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Candidate Privacy Notice

<p><strong>Solenis Company</strong>&nbsp;and its wholly and majority-owned entities (&ldquo;<strong>Solenis Group</strong>&rdquo;, "<strong>Company</strong>", "<strong>we</strong>" or "<strong>us</strong>") takes your data protection seriously. Please click below to get more details about Solenis entities acting as data controllers and responsible for the processing of your personal data (<a href="/globalassets/resources/privacy-documents/list-of-solenis-group-companies-v04.pdf">List of Solenis Group Companies</a>). You can find out more about our Group at solenis.com or by contacting us using the information in the Contact Us section of our website.</p> <p>This Privacy Notice has been issued for compliance with laws regulating processing of personal data, which are applicable to Solenis. To the extent permitted by applicable Data Protection Laws, this Privacy Notice applies in all countries throughout Solenis global operation. As Solenis is an international company operating from multiple jurisdictions, various country-specific requirements may apply. You can review<a href="/en/country-specific-information/">&nbsp;Country-Specific Information</a>&nbsp;as part of this Privacy Notice.</p> <p>This Privacy Notice applies to any information that identifies or can be used to identify a natural person (and legal person pursuant to some jurisdictions) (&ldquo;personal information&rdquo;) that the Solenis Group obtains through the recruitment process (for example where you send your resume) and employment relationship..</p> <p><strong>PURPOSE OF THIS PRIVACY NOTICE</strong></p> <p>This Privacy Notice explains the types of personal information we obtain, how we collect that information, how we may use it, with whom we may share it and what measures we take to protect it. We also tell you how you can reach us to ask us to answer any questions you may have about our privacy practices and to exercise your rights, where applicable.</p> <p><strong>WHAT PERSONAL INFORMATION WE COLLECT, HOW AND WHY WE USE IT</strong></p> <p>In connection with your application to work with us, we will collect, store, and use the following categories of personal information about you:</p> <ul> <li><strong>Contact information</strong>: such as full name, including title, name at birth and preferred name, home address, phone number, email address.</li> <li><strong>Recruitment information</strong>: <ul> <li>The information you have provided to us in your CV and covering letter.</li> </ul> </li> </ul> <ul> <ul> <li>The information you have provided on our application form, including gender, employment history, qualifications.</li> <li>Any information you provide to us during an interview (including salary expectation and current notice period).</li> <li>Other information included as part of the application process, such as test results, assessments results or references, primary language, residence status and visa sponsorship requirements, type of contract applied for, full time/part time status.</li> </ul> </ul> <p>To the extent permitted by applicable laws, we may also collect, store and use the following &ldquo;special categories&rdquo; of more special category personal information:</p> <ul> <li>Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.</li> <li>Information about your health, including any medical condition, health and sickness records.</li> </ul> <p>Information about criminal convictions and offences.</p> <p><strong>HOW IS YOUR PERSONAL INFORMATION COLLECTED?</strong></p> <p>We collect personal information about candidates from the following sources:</p> <ul> <li><strong>Directly from you,</strong> such as through your data inputted into our Human Resources and careers systems, the application process or via other forms or information you provide to us in connection with your potential employment or engagement with us.</li> <li><strong>From third parties </strong>(subject to the requirements of applicable law) including: <ul> <li>Recruitment agencies you engaged with and from which we collect your Contact information and Recruitment information;</li> <li>Former employers (references); and</li> <li>References and background screening check provider (information on qualification and education, job background, [criminal convictions data].</li> </ul> </li> </ul> <p><strong>HOW WE WILL USE INFORMATION ABOUT YOU</strong></p> <p>We will only collect, use and share your personal information where we are satisfied that we have an appropriate legal basis to do this.</p> <p>We collect, process, and otherwise use your personal information for purposes and on the legal grounds specified in the table below; where relevant the legitimate interests pursued by us are listed as well:</p> <table style="border-collapse: collapse; width: 959px; border-color: black; border-style: solid;" border="1" width="959"> <tbody> <tr> <td style="border-color: black;" width="323"> <p><strong>Purpose</strong></p> </td> <td style="border-color: black;" width="328"> <p><strong>Lawful Basis</strong></p> </td> <td style="border-color: black;" width="308"> <p><strong>Legitimate Interests Lawful Basis</strong></p> </td> </tr> <tr> <td style="width: 323px; border-style: solid; border-color: black;" width="323"> <p>Assess your skills, qualifications, and suitability for the work or role.