Privacy Notice for onshore job applicants
What is the purpose of this document?
This privacy notice applies to prospective onshore employees, interns and contractors of GasLog Ltd. and its subsidiaries and affiliates (“GasLog”, “GasLog Group”, “we” or “our”). This privacy notice describes how we collect and use personal data about you during the recruitment process, in accordance with the General Data Protection Regulation (“GDPR”). Individuals who are successful in their application for employment, internship or engagement as a contractor, will receive a separate privacy notice.For individuals who are successful in their application for employment, internship or engagement as a contractor For individuals who are successful in their application for employment, internship or engagement as a contractor For individuals who are successful in their application for employment, internship or engagement as a contractor
The data controller of your personal data is GasLog LNG Services Ltd., a company organized under the laws of Bermuda with its registered office at Clarendon House, 2 Church Street, Hamilton, Bermuda and its branch office established in Greece at 69 Akti Miaouli, GR-18537 Piraeus, Greece. This means that GasLog LNG Services Ltd is responsible for deciding how we hold and use personal data about you. We are required under data protection legislation to notify you of how we collect and use personal data about you as well as other information contained in this privacy notice.
This notice does not form part of any contract of employment or other contract to provide services. We may update this notice from time to time.
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are aware of how and why we are using such information.
If you are under 15 years’ old please do not send us your personal data (for example, your name, address and email address). If you wish to contact GasLog in a way which requires you to submit your personal data please ask your parent or guardian to do so on your behalf.
Data protection principles
In compliance with applicable data protection laws, GasLog commits that the personal data we hold about you must be:
- Used lawfully, fairly and in a transparent way;
- Collected only for valid purposes, clearly explained to you and not used in any way that is incompatible with those purposes;
- Relevant to the purposes we have told you about and limited only to those purposes;
- Accurate and kept up to date to the best of our knowledge (you are required to inform us of changes to your personal data to ensure our records are up to date);
- Kept only as long as necessary for the purposes we have told you about;
- Kept securely; and
- Shared with third parties only as required and relevant to the purposes we have informed you of. When shared with third parties, we will make reasonable efforts to ensure such third parties comply with GDPR.
The kind of information we hold about you
Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). There are "special categories" of more sensitive personal data which require a higher level of protection. We will collect, store, and use the following categories of personal data about you:
- Name and surname
- Contact details
- Documents verifying educational background
- Professional qualifications
- Previous employment
- Interview records, results of interviews and assessments
- Predictive Index reports
- Other information that you have included in your CV or cover letter or shared with as part of the application process
- background checks
- reports from headhunters
How is your personal data collected?
Most of your personal data is provided directly by you; however, we may also collect personal data indirectly through an employment agency, former employers or schools, predictive index reports, or background check provider.
Purposes for which we will use your personal data and legal basis for processing
We will only process your personal data when and to the extent that the law allows us to. We need all the categories of information in the list above primarily to allow us to enter into a contract with you at your request and to enable us to comply with legal obligations. In some cases we may use your personal data to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights are protected and do not override those interests. The situations in which we will process your personal data are listed below.
- Evaluating internal and external job applicants
- Ensuring you are legally entitled to work in your place of employment
- Making job offers
Compliance with laws
- Compliance with legal, tax, and social security obligations
- Complying with health and safety obligations
GasLog may process your personal data by using both automated processing and hard copies.
If you fail to provide personal data
Failure to provide us the information requested (which is limited to what required for the above purposes) may negatively affect your chances of being selected for any potential employment, engagement or internship.affect your chances of being selected for any potential employment, engagement or internship.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so and, if required, we will request your consent prior to doing so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where and to the extent this is required or permitted by law.
How we use special categories of personal data
"Special categories" of particularly sensitive personal data will be safeguarded with higher levels of protection. For the purposes of recruitment, personal data regarding health data may be processed only as strictly required and as permitted or required by local law for the purposes of making adjustments to the recruitment process, for assessing eligibility for positions and fitness to work and provision of facilities in the workplace to accommodate health problems.
To ensure equal employment opportunities as permitted or required by local law we may also gather data relating to your nationality, racial and/or ethnic origin.
We will only collect, store and use this type of personal data when justified. We may only process special categories of personal data in the following circumstances:
- In limited circumstances, with your explicit written consent.
- Where we need to carry out our legal obligations or exercise rights in connection with employment.
