privacy policy for candidates for work in the company
the azoty group "FOSFORY" SP. z o. o

1.                  Personal data protection under the General Data Protection Regulation (GDPR)

This policy (hereinafter "Policy") concerns personal data of job applicants (hereinafter "Candidates" or "State"), collected and used by Grupa Azoty "FOSFORY" Sp. z o. o. with its seat in Gdańsk, ul. Kujawska 2, 80-550 Gdańsk, being the administrator of personal data (hereinafter: "Company", "Administrator") conducting the recruitment procedure.

In this Policy, we inform you about the ways in which personal data is used, as well as the rights of individuals related to the collection and use of such data. If you have any questions or comments regarding the protection of personal data, please contact the Data Protection Officer by e-mail: dpo@fosfory.pl or by correspondence: Data Protection Officer, Grupa Azoty "FOSFORY" Sp. z o. o. with its seat in Gdańsk, ul. Kujawska 2, 80-550 Gdańsk.

2.                  What kind of personal data do we collect?

2.1                 Candidate data

2.1.1                          Mandatory data of Candidates

We collect basic data from the Candidates indicated in art. 22¹ §1 of the Labor Code, such as:

and)       name (s) and surname,

b)      Date of birth,

c)       contact details provided by the Candidate,

d)      education,

e)      professional qualifications,

f)        the course of previous employment,

with the personal data indicated in point We request d - f when it is necessary to perform work of a specific type or in a specific position.

However, we request the provision of personal data other than those specified in point. a - f, when it is necessary to exercise the right or fulfill an obligation resulting from a legal provision.

Providing these data by the Candidates is their responsibility. The consequence of not providing data is the inability to start employment.

2.1.2                          Other data about Candidates

When submitting the application documents to the Company, you can also provide other data, such as your image captured in a photo. Providing these data by Candidates is completely voluntary.

2.1.3                          Sensitive data

The personal data we process may also include special, particularly sensitive categories of data, such as information regarding the degree of disability. They will be carefully protected by the Company. Such data will not be disclosed to any unauthorized persons.

2.1.4                          Contact details

Data enabling contact with the Candidate, such as e-mail address or telephone number, are collected from the Candidates. In order to participate in the recruitment process, it is necessary to provide an address
e-mail; providing a telephone number is voluntary, however, it may contribute to facilitating contact with the Candidate.

3.                  On what legal basis and for what purposes do we process personal data?

3.1.            We process personal data only when:

and)       processing is necessary to fulfill contractual obligations towards you or, in accordance with your request, it is necessary to take specific steps before concluding the contract (Article 6 (1) (b) of the GDPR), including the recruitment process;

b)      processing is necessary in order to comply with our legal obligations or when we are expressly required to do so by a legal provision, e.g. art. 22¹ Of the Labor Code (Article 6 (1) (c) of the GDPR);

c)       Processing is necessary for the purposes of the legitimate interests pursued by the Company or a third party, except where these interests are overridden by your interests or fundamental rights and freedoms requiring the protection of personal data (Article 6 (1) (b) of the GDPR) f GDPR). When processing personal data on this basis, we always try to maintain a balance between our legitimate interest and your privacy;

Such "legitimate interests" are:

·         establishing or pursuing civil law claims by the Company as part of its operations, as well as defense against such claims;

·         taking measures to maintain operational activities in the context of employment planning and filling vacancies in the Company;

d)      in some cases, where we have obtained your prior consent (Art.6 par.1 lit.
a GDPR) - this applies to consents to the processing of data for the purpose of using them in further recruitment conducted by the Company and consents to the processing of data contained in
in Candidates' application documents without indicating a specific position.

3.2.            Legal basis for the processing of sensitive data

Special categories of personal data may be processed by the Company only in special cases, i.e. when processing is necessary to fulfill our obligations under employment, social security or social protection, this applies to personal data including the degree of disability and related special rights.

3.3.            Data processing agreement

If we process your personal data on the basis of consent, it may be revoked at any time as easily as it was given. Failure to consent to the processing of data that you are not obliged to provide will not result in a refusal to establish an employment relationship with the Candidate, and its revocation will not have negative consequences for the Candidate.

3.4.            Purpose of data processing

We always process your personal data for a specific purpose and we only process the personal data that is necessary to achieve it. We process Candidates' personal data in order to:

and)       undertaking recruitment activities;

b)      preparation of contracts for the candidate's employment;

c)       compliance with all legal obligations imposed on the Company in relation to Candidates;

d)      use of data in other recruitments conducted by the Company - if the Candidate gives consent.

4.                  How do we protect personal data?

The company allows for the processing of personal data only authorized persons. All employees of the Company who gain access to personal data must follow internal rules and processes related to the processing of personal data in order to protect it and ensure confidentiality. They are also required to follow all the technical requirements
and organizational security measures in place to protect personal data.

We have implemented appropriate technical and organizational measures to protect Candidates' personal data against unauthorized, accidental or unlawful destruction, loss, alteration, misuse, disclosure or access, and against any other illegal forms of processing.

These security measures have been implemented taking into account the relevant state of the art, implementation costs, processing risks and the nature of personal data, with particular emphasis on sensitive data.

5.                  Who has access to personal data and to whom is it transferred?

5.1.            Within Grupa Azoty "FOSFORY" Sp. z o. o

We may transfer personal data to the Company's employees, managers and employees
in recruitment processes.