</p> </td> <td style="border-color: black;" width="328"> <p>We process this personal information in order to prepare to enter into a contract with you.</p> <p>We also process your personal information on the basis of our legitimate interests.</p> </td> <td style="width: 308px; border-style: solid; border-color: black;" width="308"> <p>We have a legitimate interest in fully assessing applicants to ensure that only suitable and appropriate candidates are selected, to compare candidates and make a fair decision on the most appropriate candidate for the position.&nbsp;</p> <p>We aim to recruit the best person for each vacancy through fair, systematic, effective recruitment and selection procedures.&nbsp; This will contribute towards us continuing to meet our business objectives, maintain our reputation and attract high calibre employees.</p> </td> </tr> <tr> <td style="border-color: black;" width="323"> <p>Carry out background and reference checks, where applicable.</p> </td> <td style="border-color: black;" width="328"> <p>We process this personal information to the extent permitted by law and in order to comply with legal obligations.</p> <p>We also process your personal information on the basis of our legitimate interests.</p> </td> <td style="border-color: black;" width="308"> <p>We have a legitimate interest in ensuring that candidates for employment or engagement do not pose an unacceptable risk to us and we consider the verification carried out necessary to prevent crime and other unlawful acts and to protect us from fraud, dishonesty or incompetence.&nbsp;</p> </td> </tr> <tr> <td style="border-color: black;" width="323"> <p>Communicate with you about the recruitment process.</p> </td> <td style="border-color: black;" width="328"> <p>Some of this processing is necessary for the compliance with legal obligations to which we are subject including the requirement to issue written particulars or terms of employment and the requirement not to unlawfully discriminate in the terms of any offer to you.</p> <p>Additional processing is necessary to take steps to enter into the contract between you and us and to perform that contract because we will need information to make an appropriate offer to you and administer your employment contract if you join us.</p> <p>We also process your personal information on the basis of our legitimate interests.</p> </td> <td style="border-color: black;" width="308"> <p>We have a legitimate interest in ensuring the effective engagement of staff on appropriate terms and conditions of employment and that there is a smooth transition into employment for successful candidates and that information supplied in the recruitment process which is relevant to ongoing employment is maintained.&nbsp; This will contribute towards us continuing to meet our business objectives, maintain its reputation and attract high calibre employees.</p> <p>We have a legitimate interest in being able to provide feedback to candidates and to be able to defend any challenge or claim made in connection with our recruitment decision.&nbsp; This will assist us in avoiding the risk of financial exposure or costs incurred through challenges to recruitment decisions and to maintain our reputation.</p> </td> </tr> <tr> <td style="border-color: black;" width="323"> <p>Keep records related to our hiring processes.</p> </td> <td style="border-color: black;" width="328"> <p>We process this personal information in order to comply with legal obligations.</p> <p>We also process your personal information on the basis of our legitimate interests.</p> </td> <td style="border-color: black;" width="308"> <p>We have a legitimate interest in maintaining an appropriate pool of talent who have shown an interest in working for us and who are potentially suitable candidates for employment.&nbsp; This will potentially benefit both initially unsuccessful candidates and us.&nbsp; It will contribute towards us continuing to meet our business objectives, maintain our reputation and attract high calibre employees.</p> </td> </tr> <tr> <td style="border-color: black;" width="323"> <p>Comply with legal or regulatory requirements</p> </td> <td style="border-color: black;" width="328"> <p>We process this personal information in order to comply with legal obligations.</p> </td> <td style="border-color: black;" width="308"> <p>&nbsp;</p> </td> </tr> </tbody> </table> <p><br />It is in our legitimate interests to decide whether to appoint you to the role, work or assignment you applied for, since it would be beneficial to our business to appoint someone to that role, work or assignment.