Data Privacy Notice: Spain

Intrum is an international company, with establishments in different countries. For the purposes of this privacy notice, the Intrum entity to which you have submitted your request will be responsible for the protection of your personal data (data controller). "The company is principally engaged in the provision of Information Technology Development Services, encompassing Integration, Configuration, Customisation, and Programming. Additionally, the company specialises in the Management and Operations of Information Technology Services, grounded in established Information Technology Service Management Frameworks. This statement explains how we will use the personal data we collect from you or third parties during the job application process.

For recruitment positions for Intrum Global Technologies (Spain) in Spain, the Data Controller in GDPR terms of personal data is Intrum Global Technologies Spain, S.L. (hereafter “IGT” or the “Company”)

For positions in other locations, please see the Intrum Data Privacy Notice. 

Types of personal data to be processed

When you submit your application for a vacancy, we may process the following personal data about you:

• Contact details: Personally identifiable information and contact Information. Name, surname, residential address, e-mail address, telephone number.

• Data related to education: Qualifications, work experience, professional skills and characteristics. Information about education, foreign language skills, professional skills and abilities; information about career history and work experience (jobs, positions, length of service); characteristics and other information necessary to assess the candidate's suitability for the position offered and indicated in the candidate's curriculum vitae and/or motivation letter.

• Internal applications: If you are already employed by Intrum and apply for another position within the company, we may also use information from your personal file to supplement the information you provide when applying for a vacancy.

• Data required for general, professional skills and personality assessment: Where appropriate, we may ask for your consent to assess your skills, personality or cognitive ability. Such assessments are usually conducted using third-party software or a third-party company that will provide us with information about the results of your assessment. You will be provided with additional information as appropriate prior to making such an assessment.

• Pre-employment evaluation: Depending on the position you are applying for, we may carry out a pre-employment screening to assess the level of risk of a conflict of interest and whether there are any other circumstances that would prevent you from taking up the position. We may ask an expert, prior to your hire, to verify that there is no circumstance that disqualifies you for that position. In the case of carrying out this evaluation, you will be informed in advance about the scope and objective of it. These checks help us determine your honesty, integrity and reputation. We may ask a subject-matter expert in the technology field to evaluate your qualifications prior to your employment. Should this specialized assessment be deemed necessary, you will be provided with advance notification outlining its scope and objectives. This evaluation is conducted pursuant to our organisational policies, and is intended to rigorously verify that you meet the specific technical and ethical standards required for the specialized role to which you are applying, thereby helping us assess your technical acumen, integrity, and professional reputation.

• Sensitive data: For certain positions, in accordance with legal requirements, we may process special categories of data (sensitive data) under certain circumstances, such as criminal record, ethnic background or gender information.

• Reviews and referrals: We may ask for references (collect your personal data relating to qualifications, professional skills and characteristics) from people who have worked with you in the past and may only contact the prior your informed consent. If we decide to obtain this feedback, you will be duly informed in advance. Once we have received your consent, we may ask for feedback from people you currently work with. We will normally only contact people whose names and contact details you have provided. If you are already an Intrum employee, we may ask for references about you from your manager and/or colleagues.

Purposes of data processing

As collectors, Intrum will process your data for the following purposes:

• Conducting a pre-employment assessment: In some cases, we need to process the data in order to check the candidate to determine that there is no risk of a conflict of interest or other circumstances that would prevent you from taking up the position for which you are applying.
• Selection: We process personal data in order to contact the candidate and agree on possible interview dates, assess the candidate's professional suitability for the vacancy, prepare the necessary documents for the candidate's employment, etc.
• Dispute resolution: We may process personal data to deal with disputes, complaints or legal proceedings.
• Legal compliance: We may need to process your personal data to comply with the law or a court order.

Parties that may have access to your data

Intrum may, in accordance with personal data protection legislation, share your personal data with third parties in the following cases:

• When we collect information from third parties (as described above), we will disclose your name and other data they need to provide us with relevant information about you;
• We may provide your personal data to third parties (processors) who act on our behalf, such as service providers. In such cases, the data processors may only use your personal data for the above purposes and only in accordance with our instructions;
• We may disclose your personal data to, for example, law enforcement or other government authorities if required to do so by law or court order;
• Our employees could have access to your personal data. In this case, access will be granted only if it is necessary for the purposes described above and only if the employee is bound by an obligation of confidentiality.
• Your data may be communicated to the other entities that make up the Intrum Group for the purpose of participation in selection processes. The legal basis that legitimizes this assignment is the legitimate interest of Intrum, for the corporate management of human resources and personnel selection processes.
  Finally, we will share your data if there is a legal or judicial requirement.

Place of storage of your personal data

While your personal data is in our control, it will be available to employees in the European Economic Area (hereinafter referred to as the EEA). Your data may also be available in Switzerland, whose laws provide for a level of data protection equivalent to that of the European Union.

Intrum may also use third-party service providers to store your data outside the European Economic Area, including but not limited to the United States of America (USA). We will never transfer your personal data outside the EEA without ensuring the security and protection of your personal data. We therefore make sure that all recipients have signed EU standard model clauses and that the necessary additional safeguards are in place to justify the transfer or that the country guarantees adequate protection under data protection law. We may disclose information outside of these groups to help prevent fraud or as required by law.

Please use the contact details below if you would like to know more.

