Employees & Candidates Information Note on Personal Data Protection

1. Introduction
 
Welcome!
 
Information note of AmRest Coffee SRL employees, candidates or part-time / project-based personnel
 
This information note explains the way we collect and use  Personal Data  belonging to:
 
  • Candidates
  • Our colleagues , including all employees, workers, freelancers, individuals working with us on a contractual basis, interns, agents, director and other third parties whose data is disclosed to us in relation to one of these relationships ( i.e., close relative , emergency contact, etc.)
  • Former colleagues
 
This information note is issued by AmRest Coffee SRL with its headquarters in 46 Grigore Cobălcescu Street, 2nd floor, room 11, Bucharest, District 1, Romania. When we refer to "AmRest" "Starbucks", "We", "our", we refer to the departments within AmRest that process Personal Data and to those third parties who do this on our behalf. The company identified in your employment contract or in the collaboration / service contract (whether provided by you or a third person for a recruiting firm) is the personal data operator of your Personal Data.
 
You are a Data Subject under the Personal Data Protection (" GDPR ") Privacy Policy and some rights granted by this position. Our company grants greater interest to employees and candidates as outlined above, and in order to establish a lasting relationship based on trust, we consider that a first step is to protect your Personal Data.
 
It is important to read this information note along with any separate privacy notices / policies that we may provide when collecting personal data from you. Any such notification is important. These shall identify AmRest (or a third party) that is legally responsible for managing your Personal Data and shall provide you with more Information on how we, and any third party shall use your personal data collected, your rights and, in some cases, any other provisions that may apply to the processing of such personal data.
 
We can get your consent for certain processing. If consent for such processing is required, it shall be requested separately (either in a personal data processing notice or in another manner) directly by us or by a third party designated to do so on our behalf.
 
 This helps us ensure that you give your consent in a free, informed and explicit manner.
 
 
We only use Personal Data for the purposes we have collected it for, unless we reasonably believe that we must use it for another reason and that the reason is compatible with the original purpose. If the way Personal Data is handled differs from this information note or is incompatible with the original purpose for which Personal Data was collected, additional information shall be provided on such processing and, if necessary, we obtain your consent and we explain the consequences if you choose not to agree. You should know that it is not a condition or a requirement of your relationship with us to agree to any request that comes from us.
 
Please note that we may process your Personal Data without notifying you or without your consent, according to this information note if this is required or permitted by the applicable law.
 
If you have any questions about the way we manage your Personal Data, read this information note and the details provided here. If you still have questions, you can use the contact details provided to ask these questions directly.
 
We may change from time to time this information note to be updated, according to the current legal requirements and the way we conduct our activity.
 
 This information note was last updated on 10/10/2018.
 
2. General Information on Personal Data Processing

We have provided some Information on the way we manage the Personal Data below as Frequently Asked Questions.
Also in sections 2.1., 2.2. and 2.3. you find information on the way we use Personal Data.
 
If you have a question that was not answered below, use the Contact Details provided to ask us directly.
 
QuestionAnswer
What is the basis for processing Personal Data?

For processing Personal Data, we must ensure we have a special reason to do so. We have outlined the reasons we have for the processing of Personal Data in this information note.

These reasons may be grouped into one or more legal grounds for processing, which directly refer to the necessary legal grounds for processing set out in the GDPR and Law no. 190/2018. We have also identified these general processing grounds in this Information Note.

Please contact us in order to receive more information on the legal grounds for processing or our legitimate interests, if you have any questions or want more details than those described in this Information Note.

The legal grounds for processing and what these mean are described below:

Legal groundsDescription
Processing is required to conclude a contract with you.

We may process Personal Data if the processing is required for the performance of a contract to which you are a party or to take action / perform different actions on your application

This means that we can take the necessary actions to conclude or execute our contract with you. For example, we need information from you to pay you and give you certain benefits (i.e. meal vouchers, personal deductions, medical subscriptions, etc.).

Processing is necessary to meet a legal obligation.

We may process Personal Data if such processing is necessary to comply with a legal obligation, which we are subject to.

So we can do take all the actions to comply with the laws. This could include compliance with labor law, tax requirements or immigration rules.

Processing is necessary in our legitimate interest.

We may process Personal Data if the processing is necessary in our legitimate interests, provided your interests and rights do not prevail over our interests.

If we rely on this reason as a legal basis for our processing, we tell you what our legitimate interests are (either in this Information Note or in another such note).

We perform all actions it deems necessary for the interest as long as we believe that the processing does not affect adversely your rights and interests regarding privacy.

What are the Special Categories of Personal data?

Special Categories of Personal Data  means any Personal Data referring to racial or ethnic origin, political opinions, religious confession or philosophical beliefs or trade union membership, genetic data, biometric data, health data, or life data sexual life or sexual orientation. 

Medical Information    and  Information on Cultural  Diversity is part of the Special Categories of Personal Data. 

What is the ground to justify the processing of Special Categories of Personal dat and criminal records verification?

In order to perform any processing of Special Categories of Personal Data , we must make sure that we have a special reason to do so - in addition to the reasons for processing Personal Data set out in this Information Note. We have outlined the reasons we have for the processing of the Special Categories of Personal Data in this Information Note.

These reasons may be grouped into one or more legal processing grounds, which directly relate to the grounds for processing the Special Categories of Personal Data set out in GDPR and Law no. 190/2018. We also identified these grounds in this notice, where they are processed Special Categories of Personal Data. 

The same grounds can also be invoked for the processing of information   Verification of the criminal record.  

These reasons and what they mean are described below:

Legal groundsDescription
Processing is required to meet requirements of the labor law

This means that processing is necessary to fulfill the obligations and to exercise your rights or our rights in the field of labor law, social security and social protection (such as legislation on occupational health and safety).

This means that we can take any action necessary to fulfill our obligations arising from the labor law, tax law and social protection. This could include Personal Data management in accordance with the labor law or to comply with the requirements on reporting to competent authorities/ institutions (i.e. employment contracts registration in REVISAL).

Processing is required for occupational medicine ( HSE)

Our external and / or internal consultants on occupational health may process Special Categories of Personal Data if processing is required for training and information purposes to meet the statutory occupational safety requirements or to provide a medical diagnosis.

This means that our health team can manage your medical information to provide you with medical or professional health services.

Processing is required for fire prevention and firefighting ( PSI )Our external and / or internal fire prevention and security consultants may process Special Personal Data Categories if processing is required for training and information purposes to meet the statutory occupational safety requirements. This means our team can manage certain information to provide you with these services.
Processing is necessary for reasons of public interest 

This means that the processing is necessary for reasons of considerable public interest, as stipulated in GDPR and Law no. 190/2018.

This includes (without limitation) the processing of Personal Data in order to prevent the detection of illegal acts, equal opportunities or treatment between different groups of people and as a result of regulatory requirements for illegal acts.

