Privacy policy for job applications and unsolicited applications

Who is responsible for your personal data?

Microtron n.v., located at Generaal De Wittelaan 7, 2800 Mechelen, Belgium, coordinates the HR and recruitment activities for Microtron. For vacancies in Belgium, Microtron n.v. is the data controller. For vacancies in the Netherlands, Microtron b.v., located at High Tech Campus 5, 5656 AE Eindhoven, the Netherlands, is the data controller, with Microtron n.v. supporting the HR processing. When both companies jointly determine the purpose and means of processing, for example for a joint candidate pool for future vacancies in Belgium and the Netherlands, they act as joint data controllers.

For questions regarding the processing of your personal data, please contact us via: info@microtron.eu

This privacy statement contains the information we must provide to applicants in accordance with Article 13 of the GDPR. When we do not obtain personal data directly from you, for example because we consult your professional LinkedIn profile in the context of an application, we also inform you about the source and processing of that data in accordance with Article 14 of the GDPR.

Which personal data do we process?

When you apply for a vacancy or submit an unsolicited application, we may process the following personal data, among others:

your first and last name;
your address and contact details, such as phone number and email address;
your CV and cover letter;
your professional LinkedIn profile and other professionally relevant, publicly accessible information that you share with us yourself or to which you refer, or that we consult in the context of your application. When we consult such information ourselves, we limit ourselves to information relevant to the position and inform you accordingly;
information about your work experience, education, qualifications, knowledge, and skills;
information you provide during interviews or other contacts with Microtron;
correspondence regarding your application;
notes and assessments made during the application procedure.

We only process personal data that is relevant and necessary to assess your candidacy. The Belgian Data Protection Authority also emphasizes that only data necessary for the selection of a candidate may be collected. (Data Protection Authority)

We explicitly ask you not to include special categories of personal data in your CV, cover letter, or other application documents. This includes data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as genetic data, biometric data for unique identification, health data, and data concerning sexual behavior or sexual orientation. Microtron does not process such data for recruitment purposes unless it is exceptionally necessary and legally permitted under Article 9 of the GDPR. In that case, you will be informed separately in advance about the applicable legal basis, the purpose, and the safeguards.

What do we use your personal data for?

We use your personal data to:

receive and assess your application or unsolicited candidacy;
check whether your profile matches an existing or suitable position within Microtron;
organize job interviews and any follow-up steps;
communicate with you about your application;
prepare a possible employment contract;
contact you about future vacancies, exclusively with your explicit consent.

On what legal basis do we process your personal data?

During an ongoing application procedure, we process your personal data because it is necessary to take steps, at your request, that may lead to an employment contract. This processing is based on Article 6(1)(b) of the General Data Protection Regulation.

The processing of data necessary to handle your current application is therefore not based on your consent. (EUR-Lex)

If we wish to retain your data after the completion of the application procedure to contact you later about other vacancies, we only do so on the basis of your separate and explicit consent, in accordance with Article 6(1)(a) of the General Data Protection Regulation.

In accordance with Article 13 of the GDPR, you are not legally obliged to provide personal data to us unless a specific legal obligation applies. However, certain data is necessary to assess your candidacy, organize interviews, and communicate with you. If you do not provide this necessary data, we may not be able to process your application or continue the application procedure.

Retention for future vacancies

Data from unsolicited applicants and non-selected candidates is only retained for future vacancies if the candidate has given explicit consent for this.

This consent is completely voluntary. Not giving consent has no negative consequences for the assessment of your current application.

You can withdraw your consent at any time by sending an email to info@microtron.eu. The withdrawal does not affect the lawfulness of the processing that took place before the withdrawal. (EUR-Lex)

How long do we keep your application data?

We retain your personal data for the time necessary to assess and handle your ongoing application or unsolicited candidacy.

If your application does not lead to an employment contract and you have not given consent for retention in the context of future vacancies, we will delete your application data as soon as possible and at the latest four weeks after the application procedure or assessment is definitively completed, unless longer retention is necessary to comply with a legal obligation or to establish, exercise, or substantiate a legal claim.

If you have given explicit consent to retain your data for future vacancies, we will retain this data for a maximum of 12 months from the date you gave that consent.

After this period, we will remove your data from the candidate pool, unless you again give explicit consent for a new retention period of a maximum of 12 months before the end of that term.

If you withdraw your consent earlier, we will remove your data from the candidate database for future vacancies.

Who has access to your personal data?

Your application data is used for recruitment purposes within Microtron in Belgium and the Netherlands, insofar as this is relevant for the vacancy or, if you have given consent, for future vacancies. Because HR is coordinated from Belgium, Microtron n.v. employees can process applications for Dutch vacancies. For Dutch vacancies, the relevant managers of Microtron b.v. may also assess your candidacy.

Access is limited to:

employees responsible for HR and recruitment;
members of management who are directly involved in the assessment of your candidacy or in the relevant position.

Within Microtron, your data is not made accessible to employees who are not involved in the application procedure and is not used for other purposes.

In addition, we work with external service providers and partners who support us in recruitment and job marketing, such as job boards, social media platforms, recruitment and marketing partners, and suppliers of email, IT, hosting, data storage, or recruitment systems. They may process or receive personal data to the extent necessary for their services. When they process on our behalf, we enter into the required data processing agreements and impose appropriate security and confidentiality obligations. When a platform or partner acts as a data controller for certain processing operations, that party’s own privacy policy also applies.

Source of personal data: in most cases, we receive your personal data directly from you. In addition, we may obtain professionally relevant data from publicly accessible professional sources, such as LinkedIn, or via an external recruitment or job marketing partner when you respond to a vacancy through that partner.

Your privacy rights

You have the right to:

ask which personal data we process about you;
receive a copy of your personal data;
have incorrect or incomplete data corrected;
have your personal data deleted when there is no longer a valid legal basis for it;
have the processing of your data restricted in certain cases;
have your data transferred in certain cases;
withdraw your consent for retention for future vacancies at any time.

You can submit a request via info@microtron.eu.

To prevent personal data from being provided to the wrong person, we may ask you for additional information that allows us to reasonably verify your identity. We will handle your request within the legal timeframe. The GDPR provides, in principle, for a response within one month. (EUR-Lex)

Filing a complaint

If you believe that Microtron is not processing your personal data correctly, we request that you first contact us via info@microtron.eu. This allows us to investigate your question or complaint and resolve it where possible.

You also have the right to file a complaint with the competent data protection authority. For processing by Microtron n.v., you can contact the Belgian Data Protection Authority, among others. For processing by Microtron b.v., you can contact the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) in the Netherlands. Depending on your place of residence, workplace, or the place where the alleged infringement occurred, you can also file a complaint with another competent European supervisory authority.

No automated decision-making or profiling

Microtron does not use automated decision-making or profiling for applications.

Your application is not assessed solely by a computer program, algorithm, or artificial intelligence. Decisions about your candidacy are made by HR employees and the relevant members of management.