Privacy and GDPR-agreement

1. Introduction

INEOS collects and processes personal data for recruitment purposes. We attach great importance to transparency regarding how we collect and use this data in order to comply with our data protection obligations.

2. What data do we collect?

When you apply for a position within the company, we ask for your name, email address, and telephone number so that we can contact you if necessary. We also request information about your education, including training and qualifications, to assess your competencies; information about your employment history; a copy of your CV; and information regarding your work and salary expectations.

You may also choose to include similar personal data in your CV and/or provide additional personal data that INEOS does not require. This is entirely at your own discretion.

During the selection process for interns, we also collect assessment-related information.

INEOS may collect data in various ways. For example, data may be collected through application forms or CVs, correspondence with you, interviews, meetings or other assessments, secure access systems, and security cameras used for security purposes where these are present at company locations you may visit.

In some cases, we collect personal data about you from external parties, such as references from former employers. References are only requested where relevant to the position and after the candidate has been informed and has given consent.

Data is stored in various locations within the company’s HR management systems.

3. Why do we process personal data?

INEOS collects and processes personal data for the purpose of recruiting and selecting employees. The processing of personal data is necessary to take steps prior to entering into a potential employment contract, to comply with legal obligations, and on the basis of INEOS’ legitimate interest in identifying and selecting suitable candidates for vacant positions.

If you apply for a position, we carry out work permit checks to ensure that you have the legal right to work in the EU or in the country where you are applying for a vacancy.

Candidate data may be included, for the duration of the retention period, in a shared recruitment reserve managed through the CV Warehouse platform. This recruitment reserve is accessible only to the Belgian INEOS companies listed in this privacy statement that use the same Applicant Tracking System (ATS). This enables candidates to be considered for other relevant vacancies within these companies.

INEOS believes that candidates can reasonably expect their data to be consulted by the Belgian INEOS companies listed in this privacy statement for similar vacancies for which their profile may be relevant. Such processing takes place exclusively within the shared CV Warehouse recruitment reserve and is limited to employees involved in recruitment and selection activities.

4. Who has access to the data?

Your information is shared internally with members of the HR team, who may also share this information with other INEOS colleagues involved in the recruitment, selection, or interview process.

Candidates’ personal data is processed through the CV Warehouse platform. Only the Belgian INEOS companies listed in this privacy statement and using this system have access to candidates’ personal data for their recruitment and selection activities.

If a candidate may be suitable for a position outside this shared recruitment reserve, his or her profile will only be shared after the candidate has been informed and has provided consent.

Personal data may also be shared with third parties that carry out background checks on behalf of INEOS. Contractual agreements are in place to ensure that your personal data is adequately protected.

5. How do we protect your data?

We take the security of your data seriously. The company maintains internal policies and controls to ensure that your data is not lost, accidentally destroyed, misused, disclosed, or accessed by anyone other than employees who require access in the course of their duties. For more information, please refer to the INEOS Data Protection Policy. Access to databases or systems containing your data is restricted to authorized users.

INEOS implements appropriate technical and organisational security measures to protect personal data, including:

• Multi-factor authentication for secure access to our Office 365 environment;
• Encryption of laptop hard drives to prevent unauthorized access to data if a laptop is lost or stolen;
• Measures restricting the use of external hard drives (including USB devices) to prevent company data from being stored in unauthorized locations.

When we engage external parties to process personal data, they do so only on the basis of written instructions. They are bound by confidentiality obligations and are required to implement appropriate technical and organisational measures to ensure data security.

6. How long do we retain data?

We retain your personal data for a maximum period of one year after you have provided it to us. During this period, your data may be consulted for other suitable vacancies within the Belgian INEOS companies participating in the shared recruitment reserve through CV Warehouse.

If you become employed by us, we will retain your personal data and transfer it to your employee file. In this case, you will receive a separate privacy notice.

7. Your rights

As a data subject, you have a number of rights. You may:

• Request access to your personal data and obtain a copy of it;
• Require us to correct inaccurate or incomplete personal data;
• Request that we stop processing your data or erase it, for example where the data is no longer required for processing purposes;
• Object to the processing of your data where the company relies on legitimate interests as the legal basis for processing; and
• Request that we restrict the processing of your data for a period of time where the accuracy of the data is contested or where there is a dispute as to whether your interests override the company’s legitimate grounds for processing.

If you wish to exercise any of these rights, please contact the HR Manager of the relevant INEOS business in Belgium.

If you believe that the company has not complied with your data protection rights, you may lodge a complaint with the relevant Data Protection Authority in Belgium.

Contact Details

If you believe that your personal data is not being processed in accordance with applicable privacy legislation, you may lodge a complaint with the Belgian Data Protection Authority (DPA).

8. Automated Decision-Making

INEOS does not use solely automated decision-making processes that produce legal effects for candidates. Applications are always reviewed by authorised employees involved in the selection process.

Versions of this document are controlled and are reviewed and updated annually, or whenever a significant change occurs.