Effective date: 13 August 2026
This Policy details how OCSiAl Group SA and its Affiliates (hereafter “we”, “our”, “Company”, “OCSiAl” or “us”) uses and protects Personal Data relating to job applicants (hereafter “you”. “your”, “Candidate” or “Data subject”).
1. Scope of this policy
This Policy applies to all information you provided us or that we collected during the recruitment process.
Please note that we have in place a separate internal GDPR policy that applies to the processing of Personal Data of current and former collaborators.
2. Data controller
OCSiAl Group SA, a company established and operating under the laws of the Grand Duchy of Luxembourg, registered with the Luxembourg Registre du Commerce et des Sociétés under number B278784, with its registered office at 1, rue de la Poudrerie.
For the purpose of this Policy, the Company acts as the Data controller on its behalf and on behalf of its Affiliates.
Affiliates mean any other person which directly or indirectly controls, or is under common control with, or is controlled by, OCSiAl Group SA. As used in this definition, “control” (including with its correlative meanings, “controlled by” and “under common control with”) means, with respect to the Company, the possession, directly or indirectly, of power to direct or cause the direction of management or policies (whether through ownership of securities or partnership or other ownership interests, by contract or otherwise) of a person.
3. Data sources
We collect information (“Data”) during the recruitment process that may include, but is not limited to, identifying personal information (“Personal Data”). We collect Data about candidates from the following sources:
- You, the candidate.
- Recruitment service providers, head-hunters
- Your named referees
Publicly available sources, including online, that we believe is relevant to your application or a potential future application (e.g. your LinkedIn profile).
4. Types of Data collected
During the recruitment process, we collect different types of Personal Data, that may include but is not limited to:
- Identification Data: your name, surname, date and place of birth, address, e-mail address, telephone number, nationality
- Contact information: address, e-mail address, telephone number
- Job application Data: your CV, cover letter, additional information regarding your professional qualifications, skills or abilities.
- Employment history: your current company/organisation, your current role, your past work experiences.
- Education history: your university degrees, academic records, professional licenses and certifications, memberships, awards.
- Documents required under immigration laws (such as citizenship, passport or national ID, residency or work permit).
- Professional preferences: your salary expectations, job roles preferences, willingness to relocate and other information you decide to share with us in the course of the recruitment process.
- Special categories of data: Extract of criminal records. The document will be destroyed in accordance with the terms set by the Law of July 23, 2016, modifying the Law of March 29, 2013, on Organising Criminal Record Certificates, the Code of Criminal Procedure and the Criminal Code.
We may also collect information about your health, including any medical condition or disability to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during an interview.
- Bank account details for salary payment purposes (if successful)
- Any additional information you voluntary and unilaterally decide to share with OCSiAl in the course of the recruitment process (such as your picture, your hobbies, how you first learned about our job opening, reference letters).
- Cookies: For more information about Cookies and how we use them (including information about the types of cookies used), please, review our full Cookies Policy here.
As part of your job application documentation, OCSiAl will never ask you to provide the following Data: race or ethnicity, religious or philosophical belief, political opinions, trade union membership, sexual orientation, genetic data. Please do not disclose this information with us.
In case of a successful outcome of the recruitment process, the above-mentioned categories of Personal Data will form part of your employment file with OCSiAl. You will receive more information about how OCSiAl collects and processes the Personal Data of its collaborators through our GDPR Policy.
5. Purpose of the processing
This section is applicable in the European Union (the “EU”) and European Economic Area (the “EEA”). It also applies in other regions where Data protection laws require this information.
We use your personal information to:
- Identify and evaluate your application for current or future positions
- Communicate with you about your application
- Create a CV database
- Conduct interviews and assessments
- Perform pre-employment screening and background checks
- Analyse and improve our recruitment processes
- Comply with legal and regulatory requirements
- Complete the on-boarding and screening process should your application be successful.
If you fail to provide personal information
If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.
Legal bases for processing
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Processing |
Legal Basis |
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Identification data; contact information; job application data; employment history; education history; documents required under immigration laws; professional preferences; interview notes Cookie data. |
We have a legitimate interest in collecting and processing Personal Data to assess a candidate's qualifications, skills, and fit for a particular role. This processing is also necessary to facilitate communication with candidates and to manage the recruitment process efficiently, as well as to analyse and improve our recruitment processes for the benefit of OCSiAl and future recruits. The performance of contractual and precontractual measures relating to our potential employment relationship with you. In case you were not selected for the position but would like OCSiAl to stay connected with you so that we can inform you about future job opportunities that may be of interest to you, we may process relevant contact and related information you provided as part of your initial application or information we have obtained from Sites based on our legitimate interest to find the best candidate for the position. Cookie data collected to improve our recruitment process is based on your consent. |
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Perform pre-employment screening and background checks |
We have a legitimate interest to assess and evaluate your skills and suitability for the intended role, or Comply with legal obligations depending on jurisdiction |
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Maintain records for future opportunities |
Consent |
6. Transfers and recipients
OCSiAl will need to share your Personal Data internally and may be required to share it with some external third parties or associates of OCSiAl.
Your Personal Data will only be shared if it is necessary or required and permitted by law (e.g. in order to carry out pre-employment screening).
