HEINEKEN Group N.V. (referred to as “HEINEKEN”, “we” or “us”) is (along with its affiliates and subsidiaries, referred to as “HEINEKEN” “we” or “us”) is a global organisation domiciled in Europe, Asia Pacific, Africa, Middle East, North and South America (see also www.HEINEKEN.com). Your potential HEINEKEN employer, is the controller of your personal data. HEINEKEN is committed to protecting the privacy of external and internal applicants. When an applicant visits the HEINEKEN career website or uses the internal job vacancies site, HEINEKEN collects information (personal data) about the applicant (e.g. via web forms). HEINEKEN uses the applicant’s personal data in a fair and lawful manner; this means that HEINEKEN will collect and process personal data in accordance with applicable privacy laws. Protecting the privacy and personal data of applicants is of the utmost importance to HEINEKEN and is a significant aspect of the way HEINEKEN creates, organises and implements its recruiting activities. This privacy statement is intended to inform applicants with regard to HEINEKEN’s processing of recruitment data and is applicable to HEINEKEN recruitment and selection activities.
This Privacy Notice is issued in 2019 and may be updated from time to time, of which you shall be informed.
Personal information (applicant data) submitted by an applicant to HEINEKEN will be used by HEINEKEN to support a responsible, effective and efficient recruitment and selection process. HEINEKEN will collect and process applicant data from unsolicited applications and from HEINEKEN current open positions. HEINEKEN will process applicant data for recruitment purposes. These purposes are: assessment of your application, matching applicant data with HEINEKEN current open positions and contacting applicants for future positions that suit the applicant’s skills and capabilities, evaluating your eligibility to work at HEINEKEN, communicating HEINEKEN recruitment and selection procedures, contacting applicants to schedule interviews/tests and responding to questions an applicant may raise, verifying information received via the application and for performing pre-employment screening.
In addition HEINEKEN will process your personal data for the following purposes:
3. Applicant data
HEINEKEN collects and processes applicant data (required and optional) which an applicant provides directly, via creating a profile and by attaching relevant documents (such as resume), on the HEINEKEN recruitment system. We also collect and process applicant data through recruitment agencies, personal referrals, phone calls or e-mail. Examples of applicant data collected and processed by HEINEKEN for the purposes listed under 2. include, but are not limited to:
4. Applicant sensitive personal data
During the recruitment and selection process, we may need to collect certain data viewed as ‘sensitive’ because they may reveal intimate characteristics. Any use of sensitive applicant data shall be used by us only within the strict limits set out by applicable local law. The use of applicant sensitive personal data may –if permitted or required by law- be aimed at providing preferential status to persons from particular ethnic or cultural minorities to remove or reduce inequality or to ensure diversity in staffing, provided that such use of the applicant sensitive data allows for an objective determination that an applicant belongs to a minority group and the applicant has not filed a written objection against the relevant processing
The applicant data that we collect and process will be adequate, relevant and not excessive relative to the specified purposes for which the applicant data are collected and processed. Applicant data will be as accurate as possible and, as necessary in accordance with applicable laws, kept up to date by applicants.
5. Cookies or similar technologies
Through cookies or similar technologies, we may collect the following personal data:
Quality and liability
When you provide your personal data to HEINEKEN, you are responsible for the accuracy of your personal data and to make sure that your personal data remains accurate and up to date. HEINEKEN is, except for gross negligence or unlawful intent, not liable for errors, consequences or activities taken as a result of inaccurate or incomplete information that you provided to us.