Processing is necessary to protect your vital or other interests

This means that processing is necessary to protect your vital interests or those of another person to whom you are physically or legally incapable of giving consent.

This means that we process personal data in exceptional emergency such as a medical emergency, for example 

Processing is necessary for insurance This means that processing is necessary to provide you insurance and insurance products for you and your family members.
Processing is required for retirementThis means that processing is necessary to make a determination regarding eligibility or benefits payable under a pension scheme (compulsory or optional).
Processing is necessary for legal claims This means that processing is necessary for the establishment, exercise or defense of legal rights.
What if I do not provide Personal Data?In some cases, you may choose not to provide us with your Personal Data- however, if we do not have specific information, we may not be able to continue with you if we consider that we need the information relevant to our relationship. This would make collaboration impossible. For example, we ask you  Information on Identity,    Contact Details    and  Payroll Information   to pay your wage. If this information is not provided to us, we may not be able to manage the contractual relationship that we have or that we intend to have with you.
How do you keep Data secure?

We are committed to protecting the confidentiality and security of the data provided by investing in robust technical, physical and organizational security controls to protect information against unauthorized access, damage, disclosure or loss.

For more details, read the Security Policy or contact us.

Where do you take Personal Data from?

In most cases, we receive personal data directly from you. You provide us (you or a third party) at the time of recruitment, or you do so at some point during the employment relationship. These shall include Personal Data that you enter in a form or through an on-line / on-line software program, as well as the information you provide to the human resources team and your manager.

For example, you provide us with information directly in a request form, resume or similar document. You shall provide this through our human resources team, a manager, or through our online or third-party portals.

We can create personal data about you during employment.

As mentioned earlier, in some cases, we obtain

Personal Data about you from third parties.

Internal sources

In addition to the Personal Data you provide to us, we may generate internally other Personal Data. Managers and / or the human resources department shall usually generate this.

For example, we create interview notes during recruitment and we also give you regular feedback as part of your development and any performance management processes.

Under certain circumstances, data may be collected indirectly from monitoring devices or by other means (e.g. building and localization control and monitoring systems, CCTV, logs and telephone records and e- mail and Internet). Under these circumstances, the data may be collected by us or by a third party service provider.

External sources

Due to the size and complexity of our operations, it is not possible to mention each source of Personal Data in this Information Note. However, we can obtain information from third parties, for example references from an earlier employer, medical reports from external professionals, tax authorities,

service providers or a third party if we contract for a substantive verification (where permitted by applicable law). Contact us if you have any questions about your Personal Data source or want more details than those listed in this Information Note.

When do you transfer data to other parties?

Within our company, Personal Data can be accessed or can be internally disclosed as needed.

Personal Data may also be accessed by third parties, including service providers (e.g. accountants, HR, human resources, concierge, healthcare, etc.), counselors, national authorities and governmental bodies.

f such third parties act as empowered persons (for example, a provider who performs screening before you start your business on our behalf), they perform their tasks on our behalf and according to our instructions for the purposes set out in this Information Note. In this case, Personal Data shall be disclosed to those parties only to the extent necessary to provide the requested services.

In some cases, the external recipient may also be a Personal Data Operator. In this case, you may be provided with an additional notice of processing your Personal Data.

Internal Recipients

Internal recipients of Personal Data include:

- local and global human resources departments, including managers and team members;

- local and executive management in charge of managing or making decisions about your relationship with us, or when involved in a human resources process with us, including, but not limited to, company staff, secretariat, compliance department, legal department, the investigative and audit department, etc. .;

- security department.

External recipients

Due to the size and complexity of our operations, it is not possible to mention each of our external data recipients in this notification.

Examples of third parties with which Personal Data shall be distributed include:

- our clients;

- service providers;

- tax authorities,

- regulatory authorities,

- our insurers / reinsurers,

- bankers,

- IT administrators,

- lawyers,

- auditors,

- investors,

- consultants and other professional counselors,

- human resources & payroll providers,

- public authorities and institutions,

- providers that offer benefits (i.e. health benefits, meal vouchers )

- accounting firms and

- administrators of our benefit programs (if outsourced).

Personal Data contained in HR and other interconnection systems can be accessed by the providers of their respective systems, associated companies and their subcontractors (such as those involved in hosting, supporting and maintaining the framework of our human resources or accounting systems).

We expect these third parties to process all data disclosed to them in accordance with their contractual relationship with applicable law, and us, including privacy and data security.

In addition, it is possible to share Personal Data with national authorities in order to comply with a legal obligation to which we are subject. This happens, for example, in legal proceedings or statutory / statutory audits.

Is Personal Data transferred outside  EEA ?

We share Personal Data within the company / group of companies as described in this Information Note. Some people accessing your Personal Data may not be in the same country as you and may be outside  EEA.

Any transfer within the group of companies shall be covered by an intra-group agreement that provides specific contractual protections to ensure that Personal Data receives an adequate and consistent level of protection whenever it is transferred to the group of companies.

In addition, some external organizations we share Personal Data with, may be located outside of the EEA. We always take steps to ensure that any transfer of information outside the EEA is carefully managed to protect your privacy:

- we transfer Personal Data only to countries that are recognized as offering an adequate level of legal protection or in which we can be convinced that there are alternative arrangements to protect your privacy,

- transfers to service providers and other third parties shall be protected by contract (such as the standard contractual clauses approved by the European Commission), certification systems (e.g. the EU-US data protection shield for the protection of personal data transferred from within the EU in the United States) or other legally acceptable mechanisms to ensure an adequate level of protection, and

- any request for information received from law enforcement or regulatory authorities shall be carefully checked before disclosure of Personal Data.

How long do we store your Personal Data?

We keep your Personal Data for as long as reasonably necessary for the purposes explained in this Information Note. Under certain circumstances, we may keep Personal Data for longer periods, for example, when we are required to do so in accordance with legal, regulatory, fiscal or accounting requirements.

In some cases, we may also keep your Personal Data for longer periods so that we have an accurate record of your relationship with us in the event of any complaints or if we reasonably believe that there is a possibility of dispute related to your relationship with us.

The Rules and Best Practices for Retaining Personal Data can be found in our Privacy Policy. If Personal Data is no longer required, we ensure that it is either deleted or securely stored in a way that no longer identifies (i.e., anonymization).

In general, we keep your Personal Data only for as long as it is necessary for the purposes for which it was collected. This shall usually be the period of employment or the period of collaboration with us, plus the length of any prescription period applicable after your departure or termination of the collaboration agreement with us, although some data, such as pension information, may be necessary for over a longer period of time. We may retain specific types of data, such as tax records, for different periods of time, in accordance with applicable law and set out in our Privacy Policy.

How do we manage collecting Personal Data about other people?

In addition to personal data that concerns you, you may also provide us with Personal Data of third parties. For example, you can provide us with Information on relatives,  as described in this Information Note.

