1.0 Introduction
INEOS Inovyn collects and processes personal data for recruitment purposes. We are committed to being transparent about how we collect and use that data in order to meet our data protection obligations.

2.0 What data do we collect?
If you apply for a position within the Company we will ask you for your name, email address and telephone number so that we can contact you if necessary. We will also ask you for education details including training and qualifications to assess your competency; details of your previous employment; for a copy of your resume/CV; and for information about your working and salary expectations. You may include similar personal data within your CV and/or provide additional personal data that INEOS Inovyn does not require. This is done so at your discretion.

During our apprenticeship selection process we will also collect assessment data. 

INEOS Inovyn may collect data in a variety of ways. For example, data is collected from application forms or CVs; from correspondence with you; or through interviews, meetings or other assessments; via secure access systems; and via CCTV for security purposes when it exists on any Company premises you may visit.

In some cases, we collect personal data about you from third parties, such as references supplied by former employers (with your authorisation in Germany).

Data is stored in a range of different places in the Company’s HR management systems.

3.0 Why do we process personal data?
INEOS Inovyn collects and processes personal data for recruitment purposes.  

If you apply for a position, we will carry out work permit checks to ensure you have the legal right to work in the EU or in the country where you are applying for employment. 

4.0 Who has access to data?
Your data will be shared internally with members of the HR team, however they may share this with other INEOS Inovyn or INEOS colleagues who are involved in the recruitment, selection or interviewing process.

Personal data may also be shared with third parties who carry out background checks on behalf of INEOS Inovyn (with your authorisation in Germany). Contractual agreements are in place to ensure your personal data is protected.

5.0 How do we protect your data?
We take the security of your data seriously. The Company has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by its employees in the performance of their duties. Please refer to the INEOS Inovyn Data Protection Policy for more details. Access to databases or systems holding data about you is restricted to authorised users. 

We are in the process of putting in place additional IT security controls including:

• Multi Factor Authentication for secure access to our Office 365 environment;
• hard drive encryption on laptops to prevent unauthorised access to data stored on the laptop in the event it is lost or stolen; and
• measures to prevent the use of removable hard drives (including USBs) so that Company data is not stored in unauthorised locations.

Where we engage third parties to process personal data, they do so on the basis of written instructions. They are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.

6.0 How long do we keep data?
We will hold your personal data for the duration of 6 months in Norway, 6 months in Germany, and 2 years in other countries after you have provided us with the data.

If you gain successful employment with us we will retain your personal data and transfer this to your personnel file. A separate privacy notice will be provided to you in these circumstances.

7.0 Your rights
As a data subject, you have a number of rights. You can:

• access and obtain a copy of your data upon request;
• require that we change incorrect or incomplete data about you;
• require that we 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 us to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override the Company’s legitimate grounds for processing data.

If you would like to exercise any of these rights, please contact the nominated employee or Data Protection Officer for INEOS Inovyn in your country.

If you believe that the Company has not complied with your data protection rights, you can complain to the relevant Information Authority in your country.

This information is version controlled and will be reviewed and updated on an annual basis, or when there is a major change.

END

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