5.2.            In addition to Grupa Azoty "FOSFORY" Sp. z o. o

We may transfer personal data to recipients and other third parties to achieve the purposes listed in point 3.4 to the extent that they are necessary for them to perform the tasks commissioned by us, if we are required to do so by law or if we have a different legal basis. The following can be considered recipients or other third parties:

and)       entities processing personal data on behalf of the Company, such as our IT system suppliers and their subcontractors;

These types of entities do not independently decide how to process your personal data. They process personal data only to the extent that
in which it is necessary for the conduct of business by the Company. The company has control over the operation of such entities by means of appropriate contractual provisions to protect your privacy.

b)      entities such as:

·         legal advisers or

·         medical institutions (occupational medicine) or

·         courier or postal service providers

These types of entities are independent data administrators, which means that the Company has no influence on how and to what extent they process your personal data. The company is not responsible for the compliance of the activities of such entities
with regulations.

c)       any national public administration authorities, authorities of other EU Member States (e.g. authorities established to protect personal data in other Member States) or courts, if required by applicable national or EU law or at their request.

6.                  How long do we keep your data?

We only store personal data for as long as necessary to achieve the purpose for which it was collected or to comply with legal requirements.

Candidates' personal data are processed throughout the recruitment process. The date of completion of the recruitment is the date of signing the employment contract by the selected candidate. From that date, the candidates' personal data:

–        who have not been invited to interviews or have not consented to participate in other recruitment processes will be removed,

–        Personal data of Candidates who have been invited to interviews may be processed - in the scope of Information on recruitment - as a rule for a period not longer than 12 months from the date of completion of the recruitment, in order to enable the Company to defend against possible claims or pursue such claims, if there is a risk that such claims will be made by or against the Company. However, if the Company, by assessing the actual state of affairs, can reasonably believe that the risk of claims is high (e.g. in the case of very comparable applications), it may store Candidates' personal data for a period not longer than 3 years from the date of recruitment.

If you give your consent to participate in other recruitment processes, your personal data may be stored for the purposes of their use in further recruitment conducted by the Company for a period not longer than 12 months from the date of completion of the recruitment.

Personal data provided to the Company without indicating a specific position for which the Candidate is applying will be treated as consent to participate in current and future recruitments conducted by the Company, provided that the candidate provides consent to the processing of personal data according to the template provided in point 9 c) below. They will be stored in the database for a period not longer than 12 months from the last day of the month in which the application documents were submitted.

However, if you would like your personal data to be removed from our databases, you can submit a request as detailed in section 7 below.

7.                  What are your rights and how can you exercise them?

7.1.            Your rights

The candidate has the right to access their personal data processed by the Company. If you believe that any information relating to you is incorrect or incomplete, you also have the right to request that it be corrected in the manner specified
in point 7.2. below. The company will correct such information immediately.

You also have the right to:

and)       withdraw your consent if the Company has obtained such consent to the processing of personal data (provided that such withdrawal does not violate the lawfulness of data processing carried out before the withdrawal);

b)      request the deletion of your personal data;

c)       requests to limit the processing of your personal data;

d)      to object - for reasons related to your particular situation - to the processing of your personal data (including profiling), if such processing is carried out in order to implement the public interest or legitimate interests of the Company;

e)      data transfer, i.e. receipt of personal data provided to the Company
in a structured, commonly used and machine-readable format and to request that such personal data be transferred to another personal data controller without obstruction by the Company and subject to its own confidentiality obligations.

The company will verify your requests, demands or objections in accordance with the applicable provisions on the protection of personal data, including in particular the GDPR.

However, it should be remembered that these rights are not absolute; the regulations provide for exceptions to their application.

7.2.            Exercising your rights

To exercise the above rights, please contact the Data Protection Officer at the following e-mail address: dpo@fosfory.pl

If you are not satisfied with the way in which the Company processes your personal data, please notify us of the problem and we will investigate any irregularities. Please report your doubts to the e-mail address indicated above.
If you have any objections to the Company's reaction, it is also possible to submit a complaint to the competent personal data protection authority. In Poland, this authority is the President of the Personal Data Protection Office.

In order to keep your personal information up-to-date and accurate, we may ask you from time to time to check and confirm the personal information we hold about you. Please inform us of any changes to this personal data (such as e.g. change of address or contact telephone number).

8.                  Privacy Policy Updates

This policy is subject to change. If required by law, any information regarding future changes or additions to the processing of personal data described in this policy that may apply to Candidates will be updated and published in the form of a consolidated text on the Company's website.

9.                  Clauses regarding consents to the processing of personal data:

Depending on your choice regarding the current recruitment or subsequent recruitment announced by the Company, please submit the statement "a", "b" or "c" regarding consent to the processing of personal data together with the application documents:

and.       Statement for current recruitment:

"I consent to the processing of my personal data contained in the application documents by Grupa Azoty" FOSFORY "Sp. z o. o. with its seat in Gdańsk, ul. Kujawska 2, 80-550 Gdańsk, for the needs of the current recruitment process. "

b.       Statement for current and future recruitment

"I consent to the processing of my personal data contained in the application documents by Grupa Azoty" FOSFORY "Sp. z o. o. with its seat in Gdańsk, ul. Kujawska 2, 80-550 Gdańsk, for the needs of the current and future recruitment processes. "

c.       Statement of the Candidate who sends his application documents without indicating a specific position:

"I consent to the processing of my personal data contained in the application documents by Grupa Azoty" FOSFORY "Sp. z o. o. with its seat in Gdańsk, ul. Kujawska 2, 80-550 Gdańsk, for the needs of current and future recruitment processes. "