This Privacy Notice was last updated on May 16th, 2018.
Santen SA, and its subsidiaries and affiliates (“Santen”, “us” or “we”), understand that your privacy is important to you. Santen subsidiaries and affiliates may process your personal data in their capacity as data controllers. We are committed to respecting your privacy and protecting your personal data, which is any information that is capable of identifying you as an individual person. This Recruitment Privacy Notice (“Privacy Notice”) describes how we handle and protect your personal data in connection with Santen’s recruiting processes and programs.
This Privacy Notice only applies to the personal data of job applicants, potential candidates for employment, and our optional recruiting programs and events. It does not apply to our employees, contractors or clients, or other personal data that Santen collects for other purposes.
As used in this Privacy Notice, “personal data” means information that identifies job applicants and potential candidates for employment with us, either submitted as part of the online application and/or through alternative channels (e.g., via professional recruiting firms).
We will process your personal data in accordance with this Privacy Notice, unless such processing conflicts with the requirements of applicable law, in which case, applicable law will prevail.
By submitting your personal data to us, you acknowledge that:
- You have read and understood this Privacy Notice and agree to the use of your personal data as set out herein.
- Your personal data may be transferred and processed worldwide, including countries that may not be deemed to provide the same level of data protection as your home country, for the purposes and in the manner specified in this Privacy Notice.
- You are not required to provide any requested information to us but failing to do so may result in not being able to continue your candidacy for the job for which you have applied.
- All your representations are true and correct to the best of your knowledge and belief, and you have not knowingly omitted any related information of an adverse nature. Providing any inaccurate information may make you ineligible for employment.
- This Privacy Notice does not form part of any contract of employment offered to candidates hired by Santen.
Personal data we collect
The types of personal data that we request from you and the ways that we process it are determined by the requirements of the country in which the position is located, and not the country in which you reside. Should you apply to more than one location or should the role to which you apply be available in more than one country, the types of personal data we request from you and the ways that we process it are determined by the requirements of all the countries in which the position is located.
We usually collect personal data directly from you when you apply for a role with us, such as your name, address, contact information, work and educational history, achievements, and test results. We also may collect personal data about you from third parties, such as your references, prior employers, Santen employees with whom you have interviewed, and employment background check providers, to the extent this is permitted by applicable law. Finally, we may also collect and process your personal data from publicly available social media profiles e.g. Facebook, Linkedin.
Sensitive personal data is a subset of personal data and includes ethnicity, health, trade union membership, philosophical beliefs, sexual orientation, as well as other categories as allowed by law. We do not seek to obtain and will not collect such data about a candidate unless permitted to do so by applicable laws (e.g., government reporting in the US).
Use of your personal data
We collect and use your personal data for legitimate human resources and business management reasons including:
• identifying and evaluating candidates for potential employment, as well as for future roles
that may become available;
• recordkeeping in relation to recruiting and hiring;
• ensuring compliance with legal requirements, including diversity and inclusion
requirements and practices;
• conducting criminal history checks as permitted by applicable law;
• protecting our legal rights to the extent authorised or permitted by law; or
• emergency situations where the health or safety of one or more individuals may be
We may also analyse your personal data or aggregated/pseudonymised data to improve our recruitment and hiring process and augment our ability to attract successful candidates.
We may desire to retain your personal data to consider you for future employment opportunities. In such an event, we will seek your consent, either prior to or after you formally apply for a job opportunity, to be part of one of our recruiting programs that provides you ways to further learn about Santen. These recruiting programs are entirely optional.
If you join a recruiting program, but subsequently wish to withdraw, please contact us at email@example.com.
Data recipients and international data transfers
Your personal data may be accessed by recruiters and interviewers working in the country where the position for which you are applying is based, as well as by recruiters and interviewers working in different countries within the Santen global organisation. Individuals performing administrative functions and IT personnel within Santen may also have a limited access to your personal data in order to perform their jobs. We have put in place legal mechanisms designed to ensure adequate data protection of your personal data that is processed by Santen subsidiaries and affiliates within the Santen global organisation, including the transfer of your personal data to countries other than the one in which you reside.
We use third party service providers to provide a recruiting software system. We also share your personal data with other third-party service providers that may assist us in recruiting talent, administering and evaluating pre-employment screening and testing, and improving our recruiting practices.
We maintain processes designed to ensure that any processing of personal data by third party service providers is consistent with this Privacy Notice and protects the confidentiality, availability, and integrity of your personal data. Where required by law, we put in place legal mechanisms designed to ensure adequate data protection of your personal data.
In addition, in the event of a re-organisation, merger, sale, joint venture, assignment, or other transfer or disposition of all or any portion of our business, we may disclose or transfer your personal data.
If you accept an offer of employment by us, any relevant personal data collected during your pre-employment period will become part of your personnel records and will be retained in accordance with specific country requirements. If we do not employ you, we may nevertheless continue to retain and use your personal data for a period of time (which may vary depending on the country) for system administration purposes, to consider you for potential future roles, and to perform research. If you elect to join a recruiting program, we may retain your personal data to consider you for future employment opportunities.
We have implemented generally accepted standards of technical and operational security to protect personal data from loss, misuse, alteration, or destruction. Only authorised personnel of Santen and of our third-party service providers are provided access to personal data, and these employees and third-party service providers are required to treat this information as confidential. Despite these precautions, we cannot guarantee that unauthorised persons will not obtain access to your personal data.
We take reasonable steps that are designed to keep your personal data accurate, complete, and up-to-date for the purposes for which it is collected and used. We also have implemented measures that are designed to ensure that our processing of your personal data complies with this Privacy Notice and applicable law.
You may have the right to request access to the personal data that we have collected about you for the purposes of reviewing, modifying, or requesting deletion of the data. You may have the right to request a copy of the personal data we have collected about you.
If you would like to make a request to access, review, or correct the personal data we have collected about you, or to discuss how we process your personal data, please contact us at firstname.lastname@example.org.
To help protect your privacy and security, we will take reasonable steps to verify your identity before granting you access to your personal data. We will make reasonable attempts to promptly investigate, comply with, or otherwise respond to your requests as may be required by applicable law. Depending upon the circumstances and the request, we may not be permitted to provide access to personal data or otherwise fully comply with your request; for example, where producing your information may reveal the identity of someone else. We reserve the right to charge an appropriate fee for complying with your request where allowed by applicable law, and/or to deny your requests where, in the Santen’s discretion, they may be unfounded, excessive, or otherwise unacceptable under applicable law.
In addition, and where granted by applicable law, you may have the right to lodge a complaint with a competent data protection authority.
Cookies and other tracking technologies
Santen Privacy EMEA Office
La Voie-Creuse 14
1202 Geneva, Switzerland
Email address: email@example.com
Santen reserves the right to modify this Privacy Notice. We will post any changes made to our Privacy Notice on this page. Please check this page regularly to keep up-to-date.