our employee, your personal data will become a part of your employee file and will be used later for the management of the employment relationship.
- If you are not successful, We will retain your personal data for up to 6 months to review our recruitment decision and to keep you in mind for future recruitment processes. If you do not want us to keep your personal data for the purposes of potentially considering you for future positions, please notify us.
- Your legal rights
To the extent permitted by applicable data protection laws and regulations, you have the following rights in relation to your personal data:
- Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
- If you want us to establish the data’s accuracy;
- Where you believe our use of the data is unlawful but you do not want us to erase it;
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
If you wish to exercise any of the rights set out above, please refer to section ‘Contact Us’.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We hope we will be able to resolve any issues you may have. If you have a concern about how we use your personal data, we would like to work with you to resolve it.
You have the right to make a complaint at any time to your local data protection authority, such as the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). For a list of EEA data protection supervisory authorities and their contact details, see here. We would, however, appreciate the chance to deal with your concerns before you approach the relevant data protection authority so please contact us in the first instance.
We reserve the right to update this Privacy Notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal data.
Questions, comments and requests regarding this Notice are welcomed and should be addressed to Privacy Team and our EU Representative, [email protected].