Processing of (personal) data by the entity in charge of the online application process
1. Purpose and scope
This Privacy Policy governs the processing of personal data of individuals who participate or may participate in recruitment processes managed by SOLTEC POWER HOLDINGS, S.A. (hereinafter, “SOLTEC”) through this careers portal.
Its purpose is to provide candidates with clear and transparent information on how their personal data will be processed in accordance with Regulation (EU) 2016/679, the General Data Protection Regulation (“GDPR”), and Organic Law 3/2018 of 5 December on the Protection of Personal Data and Guarantee of Digital Rights (“LOPDGDD”).
2. Data Controller
The data controller responsible for the processing of personal data is:
- Legal name: SOLTEC POWER HOLDINGS, S.A.
- Tax Identification Number (NIF): A05556733
- Registered address: P.I. La Serreta, C/. Gabriel Campillo, s/n, 30500 – Molina de Segura (Murcia, Spain)
- Data protection contact email: dpo@soltec.com
- Data Protection Officer (DPO): dpo@soltec.com
3. Personal data processed
Depending on the position applied for and the development of the recruitment process, we may process the following categories of personal data:
- Identification and contact details, such as first and last name, email address, telephone number or address;
- Academic and professional information, such as education, qualifications, professional experience, languages, skills and other information included in the CV;
- Information relating to the application, such as the position applied for, availability, career preferences, professional expectations and, where relevant, salary expectations;
- Documents voluntarily provided by the candidate, such as CVs, cover letters, qualifications, certificates or professional references;
- LinkedIn profiles or other professional profiles when voluntarily provided or, where legally permitted, when consulted in the context of the recruitment process;
- Information obtained during interviews, tests or assessments carried out as part of the recruitment process;
- Assessments and comments made by those responsible for the recruitment process.
Candidates are requested not to include in their CV or other documentation any information that is not necessary to assess their application and, in particular, any data belonging to special categories of personal data, such as information concerning health, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data intended to uniquely identify an individual, or information concerning sex life or sexual orientation.
In the exceptional circumstances where it is necessary to process special categories of personal data for the purposes of the recruitment process, such processing will only take place where one of the circumstances provided for in Article 9.2 of the GDPR applies and where the processing is necessary and proportionate to the intended purpose.
4. Purposes and legal bases
4.1. Recruitment process management
Personal data will be processed for the purposes of receiving, reviewing and managing the application; assessing the candidate’s suitability for the requirements of the position; contacting the candidate; arranging interviews; carrying out assessments or tests that form part of the recruitment process; conducting the corresponding internal assessments and, where applicable, taking the necessary steps to formalise the employment relationship.
The legal basis for this processing is Article 6(1)(b) of the GDPR, as the processing is necessary for the implementation, at the candidate’s request, of pre-contractual measures with a view to the possible conclusion of an employment contract.
4.2. Compliance with legal obligations
Where necessary, certain personal data may be processed to comply with legal obligations applicable to SOLTEC, in accordance with Article 6(1)(c) of the GDPR.
Where such obligations exceptionally involve the processing of special categories of personal data, the corresponding exception under Article 9(2) of the GDPR will also apply.
4.3. Retention for future recruitment processes
If the candidate expressly authorises it, once the recruitment process has ended, we may retain their application in order to consider their profile for future vacancies that may be suitable for their experience, qualifications or professional interests.
This processing will be based on the candidate’s consent, in accordance with Article 6(1)(a) of the GDPR.
Consent to inclusion in the candidate pool is voluntary, and refusal to provide consent will have no consequences for the candidate’s application for the specific position for which they have applied.
Consent may be withdrawn at any time, without affecting the lawfulness of processing carried out prior to its withdrawal.
Data will be retained for this purpose for a maximum period of 12 months from the end of the recruitment process or from the candidate’s last update of their data.
5. Mandatory nature of the data
The data identified as mandatory in the application form are necessary to process and assess the application.
Candidates are not legally required to provide their personal data. However, failure to provide the information necessary to assess the application may prevent the candidate from participating in or continuing with the relevant recruitment process.
Candidates guarantee that the information they provide is truthful, accurate and up to date and undertake to communicate any relevant changes.
6. Data recipients
Personal data may be accessed exclusively by those individuals who need to know such information in order to participate in the relevant recruitment process, including authorised Human Resources personnel and individuals responsible for the departments or areas involved in the recruitment and potential hiring process.
Where the recruitment process relates to a vacancy at another company belonging to SOLTEC, the candidate’s data may be disclosed to that company where necessary to manage the application. In such cases, candidates will be appropriately informed of the identity of the entity acting as the data controller.
For the technological management of recruitment processes, SOLTEC uses the platform provided by Personio SE & Co. KG, which acts as a data processor in relation to data processed on behalf of SOLTEC.
Data may also be disclosed to Public Authorities, courts, tribunals, law enforcement authorities or other competent authorities where there is a legal obligation to do so or where necessary for the establishment, exercise or defence of legal claims.
Personal data will not be disclosed to third parties for commercial purposes.
7. International data transfers
No international transfers of personal data are currently envisaged.
8. Data retention periods
While the recruitment process remains open, personal data will be retained for as long as necessary to manage the application and make a decision regarding the filling of the position.
If the candidate is selected, any data necessary to formalise and manage the employment relationship will be incorporated into their employee file and processed in accordance with the applicable privacy information for employees and for the periods corresponding to that employment relationship.
If the candidate is not selected, once the recruitment process has ended, their data will no longer be used for this purpose and will be deleted, without prejudice to the possibility of retaining such data in a duly restricted or blocked form, as provided for in Article 32 of the LOPDGDD, for the applicable limitation periods relating to any potential liabilities arising from the processing.
While the data remain blocked, they may not be used for new recruitment processes or for any other ordinary purpose and will remain exclusively available to judicial authorities, the Public Prosecutor’s Office or the competent Public Authorities where necessary to address potential liabilities.
Once these periods have expired, the data will be permanently destroyed.
However, if the candidate has expressly consented to their inclusion in the candidate pool for future vacancies, their data may remain active for this purpose for the period indicated in section 4.3.
9. Automated decision-making and profiling
SOLTEC does not make decisions that produce legal effects concerning candidates or similarly significantly affect them based solely on automated processing of their personal data.
Decisions concerning the suitability or recruitment of candidates involve human intervention.
10. Security and confidentiality
SOLTEC will process candidates’ personal data confidentially and will implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk and to prevent the destruction, loss, alteration, unauthorised disclosure of or access to personal data.
Access to the information will be limited to individuals who need to process it for the purposes described in this Privacy Policy.
11. Candidates’ rights
Candidates may exercise, under the terms established by applicable data protection legislation and where applicable, their rights of access, rectification, erasure, restriction of processing, objection and data portability.
Likewise, where processing is based on consent, candidates may withdraw their consent at any time, without affecting the lawfulness of processing carried out prior to its withdrawal.
To exercise their rights, candidates may contact: dpo@soltec.com
If a candidate considers that the processing of their personal data infringes applicable data protection legislation, they may lodge a complaint with the Spanish Data Protection Agency (AEPD), without prejudice to any other administrative or judicial remedy that may be available to them.
12. Updates to this Privacy Policy
SOLTEC may amend this Privacy Policy where necessary to reflect changes in legislation, guidance or criteria issued by data protection authorities, or changes to the procedures or tools used to manage recruitment processes.
The current version of this Privacy Policy will be the version published on the careers portal at any given time.