Retention of  personal data:

We retain your personal data for a certain period of time. We will keep your personal data during the recruitment process, contractual relationship and after the termination of the contract for no longer than necessary for the purposes for which your information is processed. This means that the data will generally be kept for six (6) years after the termination of the contract or after leaving the job with the Company.

We may retain your personal data for a longer period after the application process ends, if there is a pending/ongoing legal obligation/claim, resolving employment-related matters, compliance or if you have given us permission to keep your personal data on record for a longer period of time.

Other retention periods:

Applicant Data Base: We may retain the names of non-recruited applicants on a reserved list for internal tracking of the selection processes. Provided your prior consent, this list will be updated every year in accordance to what is necessary considering the purpose

Opt-outs from process: Should you opt out voluntarily opt-out from the process we may retain the data as legally necessary.

By taking part in this recruitment process, you consent to the maintenance of your personal data for the time span outlined in this clause

Legal basis for processing your data

Depending on the purpose of data processing:

• Legitimate interest: We process your personal data on the basis that the processing is necessary for the purposes of our legitimate interests as your potential employer. Our legitimate interest in this case is to recruit qualified candidates and determine their suitability for the role and determine their honesty, integrity and reputation. In some cases, we will also be required to process your personal data due to a legal obligation.
• Consent: We may process your personal data where you have given consent to the processing of a certain treatment .
• Legal obligation: We may process your personal data on the basis of a lawful reason for processing, which includes the fulfillment of a legal obligation like for example and not limited to the exercise or defend legal claims.

Your rights under the data protection law

You have certain rights under the European Union Data Protection Regulation (GDPR).

1. Right of access

You have the right to request information about how we process your personal data, and details of how we use it, including information about:

• Why we process your personal data;
• What categories of personal data we process;
• Who we share your personal data with;
• How long we store your personal data or the criteria for determining this period;
• What are your rights;
• Where we have received your personal data from (if we have not received it from you);
• Does the processing involve automatic decision-making (so-called profiling);
• If your personal data is transferred to a country outside the EEA, how do we ensure the protection of your personal data.

All of the above information is available in this Privacy Policy.

You can also request a copy of your personal data that we process. We will normally provide you with your personal data in writing and, if feasible, electronically. In any case, whenever possible, it will be provided to you by electronic means. However additional copies of such information will be issued for a fee.

2. Right to correct

We take reasonable steps to ensure that the information we hold about you is accurate, truthful, complete and correct. However, if you don’t think this is the case you have the right to contact our company with a request to correct your personal information if you find that the processed data is incorrect or inaccurate.

We may ask you for evidence to support that data change.

3. Right to erasure and to be forgotten

In certain cases, you have the right to ask us to erase your personal information, for example, when the personal information collected from you is no longer necessary for the original purpose or you withdraw your consent. However, in this case, other circumstances that determine the legality of data processing must also be taken into account. For example, we have the right to process your personal data because we may have legal or regulatory obligations that prevent us from fulfilling your request.

4. The right to restrict processing

In certain cases, you have the right to ask us to restrict the use of your personal information, for example, if you believe that the personal information we hold about you is incorrect, or where you believe that we no longer need to use your personal data. However, this will need to be balanced with other factors. For example, if we accept your request, we may not be able to proceed with the job application.

That being said we will continue to process your personal data for the purpose of, fulfilling or defending legal claims, to protect the rights of another person or to protect the public interest and legal obligations.

5. Right to data portability

You have the right to request the transfer to you and/or another data controller of your personal data, which you have provided to us and which we process based on your consent or for the performance of a contract, in a structured, generally accepted and machine-readable format. While this right is unlikely to apply in the context of our processing, Intrum will consider requests where it considers this right to apply.

6 The right objects

If you believe that we do not have the right to process your personal data on the legal basis of our legitimate interests, you have the right to object to the processing. In such cases, we can only continue processing if we can present compelling justifying reasons that outweigh your interests, rights and freedoms. However, please note that in some cases this means that we will no longer be able to process your job application. We may in any case process your personal data if it is necessary for the establishment, exercise or defense of legal claims.

7. Rights related to automated decision-making

You have the right not to be subject to automated decision-making, including profiling, which may have legal or otherwise material consequences for you. Intrum generally does not use automated decision-making or profiling in the selection process, but if you have been subject to automated decision-making and do not agree with the outcome, you can contact us using the contact details below and ask us to review the decision.

8. Right to withdraw consent

For the most part, the processing of personal data does not depend on your consent. However, we may ask for your consent in certain cases. In this case, you have every right to withdraw your consent to further use of your personal information. However, please note that this means that we can no longer proceed with the job application.

How to contact us regarding the processing of your personal data and data subject rights?
 

At any time you can exercise your rights through postal mail to IGT Spain at Calle Vía de los Poblados, 3, Edificio 1, 28033 Madrid or by email address dpo_igt_spain@intrum.com  providing a copy of your ID or equivalent document.

If you wish to contact our Data Protection Officer (in Spain) regarding the processing of your personal data or data subject rights, you can send an email to dpo_igt_spain@intrum.com 

If you consider your right to data protection infringed, you can file a claim with the Spanish Agency for Data Protection at www.agpd.es.   

If you are applying to a position in Intrum outside Spain, and have a query regarding how your data is being processed please reach out to our Global Data Protection Officer: gdpo@intrum.com

* Interpretation: In the event of any conflict or uncertainties arising in the interpretation of this policy, the Spanish version shall invariably hold precedence.