Recruitment Privacy Policy
Thank you for your interest in joining Macadam Europe! In order to process your job application, we ask you to provide certain personal details, such as your contact details and CV. We may also ask you to provide some additional information where required for a specific function you are applying for, or where necessary to onboard you as an employee.
All personal data provided by you during the recruitment and onboarding process is processed, collected and stored in accordance with this Policy. This Privacy Policy informs you about the way in which we will collect and use your personal data, how we protect it and how you can exercise your privacy rights.
Note that you are responsible for the information you provide to Macadam Europe, and you must ensure it is honest, truthful, accurate and not misleading in any way. You must ensure that the information provided does not contain material that is obscene, defamatory, or infringes on any rights of any third party; does not contain malicious code; and is not otherwise legally actionable. Further, if you share with us any information concerning any other person, such as individuals you provide as references, you are responsible for providing any notices and obtaining any consents necessary for Macadam Europe to collect and use that information as described in this Policy.
1. Who are we?
We are Macadam Europe NV (with registered offices at Schaarbeeklei 613, 1800 Vilvoorde, and registered with the KBO under number 0881.767.513, hereinafter referred to as ‚Macadam Europe‘).
We are a Data Controller in relation to any personal data provided by you during the recruitment and onboarding process if you apply for a job at Macadam Europe.
We are a Data Processor in relation to any personal data provided by you during the recruitment and onboarding process if you apply for a job at Macadam Europe. Your personal data will be processed in accordance with their respective privacy policies.
2. Who is protected by this privacy policy?
This Recruitment Privacy Policy applies to all candidates applying for a position at Macadam Europe including full-time positions, specific consultant roles, traineeships or temporary assignments.
3. Which personal data does Macadam Europe process, and why?
Macadam Europe collects only necessary information during the hiring and onboarding process. This information might be mandatory and will be indicated in the job description. Candidates not providing such information will be unable to continue the recruitment and onboarding process. Any additional information you provide to us will be processed in accordance with this Policy as well.
a. What data do we process?
The personal data that we collect or obtain may include different kinds of information, as may be specified in a job description. In general, when you apply for a position, we will process at least your email address or phone number and CV details. During the hiring process, however, we may need to collect additional information, such as your ID, education details or driver’s license info. You may find the summary of the data that we collect below:
- Identification details: We may process your contact details, such as your name, email or home address, phone number, family data, ID data or driver’s license information. In certain circumstances, where, for example, Macadam Europe needs to request authorisation from the government authorities to hire a candidate located outside of Belgium, we may need to process your passport information, identity card information, social security number, etc.
- Photos and videos: We may process images of you or videos if you take part in a video interview or a recruiting event, or if you provide it to us with your application.
- Employment history, education details, CV info and any other data in your application: For most vacancies you can apply with your CV which typically contains your professional experience, education background, skills, etc. You may also provide us with any other information you find relevant for recruitment purposes (eg, your hobbies, volunteer experience, specific dietary or mobility preferences). We may also request your diplomas or professional certifications where necessary for specific vacancies.
- Metadata: We might collect the data on your IP address, for example, if you apply online. We may also process the information on communication channels that you used to apply for a position, such as job sites or social media (eg, LinkedIn).
- Sensitive data: You may communicate to us health-related or other information that may constitute special categories of data under privacy legislation. Macadam Europe processes such data always in accordance with our legal obligations and our security and privacy policies. For specific positions such as those requiring access to sensitive security information, we are also required to collect criminal offence data.
- Recommendations and feedback: You may provide your recommendation letters to us, or we may contact your professional references.
b. How do we obtain this personal data?
We may receive the data directly from you when you apply for a position via our online recruitment portal, via social media, job fairs, recruitment events, etc. The data may also be collected indirectly from you in case you apply via employees, an interim agency or your consultancy company. In this case, they should inform you of the essence of this Policy.
c. Why do we process this personal data?
In general, we process your personal data when this is necessary:
- in connection with the performance or preparation of an employment contract;
- to comply with our legal obligations;
- for the protection of our legitimate interests in which case we will always try to strike a balance between that interest and respecting your privacy.
You may also provide certain data to us yourself or authorise us to collect information about you, in which case we will process your data based on your consent.
