Data Privacy – Information to any prospective Employees (Recruitment Privacy Notice)
Coty's data privacy vision is to actively build trust with our customers, consumers and employees, through the robust governance and proactive management of the way Personal Data is captured, processed and used.
Coty is committed to protecting data and promoting Individuals' privacy, as well as delivering business value, through better understanding our data and processing it in a structured and purposeful manner.
1.1 We respect the privacy rights of individuals and are committed to handling personal information responsibly and in accordance with applicable law. It is important that you read all of this Notice carefully as it sets out how Coty handles your personal information when you apply for a job or other role with us and the rights you have in connection with that information. The term "applicants" is used in this Notice to refer to anyone who applies for a job, or who otherwise seeks to carry out work with or for us (whether on a permanent or non-permanent basis).
If you are in any doubt, or have any comments or questions about this Notice, please contact us using the contact details set out at Section 8 below.
2. Types of personal information we collect when you apply
2.1 Information that we collect automatically
You can visit Coty's career site, including the recruitment section of our website, ("Website") and search for jobs without providing personal information. However, we do collect certain information automatically from your device when you visit our Website
We may also collect information about how your device has interacted with us, including the pages accessed and links clicked, how you navigate to and from the Website, crashes and download errors and response times. Learn more about cookies and other similar technologies, including how to amend your cookie settings by referring to the sections on Cookies below.
2.2 Personal Information collected from you
During the recruitment process, we will collect and process your personal information as appropriate to the stage of the recruitment process, the role you have applied for and in accordance with applicable laws. This can include (but is not limited to):
- Identification data and contact details – including your name, address, email address, phone number and other contact information.
- Employment history – such as previous employers and job titles/positions.
- Background information – such as academic/professional qualifications, job qualifications, education, details included in your CV/résumé (which might include details of any memberships or interests constituting sensitive personal information), transcripts and employment references.
- Contact details for any personal or previous employer references (including name, contact details, employer and job role).
- Previous applications/roles (information relating to previous applications you have made to the Company's Group and/or any previous employment history with the Company's Group).
- Other information you voluntarily provide throughout the process, including through assessment centers / exercises and interviews.
As a general rule, during the recruitment process, we try not to collect or process any of the following: information that reveals your racial or ethnic origin, religious, political or philosophical beliefs or trade union membership; genetic data; biometric data for the purposes of unique identification; or information concerning your health/sex life ("Sensitive Personal Information"), unless authorized by law or where necessary to comply with applicable laws.
However, in some circumstances, we may need to collect, or request on a voluntary disclosure basis, some Sensitive Personal Information for legitimate recruitment-related purposes: for example, information about your racial/ethnic origin, gender and disabilities for the purposes of equal opportunities monitoring, to comply with anti-discrimination laws and for government reporting obligations; or information about your physical or mental condition to consider accommodations for the recruitment process and/or subsequent job role. You may provide, on a voluntary basis, other Sensitive Personal Information during the recruitment process. Coty is committed to providing equal employment opportunities and any Sensitive Personal Information you provide will be treated securely and in confidence and will not impact the hiring decision.
2.3 Personal information collected from other sources:
- References provided by referees.
- Other background information provided or confirmed by academic institutions and training or certification providers.
- Criminal records data obtained through criminal records checks.
- Information provided by background checking agencies and other external database holders (for example credit reference agencies and professional / other sanctions registries).
- Information provided by recruitment or executive search agencies.
- Information collected from publicly available sources, including any social media platforms you use or other information available online.
(in each case, where permissible and in accordance with applicable law).
3. Purposes for processing personal information
3.1 We collect and use your personal information for recruitment purposes, in particular, to determine your qualifications for employment and to reach a hiring decision. Under applicable data privacy law, we are required to satisfy one or more specified legal grounds before we can collect and use your personal information. Coty relies on the following legal grounds where processing your information in connection with the recruitment process:
What are the legal grounds?
Data processing for employment purposes / Performing or entering into a contract
As part of the recruitment process it is necessary for us to process your information to assess your skills, qualifications and background for a particular role, verify your information, carry our reference checks or background checks (where applicable), manage the hiring process, and communicate with you about it.
