Candidate Policy

Introduction

Kempinski Hotels S.A., and all hotels and residences run under the Kempinski brands and managed by Kempinski, (“we”, “us”) are committed to protecting and respecting your privacy. This Candidate Policy sets out the basis on which the personal data collected from you, or that you provide to us, will be processed by us in connection with our recruitment processes.

For the purpose of the General Data Protection Regulation (“GDPR”) the Data Controller is Kempinski Hotels S.A. or the relevant hotel/ residence/ Kempinski’s business unit offering the position you are interested in.

We use Pinpoint, an online software product provided by The Infuse Group Ltd (t/a Pinpoint Software), to assist with our recruitment process. We use Pinpoint to process personal information as a data processor on our behalf. Pinpoint is only entitled to process your personal data in accordance with our instructions.

Where you apply for an opportunity posted by us, these Candidate Policy provisions will apply to our processing of your personal information.

Personal Data

For the purpose of this Privacy Statement and Consent Declaration personal data mentioned includes any individual element of information concerning the personal or material circumstances of an identified or identifiable individual including, but not limited to mandatory information such as name, contact details, location address, as well as additional information you may volunteer to further provide information on your application, such as work competencies, work experience, education and certifications, references, cover letter, job preferences, personal context in case of relocation, and related uploaded documents.

Your Personal Information

Information we collect from you

We collect and process some or all of the following types of information from you:
● Information that you provide when you apply for a role. This includes information provided through an online application, via email, in person at interviews and/or by any other method.
● In particular, we process personal details such as name, email address, address, date of birth, gender, citizenship, eligibility to work in certain countries, notice period, qualifications, education, certifications, experience and any information relating to your employment history, skills and experience that you provide to us.
● If you contact us, we may keep a record of that correspondence.
● Details of your visits to our careers website including, but not limited to, traffic data, location data and other communication data, the site that referred you to our careers website and the resources that you access.

Information we collect from other sources

Pinpoint provides us with the facility to link the data you provide to us with other publicly available information about you that you have published on the Internet – this may include sources such as LinkedIn and other social media profiles.

Pinpoint’s technology enables us to search various databases, which may include your personal data, to find possible candidates to fill our job openings. Where we find you in this way we will obtain your personal data from these sources.

Uses made of your information

Lawful basis for processing

We rely on legitimate interest as the lawful basis on which we collect and use your personal data. Our legitimate interests are the recruitment of staff for our business.

Purposes of processing

We use information held about you in the following ways:
● To consider your application in respect of a role for which you have applied.
● To consider your application in respect of other roles.
● To communicate with you in respect of the recruitment process.
● To enhance any information that we receive from you with information obtained from third party data providers.
● To find appropriate candidates to fill our job openings.
● To help Pinpoint improve their services.

If you provide the details of a reference or any other third party e.g. educational institution as part of your application, it authorises us to contact the said person or organisation to validate any information provided and related to your relevant work experience and qualifications. You warrant to us that you have such authorisation.

During the recruitment process we may ask you to provide us with additional information or request additional consent allowing us to conduct pre-employment checks to further assess your qualifications and suitability for the role it applied for or for other roles. If a consent to a pre-employment check by a third party is provided, the personal data concerned will be controlled by the data protection policy of that third party, and it is your responsibility to read and agree on the data treatment conditions of such third parties.

Automated decision making / profiling

We may leverage Pinpoint’s technology to help us select appropriate candidates for us to consider based on criteria we have identified. The process of finding suitable candidates is automatic, however, any decision as to who we will engage to fill the job opening will be made by our team.

How we store your personal data

Security

We take appropriate measures to ensure that all personal data is kept secure including security measures to prevent personal data from being accidentally lost, or used or accessed in any unauthorised way. We limit access to your personal data to those who have a genuine business need to view it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted through any online means, therefore any transmission remains at your own risk.

Where we store your personal data

The data that we collect from you and process using Pinpoint’s Services will be transferred to and stored at one of several datacentre locations in Amsterdam (Netherlands) and may be synchronised to one of several datacentre locations in London (United Kingdom) for backup and redundancy purposes. By submitting your personal data, you agree to this transfer, storing or processing.

How long we keep your personal data

We comply with applicable data protection regulations for data retention and retain all candidate data for a statutory period that is applicable. Your personal information will be deleted upon receipt of a written request by you to us.

Access and sharing of your personal data

The data may be accessible by our human resources talent and recruitment managers as well as department hiring managers; located either in our corporate, respective regional offices or hotels and residences. We take reasonable care to protect the personal data transmitted to us and the data stored on us.

We will not sell nor share the personal data provided with any third party without your consent unless required to do so by law.

It is your responsibility to ensure that it uses the appropriate level of care when sharing information with us. If you believe that the interaction with us is no longer secure or safe, in cases such as a breach of a personal account, you shall notify us immediately.

As far as permitted by local laws and legislations, we disclaim any liability for the misuse, illegal access, disclosure, alteration, or loss of information delivered to us through our careers website.

Your rights

Under the General Data Protection Regulation you have a number of important rights. In summary, those include rights to:
● access to your personal data and to certain other supplementary information that this Candidate Policy is already designed to address
● require us to correct any mistakes in your information which we hold
● request the erasure of personal data concerning you in certain situations
● request access to the personal data concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
● object at any time to processing of personal data concerning you for direct marketing
● object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
● object in certain other situations to our continued processing of your personal data
● otherwise restrict our processing of your personal data in certain circumstances
● claim compensation for damages caused by our breach of any data protection laws.

If you would like to exercise any of those rights, please contact us using our contact details below, ensuring we have enough information to identify you, proving your identity and address and confirming which information to which your request relates.

How to complain

We hope that we can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred.

Cookies policy

Cookies are used within the system to improve user experience. Cookies enable the storage of information and improve the quality and relevance of search results generated for registered users who authorise cookies. By submitting an application via the careers website or otherwise using the careers website, the user consents to the use of cookies in accordance with this Candidate Policy. Every user may disable the use of cookies at any time, but should understand that this may limit certain functionalities. Once a session is closed or expired, so is the use of cookies.

Consent

By clicking “Allow us to process your personal information” and submitting an application on our careers website platform you acknowledge that you have read the above Candidate Policy and consent to us collecting, storing, processing and disclosing the personal data provided to evaluate the application of the concerned candidate in accordance with the process outlined above. You understand that the processing of the personal data provided and the consent are necessary to administer, process and evaluate the application of the concerned candidate, and we will process the personal data in accordance with relevant data privacy legislation for the purposes previously described.

If no consent is provided or the consent is withdrawn, we would be unable to manage the application of the candidates concerned.

Additional Information for candidates

You certify that the completed information provided in the application by yourself, including the information stated on your CV, and provided in any interview(s) and certificates is true and correct, and that you have the lawful right to provide it. You understand that falsifying information may disqualify you from employment and, if hired, may be grounds for employment termination subject to local legal requirements. You understand that the application and indicated employment preferences do not constitute a guarantee of future employment and that our recruitment process may include phone, online and/or face-to-face interviews as well as other assessments, references, and background checks. You further understand that no candidate with us would ever be asked to pay any monetary amount to the respective employer in order to secure a job.

Contact

If you require further information regarding our Candidate Privacy or our dealing with personal data in connection with the careers website you can contact us at the following address:

Kempinski Hotels S.A.
For the attention of the Human Resources Department

10 Rue Henriette et Jeanne- Rath
1204 Geneva
Switzerland

or you can contact us at data.privacy@kempinski.com.