Data protection notice for recruitment

Cargolux International Airlines S.A., Luxembourg Airport, Luxembourg (hereafter referred to as “Cargolux” or “we”) is committed to the protection of your personal data in accordance with data protection legislation, especially the General Data Protection Regulation EU 2016/679 (the “GDPR”).

This Data Protection Notice for recruitment is intended to inform candidates who apply for a job at Cargolux (“you”) on the processing of their personal data.

Please be informed that the duration, nature and purposes of the processing, as well as the type of personal data collected in the scope of the recruitment process may vary according to the nature of the position to which you are applying to.

1. Who is the controller of your personal data?

Cargolux is responsible as a data controller, for collecting and processing your personal data in relation to your application for a position at Cargolux and our recruitment process.

2. What personal data do we process?

We collect and use your personal data to the extent necessary in relation to our recruitment process and to ensure that your application can be considered by the relevant Cargolux department(s).

We may collect various types of personal data that you decide to or are requested to submit in relation to your application for a particular job position, including:

Identification data: name, date and place of birth, nationality, ID information, driving license information, contact details, address, telephone, email, country, or other contact information);

Job application data: CV, cover letter, previous work experience, education, additional qualification, or other information regarding your professional qualification and experience, additional skills and abilities, professional interest, details of your right to work in the concerned country, type of employment sought, desired salary, job preferences, etc.;

Names and contact details of referees and knowledge of a person among our staff or management (relative or contact person). Prior to providing personal data of any data subjects, you must inform them about the content of this note and ensure that they do not object to the processing of their personal data by Cargolux.

We do not usually require from job applicants to include any special categories of data (racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning sex life or sexual orientation) or any judicial data (e.g. criminal records) as part of the job application documentation. However, such processing may take place in specific circumstances where required to fulfil the obligations and exercise the rights of Cargolux or yours, in accordance with applicable labor law or in the interest of social security and social protection, to the extent that it is authorized or required by law.

We may also collect information about you (your full name, email, work history, and other data included on your profile) from publicly accessible sources, such as LinkedIn.

3. Why we process your personal data (purpose and legal basis)

We collect and use your personal data for the following purposes:

to assess your skills, qualifications and interests against our career opportunities, to maintain our relationship during the recruitment process, including by calling you and inviting you to interviews, exchange of offers and terms of employment, etc

to verify your information, to run our internal compliance and conflict checks and to conduct reference/background checks;

to communicate with you and, if applicable, to inform you of other career opportunities;

for security and protection of our organization, IT networks and CARGOLUX information;

to improve our recruitment process; and

to defend ourselves in any legal or court proceedings.

Cargolux will only process your personal information where we have a legal basis for doing so. In the frame of the recruitment process, we process your personal data on the following basis:

pre-contractual measures necessary to establish a contractual relationship with you,

pursuing our legitimate interests, including to ensure that our company’s IT networks and information are secure, to manage our recruitment process; to keep records of the recruitment process, to prevent conflicts of interests and confidentiality issues and to protect our interest and rights in the event of suspected, investigated or actual violations of applicable law.

4. Who do we share your personal data with?

For the purposes of the recruitment process, your personal data may be shared internally on a strict need to know basis, with members of the Cargolux human resources department, interviewers involved in the recruitment process and management in the business area with a vacancy.

We may also communicate your personal data to:

Service providers (such as recruitment agencies) that perform services on our behalf,

Certain software that enable you to apply and transfer documentation to us

Law enforcement or other government and regulatory bodies or agencies, upon request and to the extent permitted by law.

Certain regulated professionals such as lawyers or auditors.

5. Where do we transfer your personal data?

We may process personal data in view of filling vacancies based outside the EU/EEA, as well as use third party providers to deliver our services and this may involve transfers of your personal data to countries outside of the EU/EEA. In case of international transfers to a country outside the EU/EEA, the transfer may occur where the European Commission has decided that the receiving country ensures an adequate level of data protection. For transfers to countries for which the level of protection has not been recognized as adequate by the European Commission, we will implement appropriate safeguards provided for by data protection law (e.g. entry into standard dat protection clauses) or rely on a derogation applicable to specific situations.

6. How do we protect your personal data?

The processing of your personal data is carried out through IT, electronic and manual tools, with logics strictly related to the aforementioned purposes and, in any event, in compliance with the appropriate technical and organizational measures required by law to ensure a level of security that is adequate to the risk, in order to avoid unauthorized loss or access to your data.

7. How long do we keep your personal data?

Unless applicable laws and regulations provide otherwise, if your job application is unsuccessful, we will retain your personal data for up to 1 year after the end of the relevant recruitment process. At the end of that period, or once you opposed to your personal data being processed, your personal data will be anonymized, deleted or destroyed.
Note that in case you are selected for the job position you have applied for, the above categories of personal data will continue being processed as part of your employment.

8. What are your rights regarding your personal data?

In accordance with the applicable data protection legislation (and subject to conditions and restrictions set forth therein), you may exercise at any time the following rights in relation to your personal data:

Right to access: which enables you to obtain from us confirmation of whether your personal data are being processed or not and, if so, obtain access to such data; considering that we process a large quantity of information, you must specify the information or processing activities to which your request relates;

Right to rectification: which enables you to obtain from us the correction and/or integration of any of your personal data that are incorrect and/or incomplete; and

Right to erasure: which enables you, in specific cases provided for by art. 17 GDPR, to obtain from us the erasure of your personal data;

Right to restriction of processing: which enables you, in specific cases provided for by art. 18 GDPR, to restrict the processing of your personal data by us;

Right to object: which enables you to object to the processing of your personal data in specific cases provided for by art. 21 GDPR;

Right to data portability: which enables you, in certain cases (subject, in particular, to technical feasibility) and with regard only to the data you have provided to us, to request receipt of your personal data in a structured and commonly machine-readable format.

If you have provided your consent to the processing of your personal data, you can withdraw such consent at any time, without affecting the lawfulness of processing based on consent before your withdrawal.

To exercise any of these rights, you may contact us by email dataprotection[@]cargolux.com or by postal mail:

CARGOLUX Airlines International S.A.
Compliance Department
L-2990 Luxembourg Airport
Luxembourg

You have the right to lodge a formal complaint with the Commission Nationale pour la Protection des Données (CNPD).

9. Changes to this data protection notice for recruitment

Changes may occur in the way we process personal data. In case these changes oblige us to update this Data Protection Notice for recruitment, we will clearly communicate it to you, either via our website or via other appropriate means. The latest applicable version will always be available on our website.

Last revised on 03/09/2024