Recruitment and Selection
Data Protection Policy


Recruitment and Selection Data Protection Policy

ZSE Technology NV, hereinafter the company, thank you for your interest in our company and your application.

The company has prepared this information note to inform you about the collection, use and management of your personal data in the context of your application/selection process. Indeed, the company understands your concerns regarding the processing of your personal data and wishes to inform you in full by clearly stating the purposes for which the company processes your personal data, to whom it is passed on and the appropriate safeguards provided in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act and other applicable data protection regulations.

Every applicant with the age of at least 15 years acknowledges having read this policy. Sending in the CV and continuing the selection procedure implies acceptance of this policy and the processing of your personal data by the company.

The applicant is obliged to cooperate in the selection procedure in good faith and to provide all necessary information about his professional and educational history, if these relate to the nature and conditions of the position. The applicant may not disclose confidential information of which he would have become aware as a result of the recruitment and selection procedure.

By applying to the company, the applicant acknowledges having read this policy and understands how the company processes his or her personal data.

  1. Categories of persons

This information note applies to the following persons regardless of their nationality or place of residence:

  • Any natural person who, as a result of a job offer, submits his/her application with a view to obtaining the job as described in the job offer.
  • Any natural person who applies spontaneously with the intention that his/her CV will be included in a database intended for recruitment and selection.
  • Any natural person whose CV has been passed on to the company through a third party by a recruitment firm or by recommendation. The company will communicate the policy to the applicant upon first contact.
  1. Categories of personal data

In the context of the application, and more specifically for the selection process, the company will process, among other things, the following personal data:

  • Identification data such as your name, first name, marital status, address, date of birth, age and gender;
  • Data related to studies and training: education, training, diplomas, certificates;
  • Work-related information : current position and responsibilities, previous positions and professional experience, departure date, reason for departure, employment conditions and gross salary, salary expectations, skills and competence;
  • Health assessment form for a safety function, a function with increased vigilance or an activity with a specific risk (art. I.4-46 of the codex on well-being at work). This form contains no health data;
  • Data related to mobility (driving license, transport options);
  • Our website uses cookies that may process your personal data such as IP address, navigation on the website, … For more information about the processing of your personal data by means of cookies, please visit our internet and cookie policy.

The company strives to obtain all information relevant for recruitment directly from the applicant. If the company deems it necessary, it will contact one or more previous employers to request information about you and your work experience, only with your consent.

The company will not request certified copies of diplomas, certificates or certificates from the applicant before signing an employment contract. If the applicant has added documents to his application, such as transcripts or copies of diplomas, certificates, photos, etc., the company will keep these available for a reasonable period if he is rejected. In case of doubt about the veracity of the submitted or sent copy, the company may ask the applicant to present the original document ;

The company will only ask questions about private life that are relevant to the nature and conditions of the job;

It is possible that the company will process sensitive personal data in certain cases, but this will always be kept to a minimum. In any case, the company will not process so-called ‘sensitive’ personal data, such as racial or ethnic origin, political opinions, religious or philosophical beliefs, health, sexual orientation …) during the recruitment process.

The company will also not process an extract from the central criminal record (previously: proof of good conduct and morals), except for specific positions that require it by law. The company may, however, ask you to bring the extract from the central criminal record with you in order to view it and return it without processing it.

  1. Purposes and bases for processing

The company will only collect and process your personal data to the extent necessary for the purposes of recruitment and selection. The processed personal data are relevant to the position being filled and are limited to the information necessary to assess the extent to which your motivation, knowledge, skills, abilities, and experiences align with the profile of the vacant position for which you are applying or eligible.

The company processes the above personal data on the basis of various processing grounds as listed in art. 6 (1) (a), (b), (c) and (f) and 9 (2) (b) GDPR:

  • you have given your explicit permission for this
    • example : forwarding the resume
    • example : inclusion in a reserve pool, as further explained below.
  • the processing is necessary in order to take measures before the conclusion of an employment contract between you and the company to promote, among other things, the smooth management of your employment.
    • example : drawing up an employment contract
  • the processing is necessary to comply with a legal obligation to which the company is subject;
    • Example : draw up a certificate of attendance from VDAB, Actiris, Forem at the request of the applicant
    • Example : the company has to process certain personal data on the basis of a specific legal obligation such as the recruitment of a security guard. These specific cases will always be further explained in a separate interview with or memorandum with regard to the applicant.
    • Health assessment form for a safety function, a function with increased vigilance or an activity with a specific risk (art. I.4-46 of the codex on well-being at work).
  • The processing of your data is necessary for the legitimate interests pursued by the company, aiming for a fair assessment of your candidacy, provided that the interests or fundamental rights and freedoms of the applicant do not outweigh these interests.
  • example: forwarding your contact details to centers that administer tests or trials, processing test or trial results, forwarding your data to other services or affiliates that may be interested in your profile.
  1. The processing of your personal data

4.1 General

The recruitment procedure and associated data processing starts at the company when:

  • you are applying for a specific position
  • you apply spontaneously;
  • a third party recommends you (e.g. recruitment office).