7. Transfer of & Access to your personal data
To operate as a global business and to promote an applicant’s career within HEINEKEN, it is in both the job applicant and HEINEKEN’S interests to enter applicant data in an international database that may either be limitedly available or available for all HEINEKEN recruiters worldwide. A third party service provider of HEINEKEN may also be located outside your home jurisdiction. Where such international data transfer takes place to a country that has a different data protection regime, HEINEKEN will ensure that the international data transfer will not negatively affect the level of protection of your personal data. Where required, HEINEKEN will inform you of any additional details on the international data transfers.As part of the application process, applicants are asked to select any of the following choices:
When the applicant selects ‘any company recruiter worldwide’, applicant acknowledges that his/her personal data are being transferred outside his/her country of origin and shall be accessible for processing by all HEINEKEN recruiters in the various countries in the world where HEINEKEN operates for the purposes listed in this HEINEKEN recruitment privacy statement. HEINEKEN will ensure adequate security measures and valid transfer mechanisms for the transfer to and processing of applicant data in the HEINEKEN locations in the various countries where HEINEKEN operates. During the recruitment process, candidates information will be accessed internally only by those HEINEKEN employees (including employees of HEINEKEN affiliates) who are involved in the recruitment process. Where your information is submitted to, or processed on behalf of, HEINEKEN by a contracted and trusted third party provider, we put in place an agreement with such third party service provider to protect your personal data. It will only use candidate information to process HEINEKEN employment applications and not for its own purposes. The recruitment website runs on SuccessFactors. SuccessFactors is a SAP cloud application owned by SAP and stored on servers in Germany with back up servers in the Netherlands. SuccessFactors has access to the system when providing hosting, maintenance and support services. We have agreements in place with SuccessFactors to protect the confidentiality and security of your personal data. From time to time, we may need to make personal data available to other unaffiliated third parties, such as recruitment agencies or IT systems suppliers, professional advisors (such as accountants, auditors, or lawyers), public and governmental authorities (entities that regulate or have jurisdiction over us such as regulatory authorities, law enforcement, public bodies and judicial bodies), or in the context of corporate transactions (a third party in connection with any proposed or actual reorganization, merger or sale). We require third parties and professional advisors to use appropriate measures to protect the confidentiality and security of the personal data. Where such international data transfer takes place from an EEA country to a recipient in a country that has a different data protection regime, we will ensure that this international data transfer will not negatively affect the level of protection of your personal data and is based on appropriate safeguards including EU Model Clauses or Binding Corporate Rules.
HEINEKEN will retain applicant data during the recruitment and selection process. HEINEKEN will only retain applicant data in relation to a particular vacancy as long as legally allowed after the recruitment and selection process. If there is a legal obligation to retain personal data longer, HEINEKEN will do so (e.g. equal opportunity requirements in local employment laws). HEINEKEN may also retain applicant data in relation to a particular vacancy if you have given your consent to keep the applicant data, e.g. keeping an applicant’s resume on file if a suitable vacancy arises. In addition, you may create a profile without actually applying to a particular vacancy. In those cases, HEINEKEN will generally delete your data after 1 year – or shorter when legally required based on local law - of inactivity in our recruitment system (i.e. after not having logged-in to your account/profile). After the retention period the applicant data will be completely deleted from HEINEKEN’s system. An applicant is entitled to request deletion of his or her personal data at any time.
HEINEKEN uses a number of technical, physical and organizational security measures to assure the integrity, confidentiality and availability of applicant data, taking into account the nature, scope, context, purposes and risks involved. HEINEKEN has implemented security technologies to protect the stored applicant data from unauthorised access, improper use, alteration, unlawful or accidental destruction and accidental loss. HEINEKEN continues to enhance its security procedures as new technology becomes available. An applicant has an important role to play in assisting HEINEKEN in keeping applicant data secure. An applicant should at all times keep his or her password confidential and use the correct procedure to log in and out of the HEINEKEN recruitment system.
10. Applicant's rights
An applicant has the right to request access to his or her applicant data that HEINEKEN holds. Applicants also have the right to have your data rectified, deleted or restricted (as appropriate). HEINEKEN facilitates access to applicant data by sending an email to MyHR@heineken.com. Applicants can correct or delete their applicant data themselves by making changes to their profile. Applicants also have the right to have the processing of their data restricted (as appropriate) or to object to the use of their personal data by HEINEKEN. Please note that requests that do not meet the requirements set out by applicable law or HEINEKEN guidelines may be requested to be re-issued or ultimately denied and that certain personal data may be exempt from an applicant’s request pursuant to applicable data protection laws and other laws and regulations. For any other questions relating to their personal data, or for complaints about how their personal data is processed by HEINEKEN, applicants can send an email to MyHR@heineken.com. Please state clearly in the subject that your request concerns a privacy matter. If you inform us that you do no longer wish to be approached (via a certain medium), HEINEKEN shall move your applicant data to a separate file and you will not receive information from us regarding new job vacancies and other alerts. The application process may include an automated rejection of your application. Where this is the case, the criteria used to make such automated decision shall be included in the relevant job requirements. You have the right to ask us to look at your application notwithstanding the automated response you have received or to inform us that you do not agree with the rejection of your application and the reasons why. We also draw attention to the right of applicants in European countries to go to their local Data Protection Authority with complaints.
11. Contact information
Please send any questions, comments or issues about this privacy statement or HEINEKEN’s applicant data collection and processing activities to MyHR@heineken.com.