1 Our Privacy Promise

We aim to create a culture where everyone at Vodafone has a clear understanding of how important privacy is to our employees and how to ensure it is respected. Our Privacy Promise sets out the principles that govern our approach to privacy and how we communicate with employees, partners and other stakeholders on relevant issues – such as designing products to protect privacy or assisting with law enforcement.

Vodafone’s privacy principles are:

How we operate

• Accountability: we are accountable for living up to these principles throughout our corporate family, including when working with our partners and suppliers. We have in place accountable privacy compliance measures and we monitor and enforce our compliance with these principles;
• Fairness and lawfulness: we comply with privacy laws and act with integrity and fairness. We will work with governments, regulators, policy makers and opinion formers for better and more meaningful privacy laws and standards;
• Openness and Honesty: we communicate clearly about actions we take that may impact privacy, we ensure our actions reflect our words, and we are open to feedback about our actions;
• Choice and access: we give people the ability to make simple and meaningful choices about their privacy and allow individuals, where appropriate, to access, update or delete their personal information.

How we manage and protect information

• Responsible Data Management and limited disclosures: we apply appropriate data management practices to govern the processing of personal information. We choose the partners who participate in processing of personal information carefully and we limit disclosures of personal information to such partners to what is described in our privacy statement or to what has been authorized by our employees;
• Security safeguards: we implement appropriate technical and organisational measures to protect personal information against unauthorized access, use, modification or loss.

How we design our products and services

• Privacy by Design: respect for privacy is a key component in the design, development and delivery of our products and services

How we make decisions

• Balance: when we are required to balance the right to privacy against other obligations necessary to a free and secure society, we work to minimize privacy impacts

2 Who we are

Vodafone GmbH is the controller of your personal information We are a member of the Vodafone Group and manage HR operations, including the processing of personal information about the employees and applicants to the Vodafone company to which you are applying.

Our registered office is Ferdinand-Braun-Platz 1, 40549 Düsseldorf. We are registered in Handelsregister: Amtsgericht Düsseldorf, HRB 53554. We provide details of how to contact us in the How to contact us section of this privacy statement.

3 Definitions

In this privacy statement:

• “we/us” means Vodafone Group Services GmbH;
• “third party” means someone who is not you or us or a part of Vodafone Group; and
• “Vodafone Group” means Vodafone Group Plc and any company or other organisation in which Vodafone Group Plc owns 50% or above of the share capital

4 The Basics

4.1 Personal information we collect about you

4.1.1 Vodafone will process your personal information based on:

1. Vodafone’s legitimate business interest, when you apply for a role at Vodafone you provide us with your personal information so that we can use this information to assess your application, progress your application through the recruitment process, make a decision about your suitability for the role and contact you throughout the recruitment and onboarding process;
2. Consent you provide, we may ask you to provide information voluntarily, including for example your age group and gender. You can withdraw your consent at any time by editing your candidate profile;
3. Compliance with the law, where certain information is necessary to satisfy a legal or regulatory requirement.

4.1.2 How we collect personal information about you

We collect personal information about you when you register a general interest or apply for a specific role at Vodafone. Some of the information we collect about you is required to make an assessment on your application to Vodafone and contact you as you progress through the recruitment process, for example your telephone number, email address, CV. If you do not provide this information then we will be unable to make an assessment of your application or contact you to invite you to interview, or make you an offer. We may collect information about you from recruitment agencies or from the public internet where you have made this information publicly available, for example, we may find your profile on LinkedIn and contact you about suitable roles.

4.1.3 The types of information we may collect about you are, for example:

1. Personal details, such as name, personal email address, current address, telephone number;
2. Recruitment information, such as application form (website and paper), CV, resumes, interview notes of successful candidates, interview notes of unsuccessful candidates, video interviews, references from previous employer, psychometric test results;
3. Internal candidate information, such as references given by Vodafone, interview notes, internal transfer or promotion, succession planning documents;
4. Identification information, such as proof of identity;
5. Authentication information, user name and password for the recruitment portal;
6. Cookies, such as performance and functionality cookies.

We may also process sensitive personal information about you – but only where this is strictly necessary to assess your suitability for the role you have applied for. For example,

1. We may collect records of criminal convictions or right to work in the country you are applying to in order to perform security background checks where it is required by local law;
2. We may collect information such as your age, gender or nationality to evaluate who applies for roles at Vodafone in order to meet our targets for diversity and inclusion – but only where you provide this information voluntarily and provide consent for us to process this information.