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your vital interests (or someone else's vital interests) and you are not capable of giving your consent.
Do we need your consent?
We do not need your consent if we use special categories of your personal data in accordance with this notice to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we may approach you for your written consent to allow us to process certain categories of personal data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of entering into a contract with us that you agree to any request for consent from us.
Information about criminal convictions
We will only collect information about criminal convictions if it is appropriate and where we are legally able to do so. Where appropriate (depending on the nature of the role), we will collect information about criminal behavior, criminal records or proceedings as part of the pre-employment/pre-engagement screening but only for the purposes of ensuring compliance with legal and regulatory obligations and/or to the extent permitted or required by law.
Pre- screening of applicants
We carry out screening for all applicants who we intend to hire on permanent roles and prior to entering into any employment agreement with you, for the purposes of:
- verifying the information that you provide during the screening/interview process. This will include current/previous employers and educational institutions information verification. No steps will be taken in this respect until you confirm the action can take place.
- screening you against publicly available or government issued sanctions lists may apply for specific roles. This is to comply with legal and regulatory obligations, to protect GasLog’s assets and employees/contractors and specifically to ensure that GasLog can comply with anti-money laundering and/or bribery and corruption laws and other regulatory requirements.
Automated decision-making takes place when an electronic system uses personal data to make a decision without human intervention. You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
We do not envisage that any decisions will be taken about you using solely automated means, however we will notify you in writing if this position changes.
We may have to share your data with (a) other entities in the GasLog Group, (b) third-party service providers (c) other third parties and (d) authorities, to the extent permitted by law and on a need to know basis.
Which third-parties process my personal data?
The GasLog entities and the third parties (including contractors and designated agents) which may process some or all of your personal data, as the case may be, are:
- Other entities in the GasLog Group
- Third parties carrying out reference and background checks on behalf of GasLog Group
- Audit (both internal and external)
- Building administration and security service
- Judicial authorities or regulatory bodies
How secure is your information with third-party service providers and other entities in our group?
GasLog requests third-party service providers and other entities in the GasLog Group to assure GasLog that they take appropriate security measures to protect your personal data in line with our policies. GasLog requests its third-party service providers assurance they will not use your personal data for their own purposes but will only process your personal data for specified purposes and in accordance with our instructions and will retain your personal data only as long as required for said purpose in accordance with legal requirements.
Transferring information outside the EU
We may transfer the personal data we collect about you other entities of GasLog Group and third party service providers not established in the European Union nor in a country for which the European Commission has issued an adequacy decision. This means these countries to which we transfer your data are not deemed to provide an adequate level of protection for your personal data. As a result, we will only effect such transfers (a) after taking organizational, contractual and legal measures to ensure that your personal data is adequately protected and processed as reasonably required for the purposes outlined in this notice under Article 46 of GDPR or (b) on limited circumstances, on the basis of the derogations under 49 of GDPR.
We have put in place appropriate security measures to prevent your personal data from being lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from the Data Protection Manager.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
How long will we use your information for?
We will only retain your personal data for 3 years after the completion of the assessment or recruitment process unless we have a legal or regulatory reason to keep it longer.
If your application is successful, we will keep your personal data collected during the recruitment process and we will process it in accordance with the relevant privacy notice which will be provided to you upon commencement of your employment, internship or engagement.
Rights of access, correction, erasure, and restriction
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. You are required to keep us informed if your personal data changes during your working relationship with us.
Your rights in connection with personal data
You have the right to:
- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal data to another party.
If you want to review, verify, correct or, under certain circumstances as provided by law request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact the Human Resources Officer in writing.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Human Resources Officer. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Data privacy manager
We have appointed a data privacy manager to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal data, please contact the Data Protection Manager at the following e-mail address: firstname.lastname@example.org
Alternatively, you may send your written comments, inquiries or concerns to:
GasLog LNG Services Ltd
69 Akti Miaouli street,
Piraeus 185 37,
Attention: Data Protection Manager
You also have the right to make a complaint at any time to your local data protection authority or to the Hellenic Data Protection Authority (HDPA), the Greek supervisory authority for data protection issues, at Kifissias 1-3, 115 23 Athens, Greece.
Please visit http://www.dpa.gr/portal/page?_pageid=33,40911&_dad=portal&_schema=PORTAL for more information.
Changes 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 data.