GBS Change Management & Stakeholder Engagement Manager

How we process your personal data:

Basic information on the processing of personal data

Data Controller:
The data controller is JTI GBS Poland sp. z o.o. with its registered office in Warsaw, ul. Żelazna 51/53, 00-841 Warsaw (‘JTI GBS’).

Purposes of processing:
1. participation in the recruitment process announced by JTI GBS., in which you are applying;
2. in case of receiving your consent – enabling participation in recruitment processes conducted by JTI GBS in the future;
3. if your application is submitted under the employee referral program conducted at JTI GBS - handling your application and implementing the objectives of the program.
In specific situations, JTI GBS may also process your personal data to the extent necessary to establish, assert or defend against claims.

Legal basis for processing:
Ad. 1. Depending on the data scope :
- name, surname, date of birth, contact details, education, course of employment, professional qualifications: necessity for compliance with a legal obligation to which the controller is subject; – Art. 6(1)(c) of the GDPR in connection with Art. 22(1) § 1 of the Labour Code (however education, course of employment and qualifications are required only when it is necessary for the given position);
- other data provided by the candidate: consent – Art. 6(1)(a) of the GDPR
Re. 2. - Future recruitments – consent – Art. 6(1)(a) of the GDPR
Re. 3. - Employee Referral Program - the controller's legitimate interest consisting in conducting effective recruitment - Article 6(1)(f) of the GDPR.
In case your personal data are be processed for the purpose of establishing, investigating or defending against claims, the legal basis of the processing is the legitimate interest of the controller consisting in protecting JTI GBS rights.
GDPR – Regulation (EU) No 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

Rights related to the processing of personal data:
right to object to the processing of personal data;
right to erasure of data;
right of access to data;
right to restrict the processing of data;
right to rectify data or complete incomplete data;
right to transfer data;
right to withdraw consent to the processing, at any time;
right to lodge a complaint with the President of the Personal Data Protection Office.

Detailed information on processing: see the questions and answers below.

Detailed information on the processing of your personal data:

1. Who is the controller of your personal data?
Name and registered office: JTI GBS Poland sp. z o.o., ul. Żelazna 51/53, 00-841 Warsaw
Contact mailbox regarding data processing: wawgdprgbs@jti.com
Data Protection Officer: The data controller has appointed a Data Protection Officer who can be contacted directly at the following address: wawgdprgbs@jti.com. The Data Protection Officer can be contacted in all matters related to the processing of personal data and the exercise of rights related to the processing of such data.

2. For what purposes is your personal data processed?
Your personal data will be processed for the purpose of enabling you to take part in the recruitment process for the position in JTI GBS to which your application relates. If you have provided your consent to participate in the recruitment processes conducted by JTI GBS in the future, your data will also be processed for this purpose. If your application is considered under the employee referral program, your data will also be processed to accomplish the objectives of the program. In specific situations, JTI GBS may also process your personal data to the extent necessary to establish, assert or defend against claims. Detailed information on the basis of data processing is provided in the table.

3. What is the data retention period?
The data provided in order to take part in a specific recruitment project will be retained for the period until the end of the recruitment process, up to a maximum of 3 months from the selection of the employee in case no contract has been concluded. If you have given your consent to the processing of your personal data for future recruitments, then your data will be processed until your consent is withdrawn, but for no longer than for 12 months. In case of processing your application under the employee referral program, your personal data will be processed until the objectives of the program have been met. The duration of the processing of your personal data may be extended each time by the period of the statute of limitations for claims, if the processing is necessary to establish, assert or defend against claims.

4. Who will be the recipients of your personal data?
The data may be transferred to entities processing personal data on behalf of the controller, e.g. IT service providers, entities operating the database, entities handling application requests – however, these entities process data on the basis of an agreement with the controller and only in accordance with the controller's instructions and within the scope of the granted consent. Personal data may also be transferred to other JTI Group companies in connection with intra-group purposes.

5. Will your personal data be subject to profiling?
During the recruitment process, you may be asked to complete tests (e.g. analytical test, behavioural test, cognitive test) or to participate in an Assessment Center session. In the case of behavioural test, you will be subject to profiling. The system will evaluate the answers you give in the survey and create a profile of your behaviour and preferred working conditions based on these answers. The test is only a support material for the recruiter conducting your recruitment process and no automated decisions are made based thereon.

6. What are your rights in relation to the processing of your personal data?
You have the right to withdraw your consent for processing of data at any time. The withdrawal of consent shall not affect the lawfulness of processing carried out on the basis of consent prior to its withdrawal. You have the right to obtain information about the processing of your personal data concerned in accordance with Art. 15 of the GDPR, including to obtain copies of your personal data. In addition, you may request the rectification of inaccurate personal data, as well as the completion of incomplete personal data. You may also request restriction of the processing in the cases referred to in Art. 18 of the GDPR, as well as the data portability. You have the right to object to the processing of your personal data. You have also the right to erasure your personal data. . When profiling is used (it may take place when using behavioural tests in the recruitment process), you have the right to object to the profiling of your personal data. In order to exercise the above rights, please contact the data controller, e.g. by sending an appropriate request via e-mail. You also have the right to lodge a complaint with the supervisory authority (Poland: President of the Personal Data Protection Office).

7. Is personal data transferred outside the European Economic Area?
Your personal data may be entrusted for processing to JT International S.A. with its registered office in Switzerland, i.e. outside the European Economic Area (EEA). The European Commission has stated that this country offers an adequate level of personal data protection (Commission Decision of 26 July 2000). The recipient has implemented adequate and appropriate safeguards for your personal data. You have the right to receive a copy of the transferred personal data. Your personal data may also be transferred to other JTI Group companies that are based outside the EEA. Whenever the country to which the transfer of personal data will take place does not provide an adequate level of protection for personal data, JTI GBS will ensure the protection of your personal data in accordance with applicable legislation.

8. Is provision of the personal data mandatory?
Responding to the Company's advertisement and providing your data is voluntary. However providing the mandatory data is necessary for your application to be considered during the recruitment process. Failure to provide this data will prevent your application from being considered. The provision of other data is voluntary and constitutes the candidate's consent to their processing in the recruitment process. If you raise an objection to the processing of your personal data during the recruitment process, further participation will not be possible.