Global Candidate Privacy Policy
This global candidate privacy policy sets out how COFCO International uses and protects personal data collected about you during our application and recruitment process.
1 Overview
At COFCO International (CIL, “we” “our” or “us”), we are committed to protecting the confidentiality, accuracy and integrity of any personal data you provide to us. We always strive to safeguard such data from misappropriation, loss, misuse, unauthorized access, disclosure and/or alteration. We only collect personal data that is relevant for our described purposes, as described herein.
The local CIL company hiring for the position you apply for will be the controller of your personal data.
COFCOINTL II Services Portugal, Unipessoal, Lda., having its registered offices at R. da Lionesa – Espaço D2, 4465-671 Leça do Balio, Matosinhos, Portugal, is our CIL member with delegated data protection responsibilities, and it will be a controller of your personal data as well. In some cases, COFCOINTL II Services Portugal, Unipessoal, Lda. may also act as a processor on behalf of other CIL entities.
CIL has also appointed a Data Protection Officer who can be reached at [email protected].
Prior to providing any Personal Data to CIL, you must read and agree to the terms and conditions of this Privacy Policy.
2 Scope
This global Candidate Privacy Policy explains what information we, including our subsidiaries and affiliates, collect during our application and recruitment process and why we collect it, how we use that information and how to access and update that information.
Unless otherwise required by a local law or jurisdiction or provided for in a subsequent or different notice coming from a local CIL company, this Policy applies to all CIL companies, including its wholly owned or controlled subsidiaries and affiliates.
This Policy applies to all applications submitted via CIL’s careers website, via third party systems such as recruitment agencies and all other means, such as by post and by email.
3 Which Personal Data We Collect
We will not use Personal Data for any purpose that is incompatible with the purpose for which it was initially collected unless you provide your prior explicit consent for further use.
CIL will generally only collect personal data that is necessary to assess you for the position for which you have applied. This includes the following categories:
a) Contact Data, which may include information such as first and last names, e-mail address, mailing address, zip code, phone numbers, country, personal ID, passport and others;
b) Job Applicant Data, which may include information such as your Contact Data and all information available in your resumé, the information filled in CIL’s website, i.e., country, residence, work permit, languages, years of experience, current company, current/previous positions, current/previous functions, current/previous professional areas, CV, cover letter as well information contained in your social media accounts like LinkedIn;
c) Financial information, which may include information such as your bank account details;
d) Internal Candidate Information, which may include information such as references given by CIL and performance results during the various stages of the recruitment process;
e) Internet/Network Information, which may include information related to your use of CIL’s careers website, such as your username and password to authenticate in our website as well your IP address, browser or device information as described in your Cookie Policy.
CIL will not collect Personal Data if such collection is prohibited under the applicable data protection laws. We will always indicate whether the information requested is mandatory or optional. If you fail to provide mandatory information, in some circumstances this may mean CIL will be unable to process your application.
4 How We Collect Your Personal Data
CIL may collect Personal Data from multiple sources, namely:
- Personal Data that we receive directly from you, in one of the situations listed above, when you voluntarily submit it to us or that we ask you for when you interact with us.
- Personal Data that we receive from other sources, such as recruitment agencies or from the internet where you have made this information publicly available, for example, on your LinkedIn profile as well information collected from diplomas, certifications or other documentation received.
- Personal data that we collect when you interact with us online, according to our Cookie Policy.
5 How We Use Your Personal Data
We process the personal information that we collect about you for the following purposes:
a) Application Assessment and recruitment, for example, so CIL can evaluate your application, assess your eligibility to meet the job requirements, verify your information and progress your job application and to make any verifications required by local law.
b) Reimbursement of travel expenses, for example, if we require you to travel to some place during the recruitment process;
c) Future jobs opportunities resourcing, for example, if your application is unsuccessful and you have given us consent to contact you in case we consider you for future suitable vacancies.
d) Creation of an employee record, for example, if your application is successful, the information collected so far will form part of your employee record and will be used to manage your career at CIL.
e) Automated decisions, for example, in some cases we might need to make an automated decision on the suitability of your application based on certain criteria, such as proficiency in English – and you will be informed in those cases whereas information is collected to make a possible automated decision about you.
f) Improvement of your experience, for example, by collecting cookies in accordance with our Cookies Policy so we can better understand how you use our recruitment website and how can we improve its performance and your experience;
g) Comply with legal obligations, for example, with health & safety and other legal or fiscal obligations.
