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 consistent 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 Intelligent Solutions España, S.L.U. are 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 Torre Norte Adif, explanada de la Estación no 7, 29002, Málaga, Spain; Registration Number: volume 6122, page 76, sheet MA-165227; Tax ID: B67824243. We provide details of how to contract us in the ‘How to contact us’ section of this privacy statement.

3. Definitions

In this privacy statement:

“we/us” means Vodafone Intelligent Solutions España, S.L.U.;

“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%  above of the share capital.

4.The basics

Personal information we collect about you:

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. Performance of a contract, if you are successful in your application, there will be some basic personal details that we will require from you in order to honor your employment contract. The specific data categories are specified in the subsection below: “Detailed description on personal data categories, purpose of processing and lawful basis”
3. 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;
4. Compliance with the law, where certain information is necessary to satisfy a legal or regulatory requirement.

How we collect personal information about you:

We collect personal information about you when you register a general interest in careers at Vodafone or when you 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 about your 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 assess 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.

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

1. Personal details, such as name, given name at birth, date and place of birth, address, mother’s maiden name, nationality, gender, personal email address, telephone number, emergency contact details;
2. Recruitment information, such as your application form CV, resumes, interview notes, video interviews, references from previous employers, internal references, Certificate of Police Clearance (in case it is necessary for the role you applied for in line with our internal policy), educational attainments, qualifications, postgraduate and professional training records, spoken languages and proof of language proficiency, references from previous employer, psychometric test results, publicly held financial information, information regarding disqualified directorship and any potential conflict of interest, any relevant information available in the media (newspaper, internet, etc.),
3. Diversity information, such as your age group, gender or nationality;
4. Internal candidate information: such as references given by Vodafone, interview notes, internal transfer or promotion, succession planning documents
5. Identification information, such as proof of identity, ID number, Registration Card ID and residence permit in case of non-Hungarian personnel;
6. Authentication information, user name and password for the recruitment portal;
7. Cookies,
8. Data regarding the vetting/security background checks

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 or where we have a legal obligation. 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 ethnicity, race, but only where it is required by law or we have collected your explicit consent to process this information

Detailed description on personal data categories, purpose of processing and lawful basis:

• Official name indicated in your ID/Passport: Needed for identification and database checks for applicable company registers. (Legal Basis: Art. 6 (1) b) GDPR– performance of the employment contract)
• Other names (e.g. birth name, maiden name, etc.): Also necessary for identification and relevant database checks. (Legal Basis: Art. 6 (1) b) GDPR – performance of the employment contract)
• Place and date of birth: Required for clear identification and database checks. (Legal Basis: Art. 6 (1) b) GDPR – performance of the employment contract)
• Mother’s name: Supports identification and cross-referencing in databases. (Legal Basis: Art. 6 (1) b) GDPR – performance of the employment contract)
• Tax Number: Essential for identification and verification with relevant tax databases. (Legal Basis: Art. 6 (1) f) GDPR – legitimate interest of Vodafone)
• Country of citizenship(s): Used for identification, verification, and potential international database checks for authorities, police departments, companies, etc. (Legal Basis: Art. 6 (1) f) GDPR – legitimate interest of Vodafone)
• Country of issuance of passport: Supports verification and guides specific country-related checks. (Legal Basis: Art. 6 (1) f) GDPR – legitimate interest of Vodafone)
• Permanent address: Required for verification and identification across databases, also crucial for the employment contract. (Legal Basis: Art. 6 (1) b) GDPR – performance of the employment contract)
• Temporary address: Also used for verification and identification, plus necessary for the employment contract. (Legal Basis: Art. 6 (1) b) GDPR – performance of the employment contract)
• Company information (ownership, management, activity, business relationship with Vodafone): Collected to prevent potential conflicts of interest or disqualifications. (Legal Basis: Art. 6 (1) f) GDPR – legitimate interest of Vodafone)
• Personal financial data (bankruptcies, debt, judgments): Used for risk assessment purposes. (Legal Basis: Art. 6 (1) f) GDPR – legitimate interest of Vodafone)
• Directorships (past, present, disqualified): Identifies potential conflicts of interest. (Legal Basis: Art. 6 (1) f) GDPR – legitimate interest of Vodafone)
• ID/Passport (verification only – no copy made): Used to verify identity and legal capacity for employment. (Legal Basis: Art. 6 (1) b) GDPR – performance of the employment contract)
• Permanent residential address card (verification only – no copy made): Verifies identity and address. (Legal Basis: Art. 6 (1) b) GDPR – performance of the employment contract)
• Residency permit (if applicable, verification only – no copy made): Necessary to check the validity of employment eligibility. (Legal Basis: Art. 6 (1) b) GDPR – performance of the employment contract)
• Degree/diploma certificates, professional qualifications: Ensures required qualifications, with potential for originality validation checks. (Legal Basis: Art. 6 (1) b) GDPR – performance of the employment contract)
• Certificate of good conduct: Protects Vodafone’s financial interests and ensures trustworthiness of employees. (Legal Basis: Art. 6 (1) f) GDPR – legitimate interest of Vodafone)
• OSINT check (e.g., social media): May be conducted to collect relevant information. For most roles, the only social media platform will be Linkedin. Other social media platforms such as Facebook or twitter will only be considered in a background check where your social media skills are relevant to the role you have applied for (Legal Basis: Art. 6 (1) f) GDPR – legitimate interest of Vodafone).
• Reference from previous Vodafone employer (if applicable): Used to assess suitability for the position. (Legal Basis: Art. 6 (1) f) GDPR – legitimate interest of Vodafone)
• References from previous employers (with consent): Further validates suitability. (Legal Basis: Art. 6 (1) a) GDPR – consent)