Before you provide us with Information on other people, you must first inform them about the data you intend to communicate to us and about the processing, we must perform, as detailed in this Information Note.

How do we handle changes to this Information Note?

We may occasionally change this Information Note, for example, update it or update it with the new legal requirements, or highlight changes in the way we operate.

This Information Note was last updated at 

 10/10/2018.


2.1. Learn more about Common Personal Data
 
Please be aware that we can find out if we do not process all the Personal Data categories listed below at this time, but we have decided to introduce them in order to have a broader view of our responsibility, including future, on the protection of personal data.
 
The type of personal data owned by usWhy do we use itLegal grounds
Biographical data (including name, title, contact details, date of birth, sex, emergency contact details, photo)

In order to manage the contract as follows: Emergency contact data to be able to take care of your welfare in emergency situations; sex - for reporting differences  of  remuneration  between women and  men  and monitoring equal opportunities; date of birth 

– for analyzing, managing and improving bonuses/ benefits

- photo - for identity badges and intranet / website , to help colleagues / clients and security staff to identify you

Legal obligation

Contract termination

In our legitimate interest in having emergency contact details to inform a person designated by you in an emergency.

In our legitimate interest in providing benefits to our staff

In our legitimate interest to  use photos to help colleagues / clients / security to identify you

Information on recruitment (including correspondence / references /Contract management and verification and demonstration of your legal right to work in Romania

Legal obligation

Contract termination

The right to  employment inspections and related documents)In our legitimate interest in keeping relevant and appropriate recruitment records  for business administration and job management
Employment details (including start date, contract terms, location, job title, career history)

Contract management

Manage our relationship with you continuously

Details  about role / experience, etc. can be used in communication with existing and potential customers

Legal obligation

Contract termination

In the legitimate interests   to manage our current relationship and to promote products / services to our customers and potential customers

Payroll, taxes, insurance and bank details Payment, deduction of taxes and insurance, keeping appropriate records

Legal obligation

Contract termination

Working hours

Appropriate payment

Compliance with legal requirements on working time

Management of participation ,  operational management and resolution  of daily requests for changes on working hours

Legal obligation

Contract termination

In our legitimate interest in managing working hours / arrangements to ensure efficient business operations

Payments and benefits, including pensions (and information needed to manage them) and expensesFor offering / covering the agreed payments, benefits and expenses;  making decisions on future compensation ; tracking and reviewing payments, benefits, and expenses; taking strategic decisions on compensation; auditing and reporting the financial position of the company

Legal obligation

Contract termination

n our legitimate interest to analyze remuneration, benefits and costs and to make decisions about appropriate compensation at individual and company level

Performance and career progress (including performance management, setting goals, taking into account new tasks / roles)To ensure that you perform tasks according to your contract and the standards we request; taking into account future the tasks/roles ; establishing the wage increases based on performance; determining eligibility for performance bonuses

Contract termination

In our legitimate  interests to manage performance and duties / roles for ensuring effective operations of the business and to determine appropriate levels of remuneration

Qualifications (including education, professional, management, if any) and trainingTo make sure you are qualified and properly trained for current or potential roles

Legal obligation

Contract termination

In our legitimate interest to ensure that you have appropriate qualifications and training for your current or future potential roles

Leaves and other holidaysManaging holidays / free days  legal and planned  and other holidays

Legal obligation

Contract termination

In our legitimate interest for ensuring the leave is compatible with our business requirements and that further operational adjustments are made

Aspects relating to discipline, conduct and complaints about you or in which you are involvedinvestigation and resolution of matters pertaining to discipline, conduct and complaints about you or you are involved

Legal obligation

Contract termination

In our legitimate interests to deal effectively    with disciplinary , behavioral issues or complaints, whether you are the subject of or are otherwise related to the  issues raised

Public interest in the detection or prevention of illegal acts

Health and safetyPerforming risk assessments; establish safeguards to mitigate the risks identified ; ensuring a safe environment for efficient business operation

Legal obligation

In our legitimate interest, to ensure that employees can perform their duties in a safe working environment ; keeping the necessary records

Modification of employment conditions or termination of employmentContract management, by modifying employment conditions depending on business requirements ; continuously managing our relationship , including during notification; promotions, role changes and other career progresses; employment relationship termination whether it was initiated by our company or by you; post-employment issues management

Legal Obligation

Contract Execution

In our legitimate interest in managing, modifying and, where appropriate, concluding  the contractual relationship or responding to resignations and effectively addressing post-employment problems 

CCTV recordingsFirst, for security reasons, although we may use CCTV recordings when investigating allegations concerning employees misconduct

Legal Obligation Contract Execution

In our legitimate interest in dealing effectively with allegations of misconduct and maintaining the security of our premises

Information on using our business equipment, technology and systems, including computers/telephones/ mobile phones/software/applications/social media/access or timekeeping systems and monitoring systems and/or performance recording

Maintain the functioning, security and integrity of business communications systems (e.g., protection against hackers, malware, etc.); providing support for information and communication systems; preventing excessive personal use;

[registration of customer communication for quality control and for training / training purposes; ensuring safety; time management; employment rate / labor efficiency ratio]

Contract termination

In our legitimate interest in maintaining the functioning, security and integrity of communications systems, prevent excessive use of

business resources for personal purposes and to monitor and maintain the quality of customer communications; the time recorded and the rate / efficiency of work

Personal data produced by you and others during your business (e.g. job-related emails, meeting minutes, written reports, social presence in the business environment, etc.)Fulfilling your service tasks by you and your colleagues; the conduct of the company's business; monitor your presence on the social media business to make sure you meet the expected standards

Contract termination

In our legitimate interest in achieving the business plan

Personal data, which may include any of the data types presented in this appendix that are relevant to our strategic decision-making processes, business planning, current and potential legal claims, corporate reporting and business risk analysisTo allow us to operate the company, to analyze the current performance of the business, planning for the future, to present information in reports audiences relevant such as shareholders, to protect the company from legal complaints, seeking professional  advice when necessary, during the course of our activity 

Legal obligation

Contract termination

In our legitimate interest in making the company's business plan, including making strategic decisions in the business interest, communicating about business to the relevant governing bodies and soliciting professional advice, where applicable 


2.2. More about Special Categories of Personal Data 
 
Please be aware that we can find out if we do not process all the Personal Data categories listed below at this time, but we have decided to introduce them in order to have a broader view of our responsibility, including future, on the protection of personal data.
 