CIL will only process your personal data where it has a legal basis for doing so. Most of the time, we will be processing your personal data in order to take the reasonable steps to decide whether to enter into an employment agreement with you. In some cases, we will also be processing your personal data because you have given us your consent to do so. In such case, your consent can be withdrawn at any given time. Our legitimate interests can also be used as a basis to process your personal data when they are not overridden by your data protection interests or fundamental rights and freedoms.
6 How And Why We Share Your Personal Data
CIL does not sell, share, or otherwise distribute your personal data to third parties for promotional purposes.
CIL will only share your Personal Data with third parties in strict compliance with this policy, your preferences and applicable laws and regulations.
We may disclose personal information collected and contained in your applicant data to the following categories of recipients:
a) Within CIL
CIL operates globally, which means your information may be stored and processed outside of the country or region where it was originally collected in order to carry out the activities specified in this Policy.
We restrict information to people within our company based on a “need to know” principle, for example, our team members (e.g., our recruitment and acquisition teams) may need access to process your application and manage your recruitment process. Because of this we may share your Personal Data to our companies that provide shared services within CIL, for example, in connection with HR services, financial and accounting support, credit control, recordkeeping and payroll.
If your data has to be shared outside of the European Economic Area (“EEA”) or in a country where you may have fewer rights in respect of your information than you do in your country of residence, we will make sure that there is a legal basis for such transfer and that your personal information is adequately protected as required by applicable law, for example, by using standard agreements approved by relevant authorities and by requiring the use of other appropriate technical and organizational measures to protect your personal information or by implementing “Binding Corporate Rules” within our company.
Regardless of where your information is processed, we apply the same protections described in this Policy.
b) Outside CIL
We may also share your personal data with our third-party services providers that may need your data for the purposes described in this policy, such as recruitment agencies. These third-party service providers act on our behalf and are bound by law or contract to protect your Personal Data and only use your Personal Data in accordance with our instructions.
We may also only disclose your Personal Data outside CIL:
- When legally needed to comply with legal obligations, investigate legal issues, enforce our rights, protect our property or as needed for any other legal or regulatory investigation or proceeding;
- When you give us your explicit consent to disclose your Personal Data.
You should also be aware that, when you use features such as message boards, chats, or other social media channels to interact with CIL, any information you submit, including your name, location and email address, may be publicly available to others. We are not responsible for any information you choose to submit through these features, and we strongly discourage you from disclosing any sensitive Personal Data (such as health or credit card information) through these features. If you use these features, your Personal Data may remain on the Site or App even after you cease use of the Site or App.
Finally, and where permitted by applicable law, Personal Data may be disclosed in connection with corporate restructuring, sale, or assignment of assets, merger or other changes of control or financial status of CIL.
7 How Long We Keep Your Information
Unless a longer retention period is required by law, CIL will keep your information for as long as it is necessary for the recruitment process. If your job application was successful, we will keep your information for the duration of your employment to comply with our legal obligations and in accordance with our retention policies and procedures.
If your application was unsuccessful, and in cases where you have given your consent to do so, we will keep your information for up to 3 years after your last interaction with us or after your last profile update, whichever occurs later, so we can contact you about future roles that may interest you. During this period, you can withdraw your consent at any given time by contacting us.
When we are no longer able to retain your personal data in accordance with this Policy, we will anonymise your information and may retain those records to monitor the general performance and effectiveness of our recruitment process.
8 How And Where We Store Your Personal Data
We store your Personal Data carefully. We follow industry standard measures to protect them against unauthorized access to, and unlawful interception or processing of Personal Data. Once we have received your Personal Data, we will use strict procedures and security features to prevent unauthorized access.
