Recruit­ment Privacy Policy

Heidelberg Materials AG and its affiliates (“HM Group”, “we” or “us”) are committed to protecting the personal data of applicants and candidates (“you” or “your”). 

This Recruitment Privacy Policy only applies to the personal data of job applicants, potential candidates for employment, and our optional recruiting programs and events.

We process personal data only in accordance with the applicable data protection regulations, in particular the General Data Protection Regulation (“GDPR”) and lo-cal data protection laws such as the German Federal Data Protection Act (“BDSG”).

Some of our online recruiting activities enable access to external sites operated by third parties, which are not governed by this Recruitment Privacy Policy. We do not take responsibility for the privacy practices of these third-party websites to which we link. We encourage you to review the privacy policies of any such web-sites before you submit information there.
 

How to contact us

To make it easier for you to contact us with regard to any data protection-related inquiry, you may always use our parent entity, Heidelberg Materials AG, as your point of contact: 

Heidelberg Materials AG
Berliner Straße 6
69120 Heidelberg
Phone: +49 6221-481-0
Email: info@heidelbergmaterials.com

You can contact our Group data protection officer as follows:

Group Data Protection Officer
Heidelberg Materials AG
Berliner Straße 6
69120 Heidelberg
Email: info.dataprotection@heidelbergmaterials.com

Who is responsible for the processing of personal data?

As part of a standard application process, the respective entity within the HM Group that advertises the position acts as the controller within the meaning of applicable data protection regulations and is thus responsible for the processing of your personal data described in this Recruitment Privacy Policy. 

If you consent to be part of our talent pool, all entities within the HM Group that are using our recruitment software are jointly responsible for the processing activities of your personal data described in this Recruitment Privacy Policy as joint controllers within the meaning of the GDPR. 

For these purposes, the respective entities within the HM Group have concluded the necessary intra-group agreements to ensure an adequate level of data protection as required by data protection regulations. 

You may exercise your rights pursuant to Articles 15 to 22 GDPR against the respective relevant entity of the HM Group. However, you will generally receive the answers and information from Heidelberg Materials AG as the parent entity of the HM Group. The notification and reporting obligations resulting from Articles 33 and 34 GDPR are incumbent on each entity of the HM Group. We will gladly provide you with further information at any time upon request to info.dataprotection@heidelbergmaterials.com, including information about the relevant entities within the HM Group.
 

What information do we collect?

We process personal data that you provide to us in connection with your application as part of the application process.
We process, for example, the following categories of personal data regarding your application: Master data (name, date of birth, nationality, place of birth, country of birth, marital status), contact data (private address, email address, telephone number), application data (contents of application documents, in particular photo, curriculum vitae and certificates, contents of written (including electronic) correspondence regarding the application), account data (email and password), contents of examination notes, perceptions from job interviews, feedback and evaluations. 

In addition to personal data, you submit directly to us, we may also collect information from third-party sources, such as professional recruiting firms, student organizations, and career and job related social media sites (such as LinkedIn), in order to populate your profile. 

We do not seek to process special categories of personal data about a candidate (including personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, data concerning health or data concerning a natural person’s sex life or sexual orientation) unless (i) it is necessary to exercise rights or comply with legal obligations derived from labor law, social security and social protection law, and there is no reason to believe that the data subject has an overriding legitimate interest in not processing the data (Section 26 (3) sentence 1 BDSG), or (ii) you have given explicit consent (Section 26 (3) sentence 2 BDSG), e.g. by transmitting such data to us without being requested to do so. 

Please note that the types of personal data that we may request from you and the ways that we process it are determined by the requirements of the jurisdiction in which the relevant position is located. If you apply to a position with a location outside the European Economic Area (“EEA”), we transfer your data outside the EEA. 
You are not legally obliged (neither by law nor by contract) to provide any of the requested personal data to us. However, if you do not provide such personal data, we may not be able to carry out any application procedure (including possible recruitment). 

We do not use automated decision-making for the hiring process. 

For what purposes do we use your personal data?

We use your personal data for:

  • recruiting and business management reasons including identifying, contacting and evaluating candidates for potential employment, as well as for future roles that may become available;
  • if applicable, managing the account, you set up within our application platform;
  • inviting you to recruiting events;
  • keeping you informed about open positions within the HM Group if you are part of our talent pool (our talent pool offers you the opportunity to get contacted directly by us for a specific open position that might be interesting to you);
  • record keeping in relation to recruiting and hiring;
  • ensuring compliance with legal requirements, including diversity requirements and practices; and
  • protecting our legal rights to the extent authorized or permitted by law.

We may also aggregate your personal data to analyze and improve our recruitment and hiring process and augment our ability to attract successful candidates.
 

What are the legal bases of the processing of your personal data?

Legal bases for processing your personal data are (i) Article 88 (1) GDPR and Section 26 (1) BDSG (hiring decisions), (ii) Article 6 (1) (a) GDPR and Section 26 (2) BDSG (talent pool; consideration for future job offers), (iii) Article 6 (1) (b) GDPR (implementation of pre-contractual measures), (iv) Article 6 (1) (f) GDPR (evidentiary purposes: assertion, exercise or defense of legal claims; analysis), and (v) Article 6 (1) (f) GDPR (transfer of personal data to entities within the HM Group as part of a talent pool). Your personal data may be transferred to a third country in the case of an application from the EEA for a job advertisement in a third country on the legal basis of Article 49 (1) (b) GDPR.