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;
• Contacting you about other roles, where we have collected your consent to do so;
• 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, when it is required by law or to enter into a contract, we will make an automatic decision on the suitability of your application based on certain criteria such as your qualifications. For example, graduates must be proficient in English and have completed a university degree to be considered for a role at Vodafone, or retail employees must be able to work at weekends and national holidays. We will bring this to your attention wherever we collect personal information to make an automatic decision about you and you can contest a decision by exercising your rights (see 5. Your Rights);
• Cookies, we use cookies that are strictly necessary for the functioning of the Careers site and we may use cookies to understand how you use our recruitment website and how we can improve the customer experience, where we have your permission to do so.

Who we share information about you with:

We may share personal information about you with:

• Other companies in the Vodafone Group subject to inter-company data processing agreements;
• 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 there is a written agreement and 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.
• Vodafone Group Services Limited where they may be a joint data controller;

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.

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 are not 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. However, the withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

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.

5. Your Rights

You may make a request to the data controller to exercise the following rights over your personal information:

1. Right to correct or update information: you have the right to correct or update the personal information we process about you if it is not accurate. If the information we process about you needs updating, or you think it may be inaccurate, you can update your information in your candidate profile or write to our HR team at Spain@vodafone.com;
2. Right to access: you have the right to request a copy of the personal information we process about you.? You can request a copy of your personal information by contacting Spain@vodafone.com;
3. Right to object: you have the right to object to Vodafone processing your personal information where we rely on out legitimate interest to do so for example, using your contact information to contact you about other roles at Vodafone. . If you wish to object to processing, you can change your preferences in your candidate profile at any time or. you can make an objection request by contacting us via e-mail at Spain@vodafone.com;
4. Right to contest an automated decision: you have the right to obtain human intervention and to contest an automated decision that has been made about you. You can contest a decision by contacting us via e-mail at Spain@vodafone.com;
5. Right to deletion: in certain circumstances, you may have the right to request that we erase the personal information we process about you. You can request for your information to be deleted by contacting us  at Spain@vodafone.com;
6. Right to restrict use of your information: if you feel the personal information we process about you is inaccurate or believe we should not be processing your personal information, you may have the right to ask us to restrict processing that information. You can request to restrict processing by contacting us via e-mail at Spain@vodafone.com;
7. 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 by contacting us via e-mail at Spain@vodafone.com;

If you wish to know more about how to execute your rights and have any further requests for information about your personal data, please get in touch with our local Privacy team at privacy_voisespana@vodafone.com.

You may exercise the same rights over your personal information controlled by Vodafone Group Services Limited by emailing AskHRGroupUK@vodafone.com.

6. Changes to this Privacy Statement

This privacy statement is updated from time to time, so we would encourage you to check it regularly in your candidate profile on the recruitment portal. If we make a major change, we will let you know by email.

7. How to contact us

If you have any further questions about this privacy statement or how we process your information, please contact your local Privacy Officer: privacy_voisespana@vodafone.com.

We’ll do our best to help; however, if you feel that neither your HR team nor the Privacy Officer was able to help and you’re still unhappy, you can contact the Spanish Data Protection Agency, Calle de Jorge Juan, 6, 28001, Madrid.

8. Description of the application process

• Application: You submit your application through the SuccessFactors system.
• Personal Interview: If your application is successful, you’ll be invited to a personal interview.
• Additional Information: Before an offer is extended, you might be asked to provide additional information as part of the process.
• Background Check Acknowledgement: When you receive the job offer, you’ll acknowledge that Vodafone will conduct a security background check. This check will involve processing certain personal data described in the section 4 of this notice.
• Offer and Payroll Form: You’ll receive the official job offer and a payroll form to complete.
• Signing the Contract: The final step is to sign the employment contract, officially starting your position at Vodafone.