Privacy notice for job applicants
Introduction
This Privacy Notice applies to the processing of your personal data in connection with your online application (via our online application portal, and via email) and your application by regular mail. You will find information on how Sygnum Bank AG and its subsidiaries and branches (hereinafter “Sygnum” or “Group”, “we”, “us”) processes personal data as part of the application process. “Personal data” is any information that can be linked to a particular individual, and “process” means any handling of personal data, such as the collection, use and disclosure of personal data.
1. General information
For the purposes of this Privacy Notice, job applicants (also referred to as “you”) are persons who apply for a position advertised by us or submit a spontaneous application to us. Please take the time to read this Privacy Notice to understand how and why Sygnum processes your personal data, how Sygnum protects your personal data, and to learn more about your rights.
This Privacy Notice applies in addition to our existing general “Privacy Notice” on our website (see https://www.sygnum.com/privacy-notice/), which provides you with general information on how we process your personal data, e.g. in the context of your visit to our website and for other topics not related to your application.
2. Who is responsible for processing your personal data?
For data processing under this Privacy Notice, the Group company to which you are applying is in each case the “controller”, i.e. the party primarily responsible under data protection law.
If you have any questions regarding data protection, please feel free to contact the following address:
Sygnum Bank AG
Attn. Data Protection Officer
Uetlibergstrasse 134a
8045 Zurich
Switzerland
[email protected]
T +41 58 508 20 00
3. What data do we process?
We process your personal data if it relates to your suitability for the employment contract or with your separate consent and insofar as the processing is permitted by law and in accordance with our internal guidelines. Information on the purposes of this data processing can be found in section 4.
We process the following personal data from you as far as they are or become known to us, in each case with the current and also the previous information, if information changes over time:
- Identification data and master data: In connection with your application, we receive certain basic data that we need for the review, establishment and execution of an employment contract, including communication with you. This includes, for example, first and last name, home address, phone number, email address, date of birth and age, place of origin and nationality(ies), gender, language skills, marital status, family status and number of children, work and residence permit, photo(s) and video(s), passport and ID cars, military status, information on any trade union affiliation and political offices, details of hobbies and interests, your religious affiliation and details of previous convictions and debt collection;
- Data in connection with your current position and the organizational framework conditions for a possible employment: In the course of your application, we receive or generate and process various other information about you, your current employment and the organizational framework conditions, e.g. information on the notice period of the current employment contract, data in connection with your job and your employment contract, professional achievements, work content and job satisfaction, desired salary, your motivation, information on a disability, if applicable (only if relevant for the advertised position), information on special health, religious and other needs in connection with your employment;
- Applications, professional career, education and training: As part of an application, we receive information about your work history, qualifications, education and other data, such as curriculum vitae, information about certificates, diplomas, job references or confirmations of employment and other information about skills, competencies and qualifications, language skills, information about previous jobs and employers, reference persons and their contact details, information from references, information from official registers, information from interviews, assessments and aptitude tests, information about external mandates, offices and functions and information from publicly accessible profiles in social media (in particular LinkedIn profile, insofar as these are intended for business or professional use) and other information from the application and from the internet and other public sources;
- Data in connection with consent: Insofar as further personal data is processed with your separate consent, we process the relevant data including the date, subject matter and, if applicable, your withdrawal of consent (e.g. in the case of recordings of calls);
- Further data: It is possible that we process further personal data which we cannot list here conclusively. We inform you separately about the processing of such data if this is possible or we are obliged to do so.
If you are already employed by a Sygnum company, we may also use information we already have based on your previous employment. We process much of the above-mentioned data only if you voluntarily disclose it. However, certain data must be processed for us to consider an application. We point out in each case, if it is not already clear from the circumstances, whether certain information is mandatory (e.g. input fields marked with an asterisk (*) when applying on our online job portal). If you provide us with sensitive personal data as part of the application (e.g. health data), we may also process such personal data.
4. Processing purposes
We process the data mentioned in section 3 for various purposes related to your job application, in particular for the following purposes:
- Assessing application documents and the suitability of a job applicant, e.g. evaluating the suitability for a specific position with us for which you apply via our online portal or by other means or for which we inquire about you, assessing the suitability for other jobs or positions at Sygnum, including checking or re-checking documents and other information (for the retention period of your data, see section 7), verifying references, conducting background or security checks (if required);
- Preparation and conclusion of employment contracts, g. drafting, negotiating and concluding the employment contract;
- Analysis of the application process, e.g. checking your satisfaction with the application process, provided you have given us your consent to do so;
- Ensuring business operations and other security purposes, g. building security including access controls. Also, documentation of security incidents, data breaches, complaints, interactions with authorities and third parties and other relevant events and corresponding measures that relate to you or contain information about you;
- Investigations and legal proceedings, e.g. the prevention, investigation and prosecution of possible misconduct against the law by job applicants, including reviewing complaints, tips and objections, evaluation of surveillance measures and the conduct of investigations, participation in official investigations and proceedings, and the assertion, exercise or defense of legal claims.
