Privacy Policy for Job Applicants' Personal Data

Privacy Policy for Job Applicants’ Personal Data

This Job Candidate Personal Data Privacy Policy (hereinafter referred to as the “Policy“) details how the UAB Fegda Group and its individual companies UAB Fegda, UAB Tilsta, UAB SRP Projekt and UAB Alkesta (hereinafter collectively referred to as the “Group of Companies”), acting as joint data controllers, collect, use and protect the personal data of job candidates.

This Policy contains information about:

the type of personal data processed on job applicants;
for what purposes and on what basis personal data of job applicants are processed;
how long the personal data of job applicants is kept;
other relevant and up-to-date information.

This Policy may be amended without notice. The latest version is always available on the Group’s website: www.fegdagrupe.lt

Who is responsible for processing my personal data

Depending on which Group company you are applying for, your Data Controller is one of the following companies respectively:

UAB „Fegda grupė“

Legal entity code: 305839557

Registered office address: Geologu g. 12, LT-02190 Vilnius

E-mail address: info@fegdagrupe.lt

UAB „Fegda“

Legal entity code: 110801759

Registered office address: Geologu g. 12, LT-02190 Vilnius

E-mail address: info@fegda.lt

UAB „Tilsta“

Legal entity code: 121477326

Registered office address: Granito g. 6, LT-02241 Vilnius

E-mail address: info@tilsta.lt

UAB „SRP projektas“

Legal entity code: 300043111

Registered office address: 176C Savanoriu pr., LT-03154 Vilnius

E-mail address: info@srp.lt

UAB „Alkesta“

Legal entity code: 249672710

Registered office address: Naujoji g. 118, LT-62175 Alytus

E-mail address: info@alkesta.lt

What personal data do you collect and why?

In order to select the right candidate for a vacancy, the Group of Companies and/or its individual companies shall only collect, use and store Data that is necessary to carry out the selection process for vacancies. In addition, the candidate may voluntarily provide information that is not mandatory.

In all cases, the group of companies and/or its individual companies collect this personal data on candidates:

your name;
email address and/or phone number;
information on the candidates’ work experience (job title, length of service, position, responsibilities and/or achievements);
information on candidates’ education and qualifications;
information on language skills and other competences needed to perform the functions of the post;
a summary of the interview and the results, feedback and insights from the interviewer;
information on your preferred salary level;
other information provided voluntarily by candidates in their CVs, cover letters or other application documents (e.g. references, testimonials). If candidates choose to provide such data, it will be treated in the same way as personal data requested by Group companies.

Special categories of personal data (e.g. health-related information, criminal records) may only be collected where this is necessary for the purpose of selection for a specific job position and only to the extent necessary and permitted by the applicable law.

The group of companies and/or its individual companies may also collect personal data relating to the qualifications, professional abilities and personal qualities of candidates from his/her former employer, after having informed the candidate beforehand, and from his/her current employer only with the consent of the candidate.

Do you have to provide your personal data?

Please note that you are only obliged to provide your data where it is necessary for the purpose of the selection process. If you do not provide the necessary personal data, the Group and/or its individual companies will not be able to assess your candidature for the vacancy.

Legal bases for processing personal data.

In order to select the right candidate for a vacancy, the Group and/or its individual companies collect data on the following grounds as set out in the General Data Protection Regulation (“GDPR“):

with the consent of the candidate when the recruitment documents are submitted (Article 6(1)(a) GDPR);
having a legitimate interest in selecting the right candidate for a specific job (Article 6(1)(f) GDPR).

Retention period for personal data.

Your personal data shall be retained for the duration of the selection process and for 30 (thirty) days thereafter, unless the candidate consents to the processing of the data by the Group of Companies and/or its separate company for a period of 6 (six) months after the end of the selection process, or otherwise provided for by applicable law.

Sources of personal data.