The type of special category of personal data we ownWhy do we use itLegal groundsThe special category of the legal ground
No illness and medical information (including absenteeism records and its management, Information on any medical condition and  physician reports) drug and alcohol testsPayment  medical leave; health insurance; absence management and ensure appropriate replacement; considering how your state of health affects your ability to do your job and necessary adjustments which can involve medical advice   in this regard; health and safety requirements

Legal obligation

Contract termination

Our legitimate interest to manage employees in   health care, to  maintain a safe working environment and manage absence of employee illness and ensure adequate coverage  in case of absenteeism

Legal obligation / employment law

Work capacity assessment

In exceptional circumstances, to protect  your interests or the interests of someone else if consent cannot be obtained

Family leave (including maternity, paternity adoption, parental leave  ) (which could include Information on health, religion,  sexual life   or sexual orientation)

Facilitating   family leave; payment of indemnity of maternity,paternity, adoption, absenteeism management and ensuring an adequate replacement 

Legal obligation

Contract termination

In our legitimate interest, to manage absences and ensure  a proper replacement

Legal obligation / right in terms of employment

Work capacity assessment

Union membershippay union fees; facilitating meetings with representatives of trade unions for collective negotiations ; compliance with the legal obligations provided by the Law on Social Dialogue and other legal provisions in the matter

Legal obligation

In our legitimate interest in engaging with trade union representatives and managing and facilitating employee meetings with them

Legal obligation / right in terms of employment
Equality and diversity (which may include Information on race or ethnicity, religious beliefs, sexual orientation or health).To monitor equality and diversity in our organization, to comply with the  organization policiesIn our legitimate interest to understand the way our organization intervenes in terms of diversity and equal opportunitiesPublic interest in monitoring equal opportunities of workforce
Convictions / criminal offensesIn the case of a criminal conviction, to investigate and assess the impact, if applicable, employment for an indefinite period

Legal Obligations 

Contract termination

In our legitimate interest to determine if we hire people with criminal convictions in certain roles / positions

The information was clearly made public

exercise  or the defense of legal claims

Public interest in detecting or preventing illegal acts


2.3. More Information on the way we distribute Personal Data (if applicable)
 
Please be aware that we can find out if we do not process all the Personal Data categories listed below at this time, but we have decided to introduce them in order to have a broader view of our responsibility, including future, on the protection of personal data.
 
Who do we share your data with?What data do we share?Why do we share data?Legal grounds
National Agency for Fiscal Administration (NAFA)Data on pensionsIn order to ensure adequate pension contributions.

Legal obligation

Contract

termination

Our legal advisers and other professionals appointed from time to timeAny of your personal data would be relevantTo obtain legal advice   or   of another     professional nature   with regard to issues related to you or in the course of resolving legal disputes with you or other employees; to get advice on business management and planning, including accounting advice

Legal obligation

Contract termination

In our legitimate interest in seeking professional advice in order to clarify our rights / obligations and to adequately defend us from possible claims; to manage the business and finances (Regarding special category data - obligation/ legal rights in relation to employment of work defending legal claims) 

Professionals in the field of occupational health / medical professionalsDetails regarding absences in case of    sickness, relevant information we already have on to your health / medical condition Generating a medical report about you to conduct assessments required by legislation on occupational health and safety

In our legitimate interest to manage illness, absence and health problems occurring in workforce

In our legitimate interest to manage illness, absence and health problems occurring in workforce

Potential buyers / new service providersAny of your personal data would be relevantTo provide relevant information to potential buyers  or suppliers  of services    in case of a possible business transfer,     sale,  takeover or other corporate transaction

Legal obligation

In our legitimate interest to consider / continue with  a transfer / sale of the business and when information  is required by potential buyers

Customers, potential customers, shareholders and stakeholders

Any of your relevant personal

data, including,  in particular, business information and experience in the position occupied

Including   corporate reports for use in  business communications to obtain security authorizations to work directly at the customer's headquarters (in-house)


Legal obligation

In our legitimate interest in communicating about our business and employees to the public, including customers, potential customers, shareholders and other stakeholders

Third parties upon your requestRelevant details on employmentUpon your request, to provide a reference to a potentially new employer/details on your job to a bank or credit institution

Based on your consent

In our legitimate interest in reasonably acting on requests to provide your personal data to third parties


3. All colleagues
 
We perform certain processing activities for all employees and collaborators, regardless of the type and status of the relationship you have with us. Insofar as such Personal Data are not collected from you, they are generated internally through Managers, the Human Resources Department, and the Payroll Department.
Click on the links below to learn more about these activities and types
of Personal Data that we usually process for all our colleagues.
 
In particular:
 
ActivityDescription
Reporting

We process Personal Data to analyze trends and patterns, which can include centralized staff / department performance to make better business decisions in terms of resources and structural performance within business departments and processes, with better results from our customers.

In this regard, depending on the nature of the relationship we have with you, we process Information on Career, Contact details, Information on Rights ,    Information on    Identity ,    Information on Employment,    Information    on departures ,       Medical information,    information on Relatives,       Information on remuneration,       Information on Performance ,    Human Resources Information,    Regulatory Information ,    Information on Remuneration ,    Information on Abilities ;    Information on Termination,    Information on training .  

We process such Personal Data in our legitimate interests to understand and analyze our business operations.

Diversity, Inclusion and Equal Opportunities

As an equal opportunity employer, we monitor and analyze the diversity of candidates and the existing workforce. We do this to ensure that we observe our obligations and promote a diverse workplace that promotes equal opportunities for all.

The Personal Data we process for this purpose are  Information    on Identity,    Information on Nationality   and  Information   on Diversity.  

We process such Personal Data because it is necessary for the performance of our legitimate interests to manage and monitor equality at the workplace.

Information on diversity  is a  Special Category of  Personal Data.   To the extent that this activity is required by applicable law, we process such Personal Data to comply with our legal obligations to report certain information in a statistical format. Otherwise, we rely on our major public interest in ensuring equal opportunities or treatment between different groups of people. 


4. When applying for a position with us
 
When applying for a position within our company, we process your Personal Data  
to manage your application.
 
Click on the links below to learn more about these activities and about the Types of Personal Data that we typically process about recruiting and selecting candidates.
In particular:
 
ActivityDescription
Acceptance of the application

We need to know who you are and identify you so we can get in touch with you for your application.

We use  Contact Details, Information on Identity and   Information on Nationality   to establish your identity and accept your application. We can also use the  Regulatory Information  if you apply for a position requiring certain legal qualifications.

We do so to prepare to conclude a contract with you and on our legitimate interest in complying with legal / statutory obligations.

We can add new elements to the information you provided us when we do the identity verifications and when we analyze the application. Any new Personal Data shall be generated internally through the human resources department or the management team.

If your application is managed by a recruiting agency or a third person acting on our behalf, this information shall be received from the agency or third person.

Diversity, Inclusion and Equal Opportunities

During the recruitment process, we communicate with you on your application.

We process your  Contact Details  and Information on Identity .

We do this in order to prepare to conclude a contract with you and in our legitimate interest in managing an efficient recruitment process.

The content of any communication with you (whether we are talking about your application or related issues) shall be generated by our recruiters, personnel in the Human Resources department and management teams.

Analysis and selection

To analyze to what extent you fit a particular position, we collect and process your Personal Data. This analysis includes the analysis of your qualifications, educational background, work experience and skills that we compare with those of other candidates and with the specific requirements of the respective position.

