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 Romania Technologies S.R.L., 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 in City Offices Building, Bucharest, District 4, Oltenitei Street, no.2  , 3^rd floor. We are registered in Romania under company number J40/6679/2016.

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 Romania Technologies S.R.L.,

“third party” means someone who is not you or us or a part of Vodafone Group; and

“Vodafone” or “Vodafone Group” means Vodafone Group Plc and any company or other organisation in which Vodafone Group Plc owns 50%  above  of the share capital

Further on, we would like to highlight the most important data protection terms:

Personal data: any information related to an identified or identifiable natural person (“data subject”); a natural person can be identified by direct or indirect means, especially through any one or more identifiers such as name, number, location data, online ID or the natural person’s physical, genetic, mental, financial, cultural or social traits;

Special Categories of Personal Data: racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership data, furthermore genetic and biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation;

Data Controller: the natural or legal person, public authority, agency or any other organisation who – alone or joined with others – specifies the purpose and means of the handling of the personal data; if the purpose and means of processing is specified by Union or Member State law, the data controller or the aspects of designating the data controller can be decided by the Union or Member State law;

Data Processor : any entity acting in accordance with Vodafone’s instructions on its behalf and processing personal data solely in line with the purposes and means pre-set by Vodafone;

Processing : any operation undertaken by us in relation to your personal data (e.g., collection, storage, use, transfer, deletions, etc.);

“GDPR” means the EU Regulation No. 679/2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

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. Necessary for entry into, or the performance of a contract, we may ask you to provide personal information that is required to enter into an employment contract with the Vodafone company you are applying to;
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; In case you have consented, we may ask for reference from your previous employers. You have the right to withdraw your consent at any time. However, the withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
4. 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 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 and taking unterview notes about you, 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:

We process the following categorie of personal data:

• Personal details, such as name, personal email address, current address, telephone number, date of birth / age, gender, education, current / previous work contat details, as well as former / current job titles;
• Recruitment information, such as application form (website and paper), CV, resumes, interview notes of successful candidates, interview notes of unsuccessful candidates, video interviews, psychometric test results, 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, , publicly held financial information, information regarding disqualified directorship and any potential conflict of interest, any relevant information available in the media (newspaper, internet, etc.);
• Diversity information, such as your age group, gender or nationality;
• Salary and Payment information, such as social security and tax ID number, record of pay, bank details, tax reference details;
• Security in the workplace, such as onsite CCTV footage,
• Internal candidate information, such as references given by Vodafone (including by related personnel), interview notes, internal transfer or promotion, succession planning documents;
• Identification information, such as proof of identity, ID number, Registration Card ID and residence permit in case of non-Romanian personnel; In order to streamline the process of signing administrative and employment-related documents (employment contract, employment offer, etc.), Vodafone has contracted the services of the qualified electronic signature provider CertSign;
• Authentication information, user name and password for the recruitment portal;
• 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 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.

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;
• Progressing your job application: we are entitled to use your information for this because we need to valuate you and your application prior to entering into a labour contract with us (Art. 6 Para 1 let. b thesis 2 of GDPR) and to ensure that you suit the role (Art. 6 Para 1 let. f of GDPR);
• The evaluation of your performances and evolution, during your job with us: we are always committed and interested in making an appropriate and fair evaluation of our personnel and therefore we may use some of your information provided [or generated] during recruitment to assess your progress and performances within our organization (Art. 6 Para 1 let. f of GDPR). In no case however we will use for this your references from former employers or other sensitive personal information you shared with us as part of your application.
• 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; also, we will use your data to create an electronic signature certificate, allowing you to sign human resources documents remotely.
• 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 whenever 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.

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 4.1.4;
• Third parties, such as recruitment agencies, electronic signature providers, 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.

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  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 and as stated by the law. 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 3 years, to be able to respond to any request you may have or other actions that you may pursue in relation to your application with us.

We will also 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.

Afterwards, 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

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 .
2. Right to access: you have the right to request a copy of the personal information we process about you. Want a copy of the personal information we hold on you? You can request a copy of your personal information by contacting us at at askhrromania@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 at askhrromania@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 at askhrromania@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 any time to ask for your information to be removed when:

• your personal data is no longer necessary for the purposes for which we have collected and processed it;
• you have withdrawn the consent to further processing of your personal data (only for data processed based on such ground) and we cannot process this data based on other grounds (e.g., under the law when we are talking about mandatory data retained for a certain period, Vodafone has a legitimate interest in retaining such data in order to defend a legitimate right, etc.);

If you wish to request for deletion, please contact us at askhrromania@vodafone.com

1. 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 personal data ,while complaints about the accuracy, topicality of your data and the lawfulness of their processing are processed, and when although Vodafone no longer needs your data, it must retain it for the purpose of establishing, exercising or defending a right in court. If you wish to raise a request for restriction, please contact us at askhrromania@vodafone.com
2. 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 accessing your candidate profile or by contacting us at askhrromania@vodafone.com

If we do not take action based on any of the above requests, we will inform you of the reasons why.

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

For any details on the above as well as exercising your specific rights you may contact Vodafone’s Privacy Officer / local Ask HR team with the mention in attention of Data Privacy Officer  at:

• Post address: Oltenitei Street, no.2, 3^rd floor, District 4, Bucharest
• E-mail address: privacy_vssromania@vodafone.com

We will do our best to help but if you are still unhappy, you can contact Romanian National Authority for Supervision and Protection of Personal Data here