Consent to the Processing and Transfer of Personal Data in Connection with Phenom and SuccessFactors
With this declaration of consent, you expressly give MHI ltd 2-3, Marunouchi 3-chome, Chiyoda-ku, Tokyo, 100-8332, (hereinafter referred to as MHI), and the Primetals Technologies company, which is processing your current application (hereinafter referred to as PT Company), your explicit consent to the processing and transfer of your personal data in connection with the use of Phenom and SuccessFactors and the progress of your application process.
1. Responsible entity and contact (data controller)
Responsible for the processing of your personal data are
Personal Information Advice Office, Legal Department, MHI ltd 2-3, Marunouchi 3-chome, Chiyoda-ku, Tokyo, 100-8332, Tel.: +81-3-6275-6200
and the PT Company processing your current job application. You can find a list of all PT Companies and their contact details under the following link:
Worldwide Locations of Primetals Technologies
If you have any questions or comments regarding data protection (e.g., access to your personal data, updating of your personal data), you can also contact our data protection coordinator at recruitment@primetals.com.
2. Why MHI and Primetals Technologies process your data (purpose of processing)
MHI and Primetals Technologies take the protection of your personal data (hereinafter referred to as Data) very seriously. We hereby inform you about how MHI and Primetals Technologies process your personal data when you register in Phenom and submit an application for an open job position.
We process the relevant personal data listed in section 3 to conduct the application process with you and ensure optimal staffing within our corporate group. In connection with your job application, we may also use your Data to contact you by phone and/or email, ensuring an optimal application process.
Furthermore, with your consent, we use your Data to regularly contact you via email and bring to your attention job positions you have not actively applied for but that we believe match with your profile.
We collect your Data during the application process either when you provide it to us (e.g., through registration in Phenom , uploading your resume, your certificates etc.) or when we collect it by ourselves (e.g., recording notes during the job interview). We assume that you have provided all data and information truthfully. Please note that providing false information may lead to dismissal even after employment.
In the context of a job application, we may also collect personal data about you from professional or private social networks (e.g., LinkedIn, XING, Facebook, Instagram, etc.) if necessary for the decision on establishing an employment relationship with us.
We process your Data in accordance with the applicable legal data protection requirements for the purposes mentioned above. Personal data, as referred to in this consent declaration, includes all information related to your person. Below, you will find details on how we handle this data.
The processing of your Data is based on your consent to the processing of your personal data given on a free basis for the purposes mentioned above (article 6 paragraph 1 (a) GDPR).
3. MHI and Primetals Technologies process the following Data
To fulfill the purpose mentioned above, we process the following Data from you:
- Master data (e.g., name, first name, date of birth, place of birth, residential address, citizenship, etc.);
- Contact details (e.g., phone number, email address, etc.);
- Information from your applicant profile in Phenom (e.g., photo, salary expectations, motivation, earliest start date, etc.);
- Your application documents and the data contained therein (e.g., resume, cover letter, professional development, acquired qualifications, language skills, etc.);
- Employment certificates and references provided by you;
- Data related to your application (e.g., type of application, application status, application history, correspondence with you, etc.);
- Other data voluntarily provided by you during the application process;
- Personalized technical data related to your activities in Phenom (e.g., login times, logout times, etc.);
- Other data publicly available (e.g., a profile on professional or private social media networks).
4. How MHI and Primetals Technologies process your data and recipients of your personal data
To apply for a specific job position within the Primetals corporate group , you must first register in the online application "Phenom " and create a corresponding profile. This profile will be then shared with the online application “Success Factors”, administrated by MHI. Subsequently, you will have the opportunity to submit your application for an open job position. In this case, your Data (as described in section 3) will be forwarded to the respective company within the MHI corporate group (e.g., a PT company) where the specific job position is published. This company will process your application and get in touch with you to continue or finalize the application process.
Access to your Data is restricted to selected employees responsible for the application process at MHI and Primetals Technologies and the IT department for technical administrative purposes.
Your personal data will only be transmitted to companies that provide IT systems for applicant management and selection processes (Phenom and SuccessFactors ) on behalf of MHI and Primetals, and are subsequently engaged in technical support activities (data processors). These are following companies:
- MHI Shared Services Americas Inc., 20 East Greenway Plaza, Suite 830, Houston, TX77046, U.S.A.;
- SAP SE – Walldorf, Dietmar-Hopp-Allee 16 69190 Walldorf
- IBM, 1 New Orchard Road, Armonk, New York 10504-1722, United States
- Phenom People, Inc., 300 Brookside Ave., Building 18, Suite 200, Ambler, PA 19002.
Furthermore, MHI and Primetals Technologies utilize selected and contracted service providers (so-called data processors) to perform certain IT services, which may be located outside the European Economic Area (third countries), for example, IT service providers to ensure IT infrastructure and operations. In such cases, a transfer to a third country may occur. These third countries outside the European Union may not provide an adequate level of data protection (e.g., data subjects may not have data privacy rights; there may be no data protection authority, etc.). To ensure an adequate level of protection for your data, as legally required, MHI and Primetals Technologies have established safeguards in accordance with legal requirements, such as EU Standard Contractual Clauses. Your Data will have the same level of protection as in the EU in such cases.
MHI and Primetals Technologies have entered into appropriate agreements with all data processors. The data processors process your Data solely on our behalf and according to our instructions. The individuals authorized to process personal data are obligated to maintain confidentiality regarding your Data. Additionally, we take all necessary state of the art measures to protect your Data.
5. Data storage and data deletion
MHI and Primetals Technologies process and store your personal data for as long as necessary to fulfill the purpose described under section 2 and to fulfill our legal obligations. Generally, your Data will be retained by us for a period of twelve months from the conclusion of an unsuccessful application process. After this period, your Data, including your entire applicant profile in Phenom and SuccessFactors and the data contained therein will be deleted or anonymized. In the event of a successful application, we will retain the Data collected in connection with the application process for as long as statutory retention obligations exist or until any legal claims have become time-barred.
6. Your rights
You have the right to obtain information about the personal data that MHI and Primetals Technologies process about you, as well as the right to correct inaccurate Data or delete your Data. Furthermore, you have the right to restrict processing and the right to data portability. If the legal requirements are met, you also have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you, which is based on article 6 paragraph 1 (e) GDPR (data processing in the public interest) and article 6 paragraph 1 (f) GDPR (data processing based on legitimate interests).
To exercise your rights, you can contact MHI and the PT Company processing your current application using the contact information provided under section 1.
Furthermore, you have the option to lodge a complaint with the data protection authority responsible for the respective PT Company regarding the processing of your Data. You can request the contact details of the relevant data protection authority from us.
7. Your consent
By selecting the checkbox “I consent to the processing of my personal data as described in the consent declaration” you voluntarily agree to the collection, processing, storage, transfer (as described under section 4), and use of your personal data as described above.
You may withdraw your consent to MHI and Primetals Technologies at any time and without stating any reasons by sending a corresponding message to the following email address
The withdrawal of your consent will only apply to future processing and will not affect the lawfulness of data processing carried out prior to the withdrawal.
Upon withdrawal of your consent, you will no longer receive information from MHI or Primetals Technologies as described in section 2.