When and with whom will we share your information?

HM Group uses carefully selected third-party service providers and business partners who:

  • provide a recruiting software system for us;
  • process information on our behalf to help run some of our internal business operations including email distribution and IT services (such as hosting providers);
  • assist us in recruiting talent, administering and evaluating pre-employment screening and testing, and improving our recruiting practices (such as agencies);
  • organize recruiting events for us;
  • are part of our talent pool as an entity within the HM Group (as described above); or 
  • are law enforcement bodies (an we are complying with any legal obligation or court order).

Where necessary, HM Group has entered into contractual agreements with these recipients to protect your personal data.
 

Do we transfer your personal data outside the EEA?

Because HM Group is a global organization we need to transfer personal data across geographical borders to our affiliates within the HM Group, our service providers or business partners in other countries working on our behalf in accordance with applicable law. These recipients may be based in different countries worldwide, including outside the EEA. 
HM Group will only share your personal data with recipients in a third country if the requirements set out in Chapter V of the GDPR are met, in particular if the European Commission has adopted an adequacy decision (Article 45 GDPR), the transfer is subject to appropriate safeguards (Article 46 GDPR) or the transfer is necessary for the fulfilment of a contract between the data subject and the controller or for the implementation of pre-contractual measures at the request of the data subject (Article 49 (1) (b) GDPR). 

How do we protect your information?

HM Group has in place appropriate technological and operational security processes designed to protect your personal data from loss, misuse, alteration or destruction. Only authorized employees and providers will have access to any data provided by you, and that access is limited by need. All our employees and any service providers who work for us are obliged to comply with all applicable data protection requirements. Our security measures are subject to a continuous improvement process and this Recruitment Privacy Policy is constantly revised.

How long will we retain your information?

If an entity within the HM Group, such as Heidelberg Materials AG, employs you, we will include your personal data in your personnel file. 

If we do not employ you and you give us your consent, we may continue to retain and use your personal data for a period of twelve (12) months (or until you withdraw your priorly given consent) after completion of the application process in order to consider you for future job offers, in particular to check your suitability for future job offers and to contact you to initiate an application process. If you join our talent pool, but subsequently wish to withdraw, you can contact us at any time at info.dataprotection@heidelbergmaterials.com.

Otherwise, we will retain your personal data for evidentiary purposes for any assertion, exercise or defense of legal claims for a period of six (6) months after completion of the application process.

Do we place cookies?

Our website only uses strictly necessary cookies. Strictly necessary cookies do not require the user's consent under applicable law. You can configure your web browser so that strictly necessary cookies are also blocked. In this case, however, you may not be able to use the website as intended. If the data processed with the help of strictly necessary cookies can be regarded as personal data in individual cases, the legal basis for such processing is Article 6 (1) lit. f GDPR, because we have a legitimate interest in operating the website.

Your rights

You have the right:

  • to obtain information about the personal data processed by us (Article 15 GDPR);
  • to obtain without undue delay the rectification or completion of your personal data stored by us (Article 16 GDPR); 
  • to obtain the erasure of the personal data stored by us, unless the processing is necessary for exercising the right of freedom of expression or information, for compliance with a legal obligation, for reasons of public interest or for the establishment exercise or defense of legal claims. If we have made your personal data public, we are obliged, taking account of available technology and the technical possibilities, to inform controllers which are processing the personal data that you have requested the erasure by such controllers of any links to, or copy or replication of, those personal data (Article 17 GDPR);
  • to obtain the restriction of the processing of your personal data if you contest the accuracy of the personal data, the processing is unlawful, but you oppose their erasure and we no longer require the data, but you require these for the establishment, exercise or defense of legal claims or you have objected to their processing (Articles 18 and 21 GDPR);
  • to receive your personal data in a structure, commonly used and machine-readable format or have such transmitted to another controller (Article 20 GDPR);
  • to withdraw your consent given to us at any time. This means that we may no longer continue the data processing based on this consent in future (Article 7 (3) GDPR); and 
  • to complain to a supervisory authority. You can usually contact the supervisory authority at your normal place of residence or your workplace or where we are headquartered for this (Article 77 GDPR). 
     

Right to object

If your personal data are processed on the basis of legitimate interests in accordance with Article 6 (1) (f) GDPR, you have the right in accordance with Article 21 GDPR to object to the processing of your personal data on grounds relating to your particular situation at any time. 

If you wish to exercise your right of objection or withdraw given consent, simply send an e-mail to info.dataprotection@heidelbergmaterials.com.

Amendments to this recruitment privacy policy

It may be necessary for us to amend this Recruitment Privacy Policy due to changes in internal processes within the HM Group or due to any changes to statutory or regulatory requirements. You can access and print our Recruitment Privacy Policy as amended at any time at our website.

Last modified: 28 June 2024