We process   Information on Identity  , Information   on Employment,   and Information on Abilities   for the above-mentioned purpose. We can also use   Regulatory Information if you apply for a position requiring certain qualifications from a legal point of view.

We do this in order to prepare to conclude a contract with you and on our legitimate interest in ensuring that we choose the best candidates for the company. For roles that require certain qualifications, we also process this information based on our legitimate interest in complying with our legal or statutory obligations.

We can add new elements to the information you provided us during the recruitment process. These activities may include a review of your candidacy, internal discussions, and interviews with you and internal feedback, and it is likely that additional Personal Data shall be generated by you, our managers, the human resources department and recruiters.

Background Verifications

We need to make verifications before employment (including by checking the recommendations) to confirm some relevant issues such as credit status, identity, employment history and professional qualifications. We conduct these verifications to protect our business, customers and personnel.

Personal Data that we review for this purpose may include Contact details, Information on Identity, Information on Employment, Information on Nationality, Employment and Information  on Verification.

We do so based on our legitimate interest in protecting our business, customers and employees.

Our external service providers can help us with this verification process. They can provide us with additional Personal Data in the form of verification results or reports. We are also able to generate additional Personal Data when we internally review the results (by managers, the human resources department or recruiters).

In addition, we also receive references about you from your former employers or other referrals you shall provide.

Additional background verifications - legal obligations

If you apply for a position where there are certain legal requirements (i.e., legal advisor, physician, lawyer, tax consultant, assessor, fitness instructor, etc.), we need to go through additional background verifications to make sure you meet the legal requirements for those positions.

In addition to the verifications above, we also need to go through verifications to confirm that you meet these requirements to hold those positions. We conduct these verifications to protect our business, customers and staff, and to be in line with the legal / statutory requirements.

We also need to make sure we get the right legal references as required by applicable law (i.e. we can make verifications to the competent authorities to ask them to confirm that you really have the right).

Personal Data that we review for this purpose may include  Contact Details ,    Information on Identity,    Information on Employment ,    Information on  Nationality Information on Employment, Regulatory Information and Verifications.

We do so based on our legitimate interest in protecting our business, customers and employees and complying with our legal / statutory obligations.

Our external service providers can help us with this verification process. They can provide us with additional Personal Data in the form of verification results or reports. We are also able to generate additional Personal Data when we internally review the results (by managers, the human resources department or recruiters).

In addition, we also receive references about you from your former employers or other referrals you shall provide.

Verification of the criminal record

In addition to the above-mentioned background verification, we perform analyzes and verification on the criminal record where it is necessary to protect our business and our clients.

Personal Data we revise in this regard may include Contact Details, Information in Identity, Information on Employment, Information on Nationality, Regulatory Information, and Information on Criminal Records.

We do so based on our legitimate interest in protecting our business, customers and employees and complying with our legal / statutory obligations.

When processing   Information on Criminal Records,  we do this processing of Personal Data based on the public interest.

Our external service providers can help us with this verification process. They can provide us with additional Personal Data in the form of verification results or reports.

Right to work

We have to make sure that all candidates who have been through the recruitment process have the right to work in our company before they actually start working with us.

The Personal Data that we process in this are Contact Details  Information on Identity   and  Information on Nationality. 

If you must help with visa, work permit or other requirements / documents on immigration, we need additional information for this purpose, such as  information on Relatives,    Information on Employment   and  Information   on Abilities.  

We process such personal data to comply with our legal obligations.

We can process Personal Data that we receive with regard to your visa / immigration application from immigration agencies or other governmental institutions / authorities, our immigration specialists (either internal or external), Human Resources, Team management and recruiters.

Offering / installation at work

If we want to offer you a job within the company, we need to use your Personal Data to offer you a job and to generate the necessary documentation.

The Personal Data we can process may include  Contact Details, Information on Identity, Employment information, information  on Right, information on Employment, Information on  wage, Information on Skills , Regulatory information(where applicable) and certain Information on Verifications. If you choose to accept our offer of employment, we have to process some of the above Personal Data and  Information on Relatives  and  Information on  wage.

We do so to prepare to conclude a contract with you and based on our legitimate interest to integrate you in the company and complying with our legal / statutory obligations 


As an employee

We collect, use and share Personal Data that concerns you if you work in our company. If such Personal Data is not collected from you, they are internally generated through our management processes, the Human Resources department, and the Payroll department.
Click on the links below to learn more about these activities and about the Types of Personal Data that we typically process in connection with this process.
In particular:
 
ActivityDescription
Manage our relationship

We process your Personal Data to ensure that our terms and conditions are effectively managed. This includes answering your questions through the Human Resources department or other persons responsible for this, managing your employment history, through software or other means, as well as any other management action / operation which we take in relation to you.

In this regard, we have to process Contact Details, Information on Career, Information on Identity, Information on Employment, Information on Rights , Information on Leaves, Information on Sick Leaves, Information on Nationality, Information on Relatives, Information on Wage, Information on Performance, Regulatory Information (if applicable), Information on Payment, Information on Skills, Information on Termination  and Information on Verification.

We process such Personal Data because it is necessary to execute our contract with you and to comply with our legal / statutory obligations.

Medical Information  is a  Special Category of Personal Data

The personal Data is processed based on the legal obligations we have under labor legislation concerning you and your possible consent or our legitimate interest.

Personal Data can also be generated by the health care team or third-party service providers, including those who assist us in conducting background verifications.

Benefits / Rewards

We process your Personal Data to ensure that you receive the benefits and rewards applicable to the relationship you have with us.

In  this regard, we process  Contact Details  ,    Information on Career ,    Information on Identity ,    Information on jobs ,       information on       Rights ,       Information on Holidays ,       information on       Nationality ,    Information on Relatives ,    Information on  Performance ,    Information on Remuneration ,    Information  on Abilities   and  Information on Termination .  

We process such Personal Data because it is necessary for the execution of our work / collaboration agreement and in our legitimate  interest in ensuring that we properly reward our employees.

Personal Data shall be shared with our external service providers (where applicable) as well as with other group / affiliate companies that can provide the services described in this Information Note .

Payment

We process Personal Data to ensure that the terms of the contract are effectively managed, including payment.

In this regard, we process your Contact details, Information on Career ,    Information on    Identity ,    Information on Remuneration ,    Information    On Rights ,    Information on Leave ,    Information  On Wage    and  Information on Termination .  

We process such personal data, as it is necessary for the performance of the contract we have with you.

We can receive and share information from third parties in order to manage this activity, such as tax authorities.

Management of all types of leave, including annual leave, holidays granted by the company, sick leave and all other types of legal / statutory leaves 


We process your Personal Data in order to be able to manage all types of holidays, including annual leave, free days, medical leave and all other types of statutory / statutory leave.

