Del Monte Europe Job Applicant Data Protection Privacy Notice

Introduction

For the purpose of this Privacy Notice ("Notice"), the Data Controller is the recruiting Del Monte company ("Company") to which you have submitted your job application. You can find information about the different European Del Monte entities and their contact details here .

As part of its recruitment process, the Company collects and processes personal data relating to job applicants. The Company is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations. For this purpose, and in compliance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data ("GDPR"), we hereby provide you with the required information regarding the processing of your personal data throughout our recruitment process.

We ask that you carefully review this Notice to obtain information regarding: (i) how we collect your personal data; (ii) what information do we collect; (iii) the purposes for which we process your personal data; (iv) the legal basis that we rely on for the processing of your personal data; (v) with whom we share your personal data; (vi) for how long we retain your personal data; and (vii) your privacy rights.

Definitions

For purposes of this Notice, all references to "personal data"; "legal basis"; "processing"; or "data controller" shall have the meaning established in the GDPR.

Applicability

This Notice does NOT apply to the processing of personal data of the following individuals, which are all subject to separate and specific privacy notices:

• employees;
• customers or website users;
• independent contractors; and
• other individuals with whom we engage in solely business-to-business communications and transactions.

Sources of Personal Data

• Personal data you directly provide when you apply for a job with us. We collect personal data directly from job applicants' who submit employment applications for our consideration. The Company may collect this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes (obtained from you or from Professional Social Media providers), obtained from your passport or other identity documents, or collected through interviews or other forms of assessment, including online tests, if appropriate.
• Personal data received from third parties: We may receive personal data about job applicants' from third parties who provide services to us, including but not limited to staffing or recruiting firms, internal or external referrals and from background checks service providers when the conduction of background checks is mandatorily required by the local laws of the territory where the job position is based.

What information does the Company collect?

The Company collects a range of information about you during the recruitment process. This includes:

• your full name, address and contact details, including email address and telephone numbers;
• your image, where included in your professional resume/ CV;
• details of your educational and professional qualifications, skills, achievements, experience and employment history;
• information on your hobbies and extracurricular activities, where included in your professional resume/ CV;
• information about your current level of remuneration, including benefit entitlements;
• other information about you contained in any cover letter submitted to us during the recruitment process;
• any notes which are produced before, during or after an interview or any test scores in respect of any aptitude tests which you complete at the Company request;
• information about your entitlement to work in the country where the position is located.

Notwithstanding the above, we may process criminal convictions data or equal opportunities monitoring information from you, including information about your gender, ethnic origin, sexual orientation, health / disability and religion or politic beliefs related data only if the local laws of the territory where the job position is based require us to do so.

Purposes of the data processing and applicable legal basis

The Company will process your personal data for different variety of purposes during the recruitment process under the following legal basis:

• We collect and process your personal data to take steps at your request prior to entering into a contract with you. In particular:
  • To administer your job application, convene you for interviews and carry out additional assessment rounds with some of the candidates where further information may be required;
  • to deal with any query or request directly received from you in relation to our recruitment process;
  • to send you a formal employment offer if we consider you are a suitable candidate for the job position for which you have applied.
• For compliance with a legal or statutory obligation to which we are subject, we will process your data for the following purposes:
  • to check a successful applicant's eligibility to work in the country where the position is located before employment starts;
  • to conduct screening and employment background checks (only if this is required by the local laws of the territory where the job position is based);
  • to ensure compliance with equal opportunity obligations (only if this is required by the local laws of the territory where the job position is based); and
  • to share your personal data with public authorities, courts, governmental or law enforcement agencies in case we receive a lawful information request from them or we are required by applicable law to provide certain information about our job applicants to them.
• Where we have a legitimate interest, we will process your personal data as follows:
  • to consider your suitability to work for us in the role you have applied for, comparing you to other candidates and making recruitment decisions and to carry out an initial screening of applications received. In this case, our legitimate interest is to provide us with a workforce that matches our needs and preferences.
  • for the establishment, exercise or defense of a legal claims. We may process your personal data to respond to subpoenas, lawsuits, judicial proceedings, court requests or for initiating legal actions if we believe that there has been a violation of any legally binding document executed between us; the rights of any third party; or if you have provided us with fake information about you during the recruitment process. In this case, our legitimate interest is to protect our assets and our shareholders' business and commercial interests.
• Where you give us prior and express consent to do so, we will collect and process your personal data for the following purposes:
  • to keep your personal data on file in case your application is not successful but you are interested in future employment opportunities with the Company for which you may be suited.
  • to share your personal data with other Del Monte corporations different than the Company ("Affiliates") in case your application with the latter is unsuccessful but there is another vacancy offered by the Affiliates for which you may be suited.
  • Please note that you are entitled to withdraw your consent at any time by writing an e-mail to privacyofficer@freshdelmonte.com

With whom do we share your personal data?

