DATA PROTECTION NOTICE
Last Updated: April 2020
Coca-Cola Beverages Philippines, Inc. (“CCBPI”, "us" or "we") which seeks to fill a position for which you have applied and which would be the employing entity in case you were offered employment, will, as a rule, be the controller within the meaning of the Data Privacy Act of 2012, responsible for the processing of your personal data described in this Recruitment Notice.
We are committed to protecting the privacy of anyone who applies for employment with us.
We set out below information regarding our collection, analysis, disclosure and other processing of your personal data during the recruitment process with us. If you are offered and accept employment with us, we will collect more information about you and make other uses of your information – this will be explained to you as part of the onboarding process and be addressed by a separate notice.,
Nothing in this Data Protection Notice (the "Notice") shall be construed as an offer of employment or other contract with CCBPI.
I. Which personal data do we collect and process for the purposes of the recruitment process?
The following categories of personal data are collected and processed in connection with your application:
- Personal data as required to identify and contact you during the recruitment process: name (given and family name), contact details (e-mail address and mobile number), (free text); City and country of residence (drop down);
- Eligibility to work in the Philippines where the job is located (by confirming through a yes or no answer);
- Preferred work location (drop down) and whether you are willing to relocate (confirm through a yes or no answer);
- What is your highest level of education completed (options from drop-down menu); education: degree, if applicable (free text);
- Position Title (free text);
- Current job level, years of relevant experience (drop down);
- Areas of significant work experience (multiple selection from list)
- Work environments, industry, size of current organization, if applicable (drop down);
- How you heard about us and where did you learn about the opportunity (drop down)
- Other information about yourself that you provided in your uploaded CV.
To the extent you decide to disclose the following information in a potential job interview, we will also process the respective items of personal data for the purposes of the recruitment process:
- Whether you have any relatives and/or friends employed at The Coca- Cola Company (options yes/no; if yes, you are asked to provide the names of your friends or relatives);
- Whether you currently work for The Coca-Cola Company as a contract employee or an employee of a subsidiary, Bottling partner or affiliate of the Company;
- Whether you have ever worked for The Coca-Cola Company or any of its subsidiaries or Bottling partners (if you have been previously employed, you are asked to list dates and locations).
- Other information that you provide upon request around your expected employment benefit package, including (base) salary, short term incentive, long term incentive, options, car allowance, expense allowances, pension schemes, healthcare benefits and other employment benefits;
- Further information you may decide to disclose, such as interests, your interest in the role or working at Coca-Cola, how you currently work and collaborate with others, development areas, etc.;
- Functional/technical and personal skills, experiences and performance relevant for the aspired position, career aspirations and plans as disclosed through an online assessment/exam;
- Information as observed by interviewers in any such interview and/or those disclosed through an online assessment/exam (i.e. Psych Exam), such as communication style, tone, engagement, personality traits (curiosity, creativity, etc.), team working, collaboration, leadership skills, and management skills to the extent apparent from the interview and relevant to your recruitment.
- Information as collected by your interview panel and compiled into a Interview Feedback Form including technical capabilities, personality traits (curiosity, creativity, etc.), confidence to hire and leadership capability (where relevant) to assist the talent selection process.
- If the job grade of the position for which you’ve applied requires it, information as collected during an online assessment/exam as well as a business-related simulation. These simulations will be modeled after the types of decisions and responses that may occur in the job which you’ve applied for.
- Contact details of references, pursuant to law, legitimate and practiced. In this case, you will be provided with further information.
If you qualify for cash reimbursement, we may also ask you to provide:
- Official receipt/s and your bank account details for the purpose of reimbursement.
We ask that you do not provide:
- your gender (this information may, however, nevertheless become apparent from your name or otherwise (e.g. in an interview));
- a photograph of yourself;
- any sensitive personal data (see section III below for a description of what is considered sensitive personal data).
If CVs or similar correspondence containing personal data are sent to us on an unsolicited basis it is our policy to delete the respective records once the recruitment cycle for the/such a position has been completed, or your application has been rejected and the time limits for potential anti-discrimination or other employment- related claims under local law following such a rejection have lapsed or earlier if shorter periods are required by our CCBPI Record and Data Retention Policy, or, in case your application is successful, to retain personal data as long as is required in line with the CCBPI Record and Data Retention Policy.
II. For which purposes do we process your personal data and on which legal bases?
We process your personal data to attain the following purposes and on the following legal bases:
Except in those cases where we indicate expressly that the provision of information is purely voluntary you should assume that we process it for the purposes of the recruitment process, and that failure to supply the personal data required may mean that we are unable to consider your application for recruitment.
Specifically, we require the data items listed in section I 1 for the purpose of contacting you during the recruitment process (legal basis: legitimate interest to recruit) and those in section I 2-4; for the purpose of making a decision on the establishment of an employment relationship (legal basis: legitimate interest to recruit and to adequately source our organization).
We require the data items listed in section I 5 for the purpose of efficiently carrying out our recruitment process through the platform and those listed in section I 6 for the purpose of improving our recruitment process (legal basis: legitimate interest to efficiently manage our operation).
If you do not provide the personal data items listed in section I 1-10 above, we will not be able to consider your application for the job(s) you apply. In cases where employment has not yet commenced, failure to provide information requested and not expressly referenced as voluntary may lead to the withdrawal of an offer of employment/engagement.
We require the data items listed in section I 11-13 for reasons of compliance with our internal policies on impartiality in the selection process (legal basis: our legitimate interests to protect our reputation and that of CCBPI and to follow consistent Compliance standards and policies on the selection of candidates).
