PRIVACY POLICY - INTERNAL EMPLOYEES

Primetals Technologies Group

Data Privacy Notice

on Phenom

(hereinafter: Phenom)

 

  1. General information

Primetals Technologies Group (hereinafter also referred to as PT) takes the protection of your personal data (hereinafter also referred to as data) very seriously. We process your data in accordance with the applicable legal data protection requirements for the purposes listed below. Personal data in the sense of this privacy notice is all information that is related to you personally. Relevant data are in particular your personal data (e.g. last name, first name, contact data, name of company), as well as personalized technical data (e.g. IP-address, URL, User-ID etc.). In the following you will learn how we handle these data.

 

  1. Responsible data controller and contact

The data controller responsible for the processing of your data is the PT entity, with which you have your employment contract.

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 about PT's data protection (e.g. how to access and update your data), you may also contact our data protection coordinator under xxx@primetals.com.

PT’s Talent Hub is a web based portal for empoyees where they can create an employee profile to share information about themselves, search colleagues, get suitable job recommendations within PT, and refer people from their personal networks to jobs with PT. The Phenom Website is operated by Phenom People, Inc., 300 Brookside Ave., Building 18, Suite 200, Ambler, PA 19002.

 

  1. What data sources and which data do we use?

Relevant personal data when using Phenom are:

  • Your personnel master data (e.g., last name, first name);
  • Other personal information (e.g., gender, language preferences);
  • Employee information (e.g., employee ID number);
  • Your communication data (e.g., email address, phone number);
  • Your relevant company information (e.g., department, work location);
  • Data about your employment (e.g., start date,  job title);
  • Personalized technical data of your network accesses to the internet and intranet (e.g., IP address, URL, user ID, PC name, time stamp);
  • Data relating to the Learning Module (e.g., trainings, certificates);
  • All other data that you have inputted into Phenom modules yourself.

 

  1. Purposes for which your data is collected and processed and their legal basis

Phenom enables global hosting, analysis, sharing and other processing of personal data about the entire workforce of PT for the purposes of general data management, reporting, talent management, succession planning and training.

Your personal data will be processed by the participating companies only to the extent strictly necessary for the above purposes.

The processing of your personal data within and in the course of use of Phenom is carried out on the legal basis of assessment and protection of the legitimate interests of PT (Art. 6 para. 1 f GDPR).

The legitimate interests of PT in this case are in particular:

  • The optimized resource planning and risk management in the company;
  • The optimized company group management and in particular the strengthening and improvement of human resources management.

 

 

  1. Recipients of your personal data

5.1 Third parties and data processors

In order to ensure proper operation of the Phenom-Platform, we have to grant trustworthy third parties an access to the respective personal data for the purposes of service provision and maintenance. This is done strictly on an as-needed basis.

In this context, your personal data will only be processed by the companies that provide the Phenom platform on behalf of PT and subsequently provide support services (so-called data processors). These are the following companies:

  • Phenom  People, Inc., 300 Brookside Ave., Building 18, Suite 200, Ambler, PA 19002.

In addition, the respective sub-contractors of the above-mentioned data processors may also have access to your data for support purposes. A list of the respective sub-contractors is available upon request by using the contact details provided in section 2.

We would like to point out that the persons authorized to process your data are bound by confidentiality obligations about all related information. Furthermore, we ensure that the data processors take all state-of-the-art measures to protect your data. Respective agreements have been signed with all data processors to ensure compliance with all data protection requirements.

5.2 Recipients within PT

Employees in the HR departments of PT that were granted a recruiter license for Phenom will be able to see and process application data where applicable.

All users of the Talent Hub within PT will be able to see profile data that employees decide to share with all users.

5.3 Recipients outside the European Union (EU)

Your personal data is generally stored in data centers in the EU. However, in the course of the data processing activities described in section 5.1 and 5.2, your data may be transferred to a destination outside your country or the EU and stored there.

If such transfer is restricted by applicable data protection laws, PT will implement safeguard measures in accordance with the legal requirements to establish an adequate level of data protection, including the so-called EU standard contractual clauses that we have concluded with all data processors. In this case, your data has the same protection as in the EU. If you would like to get more information in this regard, you can contact PT by using the contact details provided in section 2.

 

  1. Data storage and data deletion

PT processes and stores your personal data in general as long as this is necessary for the fulfillment of the employment contract with you. When the employment relationship with you has ended, all mutual claims have been satisfied and there are no further legal obligations or legal basis, which will require or justify the data storage, your data will be deleted.

However, our legitimate interests may serve as a legal basis for the further processing of your data even after termination of the employment contract. By objecting, you have at any time the possibility to stop this processing.

 

  1. Automated decision-making

We do not use any fully automated decisions as per Art. 22 GDPR to establish and implement our business relationships.

 

  1. Profiling

We do not do profiling pursuant to Art. 22 GDPR.

No data is processed for the purpose of working performance monitoring and/or behavior monitoring.

 

  1. Provision of your personal data

Your personal data is in principle automatically provided to Phenom. You have the possibility to modify and/or complete certain data fields by yourself at any time.

 

  1. Your Data Privacy Rights

10.1 Access, rectification, erasure, restriction of processing

You have the right to have access to your personal data. Under certain conditions, you also have the right to rectification and erasure of your data. Furthermore, you have the right to restrict processing if the legal pre-conditions are given.

10.2 Right to object

You have the right to object at any time for reasons arising from your particular situation to the processing of personal data concerning you under Art. 6(1) point (e) GDPR (public interest data processing) and Art. 6(1) point (f) GDPR (data processing on the basis of a weighing of interests). If you object, we will no longer process your personal data unless we can prove compelling legitimate reasons for the processing, which outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend     legal claims.

10.3 Right of withdrawal

If you have given PT express consent to the processing of your data, you can withdraw this consent at any time and without stating any reasons. The lawfulness of the processing of your data before your withdrawal of consent remains unaffected by the withdrawal.

10.4 Right to data portability

You have the right to receive the personal data concerning you in a structured, common and machine-readable format. You are entitled to transfer this data to other controllers. If technically feasible, you have the right to obtain a transmission from us directly to another data controller.

To exercise the rights referred to in section 10, you may contact PT using the contact details referred to in section 2.
10.5   Questions or complaints

You have the right to contact the competent supervisory authority with questions or complaints. Below you can find a list with contact details of all relevant supervisory authorities in the EU:

  • Austrian data protection authority, Wickenburggasse 8, 1080 Vienna, e-mail address: dsb@dsb.gv.at;
  • Belgian data protection authority (GBA), Rue de la Presse 35, 1000 Brussels, e-mail address: dpo@apd-gba.be;
  • German data protection authority, Federal Commissioner for Data Protection and Freedom of Information (BfDI), Graurheindorfer Str. 153
    53117 Bonn, e-mail address: poststelle@bfdi.bund.de;
  • Polish data protection authority, Urząd Ochrony Danych Osobowych, ul. Stawki 2, 00-193 Warszawa, e-mail address: kancelaria@uodo.gov.pl;
  • Czech data protection authority, Office for Personal Data Protection, Pplk. Sochora 27, 170 00 Praha 7, e-mail address: posta@uoou.gov.cz.

 

  1. Updating of our Data Privacy Notice

We will update this data privacy policy accordingly, if necessary, in case data protection regulations or business needs change.

You can find the up-to-date version under following link: XXX

 

14.01.2025