In this regard, we process your Contact Details,  Information on Career ,    Information on    Identity ,    Information on Remuneration ,    Information  On Rights ,    Information on Leaves ,   Information   on Wage  ,  Information on Relatives   and  Information    on Termination.  

We process such personal data, as it is necessary for the performance of the contract we have with you.

Medical Information is a Special Category of Personal Data . The Processing of Medical Information is based on our legal obligations to you, as laid down in labor law, which includes obligations on health and safety at work and, where appropriate, the consent we give to it or our legitimate interest. Our internal and external providers of health services make this process for occupational medicine and, in particular, to assess your work capacity (OHS). 

If you need a medical check, you may provide certain Medical Information directly to the team / provider dealing with this process. The information found in this medical report shall be provided by the health care team / health care provider.

Business reorganization


We process your Personal Data at specific period to help us run the business effectively and manage / implement certain necessary changes.

In this regard, we process Contact Details,      Information on Career      and    Information on Performance   .  

We can also process  Information on  Remuneration,    Information on Skills    and Information  on Termination.  

We process Personal Data in our legitimate purpose to ensure that the business is conducted efficiently and that we comply with our legal / statutory obligations.

Depending on the way we reorganize, we may need to share Personal Data with third parties, as a result of this activity.

Legal and statutory compliance


We process your Personal Data to comply with our legal and statutory obligations in relation to state authorities / institutions, health and safety obligations, working time and any other statutory / statutory obligations imposed by public authorities / institutions, certification bodies, insurance companies or similar.

In this regard, we process    Contact Details,       Information on Career,     Information on Identity,       Information on Remuneration,     Information on    Rights,      Information on Leaves,      Information   On Wage ,    Information on Relatives,  Information   on Termination ,  Information on Verifications   and Information on training.

We process such Personal Data because we need to comply with our legal obligations and our legitimate interest in complying with statutory obligations.

Medical Information   is a  Special Category of Personal Data.   When Medical Information is processed, this is done to meet the obligations of labor law, including our occupational health and safety obligations. 

We may have to share Personal Data with regulatory authorities, public authorities, government authorities / institutions, legal counselors, and other third parties for these purposes.

From time to time, we may be required to provide Information on our workforce to regulatory or supervisory authorities or other public authorities / institutions, or to meet certain legal requirements for the disclosure of that information as part of a lawsuit, or of a court order. These applications can cover a wide range of issues including financial behavior, data protection, taxes and taxation, labor law, both nationally and internationally.

Business Protection

We have implemented processing activities during your work relationship designed to ensure that our business operations are protected. These activities include both the behavior and activity of our employees and the use of our systems.

In this regard, we can process any Personal Data found on our systems. We are also able to process incidentally  Special Categories of Personal Data   or  Information on the Criminal Record.  

We process such Personal Data, as we need to comply with our legal obligations and our legitimate interest in complying with our regulatory obligations, protecting our business, monitoring the use of our systems and assets, and managing activities and behavior of our employees.

As we process Special Personal Data Categories or Criminal Record Information, we process such Personal Data based on the major public interest.

Under certain circumstances, data may be collected indirectly through monitoring devices, CCTV, telephone and logs, as well as Internet and e-mail logos) if and in accordance with applicable law. In these circumstances, the data may be collected by us or by a third party acting as a provider of the relevant services.

Investigations, Complaints, Disciplinary Investigations, and performance management:

As a responsible business, we can  process your Personal Data for human resources processes such as disciplinary actions or complaints or management

You shall find these policies in our internal documents, made available.

The Personal Data that we process for these purposes are   Human Resources Information and Information   on Performance  

Depending on the circumstances, we are also able  to process other categories of Personal Data, including  Contact Details  ,    Information on Identity ,   Information on workplace,      information on Leaves ,  Medical information , Information on Employment ,       Regulatory Information   (if applicable), Information on Skills ,    Information    on Training   and Information on Verification.  

We process such Personal Data in our legitimate purpose to protect our business and customers. We process such personal data to comply with our legal obligations.

Medical Information is a Special Category of Personal Data . When processing Medical Information, we do so based on our legal obligations to you, as laid down in labor law, which includes obligations on health and safety at work and, where appropriate, the consent we give to it or our legitimate interest. Our providers of internal and external health services make this process for occupational medicine and, in particular, to assess your work capacity (OHS). 

We are also able to process Special Category of Personal Data or   Information on the Criminal Records  for these purposes. If we do so, we process your Personal Data based on the major public interest.

We can get a look from the above Personal Data from other colleagues, including collaborators. Where applicable, Personal Data can also be generated by the occupational health team.

Skills Management


We process your Personal Data to ensure that we effectively manage your talent and abilities within our business.

In this regard, we process Information on Career,    Information on Workplace,  Information  on Employment,    Information on Skills,    Information    on Performance.  

We process such Personal Data in our legitimate purpose to ensure that we manage the talent of the staff effectively.

Learning and development


We process your Personal Data to ensure that you receive the training and knowledge required to fulfill your role and to develop in general.

In this regard, we process   Contact Details, Information on identity, information on places, Information on Employment and information on training.

We process such Personal Data in our legitimate purpose to ensure that our employees receive the necessary training and development.

We can share this Personal Data with external training providers for this purpose and we receive certain Personal Data about you in return.

Communication

We process your Personal Data in order to communicate with you, including in relation to updates related to our business, changes in the way we work, new products and services, and product testing / testing.

In this regard, we process your Contact Details,    Information on Identity   and Information    on Jobs. 

We process such personal data as necessary for the execution of the employment contract that we have with you and our interests legitimate ensure that communicate effectively with our people and that we fulfill our general business goals. 

Questionnaires

We process your Personal Data for conducting surveys or other ways to request feedback.

In this regard, we process   Contact Details,    Information on Identity,   Information on   performance   that we obtain from stored internal data

We also collect additional information from you during these surveys, although you shall be able to decide whether you would like to provide such additional data at the time of the survey.

Answering these surveys shall be voluntarily.

We can combine your survey responses with other answers and the existing demographics about you in the internal human resources systems. We can also combine your answers to the answers given in past and future surveys.

Unless notified otherwise, most company surveys result in aggregate reports that are distributed to different company functions, including senior managers within the company for the purposes outlined below. These reports can also be used by the company and third parties for general research, data analysis and statistical purposes.

Both Personal Data used to conduct surveys and Personal Data collected and used during surveys are processed because it is necessary in our legitimate interest to improve communication, review relationships with staff, assess levels of engagement and satisfaction, and improve working arrangements or for any other purpose communicated to you at the time of the survey / survey.

Information on Diversity is a Special Category of Personal Data

As we process information on diversity in surveys or polls, it shall be processed and managed as described in the Diversity, Inclusion and Equal Opportunities section.

If we use a third party to help us provide and collate the survey / survey, Personal Data shall be processed by the respective third party for the purposes mentioned above.