Please see below the summary of the purposes and legal bases of the processing of your personal data:
Recruitment:
- We will collect your contact details, CV and any other information necessary for a specific vacancy, to process your job application – Article 6.1(b) GDPR: contract performance
- We may be required to obtain certain information from you or from government agencies, where necessary for specific roles within Macadam Europe, eg those that require security clearance due to access to sensitive information – Article 6.1.(c): legal obligation
- You may provide us with any additional information that you believe may be relevant for recruitment purposes (eg, your hobbies, recommendation letters, etc). If you participate in a recruitment event or an interview, we may process photos or videos of you – Article 6.1(a) GDPR: consent
- We may carry out basic pre-employment screening and reference checks, such as contacting your professional references, during the recruitment process or outsource these actions to a third-party service provider. We may also collect information on the communication channels you used when applying – Article 6.1(f): legitimate interest
Onboarding:
- We need to process certain information, including your ID details, to make you an offer and onboard you as an employee – Article 6.1(b) GDPR: contract performance
- We may be required to collect certain data from you based on our legal obligations, eg to apply for your work permissions, offer you a company car, collect information on your family composition, education details, etc. – Article 6.1.(c): legal obligation
- You may provide us with any other additional information (eg, your dietary or mobility preferences, or any information that you would like to be shared with your future colleagues). If you need relocation assistance, we may need certain information from you such as your home address – Article 6.1(a) GDPR: consent
4. How do we protect your personal data?
The protection of your personal data is a priority for Macadam Europe. To this end, we have implemented appropriate technical and organisational security measures to protect the personal data contained in our systems and databases as much as possible against unauthorised access and/or use, loss or theft. These measures are regularly tested, evaluated and, where necessary, adapted in order to guarantee an adequate security level at all times.
Our information security policy is fully based on the international ISO 27002 standard, and contains guidelines with regard to access control, data encryption, security of operations, security of communications, physical security, etc. A specialised security team is responsible for the implementation and follow-up of the guidelines, so that the security of our databases, networks, infrastructure and information systems is guaranteed.
The development or implementation of new systems, applications or new products is designed with the highest security in mind, and always taking your privacy into account (the ‚privacy by design‘ principle). Our security and privacy experts work closely together with the development teams to ensure that the appropriate protection is in place, commensurate with the assessed risk associated with the processing of the personal data in question.
Access control is an important aspect of our information security policy. Macadam Europe has implemented procedures to limit access to our databases, systems, equipment and networks to those persons who strictly need this access to perform their jobs. These persons must observe a strict obligation of confidentiality and comply with all guidelines for ensuring the protection of personal data.
Macadam Europe also provides privacy and security-specific training for its employees, in order to clarify the guidelines and procedures to its employees and to make them aware of the risks involved in processing personal data.
Macadam Europe also imposes high-security requirements on its partners and suppliers who process your personal data on our behalf. Partly by means of contractual guarantees, we ensure that, just like us, they process your data safely and with respect for the privacy legislation. We therefore expect our partners and suppliers to implement an information security policy and security measures that are grafted onto international standards and best practices.
5. Do we pass on your personal data? And to whom?
All the personal data you provide will be accessible to designated members of staff in the Human Resources division involved in the recruitment and onboarding process. Your personal data will also be processed by the selection panel or company division involved.
During the onboarding phase your personal data may also be processed by other divisions and departments at Macadam Europe. We may also need to share your data with certain third-party providers, or government agencies.
Third parties who provide services to Macadam Europe and are acting on our behalf
Your personal data may be used by our suppliers who provide service to Macadam Europe for the same purposes stated above. Here are a few examples:
- Digital workplace providers (such as MS Office, etc);
- Cloud providers hosting our recruitment portal;
- Companies specialized in ICT support and cybersecurity where necessary eg for support reasons;
- Companies helping us organize recruitment events, job fairs, etc;
- Tax consultancies and relocation services for expats or candidates from abroad.
Third parties who do not work on our behalf and are acting as Controllers
In case you are entitled to a company car, we may share your data with our leasing providers. We may also share your CV and personal data with other entities within Macadam Europe.
In order to comply with legal requirements
Where required by law, we may provide your personal data to government institutions, labour inspection services, police, public employment service, etc.