4.2 How we use information about you

We may process the personal information that we collect about you for the following purposes:

• Recruiting people into jobs, the information you provide to us will be shared with the Vodafone company you are applying to in order to assess and progress your job application and to make any verifications required by local law. If you apply for more than one vacancy, your information will be shared with each Vodafone company where you have applied;
• Resourcing for jobs, if you register a general interest in pursuing a career with Vodafone, the information that you provide will be retained by us and searched by people who are employed by Vodafone to help us fill future vacancies. If you apply for a specific vacancy and you are unsuccessful, the information you provide to us will be retained so that we can consider you for future suitable vacancies – but only where we have collected your consent to do so;
• Creating an employee record, if your job application is successful, the information you give during the application process will form part of your employee record and will be used to administer your employment and manage your career at Vodafone;
• Analytics, we may use some of the personal information you provide for various reporting purposes including, for example, to report on our diversity targets or the type of candidates and volumes of applications made to Vodafone and related trends – you will not be personally identified from these reports;
• Screening, in certain circumstances we will make an automatic decision on the suitability of your application based on certain criteria. For example, graduates must be proficient in English and have completed a university degree to be considered for a role at Vodafone – we will bring this to your attention wherever we collect information to make an automatic decision about you.
• Cookies, we use cookies to understand how you use our recruitment website and how we can improve the customer experience.

4.3 Who we share information about you with

We may share personal information about you with:

• Other companies in the Vodafone Group, which will process your personal information solely and only, for the purposes in section 4.2;
• Third parties, such as recruitment agencies, test providers and others who help us fill vacancies and assess the suitability of candidates and progress applications. Where we use third parties, Vodafone ensures that they meet the same privacy and security standards as Vodafone;
• Law enforcement agencies, government bodies, regulatory organisations, courts or other public authorities if we have to, or are authorised to by law;
• A third party or body where such disclosure is required to satisfy any applicable law, or other legal or regulatory requirement.

4.4 Where we process information about you

In doing the above, we may need to transfer personal information about you to other companies in the Vodafone Group or third parties located (or whose servers may be located) in countries outside of the country where you have applied, including countries outside of the European Economic Area (EEA). If we send personal information about you to a country that is not in the EEA, 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 organisational measures to protect your personal information. Please contact the local Privacy Officer if you would like to find out more about the way we comply with our legal obligations in relation to international data transfers. Their contact details are available under section 7 ‘How to contact us’ in this privacy statement.

4.5 How long we keep information about you

We will keep your information for as long as it is necessary for the recruitment process. If you are successful, we will keep your information for the duration of your employment, should you wish to apply for other roles within Vodafone. If we aren’t able to offer you a role, we may keep your information for up to 6 months to contact you about future roles that may interest you, but only where we have collected your consent to do so – you can withdraw your consent at any time in your candidate profile.

We will anonymise your information in accordance with our retention policy and may retain those anonymised records to monitor the effectiveness of our recruitment process. For example, we may create reports to understand what nationalities have applied for roles with Vodafone in the last 12 months – you will not be identifiable in these reports and you can withdraw your consent at any time by updating the information in your candidate profile.

5  Your rights

1. Right to correct or update information: you have the right to have information we keep about you corrected if it is not accurate. If the information we keep about you needs updating, or you think it may be inaccurate, you can update your information in your candidate profile or contact us at any time to update this;
2. Right to access: Want a copy of the personal information we hold on you? You can apply for a copy of your personal information here: career.de@vodafone.com
3. Right to object: you have the right to object to Vodafone processing your personal information for the purposes identified in section 4.2 How we use information about you. This includes, for example, where we make an automatic decision about you for screening purposes. If you wish to object to processing, you can modify your application in your candidate profile, or withdraw your application. You can make an objection request or contest an automatic decision we have made about you here: career.de@vodafone.com
4. Right to deletion: in certain circumstances you have the right to request that we erase the personal information we hold about you. You can request for your information to be deleted here: career.de@vodafone.com;
5. Right to restrict use of your information: if you feel the personal information we hold about you is inaccurate or believe we shouldn’t be processing your personal information, you may have the right to ask us to restrict processing that information. You can request to restrict processing here: career.de@vodafone.com.
6. Right to data portability: in certain circumstances you will have the right to take the personal information you have provided to us with you. You can request a copy of your personal information here: career.de@vodafone.com.

6  Changes to this Privacy Statement

This privacy statement gets updated from time to time, so we’d encourage you to check it regularly on the recruitment portal. If we make a major change, we’ll post this on the recruitment portal you will use to make your application.

7  How to contact us

If you have any further questions about this privacy statement or how we process your information, please contact the Thomas Born datenschutz@vodafone.com

Details of which national regulatory authority the employee can complain to: Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen Postfach 20 04 44 40102 Düsseldorf