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Data protection notice for recruitment

Cargolux International Airlines S.A., Luxembourg Airport, Luxembourg (hereafter referred to as “CARGOLUX” or “we”) is committed to the protection of your personal data in accordance with data protection legislation, especially the General Data Protection Regulation EU 2016/679 (the “GDPR”).

This Data Protection Notice for recruitment is intended to inform candidates who apply for a job at CARGOLUX (“you”) on the processing of their personal data.

Please be informed that the duration, nature and purposes of the processing, as well as the type of personal data collected in the scope of the recruitment process may vary according to the nature of the position to which you are applying.

1. Who is the controller of your personal data?

CARGOLUX International Airlines S.A., Luxembourg Airport, Luxembourg is responsible as a data controller, for collecting and processing your personal data in relation to your application for a position at CARGOLUX and our recruitment process.

2. What personal data do we process?

We collect and use your personal data to the extent necessary in relation to our recruitment process and to ensure that your application can be considered by the relevant CARGOLUX department(s).

We may collect various types of personal data that you decide to or are requested to submit in relation to your application for a particular job position, including:

identification data (such as your name, date and place of birth, nationality, ID information, driving license information, contact details, address, telephone, email, country, or other contact information),
job application data (CV, cover letter, previous work experience, education, additional qualification, or other information regarding your professional qualification and experience, additional skills and abilities, professional interest, details of your right to work in the concerned country, type of employment sought, desired salary, job preferences, etc.) you provide for our consideration in the recruitment process,
names and contact details of referees and knowledge of a person among our staff or management (relative or contact person). Prior to providing personal data of any data subjects, you must inform them about the content of this note and ensure that they do not object to the processing of their personal data by Cargolux.

We do not usually require from job applicants to include any special categories of data (racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning sex life or sexual orientation) or any judicial data (e.g. criminal records) as part of the job application documentation. However, such processing may take place in specific circumstances where required to fulfil the obligations and exercise the rights of CARGOLUX or yours, in accordance with applicable labour law or in the interest of social security and social protection, to the extent that it is authorised or required by law.

We may also collect information about you (your full name, email, work history, and other data included on your profile) from publicly accessible sources, such as LinkedIn.

3. Why we process your personal data (purpose and legal basis)?

We collect and use your personal data for the following purposes:

to assess your skills, qualifications and interests against our career opportunities, to maintain our relationship during the recruitment process, including by calling you and inviting you to interviews, exchange of offers and terms of employment, etc;
to verify your information, to run our internal compliance and conflict checks and to conduct reference/background checks;
to communicate with you and, if applicable, to inform you of other career opportunities;
for security and protection of our organization, IT networks and CARGOLUX information;
to improve our recruitment process; and
to defend ourselves in any legal or court proceedings.

We collect your personal data on the following basis:

pre-contractual measures necessary to establish a contractual relationship with you,
pursuing our legitimate interests, including to ensure that our company’s IT networks and information are secure, to manage our recruitment process; to keep records of the recruitment process, to prevent conflicts of interests and confidentiality issues and to protect our interest and rights in the event of suspected, investigated or actual violations of applicable law.

4. Who do we share your personal data with?

In order to fulfil the aforementioned purposes, your personal data may be shared internally for the purposes of the recruitment process with members of the CARGOLUX human resources department, interviewers involved in the recruitment process and management in the business area with a vacancy.

We may also communicate your personal data to:

service providers (such as recruitment agencies) that perform services on our behalf,
law enforcement or other government and regulatory bodies or agencies, upon request and to the extent permitted by law
certain regulated professionals such as lawyers or auditors.

5. Where do we transfer your personal data?

We may process personal data in view of filling vacancies based outside the EU/EEA, as well as use third party providers to deliver our services and this may involve transfers of your personal data to countries outside of the European Union/European Economic Area (EU/EEA). In case of international transfers originating from the EU/EEA to a country outside the EU/EEA, the transfer of your personal data may occur where the European Commission has decided that the country outside the EU/EEA ensures an adequate level of data protection.

For transfers to countries outside the EU/EEA for which the level of protection has not been recognised as adequate by the European Commission, we will either implement appropriate safeguards provided for by current data protection law (e.g. the entry into standard data protection clauses) or rely on a derogation applicable to specific situations.

You can obtain more information regarding relevant safeguards we rely on by contacting us at dataprotection@cargolux.com.

6. Security of your personal data

The processing of your personal data is carried out through IT, electronic and manual tools, with logics strictly related to the aforementioned purposes and, in any event, in compliance with the appropriate technical and organisational measures required by law to ensure a level of security that is adequate to the risk, in order to avoid unauthorised loss or access to your data.

7. How long do we keep your personal data?

Unless applicable laws and regulations provide otherwise, if your job application is unsuccessful, we will retain your personal data for up to 1 year after the end of the relevant recruitment process. At the end of that period, or once you opposed to your personal data being processed, your personal data will be anonymized, deleted or destroyed.

Note that in case you are selected for the job position you have applied for, the above categories of personal data will continue being processed as part of your employment file with CARGOLUX (more information will be provided to you upon the start of your employment).

8. What are your rights regarding your personal data?

In accordance with applicable data protection laws (and subject to conditions and restrictions set forth therein), you may exercise at any time the following rights in relation to your personal data:

right to access, which enables you to obtain from us confirmation of whether your personal data is being processed or not and, if so, obtain access to such data; we process a large quantity of information, and can thus request you to specify the information or processing activities to which your request relates;
right to rectification, which enables you to obtain from us the correction of your personal data that are incorrect and/or incomplete; and

in certain limited cases (in which case we will analyse whether the conditions for the exercise of such rights are fulfilled, in line with GDPR):

right to erasure, which enables you, in specific cases provided for by art. 17 GDPR, to obtain from us the erasure of your personal data;
right to restriction of processing, which enables you, in the specific cases provided for by art. 18 of the GDPR, to restrict the processing of your personal data by us;
right to object, which enables you to object to the processing of your personal data when certain conditions are met;
right to data portability, which enables you, in certain cases (subject in particular to technical feasibility) and with regard only to the data you have provided to us, to request a copy of your personal data in a structured and commonly machine-readable format.

If you have provided your consent to the processing of your personal data, you can withdraw such consent at any time.

To exercise any of these rights, you may contact us by email dataprotection@cargolux.com or by postal mail:

CARGOLUX Airlines International S.A.
Data Protection Office
Compliance Department
Luxembourg Airport
Luxembourg

You have the right to lodge a formal complaint with the Commission nationale pour la protection des données (CNPD).

9. Changes to this Data Protection Notice for recruitment

Changes may occur in the way we process personal data. In case these changes oblige us to update this Data Protection Notice for recruitment, we will clearly communicate it to you, either via our website or via other appropriate means. The latest applicable version will always be available on our website.