</p> <p>If you reside in a jurisdiction where your consent is required for the collection, use and disclosure of personal information as set out in this Privacy Notice, by submitting an application to us or communicating personal information to us in connection with an application, you are providing your consent to the collection, use and disclosure of personal information as set out in this Privacy Notice. In some cases, your consent may be &ldquo;implied&rdquo; (i.e., your permission is assumed based on your action or inaction at the point of collection, use or sharing of your personal information. If you reside in a jurisdiction where data protection laws or other applicable regulations require your &ldquo;explicit&rdquo; consent for the collection, use and disclosure of personal information as set out in this Privacy Notice, you will be asked to provide a prior and explicit consent. We will generally obtain consent when we want to use personal information for a new purpose or for a purpose other than those stated at the time of collection in this Privacy Notice. Your consent can be withdrawn at any time, except in limited circumstances, including legal or regulatory requirements or as a result of your contractual obligations with us (such as a non-disclosure agreement).</p> <p>Having received your CV and covering letter or your application form, we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the role, assignment or work. If we decide to offer you the role, assignment or work, we will then take up references and carry out, subject to compliance with applicable laws, a criminal record or any other check before confirming your appointment.</p> <p><strong>If You Fail to Provide Personal Information</strong></p> <p>If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.</p> <p><strong>HOW WE USE SPECIAL CATEGORIES OF PERSONAL INFORMATION</strong></p> <p>We will use your special categories of personal information in the following ways:</p> <table style="border-collapse: collapse; width: 963px; border-color: black; border-style: solid;" border="1" width="963"> <tbody> <tr> <td style="border-color: black;" width="482"> <p><strong>Purpose</strong></p> </td> <td style="border-color: black;" width="482"> <p><strong>Lawful Basis</strong></p> </td> </tr> <tr> <td style="border-color: black;" width="482"> <p>We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview.</p> </td> <td style="border-color: black;" width="482"> <p>This processing is necessary for the purposes of carrying out the obligations and exercising the rights of you or us in the field of employment law, social security and social protection law, to the extent permissible under applicable laws.&nbsp;</p> <p>We process your personal information on the basis of &lsquo;employment, social protection and social security laws&rsquo; and &lsquo;equality of opportunity or treatment&rsquo;.</p> </td> </tr> <tr> <td style="border-color: black;" width="482"> <p>Where permitted by applicable laws, we will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.</p> </td> <td style="border-color: black;" width="482"> <p>This processing is necessary for the purposes of carrying out the obligations and exercising the rights of you or us in the field of employment law, social security and social protection law, to the extent permissible under applicable laws.&nbsp;</p> <p>We process your personal information on the basis of Article 9(2)(g) substantial public interest. We rely on the &lsquo;equality of opportunity or treatment&rsquo; and &lsquo;racial and ethnic diversity at senior levels of organisation&rsquo; conditions as set out in Part 2 of Schedule 1 of the Data Protection Act 2018 to process this special category personal information.</p> </td> </tr> </tbody> </table> <p><strong><br />INFORMATION ABOUT CRIMINAL CONVICTIONS</strong></p> <p>Personal information relating to criminal convictions and offences will only be processed where authorized by applicable laws e.g.: (i) a criminal record check may be carried out on recruitment or transfer where authorized by applicable laws; or (ii) an allegation of a criminal offence or conviction arising during your relationship with Solenis may be processed where required or authorized. For example, where we have a legal or regulatory requirement to report an offence or applicable laws authorize Solenis to process information about the offence for the purpose of making decisions regarding your relationship with Solenis.</p> <p>To the extent that we process this personal information, we do so on the basis of substantial public interest as set out in applicable laws.</p> <p><strong>AUTOMATED DECISION-MAKING</strong></p> <p>You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.