PRIVACY POLICY

In connection with the recruitment process, STG will, as the data controller, collect, process and disclose personal data about job applicants. The local STG company to which you are applying for a position is the controller of the personal data relating to the recruitment process. Please find a full list of STG companies below:

  • Scandinavian Tobacco Group Lummen N.V. (Belgium)
  • Scandinavian Tobacco Group Belux N.V. (Belgium)
  • Scandinavian Tobacco Group Belgium Services N.V. (Belgium)Agio Cigars Belgium N.V. (Belgium)
  • Scandinavian Tobacco Group Deutschland GmbH (Germany)
  • Agio Cigars GmbH (Germany)Scandinavian Tobacco Group A/S (Denmark)
  • Scandinavian Tobacco Group Assens A/S (Denmark)
  • Scandinavian Tobacco Group Denmark A/S (Denmark)Scandinavian Tobacco Group Spain S.A.U. (Spain)
  • Scandinavian Tobacco Group France S.A.S. (France)
  • Scandinavian Tobacco Group United Kingdom Limited (United Kingdom)
  • Scandinavian Tobacco Group Italy S.R.L. (Italy)Scandinavian Tobacco Group Tobacco Service B.V. (the Netherlands)
  • P.G.C. Hajenius B.V. (the Netherlands)
  • Scandinavian Tobacco Group Nederland B.V. (the Netherlands)
  • Scandinavian Tobacco Group Eersel B.V. (the Netherlands)
  • Agio Sigarenfabrieken N.V. (the Netherlands)STG Portugal S.A. (Portugal)
  • STG Sweden AB (Sweden)

In this notice, we provide you with information, which we are legally required to provide.

1. Categories of personal data and purposes

We collect and process the following types of personal data:

Categories of data subjects and categories of personal data: Job applicants:- 

Sensitive categories of personal data: To the extent that personality traits are categorised as “health data”.

Non-sensitive categories of personal data: Name, private and job contact details (e-mail address, phone number and address), gender, date of birth, photo, CV, hobbies and educational background, references from previous employers, etc., personality assessment results of and logical assessment results (where you have taken part in these).

Nationality (only if necessary to ensure work permits, etc.).

If you provide it but are not encouraged: Marital status, children.

We process the personal data for the following purposes:

  • In order to assess job applicants' professional and personal qualifications and personal qualities when recruiting new employees.
  • To comply with applicable laws and regulations, including data protection laws and regulations and legitimate interests on the part of STG, e.g.: Compliance with basic principles and legal grounds for processing personal data, e.g. documenting consent (where provided).
  • Putting in place, maintaining and testing technical and organisational security measures.
  • Investigating and reporting suspected personal data breaches.
  • Handling requests and complaints from job applicants and others.
  • Handling inspections and queries by supervisory authorities.
  • Handling disputes with job applicants and third parties and establishment, exercise or defence of legal claims.
  • Reorganisation or sale of STG, including but not limited to; mergers, acquisitions, divestitures or sale of the company and legal reviews as part thereof.

2. Sources

The personal data are collected from the individual, the applicant’s previous employer and other references, if such references have been provided by the applicant, who has consented to the collection of reference information, and from recruiters acting for STG as well as other third parties (e.g. independent search providers).

3. The legal basis for the collection and processing of the personal data

The legal basis for the collection and processing of job applicant's personal data is the following:

  • Consent of the job applicant, cf. art. 6(1)(a) of the EU General Data Protection Regulation (“GDPR”) with regard to:

 - Personality and logical assessments.

- References from previous employers and other references.

- Registration of application, CV and supporting documentation in the Talent Community.

  • The processing is necessary in order to assess your application prior to entering into an employment contract with STG (should you be employed by STG), cf. article 6(1)(b) of the GDPR.
  • The processing is necessary for compliance with a legal obligation to which STG is subject, cf. article 6(1)(c) of the GDPR, e.g. compliance with the applicable employment laws and alien laws when the job applicant is not from the local STG jurisdiction.
  • The processing is necessary for the purposes of legitimate interests, cf. article 6(1)(f) of the GDPR, as STG’s legitimate interests, are:

- Assessing the professional qualifications and personal character of job applicants.

- Reorganisation or sale of STG, including but not limited to; mergers, acquisitions, divestitures or sale of the company and legal reviews as part thereof.

When we collect personal data directly from you for the purpose of recruitment, you provide the personal data voluntarily and in order to be considered for the recruitment process. You are not obliged to provide the information to us. For the most part of personal data, the consequence of not providing it is that we cannot consider you for employment as we will not be able to assess your professional and personal qualifications.

4. Modalities of data processing

The personal data will be processed through paper-based and electronic means, by individuals responsible for personnel administration and recruitment duly instructed in writing with respect to the modalities and security measures to implement during the processing of personal data.

5.  Disclosure of the personal data to other data controllers

The personal data will be disclosed to and shared with the following recipients:

  • Travel agency in case we need to arrange travel and hospitality for the job interview.
  • Where necessary, we disclose personal data to Scandinavian Tobacco Group A/S in Denmark, which may participate in the recruitment, including outside the EEA, or if you have enrolled in the Talent Community Registration. A full list of STG companies is set out above.
  • Where necessary, to third parties in relation to law enforcement or regulatory investigation.