5. To whom do we disclose your personal data?
In principle, only persons involved in your job application have access to your personal data, in particular personnel specialists from Sygnum and potential supervisors. These persons are subject to a duty of confidentiality and are sensitized to data protection and data security.
We may disclose personal data to other recipients to the extent necessary for the stated purposes (section 4) and to the extent permitted by law. In particular, we disclose personal data to recipients of the following categories:
- Former employers and other third parties, e.g. when we review an application and provide information about you in the process (to the extent permitted). We also work with clients, affiliates and other third parties (e.g. advertising service providers, debt-collection agencies, credit reporting agencies, etc.);
- Online application platforms: We may share your personal data with online application platforms whose services we use, such as BambooHR which is based in the USA;
- Other service providers: We work with other service providers domestically and abroad (e.g. IT service providers, maintenance and support service providers, security companies, etc.). As part of their tasks, these service providers may process or access your personal data. We ensure through the selection of service providers and through appropriate contractual agreements that data protection is also ensured by such service providers throughout the processing of your personal data;
- Group companies: If a job applicant is considered for a position with another Group company, we may disclose personal data to that company as well. For more information on how we process personal data within the Group, please see our general privacy notice which is available at https://www.sygnum.com/privacy-notice/;
- Industry organizations and other bodies, e.g. associations, federations, etc. with which you are involved in connection with your current employment relationship;
- Governmental authorities and official agencies, when we deem it necessary or appropriate in order to comply with laws and regulations or to verify compliance therewith, to respond to inquiries from competent authorities (e.g. in the context of a criminal investigation) or to participate in official or judicial investigations and proceedings;
- Parties to legal proceedings, e.g. opposing parties and other parties, experts, witnesses, etc., if we participate in legal proceedings or are considering participation;
- Acquirers or parties interested in acquiring business units, companies or assets.
6. Do we disclose personal data abroad?
Recipients of personal data are not only located in Switzerland. This applies in particular to certain service providers as mentioned in section 5. Recipients may also be located outside the European Economic Area (EEA) and Switzerland, in particular in the USA, but also in other countries worldwide, e.g. in Singapore or the United Arab Emirates (UAE). For example, we may transfer data to authorities and other persons abroad if we are legally obliged to do so or, for example, in the context of a company sale or legal proceedings. Not all of these countries currently guarantee an adequate level of data protection according to the standards of Swiss law. We therefore take contractual precautions to contractually compensate for the lower level of legal protection, especially with the standard contractual clauses issued by the European Commission and recognized by the Swiss Data Protection and Information Commissioner (FDPIC). For more information and a copy of these clauses, please visit www.edoeb.admin.ch/edoeb/en/home/data-protection/handel-und-wirtschaft/transborder-data-flows.html.
In certain cases, we may transfer data in accordance with data protection law requirements even without such contracts, e.g. if you have consented to the corresponding disclosure or if the disclosure is necessary for the performance of the contract, for the establishment, exercise or enforcement of legal claims or for overriding public interests.
7. How long do we store your personal data?
We store your personal data as long as it is necessary for the implementation of the specific application process or for compliance with legal requirements and as long as we have a legitimate interest in storing it (e.g. for documentation and evidence preservation purposes and for the protection and defense of legal claims). If we can consider you for the position for which you have applied, we will also retain your personal data for the performance of the employment contract.
In the event of unsuccessful applications, Sygnum will retain the data from your application for a period of twelve (12) months after your application in order to assess your suitability for a specific position or for purposes related to subsequent applications or vacancies and to be able to contact you. After that, only data in reduced form (in particular first and last name, date of birth and position for which the application was submitted) will be stored and definitely deleted after five (5) years.
8. How do we protect your personal data?
We take appropriate technical (e.g. access regulations and restrictions) and organizational measures (in particular instructions and directives) to protect your personal data and continually adapt these to technological developments.
9. What rights do you have with regard to your personal data?
You have certain rights with respect to your personal data processed by us in order for you to control or influence our processing. These are in particular the following rights:
- Information: You have the right to obtain information about your personal data processed by us at any time in writing and generally free of charge.
- Correction: You may, at any time and free of charge, request that we correct, complete or update your personal data if it is incorrect.
- Objection and deletion: You may object to our data processing and request that we delete your personal data at any time if we are not obliged to continue processing or storing this data and if it is not necessary for the employment contract.
- Withdrawal of consent: If we process your personal data based on your consent (see section 3), you may withdraw consent at any time. Such withdrawal of consent is only effective for future data processing.
Some of these rights may not apply in individual cases, and we may be entitled or obligated to restrict or postpone the fulfilment of a right. We will inform you accordingly in such a case. You also have the right to lodge a complaint with the competent data protection authority at any time if you do not agree with our processing of your personal data.
Status of this Privacy Notice for job applicants: August 2024