Privacy Policy statement for job applicants

Last updated October 2023.

This Privacy Notice (“Policy”) will provide you with information on the data processing activities of Sanoma Corporation, and its affiliates and subsidiaries (“Sanoma”, "we", "us" or "our"). The data controller of your personal data is the entity you are applying to or - in case of global roles - entities of the Sanoma group acting as joint-controllers (you can find the list of companies in annex 1 to this Policy).

Sanoma holds your privacy as a candidate in high regard. Sanoma is responsible for ensuring that your personal data is processed in compliance with this Policy and applicable data protection laws. 

This Policy informs you why and how Sanoma collects, uses or shares your personal data in connection with your job application and the recruitment process within Sanoma.

1.     COLLECTION OF PERSONAL DATA 

This Policy applies to all employment candidates of Sanoma Group. The Sanoma entity you are applying to will process your personal data as data controller through different means.  We obtain the following categories of personal data directly from and about you as candidate. We may also collect personal data from other sources, such as recruiting consultants and public authorities. If we collect personal data from other sources than yourself, we will only do so within the limits of applicable laws and will ask for your consent for collecting information from elsewhere if this is required by applicable laws.

We collect personal data concerning applicants that is necessary to manage the job application and the recruitment process, such as

  • basic personal data, e.g. name, home address, email address, and phone number;
  • information contained in your job application, e.g. information about your education, previous work experience, qualifications, language skills, and references;
  • information collected and processed during the recruitment process, e.g. information about the progress of the recruitment process, notes concerning your application and possible interviews, information concerning possible aptitude tests;
  • information required to be entered into a job contract.

2.     PURPOSE AND LEGAL BASIS FOR PROCESSING PERSONAL DATA

We process personal data for the purpose of managing the recruiting process and any other actions related thereto, such as: 

  • setting up an electronic job applicant HR file;
  • managing your application;
  • conducting assessments;
  • organizing interviews,
  • including arranging or reimbursing for your travel as well as providing accommodations, where needed;
  • processing interview feedback;
  • and conducting background checks and screening, where permitted.

By submitting your application via our website, by e-mail, by post or by any other means, you accept the processing of your personal data to the extent necessary to manage your application. 

Sanoma has a legitimate interest in responding to the requests or queries you submit to us through the means available for this purpose. We understand that the processing of this data is also beneficial to you insofar as it allows us to serve you properly and resolve the queries raised.

Also, we may ask you if you would like us to retain your profile and personal data for future opportunities. You may revoke your consent at any time by clicking in “Deletion Section” or by contacting our local HR department or Sanoma’s Data Protection Officer (privacyteam@sanoma.com). 

3.     TRANSFERS AND DISCLOSURES OF PERSONAL DATA 

Your personal data will only be shared within Sanoma and its affiliated companies where lawful to do so and for legitimate purposes. For this purpose, the entities of the Sanoma Group have entered into a data processing agreement in accordance with the applicable data protection regulation. We may disclose personal data to the following third parties for purposes, always strictly related to the management and execution of your recruitment process:

  • We may process your personal data within or between the legal entities belonging to  Sanoma Corporation, as the parent legal entity of Sanoma Group. This data disclosure is necessary for the purposes mentioned above, as various senior executive managers and HR functions are located here; also for the provision of shared services, for example, for application-processing and onboarding support, travel-expense management, IT support and maintenance). These transfers can be done under a Controller-to-Controller or Controller-to-Processor structure. In either case, all required legal requirements are complied with. 
  • If your application is unsuccessful and you have given us consent to retain your data, we will also share your personal data with recruiters within the Sanoma group.   
  • In addition, we use third parties for recruitment-support services (e.g., work agencies, Workday, Michael Page, etc.).  In providing such services, these third parties process your personal data on our behalf. For any third party that we use, we will confirm that they provide sufficient guarantees regarding the protection of your data. We will require that any third party complies with our data security standards and international transfer restrictions. 

4.     TRANSFERS OF PERSONAL DATA OUTSIDE THE EU/EEA 

We aim to primarily process your personal data in the EU. However for some processing purposes we may transfer your personal data outside the EU or the European Economic Area (EEA). In such cases we ensure that legal requirements regarding the Processing of Personal Data outside the EU/EEA countries are complied with. In practice this means that, among other requirements, we have executed the appropriate EU Model Clauses with suppliers and that the relevant transfer assessments have been carried out.

5.     SECURITY 

We maintain reasonable security measures (including physical, electronic, and administrative) to protect personal data from loss, destruction, misuse, and unauthorized access or disclosure. 

6.     RETENTION OF PERSONAL DATA 

If your application for employment is successful your personal data will be in accordance with the Employment Privacy Statement.

If your application for employment is not successful and you have not provided consent, we will generally keep your personal data until the end of the recruitment process. We will subsequently keep them duly stored and protected for as long as liabilities arising from the processing may arise, in compliance with the regulations in force at any given time. Once the possible actions in each case are prescribed, we will proceed to the deletion of the personal data.

If your application for employment is not successful and you have provided consent, we will keep your data for up to one year for the purpose of considering and contacting you for future job opportunities. Right after that will keep blocked such data for a limited period of time for potential use in legal proceedings, as mentioned above.

7.     YOUR RIGHTS 

You have a right to access personal data we process about you. You may access, correct, update, change or remove your personal data at any time. However, please note that certain information is strictly necessary in order to fulfil the purposes defined in this Privacy Statement and may also be required by law. Thus, you may not remove such personal data. 

You have a right to object to certain processing, especially when the legal basis is legitimate interest. To the extent required by applicable data protection law, you have a right to restrict data processing. 

You have a right to data portability, i.e. right to receive your personal data in a structured, commonly used machine-readable format and transmit your personal data to another data controller, to the extent required by applicable law.  

Please send above-mentioned requests to us by contacting the local HR department.  

If you think there is a problem with the way we are handling your personal data, you have a right to file in a complaint to your national data protection authority in the EU/EEA.  Among others:

8.     CHANGES TO THIS PRIVACY POLICY STATEMENT 

We may change this Privacy Policy Statement from time to time. If we make any changes to this Privacy Policy Statement, we will properly inform you about it and you may also find the latest version of this Privacy Policy Statement on the Sanoma career site at any time.

9.     CONTACT US 

If you have any questions regarding this Privacy Policy Statement or the personal data we process about you, please contact the local HR department or Sanoma’s Data Protection Officer (privacyteam@sanoma.com).  

Annex 1 – List of entities

Sanoma Learning B.V.

Sanoma Pro Oy

Sanoma Oyj

Sanoma Utbildning AB

Itslearning AS 

Itslearning AB

Itslearning A/S

Itslearning B.V.

Itslearning France SA

Itslearning GmbH

Itslearning Ltd.

Sanoma Educación, S.L.U. 

Ediciones Obradoiro S.L.

Ediciones Voramar, S.A.

Grup Promotor D’Ensentament I Difusió En Catalan S.L

Ítaca, S.L. 

Zubia Editorial S.L.U

Nowa Era Sp. z.o.o. 

Vulcan Sp. z.o.o

Clickart, taller de communicacio, S.L.

Iddink Digital B.V.

Iddink Gropu B.V.

Iddink Learning Materials B.V.

Iddink Spain Srl

The implementation Group B.V.

Bureau voor Interculturele Evaluatie B.V.

L.C.G. Malmberg B.V.

Uitgeverij Essener B.V.