</p> <p><strong>SHARING PERSONAL INFORMATION WITH OTHERS</strong></p> <p>Your personal information will be disclosed:</p> <ul> <li>within Solenis only to those individuals who need access to your personal information to perform their duties for the purposes listed above or where required or permitted by applicable law. This may include:</li> <li>local, regional and global Human Resources, including managers and team members;</li> <li>local, regional and executive management responsible for making hiring decisions or as otherwise appropriate (including, without limitation, staff from Legal and IT);</li> <li>system administrators; and</li> <li>where necessary for the performance of specific tasks or system maintenance by staff in Solenis teams such as the Finance, IT and the Global HR information systems support team.</li> <li>To third parties whom we work together with, for example:</li> <li>a recruitment agency supporting us with the recruitment, survey, employment on-boarding process;</li> <li>clinics organizing the pre-employment medical check-up; and</li> <li>companies providing IT services, such as hosting, supporting and maintaining the framework of our recruitment information systems.</li> </ul> <p>Applicable Data Protection Laws may permit or require the sharing of personal information some circumstances not described above. These circumstances include situations when permitted or required by law or when necessary to protect our group of companies, our employees, our customers, or others, such as when investigating and preventing suspected or actual illegal activities, including fraud, or to assist government and law enforcement agencies, as well as potential buyers or acquirers of all or part of our business. If this happens, we will not share more personal information than is reasonably required to fulfil that particular purpose.</p> <p>If you reside in a jurisdiction where applicable Data Protection Laws or other applicable regulations require your explicit consent for sharing of personal information outside the initial and specific purposes, you will be asked to provide a prior and explicit consent.</p> <p><strong>INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION</strong></p> <p>Due to the multinational character of Solenis, some of the affiliated companies and other recipients listed above may be located in countries that do not provide a level of data protection equivalent to that set forth by the law in your home country.&nbsp; We take appropriate steps to make sure that such recipients act in accordance with applicable law.</p> <p>Transfers within the Solenis Group will be covered by an agreement entered into by members of Solenis Group (an intra group agreement) which contractually obliges each member to ensure that personal information receives an adequate and consistent level of protection wherever it is transferred within Solenis Group. Where we transfer your personal information outside Solenis Group or to our third party service providers, we obtain contractual commitments from them to protect your personal information (e.g., Standard contractual clauses for data transfers between EU and non-EU countries, or other approved transfer mechanisms).</p> <p>You have a right to obtain more information about the recipients of your personal information and the safeguards we have put in place to ensure the adequate protection of your personal information when this is transferred as mentioned above. To exercise this right, please use the Contact Us section below.</p> <p><strong>DATA SECURITY</strong></p> <p>We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.</p> <p>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.</p> <p><strong>DATA RETENTION</strong></p> <p>We intend to keep your personal information accurate and up-to-date. We will not retain your personal information longer than it is necessary to carry out the purposes listed in this Privacy Notice or than is required by law.</p> <p>To the extent permitted by Data Protection Laws or other applicable regulations, we will retain your personal information for a period of six months after we have communicated to you our decision about whether to appoint you to the role, assignment or work. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with our data retention policy, applicable laws and regulations.</p> <p>If we wish to retain your personal information on file, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period on that basis.</p> <p><strong>YOUR DATA RIGHTS</strong></p> <p>Pursuant to applicable data protection laws, you have a number of rights in relation to the processing of your personal information:</p> <ul> <li><strong>Request access</strong>&nbsp;to your personal information (commonly known as a &ldquo;data subject access request&rdquo;). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.</li> <li><strong>Request rectification</strong>&nbsp;of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.</li> <li><strong>Request erasure</strong>&nbsp;of your personal information, in particular where:</li> <ul> <li>the personal information is no longer necessary in relation to the purposes for which they were collected or otherwise processed;</li> <li>you objected to the processing and there are no overriding legitimate interests for the processing;</li> <li>your personal information has been unlawfully processed; or</li> <li>your personal information has to be erased for compliance with a legal obligation to which we are subject.