From this document you will learn how and on what basis we process your personal data in connection with our recruitment processes.

You will learn, among other things:

• Why we may process your data;
• for what purpose we process them;
• whether you are obliged to provide us with your data;
• how long we keep them;
• Whether there are other recipients of your personal data;
• whether we process your data outside the European Economic Area and
• whether we process your data by automated means, including profiling.

The first part of the Privacy Policy contains general information that we must provide to everyone, regardless of the purpose of the data processing.

The second part of the Privacy Policy contains information aimed at individuals who actively contact us to take part in our recruitment processes.

The third part of the Privacy Policy contains information aimed at individuals we contact using data from publicly available sources, such as LinkedIn or company websites, exclusively related to business activities, in connection with potential networking opportunities.

Notwithstanding the above, information about the processing of your personal data in connection with the use of univio.com can be found here, and information intended for the Customer with whom we conclude a cooperation agreement can be found here.

Part I. General information

Contact details for the controller of your personal data

The administrator of your personal data in the processes described herein is We, i.e. Univio Spółka Akcyjna* with its seat in Wrocław at ul. Strzegomska 2-4, entered in the Register of Entrepreneurs of the National Court Register under KRS number: 0000004330.

We can be contacted at: hr@univio.com

*Univio consists of the following companies: Univio S.A., Univio International Sp. z o.o., Univio Systems Sp. z o.o. and Global4Net Sp. z o.o.. In principle, the controller of your personal data is Univio S.A., with the understanding that if you are interested in establishing a relationship with another Univio entity, the controller will be the agreed entity. Notwithstanding the above, your personal data may be shared with the aforementioned Univio entities on the basis of legitimate legal interest, which is the fulfilment of internal administrative purposes and optimisation of business operations.

Contact details of the Data Protection Officer

The Data Protection Officer at Univio S.A., Univio International Sp. z o.o., Univio Systems Sp. z o.o. and Global4Net sp. z o.o. is Maciej Bednarek.

The Data Protection Officer can be contacted via: iod@univio.com.

Where do we obtain your personal data from?

We generally obtain personal data directly from you. This is the case when you submit a job application to us, via external job boards, via recruitment forms available on univio.com or when you contact us in other ways to submit a job application (e.g. when you send a message or call our recruiters directly).

We also obtain personal data indirectly from you. This is the case when we contact you using the data you have provided on your professional profile on LinkedIn or on other industry-specific services that are used to establish business relationships – in this respect, we only use your basic data to get in touch with you in order to start a business relationship.

What rights do you have in relation to the processing of your personal data?

Below we set out your rights relating to data protection and the fact that we process your data. The rights you have in a specific situation depend on the purpose for which and on what basis we process your personal data.

Right of access to data

You have the right to be informed about the personal data we hold about you. This entitlement applies to all processing of your data.

Right of rectification

You have the right to have the personal data held about you rectified and/or completed without delay. This right applies to all processing of your data.

Right to restrict processing

You have the right to ask us to restrict the processing of your personal data if you question the accuracy of the data held about you, if the processing is carried out without a legal basis, or if you have presented your objection to the processing, or if we no longer need the personal data for the purposes of the processing but you need it to establish, assert or defend your claims.

Right to erasure

You have the right to request the deletion of your personal data held by us, insofar as maintaining the data is not necessary to ensure freedom of expression, freedom of access to information, to comply with a legal obligation, for reasons of public interest, to report or defend against claims or to assert rights under the law.

Right to information

If you have requested the right to rectification, erasure or restriction of processing, we will notify all recipients of your personal data of how to rectify, erase or impose restrictions on the processing of that data, unless this is impossible to carry out or involves a disproportionate effort.

Right to data portability

You have the right to obtain a copy of the data you have provided to us, which will be sent to you or a third party in a structured, standard, machine-readable format. If you request that this data be sent to another data controller, this will be done as long as it is technically possible. This right only applies if we are processing your data on the basis of your consent or in connection with the performance of a contract.

Right to object

If your personal data is processed on the basis of our legitimate legal interest, you have the right to object at any time to further processing. We will consider your request in accordance with the rules under the law.