Compliance with our legal obligations
As described in section 2,2 we may need to process your information to meet our legal obligations, including those under immigration and employment laws.
Pursuing our legitimate interests
Where such processing is not overridden by your rights, we are permitted to use your personal information to pursue our legitimate interests, for example for management reporting and to protect the rights and interests of Coty, our employees, applicants and others, as required and permitted by applicable law.
In some limited circumstances, we may rely on your consent to collect and use your personal information. For example, we may rely on consent where you have provided us with Sensitive Personal Information.
If we rely on consent, this will be made clear to you at the time we request your information. You can withdraw your consent at any point by contacting us using the contact details provided in Section 8 below.
In some instances, we may need to use your personal information to protect your vital interests or those of another person.
If you are accepted for a role at Coty, the information collected during the recruitment process will form part of your ongoing staff member record and will be processed in accordance with our Employee Privacy Notice.
4. Who we share your personal information with and transfers abroad
4.1 We take care to allow access to personal information only to those who require such access to perform their tasks and duties, and to third parties who have a legitimate purpose for accessing it. Whenever we permit a third party to access personal information, we will implement appropriate measures to ensure the information is used in a manner consistent with this Notice and that the security and confidentiality of the information is maintained.
4.2 Transfers to other group companies
We will share your personal information with other members of the Company's Group around the world in order to administer our recruitment processes and store data.
4.3 Transfers to third party service providers
We may make certain personal information available to third parties who provide services relating to the recruitment process to us, including:
- recruitment or executive search agencies involved in your recruitment;
- background checking or other screening providers and relevant local criminal records checking agencies;
- data storage, shared services and recruitment platform providers, IT developers and support providers and providers of hosting services in relation to our careers website; and
third parties who provide support and advice including in relation to legal, financial / audit, management consultancy, insurance, health and safety and security .
4.4 We may also disclose personal information to third parties on other lawful grounds, including:
Where you have provided your consent;
To comply with our legal obligations, including where necessary to abide by law, regulation or contract, or to respond to a court order, administrative or judicial process, including, but not limited to, a subpoena, government audit or search warrant;
In response to lawful requests by public authorities (including for tax, immigration, health and safety, national security or law enforcement purposes);
As necessary to establish, exercise or defend against potential, threatened or actual legal claims;
Where necessary to protect your vital interests or those of another person; and/or
In connection with the sale, assignment or other transfer of all or part of our business.
In some cases, the sharing described above may result in your personal information being transferred internationally, including from the European Economic Area to a country outside it. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).
Specifically, our group companies, affiliated companies and third party service providers operate around the world. This means that when we collect your personal information we may process it in any of these countries in compliance with applicable data privacy laws.
5. Data retention periods
5.1 Personal information will be stored in accordance with applicable laws and kept as long as needed to carry out the purposes described in this Notice or as otherwise required by applicable law. Generally this means your personal information will be retained:
- in accordance with the retention periods set out in the Company's Employee Privacy Notice (where you become our employee); or
- for a period of 6 months after confirmation that your application was unsuccessful unless you request that we delete your application.
6. Your data privacy rights
6.1 You may exercise the rights available to you under applicable data protection laws as follows:
- If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided below.
- You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided below.
- If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. (Contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries are available here.)
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
Cookies, the most common of such technologies, are small data files placed on your computer to facilitate your browsing and enhance your experience on the Coty Sites.
You can prevent this storing by refusing cookies or by changing your browser settings. Most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. However, please be aware that when you disable cookies, some features and services on the Coty Sites may not functional properly and may cancel opt-outs that rely on cookies, such as web analytics.
7.2 Cookie Types
Functional/Performance - The Coty Sites will identify your local preferences for viewing and accessing the website, such as your preferred language, local website version, display options, e-mail or social media integration (i.e., allowing you to share a Coty website via your Facebook account).
8. Contact details
8.1 Please address any questions or requests relating to this Notice to firstname.lastname@example.org or alternatively, you can raise any concerns with your recruitment consultant, HR contact or hiring manager.