Mobility

We process your Personal Data as part of our ongoing legal obligation to ensure that you have the right to work in Romania (or in any other country where you work in our company) and to make sure if the job is relocated, you have the right to work in that country.

In this regard, we process Information on Identity, Information on employment, Information on Rights, Information on Leaves, Information on Nationality, Information on Relatives, Information on Wage, Information on payment and Information on Termination.

We process such personal data to comply with our legal / statutory obligations.

We can share your Personal Data with governmental organizations, authorities and institutions and consultants in connection with this purpose.

Managing the relationship termination

At the end of our working relationship, process Personal Data to manage your departure.

In this regard, we process Contact Details, Information on Identity, Information on Employment, and Information on Termination.

We process such personal data, as it is necessary for the execution of the employment contract that we have with you and our legitimate interests to ensure the employment termination is managed efficiently.

Departure Interviews

At the end of our working relationship, we can process personal data as part of our termination of the employment relationship, to understand the reasons for leaving and see if we can improve operations.

In this regard, we process    Contact Details,       Information on Identity,       information on workplaces,    Information on Performance   and  Information   on Termination.  

We process such Personal Data in our legitimate purpose to ensure efficient business operations and processes.

Pensions

We process your Personal Data to provide and administer your pension.

In this regard, we have to process   Information    Contact ,    Information on Identity ,    Information on    Work places ,    Information on Rights ,    Information on Leave ,    Medical Information ,    Information on Nationality ,    Information on    Relatives,   Information on Wage,  Information on     Remuneration   and   Information on Termination   .

We process such Personal Data to execute our contract with you.

Medical Information is a Special Category of Personal Data . When processing Medical Information, we do so based on our legal obligations to you under labor law and social security, such as the right to retirement. 

As part of this activity, Personal Data can also be generated by other people assisting us in the management of the pension.

In addition, if we can choose to offer you voluntary private pension services as a benefit of your relationship with us, beyond the legal obligation, we provide the Personal Data to those service providers we have established contractual relationships with, so that you can enjoy such benefits.

Health insurance and other insurance types 

If you are eligible to participate in private health insurance schemes, life insurance, accident insurance or other such insurance, we process your Personal Data for including you in these schemes.

In  this regard, we process   Contact Details  ,    Information on Identity,    Information on Employment,    Information on Rights,   Information on Holidays,    Medical Information,   Information on  Nationality ,   Information on relatives,  Information  on Wage,  Information on Remuneration   and   Information on Termination   .

We process   Medical Information   about these schemes as well as other health Information on your family, where necessary and appropriate.

We process such Personal Data to execute our contract with you.

Medical Information is a Special Category of Personal Data . When we process Medical Information on your family, we do so based on the need to comply with your insurance obligations with you and your family. 


5. After you leave us
 
We have to process some Personal Data about you after our relationship terminates.
Click on the links below to learn more about these activities and the types of Personal Data that we usually process after our relationship is over.
 
In particular:
 
ActivityDescription
Records storage

We process your Personal Data in order to maintain certain records that are necessary after termination of your relationship with us. For more details, you can read our Privacy Policy or  contact us. 

In this regard, we process  Contact Details,   Information on Identity  and Information on Nationality.  

We process such Personal Data to ensure that we comply with our legal obligations and our legitimate interest in keeping records for our commercial purposes and to defend us in case of legal proceedings.

Taxes and payments

We process your Personal Data in order to comply with our legal obligations regarding taxes and taxation and to ensure that we fulfill our contractual obligations to you.

In this regard, we process Information on  Wage and Information on Termination.

We process such personal data to comply with our legal obligations.

References

We process personal data following termination of our contractual relationship to meet any requests for references from others and to respond to any legal claims or other types of claims that are made against you 

This includes but is not limited to providing information to regulatory authorities.

In this regard, we process  Contact Details, Information from Human Resources, Information on Identity, Information on Employment, Information on Leaves, Information on Performance, Information on Nationality, Information on Relatives, Information on Wage, Information on skills , , Information on Termination and Information on  Verifications.

We process such Personal Data on our legitimate interest in protecting and defending our business against any legal claims or requests and, if applicable, to comply with legal, regulatory or statutory obligations when providing a reference.

Personal Data may be generated by third-party vendors that help us with background verifications.


6. Your legal rights
 
You have legal rights provided by data protection legislation related to Personal Data. Click on the links above to learn more about your rights.
You have the right to access your Personal Data
You have the right to correct / modify your Personal Data
You have the right to restrict the way we use Personal Data
You have the right to oppose the way we use Personal Data
You have the right to ask us to transfer your Personal Data to another organization
You have the right to understand how we protect your data transferred outside the EEA
You have the right to learn more about how we use Personal Data
 
We can request proof of your identity when you make a claim by which you exercise any of these rights. We do this to make sure we disclose information or change account details where we know we are dealing with the right person.
We not charge a fee unless we consider your claim to be groundless, repetitive or excessive. If a fee is required, we inform you before processing your request.
Our goal is to respond to all valid requests within 30 days. However, it may take longer if the request is particularly complicated or if you have made more requests. We always let you know if we think a response shall take more than a month. To speed up our response, we may ask you to provide us with more details about what you want to receive.
We may not always be able to respond fully to your request, for example if it would have an impact on the confidentiality obligation we have towards other people or if we are legally entitled to resolve the request in a different way.
 
7. Your rights

RightsAdditional information:
Access

You can ask us:

  • to confirm that we process your personal data;
  • to provide you with a copy of such data;
  • to provide you other Information on your personal data, such as the data we have, why we use it, who we disclose to, whether we transfer it abroad and how we protect it, how long we keep it, what rights you have, how can you make a complaint, where we got your data, if this information is not already in this information note.
CorrectionWe can require you to complete / modify your personal data to be to be true to reality.
Deleting data ( "right to be forgotten")

You can ask us to delete your personal data, but only if:

  • they are no longer necessary for the purposes for which they were collected; or
  • you have withdrawn your consent (if processing is based on consent); or
  • you have a legal right to oppose; or
  • the data has been processed illegally; or
  • we have a legal obligation to do so.
We are not required to comply with this requirement if the processing of your personal data is required for:
 
  • compliance with a legal obligation; or
  • establishing, exercising or defending a right in court. and other circumstances, but these two are the most likely
Restricting data processing

You may ask us to restrict the processing of your personal data in the following cases:

  • disputing the accuracy of your personal data, but for a period that allows us to verify the accuracy of the data;
  • processing is illegal and you do not agree with the deletion of personal data, but we ask for restrictions on processing;
  • we no longer need your personal data, but you ask us to find, exercise or defend a right in court;
  • you oppose the processing of your personal data when the processing of personal data is for direct marketing purposes, for the period during which it is checked whether our legitimate rights prevail over yours.
Data portability

You may ask us to send you the personal data you are referring to and which you have provided to us in a structured, commonly used, readable and entitled to transmit this data to another operator in the following cases:

  • processing is based on consent;
  • processing is carried out by automatic means.
Opposition

You have the right to oppose processing when: (a) processing is necessary for the performance of a task that is in the public interest; (b) processing is necessary in our or a third party’s legitimate interests, including the creation of profiles based on those provisions.