The personal data of job applicants listed above is obtained by:

directly from the candidates themselves, in the form of a CV, cover letter or other application document submitted by e-mail from the Group and/or its individual companies;
from the Employment Service of the Republic of Lithuania;
from recruitment, placement or selection agencies;
from specialised social networks (e.g. LinkedIn) or job search platforms (e.g. CV Bank, CV Online).

In all these cases, the Group of Companies and/or its individual companies shall presume that the candidates have been duly informed of the processing and transfer of personal data and have given their consent to the relevant entity providing the above services to carry out these actions.

Transmission of personal data.

Personal data of job applicants may be disclosed to the competent state supervisory and law enforcement authorities only in cases where required by applicable law and the law applicable to the companies of the Group, or in the cases and according to the procedure provided for by law, in order to ensure or defend the rights of the Group and/or its individual companies, and to assert or defend legal claims.

Access to personal data of job applicants processed by the Group and/or its individual companies, only to the extent necessary for the performance of their functions, may also be granted to the following data recipients and processors:

IT service providers that maintain and service the Group’s email system and servers;
companies providing electronic communications and/or communication services to the Group;
recruitment services for Group companies;
firms providing audit, legal or other services.

With the consent of the job candidate, personal data may also be transferred to other companies within the Group.

Rights of job applicants.

The GDPR and other legislation on the protection of personal data give candidates the following rights:

Law	The bottom line
Right of access to data	The candidate has the right to request and obtain confirmation as to whether the Group of Companies and/or its individual companies process data relating to the candidate and, if they do, to request access to the data processed and the information relating to it.
Right to request rectification	The candidate has the right to request that incomplete personal data be rectified or, depending on the purposes for which the personal data are processed, supplemented.
The right to request erasure (“right to be forgotten”)	The Candidate shall have the right to request the deletion of information held by the Group of Companies and/or its individual companies about the Candidate if the Group of Companies and/or its individual companies use it unlawfully or in other circumstances specified in the applicable law: when the data are no longer necessary for the purposes for which they were collected or otherwise processed; where the candidate withdraws the consent on which the processing is based and there is no other legal basis for processing the data, where the candidate objects to the processing and there are no overriding legitimate grounds for processing, or objects to processing for direct marketing purposes, where the deletion of data is subject to a legal obligation imposed on the Group of Companies and/or its individual companies.
Right to restrict processing	The candidate has the right to request the restriction of the processing of his/her personal data if: challenging the accuracy of the data or objecting to the processing of the data; the processing is unlawful, but the candidate does not consent to the erasure of the personal data and instead requests the restriction of the processing of his/her personal data; the data is necessary for the establishment, exercise or defence of legal claims.
Right to object/revoke consent	The candidate has the right to object to the processing of personal data or to withdraw his/her prior consent where personal data are processed on the basis of consent (Article 6(1)(a) GDPR).
Right to data portability	The candidate has the right to request the transfer of personal data to another controller if the processing is based on the candidate’s consent or the performance of a contract and is carried out by automated means.
Right to lodge a complaint	If the candidate considers that personal data relating to him/her are being processed in breach of the GDPR or other legislation, he/she has the right to lodge a complaint with the State Data Protection Inspectorate (see https://vdai.lrv.lt).

Procedures for dealing with requests.

Data subjects should make all requests for the exercise of their personal data rights in writing:

by email to bdar@fegdagrupe.lt or
to the postal address of the company for which you are applying:
UAB “Fegda grupė” – Geologu g. 12, LT-02190 Vilnius;
UAB “Fegda” – Geologu g. 12, LT-02190 Vilnius;
UAB “Tilsta” – Granito g. 6, LT-02241 Vilnius;
UAB “SRP projektas” – Savanoriu pr. 176C, LT-03154 Vilnius;
UAB “Alkesta” – Naujoji g. 118, LT-62175 Alytus.

Upon receipt of a request for the exercise of rights, the Group of Companies and/or its individual companies shall verify the identity of the data subject and shall therefore be entitled to request the provision of personal identification data and documents.

Replies to requests from data subjects shall be provided no later than 30 calendar days from the date of receipt of the request and of all related documents necessary for the preparation of the reply.