Applicant privacy notice

Last updated: 8 March 2021

1.    What does this notice cover?

This notice describes how Telenor Magyarország Zrt., a member of the PPF Group (hereinafter: "Telenor", "we", "us" or "our") uses your personal data in connection with your application for employment with us. It also describes your data protection rights, including a right to object to some of the processing which Telenor carries out. More information about your rights, and how to exercise them, is set out in the "Your choices and rights" section.
We also may provide you with additional information when we collect personal data, where we feel it would be helpful to provide relevant and timely information.

2.    What personal data we collect

  • Personal identification and communication information: your name, home address, your country of origin, phone number; email address; date and place of birth and information about your entitlement to work;
  • Application-related information: curriculum vitae (CV), cover letter, employment history (including your current employer’s information, your current position), education history, qualifications and skills, language capabilities, reference contact information, position preferences, desired salary, starting date, interests and aspirations and background screening information if relevant; and
  • Sensitive information: We do not collect any sensitive information during our recruitment process. If you share any sensitive information with us at any step of the recruitment process, we will delete it as soon as possible we are aware of such information but until then we deem that you provided us with the sensitive information at your on choice voluntarily as a form of consent. However, as an exception, if the sensitive information is shared by you is related to the position (for example, information about your health and disabilities where we need to make any reasonable adjustments) then we will store it according to this Privacy Notice.

We collect most of this information from you directly. For example, most of the data is collected through our application portal (Success Factor) and CVs; from correspondence with you; or through interviews, meetings, or other assessments (test or Assessment Centre). We may also collect some information about you from other people (e.g. recruiters, referrals through the FirstBird referral system, headhunters), your referees or organisations (e.g. from LinkedIn if you choose to connect us with your LinkedIn profile and share it wholly with us; where applicable). We may also screen publicly available information about you on the internet that may be relevant from a professional perspective (e.g. blog posts, videos, relevant professional presence on LinkedIn or other social media sites) In all case we provide you minimum three days after the submission of your application to check your public privacy settings on these interfaces before we start screening.

Why we collect, use and store this personal data

We collect, use and store your personal data for the reasons set out below.

  • Where you have given consent:
    • To register at, and use our online job site (Success Factor);
    • To assess the application for completed by you, and make informed decisions on recruitment and assess your suitability for the role;
    • To communicate with you about your application, to respond to your inquiries and schedule interviews;
    • To contact you about future career opportunities at Telenor.
       
  • Where necessary for Telenor's legitimate interests, as listed below, and where our interests are not overridden by your data protection rights:
    • To perform video interviews via the Indivizo system;
    • To assess your suitability for certain roles via the completion of standardized tests (e.g. customer support test, numeric test) where applicable;
    • To assess your suitability for a limited number of managerial and coaching roles via the Assessment Centre. In the course of these tests licensed psychology professionals perform interviews with the candidates in order to create a competency map;
    • To verify the details you have supplied and, where applicable, conduct pre-employment background checks;
    • To assess any conflict of interests;
    • To prepare right offer for you; and
    • To protect our legitimate business interests and legal rights, including, use in connection with legal claims, compliance, regulatory, auditing, investigative and disciplinary purposes (including disclosure of such information in connection with legal process or litigation).

Where we process personal data on this basis, then – as required by data protection law – we have carried out a balancing test to document our interests, to consider what the impact of the processing will be on individuals and to determine whether individuals’ interests outweigh our interests in the processing taking place.
We may provide you with more specific notices for some of the processing described above (e.g. for video interviews, tests, background checks) and, if we require your consent, will ask for this at the time we collect your personal data.

3.    Verification and background checks

For certain positions, it will be necessary for us to verify the details you have provided us with (for example, in relation to your identity, employment history, academic qualification and professional credentials) and to conduct pre-employment background checks (for example, to filter out any conflict of interest) in accordance with our background check policy. In these cases, we will provide additional information to you before the screening takes place and allow you adequate preparation time. The level of checks will depend on your role, whether you will occupy a regulated role, and will be conducted at a later stage as is practicable in the recruitment process. We will provide further information about the checks involved and will obtain any necessary consent prior to completing such checks.