In this case, we no longer process your personal data, unless we demonstrate that we have compelling legitimate grounds which justify the processing and prevailing over the interests, rights and freedoms of the data subject and the goal is the establishment, exercise or defense of right in court.

Making automated decisions

You have the right not to be the subject of a decision based exclusively on automatic processing, including the creation of profiles that produce legal effects that concern you or which affect you to a similar extent to a similar extent.

These rights have certain limitations, namely:

  • the automatic decision is required for the conclusion or the execution of a contract between you and us;
  • the decision is authorized according to the legal norms;
  • we have your explicit consent to this effect.

8. Contact Us
 
Our contact details
 
Below you can find our identification and contact details:
 
NameAmRest Coffee S.R.L.
Headquarters:46 Grigore Cobalcescu Street, 2nd floor, room 11, Bucharest, District 1, Romania
Trade Register numberJ40/21510/2006
Sole registration code20119287
Phone:0758034418
E-maildporomania@amrest.eu
DPOegal Company & Tax Hub SRL

If you have any doubts, comments or complaints about us or your personal data we process, you can always send us an email at the address above.
 
Supervisory authority data
 
If you think there is a problem with the processing of your personal data, we ask you to send us a request at the above address first - we do our best to resolve your request as soon as possible, amicably.
 
You can also file a complaint with the personal data supervising authority. For Romania, contact details can be found below:
 
NameThe National Supervisory Authority of Personal Data Processing 
Address28-30 G-ral. Gheorghe Magheru Blvd, District 1, postal code 010336, Bucharest, Romania
Phone:+40.318.059.211 or +40.318.059.212
E-mailanspdcp@dataprotection.ro

9. Glossary

TermAdditional Explanations:

Group


Means companies that may be part of the same economic group, controlled by the same persons, as defined by applicable law.

Information on Career


Includes career preferences, career interests, availability to travel, or relocation.

Information on the Criminal Records


Includes information on criminal convictions (executed or not) and criminal files in court.

Contact details


Include the postal address and copies of the documents proving this postal address, telephone number (personal and work), mobile phone number (personal and work), e-mail address (personal and work) and any address change.
Data Operator

It means a natural or legal person (such as a company) that determines the means and purposes of processing Personal Data. For example, the company that concludes a contract with you shall be the Data Operator as it determines how it shall collect your Personal Data from you, the purpose for which it collects and the purposes for which it uses them.


Information on Diversity


Includes Information on religious beliefs, health information (including disabilities), sexual orientation, race, and ethnicity.
EEAIt means the European Economic Area, which includes all EU member countries and Ireland, Liechtenstein and Norway.
EU countries

Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Lithuania, Latvia, Luxembourg, Malta, Netherlands, Poland, Portugal, Slovakia, Slovenia , Spain, Sweden and the United Kingdom of Great Britain and Northern Ireland.


Information on rights

It means your rights from a legal or statutory point of view, including benefits and contractual terms.


Information on identity

It includes your name (surname, first name), any other name (maiden name, pre-marriage name), preferred name, title, date of birth, age, gender, details of marriage, and divorce.


GDPR and Law

no. 190/2018

Means the Genaral Data Protection Regulation (GDPR), which is the law applicable to personal data at EU level and Law no. 190/2018 which is the Romanian law for the application of GDPR measures. These laws apply to the processing and management of Personal Data.
Information on jobs

Include start-up dates for a new job, job, position, responsibilities, role description, role location, employment status, type of employment, promotion, transfer, working hours, contract terms, organizational structure, degree, style of work, person to whom it was reported, Information on managers, etc.


Information on HolidaysIncludes leave, unpaid leaves, information on maternity leave, information on paternity leave, information on parental leave, information on adoption leave, information on special leave, information on sick leave, information on free days taken, and Information on any kind of holiday / free days taken.
Medical information

Includes days of absence, reason for absence, medical information / reports / fact sheets, work permits, diagnostic information, forecast information, pre-employment analysis, details of how people adapt and adjustments.


Information on Nationality


Include nationality, place of birth (city / country), spoken languages, passport information, visa details (including expiration date), and immigration status, work right and copies of identity papers.

Information on Relatives


Include the closest contact's name to the contact, the nature of the relationship, the Contact Details of that person, and the date of birth.
Information on remuneration

Include fiscal identifier, personal code number; social security number, paid taxes, payment history, bank details, pension and social security contributions, overtime paid, personal deductions and their amount, indemnities, loyalty clauses, non-competition clauses, etc.


Personal Data

It means any kind of information that refers to a living person. Includes information that can identify a person by name and contact details, or refers to associated information such as account activity or personal preferences that can directly or indirectly identify a natural person.


Information on Performance


Include performance analysis, performance ratings, praise, awards, feedback, managers' opinions, competencies, reports, and any other feedback from employees.

Processing


Means all actions we take on Personal Data, including (but not limited to) management, viewing, storing, storing, deleting, modifying, using and saving.

Information on Human Resources


Includes details of human resources and related processes, such as disciplinary actions, complaints, including their details, the content of investigations and research, and any other information that is collected at that time relating to you.

Information on employment


Includes the source of your application, work experience, CV details, work history, educational history, salary expectations, LinkedIn information, preferred work method, referral and contact details, contractual information (such as non-competition clauses, (such as analysis, assessment, and opinion of the management team or human resources department) and any other information that arises during the recruitment process.

Regulatory Information


Includes regulations and qualifications status, complaints to authorities / competent bodies, history and references.

Information on remuneration

Include information on salary, benefits, bonuses, personal allowances, salary increases etc. 

Information on skills


Includes skills, abilities and spoken languages

Special Categories of Personal Data


Special Categories of Personal Data means any Personal Data that relates to racial or ethnic origin, political opinions, religious confession or philosophical beliefs or trade union membership, genetic data, biometric data, health data, or data on sexual life or sexual orientation.

Medical Data and Cultural Diversity Data are part of the Special Categories of Personal Data.

Supervisory authority


Means the supervisory authority that deals with the protection of personal data, which in Romania is ANSPDCP ( www.dataprotection.ro ).

Information on Termination


Includes Information on resignation / dismissal, notice, contract termination date, departure date, reasons for departure, minutes, compensation, departure interview notes, departure advice, employee feedback, and management team views.

Information on Education

Includes Information on courses and specializations followed, graduation notes, competencies, course status and progress, course completion / completion date, personal development plans, reports and training preferences.


Information on Verification


Means the data collected during the pre-employment application and verification process and includes credit data, verification agreement, addresses over the past 5 years, and reasons for previous departures, disciplinary action, reasons for dismissal / resignation, conflicts of interest, and collecting employee feedback.