Right of withdrawal of consent

If your data is processed on the basis of consent, you have the right to withdraw it at any time, with future effect. This will not affect the legality of the data processed to date. You can withdraw your consent by writing to: hr@univio.com or iod@univio.com

Right to lodge a complaint with a supervisory authority

If the processing of your personal data violates data protection legislation or if your data protection rights have been violated in any other way, you may lodge a complaint with a supervisory authority. The supervisory authority with jurisdiction in Poland is the President of the Personal Data Protection Office in Warsaw (ul. Stawki 2). Before you exercise your right to lodge a complaint, we encourage you to contact us first so that we can clarify any doubts for you.

Processing of the request

If you make a request to us to exercise a particular right, we will respond to your request within one month of receiving it. If we need to extend this period, we will inform you of the reasons for the extension.

Your request will be answered at the e-mail address from which you send your request or, in the case of requests made by letter, by ordinary mail to the address you have indicated, unless it is clear from the content of the letter that you wish to receive feedback to your e-mail address (in which case you must provide your e-mail address).

Changes to the Recruitment Process Privacy Policy

The privacy policy is subject to periodic review and update as and when reasonably necessary. You can view the changes to date below.

October 2022

We have published a new version of this Privacy Policy dedicated exclusively to recruitment processes, in which we describe precisely the data processing rules occurring in these processes.

Part II. Processing of data obtained directly from you

Below we set out for you the principles for the processing of your personal data, which apply when you send us a job application, via external advertising services, via recruitment forms available on univio.com or when you contact us in any other way to submit a job application (e.g. when you send a message or call our recruiters directly).

For what purpose do we process your data?

We process your personal data to assess your qualifications to work in our team; to assess your abilities and skills needed for the job; to select the right person to work for us. Depending on the recruitment process, we process your data in order to take part in an ongoing recruitment process (applies to standard positions for which we recruit continuously) or a specific recruitment process (applies to specialist positions).

If you have given your explicit consent or if you send us a job application when we are not recruiting for a position, we will process your data in order to participate in future recruitment processes.

If you would like us to process your personal data also in case of future recruitment processes or in the future, when we are not actively recruiting at the moment, please include your consent to the processing of your data for this purpose in your CV.

On what legal basis do we process your data?

As part of our recruitment processes, we expect to provide personal data only to the extent necessary to select a candidate for a job or cooperation. We request that you do not provide information in a broader scope than the scope indicated by the Labour Code, among others. In the event that the applications sent will contain additional data beyond the scope indicated by the Labour Code, their processing will be based on the candidate’s consent, expressed by the candidate sending the application documents. In the event that the applications sent contain information that is not relevant to the purpose of the recruitment process, they will not be used or taken into account in the process.

If your preferred form of cooperation with us is an employment contract, the legal basis for processing your personal data is:

1. Legal obligation to provide personal data pursuant to Article 22 (1) § 1 and 2 of the Labour Code – when recruiting, we have the right to expect you to provide personal data such as: first name(s), surname, date of birth, contact details, education, professional qualifications, previous employment history;
2. Your consent to the processing of the data contained in your application documents, insofar as this data goes beyond the mandatory catalogue of data resulting from the Labour Code indicated above; you give your consent by sending us an application containing a broader catalogue of data than that resulting from the Labour Code;
3. our legitimate legal interest in verifying your qualifications and skills for the job in order to select a suitable person for the position for which recruitment is being carried out – in respect of personal data collected during the recruitment interview and the results of any selection tests;
4. Your consent to the processing of the above personal data for the purpose of participating in future recruitment processes expressed by ticking an optional checkbox or including a relevant consent clause in your CV.

If your preferred form of cooperation with us is a civil law contract, the legal basis for processing your personal data is:

1. Necessity to act at the data subject’s request before entering into a contract – when recruiting, we have the right to expect you to provide data to enable us to assess your competences and qualifications, such as: first or first names, surname, date of birth, contact details, education, professional qualifications, previous employment history;
2. Your consent to the processing of the data contained in your application documents, insofar as this data goes beyond the catalogue of data indicated above; you give your consent by sending us an application containing a broader catalogue of data than the catalogue indicated above;
3. our legitimate legal interest in verifying your qualifications and skills for the job in order to select a suitable person for the position for which recruitment is being carried out – in respect of personal data collected during the recruitment interview and the results of any selection tests;
4. Your consent to the processing of the above personal data for the purpose of participating in future recruitment processes expressed by ticking an optional checkbox or including a relevant consent clause in your CV.

How long do we process your data?

Most of our advertisements are for positions for which we are continuously recruiting. The selection of a particular candidate does not close the recruitment process. In these, the most common cases, we process your personal data for the time necessary to select the best candidate, but no longer than 8 months from receipt of your application.