The legal basis for the disclosure of job applicant's personal data is the following:

  • The disclosure is based on your consent if the disclosure takes place as part of your Talent Community Registration, cf. article 6(1)(a) or (b) of the GDPR.
  • The disclosure is necessary for STG to comply with its legal obligations, cf. article 6(1)(c) of the GDPR with respect to disclosure made to third parties in relation to law enforcement or regulatory investigation.
  • The disclosure is necessary for the purposes of STG’s legitimate interests, cf. article 6(1)(f) of the GDPR:

in making travel and hospitality arrangements for the applicant.

ensuring that the relevant companies confirm their agreement to the contemplated recruitment, where necessary.

Local legislation on which disclosure is based in addition to the above:

6. Right to withdraw consent

When the data processing is based on your consent, you have the right to withdraw your consent. If you withdraw the consent, this will not affect the lawfulness of the processing prior to the withdrawal thereof. Please contact us using the contact details below if you wish to exercise this right. Please note that if you withdraw your consent, we may not be able to continue your application.

7. Transfer of personal data to data processors

We transfer the personal data to our service providers (such as IT providers) and suppliers of personality and logical assessments, which process and store the personal data on our behalf.

8. International transfers of personal data to recipients (both data controllers and data processors) in countries outside the EU/EEA

We may transfer the personal data to recipients located in countries outside the EU/EEA. We ensure that such transfer will be carried out in accordance with the applicable data protection laws. To ensure that your personal data receives an adequate level of protection, we have put in place appropriate procedures with the third parties we share your personal data with to ensure that your personal data is treated by those third parties in a way that is consistent with and which respects the data protection laws. Should you wish to receive more information on measures and procedures in place to ensure adequate protection of your personal data, please contact us by using our contact details set out in section 

9. Retention period

If you obtain employment with STG, we will store the personal data in accordance with the privacy notice for employees, for the duration of your employment. Certain personal data will be stored for another duration (shorter or longer) if required under statutory retention periods or if necessary for administrative purposes (e.g. pension payments, issuance of certificates of employment etc.) or for the establishment, exercise or defence of legal claims.

If you are not employed with STG, we will delete your application and personal data up to 6 months after the recruitment process has ended, and you received a notification of not being offered a position with STG. We may store for longer if necessary for the establishment, exercise or defence of legal claims or if you consent to us keeping your application etc. in the Talent Community Registration.

10. Your legal rights

Subject to the conditions and exceptions set out in the GDPR and locally applicable data protection laws, you enjoy the following legal rights:

  • The right to request access to the personal data processed about you.
  • The right to rectification of incorrect or misleading personal data.
  • The right to erasure (“right to be forgotten”).
  • The right to restriction of processing of personal data.
  • The right to data portability.
  • The right to object to the processing of personal data.

Additional for STG France as a data controller:

The right to define guidelines regarding the storage, erasure and disclosure of your personal data after your death, cf. Article No. 40-1 of French Act n°78-17 of 6 January 1978 on information technology, data files and civil liberties.

You also have the right to lodge a complaint with the Data Protection Agency. Please consult their website for how to submit a complaint at:

Denmark: www.datatilsynet.dk

Belgium: https://www.dataprotectionauthority.be/

France: https://www.cnil.fr/

Germany: Der Landesbeauftragte für Datenschutz und Informationsfreiheit Bremen www.datenschutz-bremen.de 

Italy: www.garanteprivacy.it

The Netherlands: Autoriteit Persoonsgegevens https://autoriteitpersoonsgegevens.nl/nl/zelf-doen/privacyrechten/klacht-indienen-bij-de-ap

Portugal: Comissão Nacional de Proteção de Dados: Rua de São Bento, n.º 148-3º, 1200-821 Lisboa, Portugal - Tel: +351 213928400 - Fax: +351 213976832 - e-mail: geral@cnpd.pt

Spain: https://www.aepd.es/

Sweden: https://www.datainspektionen.se/

The UK: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF; Tel: 0303 123 1113; email: casework@ico.org.uk; website: https://ico.org.uk

11. Right to object when the processing is based on legitimate interests

On grounds relating to your particular situation, you have the right to object, at any time, to the processing of personal data which is based on STG’s or a third party’s legitimate interests or public interests in pursuance of article 6(1)(e) and (f) of the GDPR. If you object, STG can no longer process the personal data unless STG demonstrates compelling legitimate grounds for the processing, which override your interests, rights and freedoms or if the processing is necessary for the establishment, exercise or defence of legal claims.

12. Contact

Please contact us if you have any questions in regard to the protection of your personal data or if you wish to exercise your legal rights.

Contact details of the data controller:

  • Scandinavian Tobacco Group A/S, Sandtoften 9 , 2820 Gentofte, Denmark
  • Business registration number in Denmark: 31 08 01 85
  • Email address: info@st-group.com,
  • Tel no: +45 39 55 62 00