International data transfers
We may also process your data outside the European Economic Area, for example, where support from our service providers and software applications located outside the EU is necessary. Any transfers of your personal data are based on appropriate safeguards in accordance with the GDPR, including Standard Data Protection Clauses, Binding Corporate Rules, and European Commission’s adequacy decisions.
6. How long do we keep your personal data?
Your personal data will be kept for 1 year after the recruitment process is closed, unless you oppose the retention of your data, in which case such data will be deleted. In case you become Macadam Europe employee, your personal data will be processed and retained in accordance with Macadam Europe Employee Privacy Policy.
Macadam Europe will process your personal data with the utmost confidentiality and will ensure that technical and organisational measures for the protection of your personal data are implemented, even when used by third-party service providers. We use a range of physical, electronic and managerial measures to ensure that we keep your personal data secure, accurate and up-to-date.
7. What are your privacy rights and how can you exercise them?
If you apply via our Online Recruitment portal, you may at any time access, correct and update your personal details. Otherwise, you can also request access to your data and ask for modification or deletion of your data by contacting your recruiter and our Data Privacy Officer via pierre.deschepper@macadam.eu.
Furthermore, you have various rights in relation to your personal data. In particular, you have a right to obtain confirmation that we are processing your personal data, request a copy of the personal data we hold about you and/or correct such personal data that you think is incorrect or incomplete. You have the right to ask that we delete your data or restrict the way in which we use such personal data.
- Your right of access: You have the right to know at any time from Macadam Europe whether we are processing your personal data, and, if we are processing your data, to view that data and receive information about the processing.
- Your right to correction of personal data: You have the right to have incomplete, incorrect, inappropriate or outdated data corrected. In order to keep your data up-to-date, we would ask you to notify us of any changes, such as a change of e-mail address. These changes can be communicated to your recruiter and our Data Privacy Officer.
- Your right to erasure (the ‘right to be forgotten’)
- You have the right to have your personal data deleted in the following cases:
- your prior consent to the processing, and there is no other legal basis that Macadam Europe could invoke for the (further) processing;
- you object to the processing of your personal data and there are no more weighty,
- egitimate reasons for the (further) processing by Macadam Europe;
- your personal data is processed in an unlawful manner;
- your personal data must be deleted in order to comply with a legal obligation;
- your personal data was collected when your personal data is no longer necessary for the purposes for which it has been collected or otherwise processed by Macadam Europe;
- You have the right to have your personal data deleted in the following cases:
Bear in mind, however, that we are not always able to delete all the requested personal data, for example, if the processing of this data is necessary in order to comply with our legal obligations.
- Your right to the restriction of processing: In specific cases, you have the right to obtain the limitation of the processing of your personal data. This is the case, for example, when you dispute the correctness of personal data or when your data is no longer necessary in order to achieve the purposes of the processing, but you need it for the establishment, exercise or substantiation of a legal claim.
- Your right to object to the processing of your personal data: You have the right to oppose the processing of your personal data based on your specific situation if the processing takes place within the context of a legitimate interest of Macadam Europe. Macadam Europe will discontinue the processing of your personal data unless it can demonstrate compelling and legitimate reasons for the processing that outweigh your reasons, or if the processing of personal data relates to the lodging, exercising or substantiation of a legal claim (for example, filing of a request at a court).
- Your right to the transferability of personal data, or “data portability”: You have the right to ‘recover’ your personal data, for example, if you were to change your employer. This is only possible for the personal data you yourself have provided to Macadam Europe, based on consent or after agreement. In all other cases, you will not be able to exercise this right (for example, if the processing of your data takes place based on a legal obligation).
How can I exercise my privacy rights?
You can exercise your privacy rights by contacting your recruiter and our Data Privacy Officer via pierre.deschepper@macadam.eu.
8. Keep up to date with changes
We may modify or amend this privacy policy from time to time. To let you know when we make changes to this privacy policy, we will amend the revision date in our online recruitment portal. In other cases, we will notify you of any material change in the processing.
9. Escalation to the supervisory authority
The Data Protection Authority is an independent body that ensures that your personal data is processed in accordance with the law. If you have a complaint in connection with the processing of your personal data by Macadam Europe, or if you wish to initiate a procedure for mediation, you can contact the Data Protection Authority via https://www.gegevensbeschermingsautoriteit.be/burger/acties/klacht-indienen.