The company uses various channels to find the right person for a vacancy. This can be done via your own website, but also via third parties such as social media (LinkedIn, Facebook), job websites or recruitment and selection offices. For specific functions or profiles, the company may engage a specialized office to find a suitable candidate.

If the processing of your resume is done by these third parties, it is recommended to read their terms and conditions and privacy policy to ascertain how they handle your personal data. The company cannot be held responsible for the way in which these third parties handle your personal data, nor for the content published on their websites.

The company asks you to check the correctness and completeness of your data and to contact us if changes have occurred or if you are no longer interested in a job with our company during the selection procedure.

4.2 Specific processing during the selection procedure

In a first stage of the selection procedure, the company analyzes your CV to determine whether it meets the requirements of the position.

Applicants who do not meet the requirements and whose CVs will not be further considered will be notified of this in writing. Personal data and CVs of applicants who are not shortlisted will not be retained in our database. If a particular profile is of interest, the company will inquire whether your information may be kept for a reserve pool, and you will have the choice to either agree or decline.

  1. Recipients of your personal data

The company may be required to process your personal data both internally and externally in the context of your recruitment and selection. Access to your personal data is limited to persons with a position that requires the processing of that information and is, in principle, only transferred on a need-to-know basis to the recipients who carry out the various processing operations related to the above-mentioned purposes.

5.1 Internal

The Company Support Officer and the employees he assigns for processing reasons will process your personal data as part of your recruitment and selection procedure and will therefore have access to the personal data as listed under Article 2.

In the context of the selection, the managers and the board of directors of the company will also have access to your personal data in the context of the application procedure in order to assess the suitability of your profile within the company and the specific department (position, work experience training courses, etc.).

5.2 External

The company is obliged to communicate your personal data to various external companies that provide services, such as offices specialized in recruitment and selection that nominate candidates, to conduct initial interviews and to conduct personality and competence tests.

These companies fall directly under the legal obligations of the GDPR. This implies that your personal data will be protected by these organizations in accordance with the obligations imposed by the GDPR.

Sometimes the employer is also obliged to communicate your personal data to government authorities, whereby the employer always checks whether the (legal) conditions for this have been met.

5.3 Transfer to third countries

We do not pass on your personal data to third parties (companies) outside the European Economic Area.

  1. Retention period

The employer processes your personal data for as long as they are necessary to achieve the purposes for which we need them. We use different retention periods depending on the context of the selection procedure.

6.1 Application for a specific vacancy

The company stores your personal data processed in our recruitment and selection process for a period necessary for the processing of your application.

The company stores your personal data for a maximum period of 1 month after filling the vacancy. This allows the company to contact you in the event that the selected person is not hired or if an early decision is  made to terminate this collaboration.

6.2 Reserve pool

If the company has selected a third party for a certain position, but your profile may be of interest for a similar or a different position within the company, it wishes to contact you in the future for a vacancy that may interest you. The company will ask your permission to keep your profile for one year. You always have the option to refuse this proposal and then the company will delete your personal data.

6.3 Spontaneous application

Any CV sent via an unsolicited application will be kept for a period of one year.

6.4 Employment

In the event of employment, the processing of your personal data by the company will be necessary for personnel management and payroll administration. The processing will also be necessary for the execution of the employment contract, compliance with the legal obligations of the company, and the company may rely on legitimate interests. At the latest upon the commencement of employment, you will receive further information about the processing of your personal data by the company in the context of personnel management and payroll administration.

6.5 Place of storage and request for deletion

Your personal data will be stored on the server of the company.

If you wish, you can submit an explicit request to delete your CV before the end of this retention period by following the procedure as described in Article 7.

  1. Your rights

The company endeavors to provide as much information as possible through this current policy to ensure transparency regarding the processing of your personal data in a recruitment and selection process. However, we understand that you might still have questions or require further clarifications.

You have the right to access your personal data (file) or request a copy, correct or have your data corrected if they are found to be incorrect or incomplete, and, in some cases, restrict the processing of your data. Where applicable, you can also request the transfer of your data to another data controller. The exercise of these rights should be in accordance with the provisions of the GDPR.

To the extent that the processing is based on your consent, you have the right to withdraw that consent at any time. The withdrawal only affects processing from that point forward.

The company does not engage in automated individual decision-making that has legal consequences.

You can exercise your rights – and insofar as these are within the conditions as described in the applicable legislation (GDPR) the employer will comply with them – by contacting Kris Vandepaer at [email protected].

If you believe that your rights have been violated, you always have the right to submit a complaint to the Data Protection Authority.

  1. Safeguards

The company places significant emphasis on safeguarding your personal data, and thus implements appropriate technical and organizational measures to secure your personal data. These measures are particularly designed to protect against loss, alteration, or unauthorized access.

Access rights to your personal data are restricted within the company to only those departments and/or individuals who require such access to fulfill the aforementioned purposes. This includes the Human Resources department and specific function managers. Moreover, efforts are made to transmit only the necessary personal data to achieve more specific objectives. These access limitations minimize the risks of data loss or unauthorized access.

The persons who have access to the personal data are trained in the processing of personal data and how to handle your personal data and are bound by confidentiality clauses to ensure the integrity and confidentiality of your data.