Your Personal Data collected will be stored within the European Economic Area (“EEA”) and Switzerland.
When your Personal Data has to be transferred to a destination outside the EEA and Switzerland, you must be aware that such destination countries may have different levels of privacy protection than in your country of residence. In such cases we will take all steps legally necessary to ensure that your Personal Data is treated securely and in accordance with this Privacy Policy and the applicable legislation, namely by entering into international transfer agreements or other appropriate safeguards, such as imposing contractual obligations on the recipients of your Personal Data. We may alternatively implement “Binding Corporate Rules”.
9 Your Rights
Depending on and subject to applicable laws, you have certain rights regarding the Personal Data we hold about you. These rights may include the following:
Right of Access
You have the right to access and receive a copy of your Personal Data held by us.
Right to Rectification
You have the right to demand that we correct incorrect Personal Data we might hold about you.
Right to Erasure
You have the right to request the erasure of your Personal Data at any time if you consider that we do not have the right to hold it. We may retain certain information about you as required by law and for legitimate business purposes permitted by law.
Right to Restrict Processing
You can ask us to suspend the processing of your Personal Data in several scenarios, including if you want us to verify the accuracy of the data, and if you believe our use of your data is unlawful but you do not want us to erase it.
Right to Data Portability
You can request the transfer of your Personal Data to you or to a third party. We will provide you, or the third party you have chosen, with your Personal Data in a structured, commonly used, machine-readable format. This right only applies to information which you initially provided us with, where we used the information to perform a contract with you or where the processing of your Personal Data is carried out by automated means.
Right to Object
You have the right to object to your Personal Data being processed for a particular purpose or to request that we stop using your Personal Data.
Right to Withdraw Consent
Where our processing of your Personal Data is based on your consent, you have the right to withdraw your consent at any time. If you do so we will stop processing your Personal Data unless there is another lawful basis we can rely on, in which case we will inform you of this.
Right to Reject Automated Individual Decision-Making
You can request not to be subject to a decision based on automated processing and to have safeguards put in place if you are being profiled based on your personal data.
These rights can be exercised by contacting our Data Privacy Team and Data Protection Officer at [email protected]. However, please note that we may, if and to the extent permitted by applicable law, need to retain or continue processing certain information.
If you are located in the EU, you also have the right to lodge a complaint regarding the processing of your data with your country’s supervisory authority regulating data protection.
Where required under applicable law, we may ask for proof of your identity to help us prevent unauthorized individuals from accessing, changing or deleting your Personal Data.
We will respond to your request as soon as practically possible and always within the timeframes set forth by applicable law.
10 Changes to this Policy
CIL may, at any time, revise this Privacy Policy by updating this document. If we make revisions to this Privacy Policy, we will update the date of this Privacy Policy. We will continue to use and/or disclose Personal Data in accordance with the version of this Policy that was in effect at the time the Personal Data was collected, unless you have agreed to have an updated version of the Privacy Policy apply to the Personal Data collected while a prior version of our Privacy Policy was in force.
11 How You Can Contact Us
Please contact us if you have any complaints, questions or comments about our privacy practices, your privacy choices, or this Policy. You can always reach us by e-mail at [email protected].
You may also contact us to exercise any of the rights mentioned in this Policy.
12 Application of Local Laws
This Policy is designed to set a uniform minimum standard for every CIL entity with respect to its protection of Candidates Personal Data. CIL recognizes that certain local laws and regulations may impose additional requirements than those described in this Policy. CIL will endeavor to collect and process Candidates Personal Data in accordance with local laws applicable.
13 Relevant Definitions
In the context of this document:
Personal Data
“Personal Data” means any information relating to you that would allow a party to identify you as an individual or to contact you, including, for example, your full name, address, telephone number, document number, birthdate or email address.
Company, CIL, COFCO
COFCO International Limited and its affiliated companies
Data Subjects
A data subject is any person whose personal data is being collected, held or processed.
Updated May 2024.
