PRIVACY NOTICE FOR APPLICANTS
The following companies operating as part of Lupin Europe are deemed to be data controllers:
Hormosan Pharma GmbH, Hanauer Landstraße 139-143, 60314 Frankfurt am Main, Germany
Lupin Atlantis Holdings SA, Landis+Gyr Strasse 1, 6300 Zug, Switzerland
Lupin Europe GmbH, Hanauer Landstraße 139-143, 60314 Frankfurt am Main, Germany
Lupin GmbH, Landis+Gyr Strasse 1, 6300 Zug, Switzerland
Lupin Healthcare (UK) Ltd, The Urban Building, Second Floor 3-9 Albert Street, Slough, Berkshire, SL1 2BE, United Kingdom
Nanomi BV, Zutphenstraat 51, 7575 EJ Oldenzaal, The Netherlands
Each company listed above is referred to as “Company” below.
The Company is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you.
During the recruitment process, the Company collects and processes personal data relating to job applicants.
The Company is committed to being clear and transparent about how it collects and uses that data and to meeting its data protection obligations.
2. Data Protection requirements
The Company will comply with data protection law. This means that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way;
- Collected only for valid purposes that we have explained to you clearly and not used in any way that is incompatible with these purposes;
- Relevant to the purposes we have told you about and limited to those purposes only;
- Accurate and kept up to date;
- Kept only for such time as is necessary for the purposes we have told you about; and
- Kept securely.
3. What personal information does the Company collect and process?
The Company collects and processes a range of personal information (personal data) about you. Personal data means any information about an individual from which the person can be identified. This may include:
- Personal contact details, such as your name, title, address and contact details, including email address and telephone number;
- application documents such as CV, references, certificates
- details of your qualifications, skills, experience and employment history, including start and end dates, with previous employers;
- lawful selection testing data where requested; which results shall only be interpreted by those qualified to do so;
- information about your remuneration, including entitlement to benefits such as pensions;
- information about your nationality and entitlement to work in the country;
We may also collect the following special categories of more sensitive personal information:
- information about medical or health conditions, including whether or not you have a disability for which the Company needs to make reasonable adjustments, in accordance with local labour law
- information about your criminal record; and
- equal opportunities monitoring information, including information about your health and religion or belief.
The Company collects this information in a variety of ways during the application and recruitment process.
In some cases, the Company collects personal data about you from third parties in accordance with local labour law, with your consent or if the processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as references supplied by former employers, information from employment background check providers and information from criminal records checks permitted by law.
Data is stored in a range of different places, including on your application record, in the Company's HR systems and in other IT systems (including the Company's email system).
4. Why does the Company process personal data and under what situations?
The Company needs to process data prior to entering into a contract with you. We also need to process data to enter into an employment contract with you and to meet its obligations under that employment contract.
In addition, the Company needs to process data to ensure that we are complying with our legal obligations. For example, we are required to check an employee's entitlement to work in the country. For certain positions, it is necessary to carry out criminal records checks to ensure that individuals are permitted to undertake a particular role. The Company processes health information if we need to make reasonable adjustments to the recruitment process for candidates with a disability.
The Company has a legitimate interest in processing personal data during the recruitment process and in keeping records of that process. Processing such data from job applicants enables the Company to manage the recruitment process, assess the suitability of candidates and make informed decisions as to whom we wish to recruit. The Company may also have to process data from job applicants in order to defend legal claims.
In cases where the processing of your personal data exceeds the purpose of processing the recruitment process, it shall be legitimised by an individual consent. If you have granted us your consent for the processing of your personal data, this consent will provide the legal basis for the processing specified therein.
5. If you fail to provide personal information
You are under no obligation to provide the Company with personal data during the recruitment process. However, if you do not provide certain personal information when requested, the Company may not be able to process your application for employment properly or at all. You are under no obligation to provide information for equal opportunities monitoring purposes and there are no consequences for you if this information is not provided.
6. Automated decision-making
Our employment decisions are not based on automated decision-making.
7. For how long do we keep personal data?
The Company will only hold your personal data for as long as is necessary to fulfil the purposes we collected it for, including any legal, accounting or reporting requirements. If your application for employment is unsuccessful, the company will destroy your data unless you specifically consent for your data to be kept for a longer specified period in order to be considered for any other suitable position within a twelve (12) month period.
If your application for employment is successful, personal data gathered during the new recruitment process will be transferred to your personnel file and we shall inform you through a new privacy notice which sets down the details of how we process your data in an employment relationship including the periods for which your data shall be held.
8. Who has access to personal data?
Your information will be shared internally for the purposes of the recruitment process, including with members of the HR team and interviewers.
The Company will not share your data with third parties unless you accept an offer of employment. In those circumstances, the Company shall share your data with third parties where required by law and where it is necessary in order to administer the employment relationship with you or where we have another legitimate interest in doing so.
Your data may be transferred to countries outside the European Economic Area (EEA) in order to administer employment benefits, effect compensation payments, make recommendations on compensation and promotions.
Data is transferred outside the EEA on the basis of data processing agreements, EU standard contractual clauses and other safeguards.
9. How does the company protect data?
The Company takes the security of our data seriously. The Company has internal policies and controls in place to prevent your data being lost, accidentally destroyed, misused or disclosed, and is not accessed except by its employees in the performance of their duties. When the Company engages third parties to process personal data on its behalf, they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.
10. Your rights
As a data subject, you have a number of rights. You can:
- access and obtain a copy of your data on request (known as a “data subject access request”);
- require the Company to change incorrect or incomplete data;
- request erasure of your personal information. This enables you to ask the Company to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
- object to the processing of your data where the Company is relying on its legitimate interests as the legal ground for processing; and ask the Company to suspend the processing of your personal data for a period of time if data is inaccurate or there is a dispute about its accuracy or the reason for processing it, and
- Lodging a complaint with a supervisory authority
If you would like to exercise any of these rights, or you have any questions about the privacy notice, please contact your HR Manager or the relevant Data Protection Officer.
If you believe that the Company has not complied with your data protection rights, you have the right to make a complaint to:
Information Commissioner's Office
Information Commissioner's Office
Wycliffe House, Water Lane
Phone: 0303 123 1113 / +44 1625 545 700
The Hessian Data Protection Office
The Hessian Data Protection Officer
PO Box 3163
Phone: +49 611 1408 - 144
Dutch Data Protection Authority
Authority Personal Data
PO Box 93374
2509 AJ DEN HAAG
Phone: 0900 - 2001 201
Federal Data Protection and Information Commissioner
Office of the Federal Data Protection and Information
CH - 3003 Berne
Phone: +41 (0)58 462 43 95
12. How you can get in contact with the relevant Data Protection Officer?
The Data Protection Officer
Dr. Karsten Kinast
KINAST Rechtsanwaltsgesellschaft mbH
Attorneys at Law (Germany)
Phone: +49 211 – 222 183 10
For Lupin Atlantis Holdings SA, Nanomi BV, Lupin Healthcare (UK) Ltd, Lupin Europe GmbH:
The Data Protection Officer
Dr. Katy Ritzmann
Phone: +49 30 203 907 422
13. Updating our privacy notice
Constant technological development makes it necessary to adapt our privacy notice from time to time. We reserve the right to change this privacy notice at any time with effect for the future. If we change our privacy notice, we will inform you of this by appropriate means.Fotolia.com © underdogstudios
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