There are occasions when we carry out a recruitment that is temporary in nature, with the aim of selecting only one specialist in a particular field. In these, rare, cases, we process your personal data for the duration of the recruitment process, but for no longer than 3 months after the end of the process.

If you consent to the processing of your personal data for the purpose of taking part in future recruitment processes, we will process your data for the duration of the consent given, but no longer than until you withdraw it. You can withdraw your consent by writing to: hr@univio.com or iod@univio.com

Who is the recipient of your personal data?

The recipients of your personal data, i.e. the external entities involved in the processing of your data, will be our trusted subcontractors – IT service providers for data hosting and business mail services (Microsoft Ireland Operations Limited) and the recruitment platforms through which we recruit, including most notably the owner of the Pracuj.pl platform (Grupa Pracuj S.A.).

The recipient of your data may also be Calendly LLC, a US company that provides a tool that makes it easy to synchronise calendars and arrange recruitment appointments at a mutually convenient time.

The recipients of your personal data may also be other Univio entities, viz: Univio Systems sp. z o.o., Univio International sp. z o.o. or Global4Net Sp. z o.o.. The basis for processing your data is the legitimate legal interest of internal administrative purposes and optimisation of business operations.

Nature of data provision

The provision of personal data required by the Labour Code, where your preferred form of employment is a contract of employment, and personal data indicated as mandatory, where your preferred form of employment is a civil law contract, is mandatory. We are entitled to expect you to provide this data as it enables us to consider your application. Failure to provide such data will prevent your application from being considered.

The provision of other data is voluntary and does not affect the recruitment process.

Other relevant information

Your data is only processed* in the European Economic Area, which consists of the member states of the European Union plus Norway, Iceland and Liechtenstein. We use Microsoft’s services, but your data is not processed outside the aforementioned area.

Your data is not subject to profiling.

*Only with regard to the use of Calendly’s calendar synchronisation tool may there be processing of data outside the EEA, which may increase risks for data subjects, which are however minimised by the processing of only the recruit’s email address in this way and the use of the mechanism of standard contractual clauses. Calendly ensures a high level of protection by applying numerous technical and organisational security measures.

Part III. Processing of data obtained indirectly from you

In the following, we set out for you the principles of personal data processing that apply to the processing of data of persons we contact ourselves using contact data from publicly available sources, such as LinkedIn or company websites. In this respect, we may contact you insofar as you have made your contact details available on professional portals and, in particular, you are looking for a job or your professional interests remain aligned with ours.

For what purpose do we process your data?

We process your data to determine whether you are interested in entering into a partnership.

Where such cooperation is possible, we further process your personal data to assess your qualifications to work in our team; to evaluate your abilities and skills needed for the job; to select the right person to work for us. Depending on the recruitment process, we process your data in order to take part in either an ongoing recruitment process (applies to standard positions for which recruitment is ongoing) or a unitary recruitment process (applies to specialist positions).

If you have given your explicit consent or if you send us a job application when we are not recruiting for a position, we will process your data in order to participate in future recruitment processes.

If you would like us to process your personal data also in case of future recruitment processes or in the future, when we are not actively recruiting at the moment, please include your consent to the processing of your data for this purpose in your CV.

On what legal basis do we process your data?

Where we initiate contact to encourage you to take part in a recruitment process, the legal basis for processing your data is our legitimate legal interest in finding a candidate for a job or collaboration whose professional expectations and skills may coincide with ours.

We process your personal data on the basis indicated until you decide to take part in a specific recruitment process by sending us an application (cv).

You can express your willingness to participate in a specific process in a number of ways, by sending us a relevant email, by direct message on LinkedIn or in a telephone conversation with our recruiter, after which you will receive the relevant confirmation by email.

As part of our recruitment processes, we expect to provide personal data only to the extent necessary to select a candidate for a job or cooperation. We request that you do not provide information in a broader scope than the scope indicated, among others, by the Labour Code. In the event that the applications sent will contain additional data beyond the scope indicated by the Labour Code, their processing will be based on the candidate’s consent, expressed by the candidate sending the application documents. In the event that the applications sent contain information inappropriate for the purpose of recruitment, they will not be used or taken into account in the recruitment process.