</li> </ul> <li><strong>Request the deletion </strong>of your personal information, however, does not apply in particular where the processing of your personal information is necessary for compliance with a legal obligation or for the establishment, exercise or defence of legal claims.</li> <li><strong>Object to processing</strong>&nbsp;of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.</li> <li><strong>Request the restriction</strong>&nbsp;of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.</li> <li><strong>Request the transfer</strong>&nbsp;of your personal information to another party.</li> </ul> <p>If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal information, or request that we transfer a copy of your personal information to another party, please complete and submit our <a href="/en/statement-data-request-form/">Data Request Form</a>, or use the&nbsp;<a href="/en/contact/contact-us/">Contact Us</a>, or send an email to&nbsp;<a href="mailto:privacy@solenis.com">privacy@solenis.com</a>.</p> <p><strong>RIGHT TO WITHDRAW CONSENT</strong></p> <p>Where your consent is relied upon as a lawful basis, you have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please complete and submit our&nbsp;<a href="/en/statement-data-request-form/">Data Request Form</a>, or use&nbsp;<a href="/en/contact/contact-us/">Contact Us</a>, or send an email to&nbsp;<a href="mailto:privacy@solenis.com">privacy@solenis.com</a>. Once we have received notification that you have withdrawn your consent, we will no longer process your personal information and, subject to our retention policy, we will dispose of your personal information securely.</p> <p><strong>RIGHT TO COMPLAIN TO DATA PROTECTION SUPERVISORY AUTHORITY</strong></p> <p>You have the right to raise concerns to us or to a supervisory authority, if you have concerns about how we are processing of your personal information. If you wish to raise concerns with us, please use the contact details in the Contact Us section to get in touch.</p> <p><strong>CHANGES TO OUR PRIVACY NOTICE</strong></p> <p>We may amend this Privacy Notice from time to time to keep it up to date with legal requirements and the way we operate our business and will place any updates on this web page. Please regularly check these pages for the latest version of this Privacy Notice. If we make significant changes to this Privacy Notice, we will seek to inform you by notice on our website or email or otherwise provide more prominent notice if required by Data Protection Laws or by other applicable regulations.</p> <p>If you reside in a jurisdiction where Data Protection Laws or other applicable regulations require your explicit consent for changes or updates to this Privacy Notice or for other changes in approach to data protection, you will be asked to provide a consent before material changes to this Privacy Notice or other changes in approach to data protection are implemented.</p> <p><strong>CONTACT US</strong></p> <p>We have appointed an Office of Data Privacy (ODP) to oversee compliance with this Privacy Notice. If you have any questions, concerns or complaints regarding our compliance with this Privacy Notice, the information we hold about you or if you wish to exercise your rights, we encourage you to contact our ODP by sending an email to&nbsp;<a href="mailto:privacy@solenis.com">privacy@solenis.com</a>, or by completing and submitting our&nbsp;<a href="/en/statement-data-request-form/">Data Request Form</a>, or by using&nbsp;<a href="/en/contact/contact-us/">Contact Us</a>.</p> <p>We will investigate and attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to exercise your rights as quickly as possible and, in any event, within the timescales provided by Data Protection Laws or by other applicable regulations.</p> <ul> <li><strong>Solenis LLC</strong> <br />Office of Data Privacy, Information Security Director, 2475 Pinnacle Drive, Wilmington, DE 19803, United States<br /><a href="mailto:privacy@solenis.com">privacy@solenis.com</a><strong> </strong></li> <li><strong>Solenis Switzerland GmbH</strong> <br />Office of Data Privacy, Global Data Privacy Lead, M&uuml;hlentalstrasse 38, 8200 Schaffhausen, Switzerland<br /><a href="mailto:privacy@solenis.com">privacy@solenis.com</a></li> <li><strong>Solenis Netherlands BV</strong> <br />Office of Data Privacy, Regional Business Counsel, EMEA, Maarssenbroeksedijk 2, 3542DN Utrecht, The Netherlands<br /><a href="mailto:privacy@solenis.com">privacy@solenis.com</a></li> <li><strong>Solenis Poland Sp. z o.o.</strong> <br />Office of Data Privacy, Regional Business Counsel, EMEA, Giełdowa 1, 01-211 Warsaw, Poland<br /><a href="mailto:privacy@solenis.com">privacy@solenis.com</a></li> <li><strong>Diversey Ltd</strong> <br />Office of Data Privacy, Regional Business Counsel, EMEA, Pyramid Close Weston Favell Northampton NN3 8PD<br /><a href="mailto:privacy@solenis.com">privacy@solenis.com</a></li> </ul> <p>Last Modified:&nbsp; August 9, 2024</p>