We may share your personal data with the following categories of recipients:

• Affiliates: If your job application is unsuccessful but you provide us with your prior and express consent, we will share your personal data with our Affiliates in case they have any vacancy for which you may be suited. We may also share your information with our Affiliates for centralizing the recruitment process under our legitimate interests of guaranteeing operational and cost efficiency for our group.
• Public authorities, courts, governmental or law enforcement agencies: We will share your personal data with public authorities, governmental or law enforcement agencies in case we are obliged to do so pursuant lawful information request or we are required by law to provide them with certain information about our job applicants; or under our legitimate interest for the establishment, exercise or defense of legal claims.
• Service providers: We may share your personal data with third parties that may assist the Company during the recruitment process and will process your personal data on our behalf. In this respect, the categories of service providers with whom we may share your personal data are:
  • IT and Cloud Service Providers: They provide the Company with business, professional or technical support functions that help us to administer your job application and the recruitment process;
  • Legal advisors: They provide DMI with legal advice in the establishment, exercise or defense of legal claims; and
  • Employment background check service providers: If we consider you a successful candidate, and before we make you a formal job offer, we will share your personal with employment background checks services providers only if we are obliged to do so to comply with the local laws of the territory where the job position is based.

Note that some of the above described recipients may be located in territories outside the European Union, the European Economic Area ("EEA") or in countries that have NOT been granted with an Adequacy Status by the European Commission ("Third Country(ies)") and thus, do not provide a level of personal data protection equivalent to the European standards. Whenever we share personal data with entities established in Third Countries, we will adopt the corresponding legal safeguards (i.e. European Commission Standard Contractual Clauses) required by the GDPR to ensure that the recipients of your personal data process the same in accordance with European standards. You can request additional information on the scope and content of these safeguards.

How does the Company protect personal data?

The Company takes the security of your data seriously. It has in place an internal framework of policies and procedures to ensure we comply with our legal and regulatory obligations for data security. Our policies set out our commitment and expectations for the protection and security of all Company data, including personal data, so as to provide reasonable protection against loss, accidental destruction, misuse or disclosure, and to ensure that it is accessed only by authorised Company employees in the proper performance of their duties.

For how long does the Company keeps personal data data?

If your application for employment is unsuccessful, we will delete your personal data from our systems. Notwithstanding this, if you provide us with your prior and express consent the Company will hold your data on file for a period of 2 years after the end of the relevant recruitment process in order to consider you for future employment opportunities. At the end of that period or if you withdraw your consent earlier, your data will be deleted or destroyed.

If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your employee file and retained during your employment and for some time afterwards, during the applicable statute of limitation period arising from the employment relationship. The specific periods for which your data will be held as an employee would be provided to you in the Employee Privacy Notice.

Your rights as a Data Subject.

We outline below the corresponding data protection rights you are entitled pursuant to the GDPR:

• Right to access and to obtain a copy of your personal data;
• Right to rectify / correct any inaccurate personal data concerning you;
• Right to request the erasure of your personal information;
• Right to restrict the processing when your personal data is inaccurate, processed unlawfully or the personal data is no longer needed for the purposes for which it was collected;
• Right to object to the processing of your personal data, including the objection of the processing for direct marketing purposes;
• You have the right to withdraw any consent given to DMI; and
• If the processing of your personal data is based on your consent or under the performance of a contract legal basis, you have the right to receive the personal data that you have provided to us in a structured, commonly used and machine-readable format and the right to transmit that data to another data controller (data portability).

In addition to the general rights listed above, you have the right not to be subject to automatic decision-making, including profiling.

You also have a right to lodge a complaint before the European Data Protection Supervisory Authority of the territory where you reside.

Please note that depending of the European Member State you reside, the above-described rights may not be absolute and its full exercise may be subject to specific requirements or be affected by specific circumstances or exemptions.

To exercise your rights or if you believe we have infringed upon your right to privacy granted by the GDPR, please contact privacyofficer@freshdelmonte.com.

What happens if you do not provide personal data?

You are under no statutory or contractual obligation to provide personal data to the Company during the recruitment process. However, if you do not provide us with your personal data, the Company may not be able to process your application.

Automated decision-making.

The Company does not operate any recruitment automated decision-making processes.

How to contact us

If you have any questions or concerns about this Privacy Notice or the processing activities described herein, please contact our Privacy Officer at: privacyofficer@freshdelmonte.com