4.    How we share your personal data

Personal data will primarily be processed by employees in our human resources teams in the People Division at Telenor Hungary, the compliance officer at the Business Security Department, or the leaders of the business area where the position you applied for belongs and sometimes for technical, operational reasons by the employees of the IT department.
Your personal data can be shared with companies providing services, such as technology services including hosting, maintenance, administration and analysis, as well as other agencies, under contract to Telenor as part of the recruitment process. These include a third-party applicant tracking system, and other third-party providers performing related recruitment services, performance of standardised tests, and the Assessment Centre, the provision of an online video interview system, the provision of an internal referral platform.
Your personal data will also be shared with government authorities and/or law enforcement officials if mandated by law or if required for the protection of our legitimate interests in compliance with applicable laws.
If you select during the registration process to make your profile visible to any company recruiter worldwide, your personal data will be shared between all entities within the PPF Group. Some of these companies are located in countries outside the European Economic Area (EEA). In these cases, we ensure your personal information is adequately protected by data protection polices, that comply with the local standards and the GDPR rules as well. For further info please check our Data Privacy Consent Statement on our carrier website.
Your personal data will also be shared with our application tracking system provider, SuccessFactors Inc. (registered seat: 1 Tower Place Suite 1100 South San Francisco, CA 94080 United States of America). SuccessFactors will only use data centres used to host personal data in the cloud service that are located in the EEA and only use European subprocessors to provide support, therefore there won’t be any data transfer outside of the EEA.
To obtain an up to date list of all recipients of your personal information you can directly contact us at the contact details listed below.

5.    Your choices and rights

You have the right to ask Telenor at the contact details listed below for a copy of your personal data; to correct, delete or restrict processing of your personal data; and to obtain the personal data you provide in a structured, machine readable format.
In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement). Where we have asked for your consent, you may withdraw consent at any time. If you ask to withdraw your consent to Telenor processing your data, this will not affect any processing which has already taken place at that time.
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep. If you have unresolved concerns, you have the right to complain to a data protection authority.
For more information on your rights listed above visit https://www.telenor.hu/jogi-kozlemeny/adatvedelem#on-jogai
The data protection authority competent at the registered seat of the data controller is the National Authority for Data Protection and Freedom of Information (NAIH), registered seat: 1055  Budapest, Falk Miksa utca 9-11, postal address: 1363  Budapest, Pf.: 9.; phone no.: +36 1 391 1400; fax: +36 1 391 1410; e-mail: ugyfelszolgalat@naih.hu
You also have the right to turn to the courts for the protection of your data. In this case you may freely choose to contact the regional court (“törvényszék”) at your registered address, or residence, or at the Budapest-Region Regional Court (“Budapest Környéki Törvényszék”) competent at the registered seat of the data controller.
Where we collect personal data to administer our contract with you or to comply with our legal obligations, this is mandatory and we will not be able to manage your application without this information. In all other cases, provision of the requested personal data is optional, but this may affect your ability to participate in certain programs or systems, where the information is needed for those purposes. When you request the deletion of your personal data or the withdrawal of your consent, your data will be deleted immediately, however, this may limit your ability to participate in the recruitment process.

6.    How long we retain your personal data

If you are successful: If you become a Telenor employee, relevant personal information you provide will become a part of your employee file and may be used later for the management of the employment relationship. Personal data that is not necessary for the employment relationship will be only for as long as we need it for Telenor's legitimate interest in accordance with applicable law, for the purposes of the recruitment process and, once this process is finished, for an appropriate period so as to be able to deal with any legal claims linked to the application process. Recruitment records for successful applicants – other than personal data needed for employment relationship - are generally kept until the end of a retention period that will begin upon completion of the recruitment process. Your personal data will be kept until the first working day of month, following the expiry of the 180 days retention period. After this time, we will delete your personal data or hold it in a form that no longer identifies you.
If you are not successful: we will retain your personal data until the end of a retention period that will begin upon completion of the recruitment process or upon your last login into our Success Factor platform. Your personal data will be kept until the first working day of month, following the expiry of the 180 days retention period. After this time, we will delete your personal data or hold it in a form that no longer identifies you. We keep your personal data during the retention period so we can keep you in mind for future recruitment processes, or if the position you are applying reopens during this period.

7.    Updates to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

8.    Contact us

The data controller for your personal data will be Telenor Magyarország Zrt., member of the PPF Group.
If you have questions about this privacy notice or wish to contact us for any reason in relation to our personal data processing, please contact us at

Data Protection Officer
Telenor Magyarország Zrt.
Address: H-2045 Törökbálint, Pannon út 1.
E-mail: adatvedelem@telenor.hu
Phone no.: +36 20 930 4000