Once you have expressed your willingness to participate in the recruitment process, if your preferred form of cooperation with us is an employment contract, the legal basis for processing your personal data is:

1. Legal obligation to provide personal data pursuant to Article 22 (1) § 1 and 2 of the Labour Code – when recruiting, we have the right to expect you to provide personal data such as: first name(s), surname, date of birth, contact details, education, professional qualifications, previous employment history;
2. Your consent to the processing of the data contained in your application documents, insofar as the data goes beyond the mandatory catalogue of data resulting from the Labour Code indicated above; you give your consent by sending us an application containing a broader catalogue of data than that resulting from the Labour Code;
3. our legitimate legal interest in verifying your qualifications and skills for the job in order to select a suitable person for the position for which recruitment is being carried out – in respect of personal data collected during the recruitment interview and the results of any selection tests;
4. Your consent to the processing of the above personal data for the purpose of participating in future recruitment processes expressed by ticking an optional checkbox or including a relevant consent clause in your CV.

If your preferred form of cooperation with us is a civil law contract, the legal basis for processing your personal data is:

1. Necessity to act at the data subject’s request before entering into a contract – when recruiting, we have the right to expect you to provide data to enable us to assess your competences and qualifications, such as: first or first names, surname, date of birth, contact details, education, professional qualifications, previous employment history;
2. Your consent to the processing of the data contained in your application documents, insofar as this data goes beyond the catalogue of data indicated above; you give your consent by sending us an application containing a broader catalogue of data than the catalogue indicated above;
3. our legitimate legal interest in verifying your qualifications and skills for the job in order to select a suitable person for the position for which recruitment is being carried out – in respect of personal data collected during the recruitment interview and the results of any selection tests;
4. Your consent to the processing of the above personal data for the purpose of taking part in future recruitment processes expressed by ticking an optional checkbox or including a relevant consent clause in your CV.

How long do we process your data?

By acquiring your data on the basis of legitimate legal interest, we aim to obtain clear information from you regarding the possibility of a potential collaboration. We cease to process your personal data if you do not express your willingness to participate in the recruitment process within one month of the acquisition of your data.

The following provisions will apply in the event of an expression of intent.

Most of our advertisements are for positions for which we are continuously recruiting. The selection of a particular candidate does not close the recruitment process. In these, the most common cases, we process your personal data for the time necessary to select the best candidate, but no longer than 8 months from receipt of your application.

There are occasions when we carry out a recruitment that is temporary in nature, with the aim of selecting only one specialist in a particular specialisation. In these, rare, cases, we process your personal data for the duration of the recruitment process, but for no longer than 3 months after the end of the process.

If you consent to the processing of your personal data for the purpose of taking part in future recruitment processes, we will process your data for the duration of the consent given, but no longer than until you withdraw it. You can withdraw your consent by writing to: hr@univio.com or iod@univio.com

Who is the recipient of your personal data?

The recipients of your personal data, i.e. the external entities involved in the processing of your data, will be our trusted subcontractors – IT service providers for data hosting and business mail services (Microsoft Ireland Operations Limited) and the recruitment platforms through which we recruit, including most notably the owner of the Pracuj.pl platform (Grupa Pracuj S.A.).

The recipient of your data may also be Calendly LLC, a US company that provides a tool that makes it easy to synchronise calendars and arrange recruitment appointments at a mutually convenient time.

The recipients of your personal data may also be other Univio entities, viz: Univio Systems sp. z o.o., Univio International sp. z o.o. or Global4Net Sp. z o.o.. The basis for processing your data is the legitimate legal interest of internal administrative purposes and optimisation of business operations.

Nature of data provision

The provision of personal data required by the Labour Code, where your preferred form of employment is a contract of employment, and personal data indicated as mandatory, where your preferred form of employment is a civil law contract, is mandatory. We are entitled to expect you to provide this data as it enables us to consider your application. Failure to provide such data will prevent your application from being considered.

The provision of other data is voluntary and does not affect the recruitment process.

Other relevant information

Your data is only processed* in the European Economic Area, which consists of the member states of the European Union plus Norway, Iceland and Liechtenstein. We use Microsoft’s services, but your data is not processed outside the aforementioned area.

Your data is not subject to profiling.

*Only with regard to the use of Calendly’s calendar synchronisation tool may there be processing of data outside the EEA, which may increase risks for data subjects, which are however minimised by the processing of only the recruit’s email address in this way and the use of the mechanism of standard contractual clauses. Calendly ensures a high level of protection by applying numerous technical and organisational security measures.