To enable the recruitment process, your Personal Data may be shared internally, but the information shared is limited to what is required by each individual to perform their role in the recruitment process.
For example, your Personal data may be shared internally with:
- employees who would have managerial responsibility for you or are acting on behalf of those employees;
- employees in OCSiAl’s Human Resources department who have responsibility for certain processes (for example recruitment, assessment, pre-employment screening);
- employees in Legal Services, Enterprise Risk & Compliance and Human Resources with responsibility for investigating issues of non-compliance with laws and regulations, policies and contractual requirements;
- employees in Information Technology (IT) who manage user access, should your application be successful;
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 recruiters and interviewers working in different countries within our Affiliates.
OCSiAl may also need to share your Personal Data with certain external third parties or Associates including:
- Government authorities, when required by law
- We will also share your Personal Data with other third parties if we have your consent (e.g. if you have given us permission to contact your referees, academic institutions to validating information you have provided).
It is your responsibility to obtain consent from referees before providing their Personal Data to OCSiAl.
7. Transfer of Data Outside the European Union
For service efficiency purposes, some of your Data, including Personal Data, may be transferred to, maintained and processed on computers located outside of your country or other governmental jurisdiction where the Data protection laws may differ from those in your jurisdiction, including the situations when the Data processing may occur outside the EU and the EEA.
When transferring your Data internationally, we implement adequate safeguards to ensure your data remains secure, relying on recognized mechanisms such as the EU’s Standard Contractual Clauses (SCCs) and any necessary supplementary measures required by applicable data protection regulations. For your reference, the full text of the SCCs is available at: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en.
8. Retention periods
If your application for employment is successful, Personal Data gathered during the recruitment process will be transferred to your employee record and retained in accordance with our internal GDPR Policy. If successful, our internal GDPR Policy will then apply to you.
To the extent that we have collected Personal Data, including sensitive Personal Data, for the specific purpose of fulfilling our legal obligations regarding public health or workplace safety, we will retain that Data for the duration of those legal obligations. Thereafter, we retain a minimal amount of your Personal Data to record your recruiting activity with us.
If your application is unsuccessful, we may seek your consent to retain your Personal for future employment opportunities within OCSiAl. Your Personal Data may will be retained for a maximum period of 2 (two) years.
9. Your rights in connection with your Personal Data
To the extent permitted by the applicable laws, you, as the Data subject, are entitled to:
- Request access to the Data that we have on you;
- Request us to rectify (correct) any inaccurate Data that we have. You also have the right to ask us to complete the information you believe is incomplete. When you voluntarily share your Personal Data with us via any method, you confirm their accuracy and truthfulness and agree to promptly inform us of any updates or changes. You are solely responsible for any harm, loss, or damage arising from incomplete, inaccurate, or false information provided in the forms available on ocsial.com (the Site) or LinkedIn Job Search page. Please note that, unless explicitly permitted under this Privacy Policy, you must only submit your own Personal Data, not the Personal Data of any third party;
- Request us to erase your Personal Data if it is no longer needed for any of the purpose set out above or when we are no longer legally authorized to process and use it;
- Request us to restrict the processing of your Personal Data. This includes the ability to temporarily suspend the processing in specific situations or ask that we retain the data for a longer period if you require it for a valid reason;
- Object to the processing of your Personal Data.
You may revoke your consent to process your data at any time. If processing is based on consent or required to fulfil a contract, you also retain the right to request data portability. This allows you to receive your Personal Data in a structured, widely recognized, and machine-readable format, enabling seamless transfer to another organization without obstruction from our side.
To exercise your rights specified above you shall send us a request by registered mail or by email at:
Data Protection Manager
1, rue de la Poudrerie,
L-3364 Leudelange
DPM@ocsial.com
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We will then have one calendar month starting from the day we received the request to respond. Occasionally it could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.
Additionally, you may file a claim before the responsible data protection regulatory authority. In Luxembourg, you can contact the National Commission for Data Protection.
Commission Nationale de Protection des Données
Service des réclamations
15, Boulevard du Jazz, L-4370 Belvaux
Tel.: (+352) 26 10 60 -1
10. Security of Data
We securely store your Data on a company-managed virtual server in the European Union, hosted by Microsoft Azure (https://azure.microsoft.com/en-us/support/legal/). While we shall use commercially acceptable means to protect your Data, we cannot guarantee its absolute security, since no method of transmission over the Internet, or method of electronic storage is 100% secure.
The Company will take steps reasonably necessary to ensure that your Data is treated securely and in accordance with this Policy; and no transfer of your Data will take place to an organization or a country unless there are adequate controls in place ensuring the security of your Data.
11. Anti-Discrimination
OCSiAl is dedicated to maintaining a workplace free from discrimination, harassment, and retaliation. We prohibit discrimination against employees or applicants based on race, colour, national origin, sex, gender identity, sexual orientation, religion, disability, age, or any other legally protected characteristic. Every individual will be treated with fairness, dignity, and respect at all times.
12. Availability of this Privacy Policy in Other Languages
This Privacy Policy is also available in other languages. In the event of any conflict between the English version and any translations of this Privacy Policy, the English version shall prevail.