We require information listed in section I 7-10;14; 16-18 this will help us better assess your qualifications for the role, and to assess which additional skills would have to be acquired on the job if you were chosen for the role, and we will process the respective information for the purposes of the recruitment process (legal basis: our legitimate interest to acquire suitable talent for positions and to effectively manage our recruitment process, and to make an informed decision on your recruitment). If you decide not to provide the personal data items listed in section I 7-10;14; 16-18 = (18: where locally applicable) we may not be fully aware of and take into account your skills for the purposes of the recruitment process, which may negatively impact on your chances of recruitment for a position.
Information provided pursuant to section I 7-10, 14, 15,16,17 may furthermore be processed to assess the suitable type of employment contract and contract features, salary and benefits range and salary and benefits negotiations during the onboarding phase based on legitimate interests (legal basis: legitimate interest to efficiently manage our operation and to recruit and to adequately source our organization).
We require the information collected and compiled pursuant to section I 18 above to assist with our talent selection process. After you are interviewed, the interviewer(s) are invited to complete an Interview Feedback Form. The results are turned into an Interview Feedback Form which provides us with feedback on how to evaluate what the interviewer heard from you about your skills, experience and behavior. The Interview Feedback Form is used for debriefing conversations. (legal basis: legitimate interest to efficiently manage our operation and to recruit and to adequately source our organization).
The information required in section I 19 above is addressed to assist with our talent selection process. You will be asked to complete an online assessment, which allows us to understand your cognitive ability, competency and values that allows you to have a clear understanding of the development actions that can be taken to progress your career. The online assessment is managed by a third party (Talegent)who will give you 95 minutes to accomplish and interpret the results, which will be summarized in a report automatically generated by the tool. Prior to accessing the simulation, you will be sent login information. If you start the assessment and decide you don’t want to continue, you can stop at any point and no data will be processed. You can also ask for your data to be deleted at any time using the options set out below. (legal basis: consent).
We require the information under section I 21 above if you request reimbursement for expenses where a right to such reimbursement exists (legal basis: compliance with legal obligations).
We will not, as part of our decision-making on whether to offer you employment, consider your gender or photograph (I 22; 232). Where a photograph is provided on an unsolicited basis, we will not take this photograph into account for the purposes of your application and will retain it only in line with the CCBPI Record and Data Retention Policy.
We furthermore process your personal data as provided by you during the recruitment process for the following legitimate interests:
- Monitoring our recruitment processes, including for statistical and survey purposes in order for us to e.g. gain insight in the effectiveness of the recruitment process, the duration of the process, number of applicants etc. (legal basis: legitimate interest to efficiently manage our operation and the recruitment process);
- Managing and improving the recruiting process of internal and external candidates, including reviewing and posting job requisitions; scheduling of interviews etc. (legal basis: legitimate interest to efficiently manage our operation and continuously improving the recruitment process);
- Accounting, tax and finance and operational management for the purposes of and beyond statutory obligations for material business and financial interests of us or those of CCBPI, including us, e.g. personnel cost and strategic succession planning (legal basis: legitimate interest to efficiently manage our business, costs and the recruitment process, apply consistent, standard accounting, tax and financial process management);
- Safeguarding interests of the CCBPI, including us, in- or outside of court, such as in case of potential claims of applicants (legal basis: legitimate interest to assert and defend our legal interests and those of the CCBPI in- and outside of courts);
- Ensuring the functioning, efficiency and integrity of the CCBPI Group's, including our, IT systems (legal basis: legitimate interest to efficiently manage our operation and to protect the functioning and integrity of our IT systems); and
- Ensuring the security of the premises and protecting our property and that of the CCBPI (which may concern you when you come in for an interview, for example, such as open CCTV surveillance of entrance areas; log-ging of access to secured doors with visitor access badge) (legal basis: legitimate interest to ensure the safety of our employees and premises, protect our property).
As a general rule, the Company does not rely on your consent to justify its processing of your personal data. If we do need your consent in any particular case we will ask you for it – you are not obliged to consent and, if you do consent, you can withdraw it at any time.
III. Which sensitive personal data do we collect and process and on which legal bases?
We will not ask you for any sensitive personal information within the meaning of the Data Privacy Act of 2012 during the recruitment process. Sensitive personal data is data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health or data concerning your sexual orientation.
If, however, you have made any such sensitive personal data manifestly public to us (e.g. by including in your CV or cover letter that you have a (severe) disability – which we ask you not to do), the respective sensitive personal data will be retained and erased in accordance with our CCBPI Record and Data Retention Policy.
IV. Where do we collect your personal data from?
We mainly collect personal data directly from you during recruitment (e.g., in the form that you are asked to complete during the recruitment process, or in interviews.
Other information is generated automatically when you use or otherwise interact with our IT systems (for example, when you log into our recruitment portal to submit your application).
Further information may be provided to us by third parties (for example, recruitment agencies, referees or educational institutions you have pointed out to us for this purpose (subject to local law).
V. How long do we store your personal data?
The personal data processed for the purposes described in the Recruitment Notice will be retained in accordance with the CCBPI Record and Data Retention Policy.
Therefore, we will generally retain your personal and, if applicable (see section III above), sensitive personal data throughout the recruitment cycle. Some information will be retained after the recruitment cycle ends, either because local tax or other laws require us to do so, because you are employed or otherwise engaged by us or, to defend in an employment/recruitment-related dispute.
VI. Who has access to your personal data?
- The prospective employer As the prospective employer, your personal data will be processed by the prospective employer's HR function for the purposes described in sections II and III, and, where required for the purposes listed in section II, also by your prospective line manager, indirect managers, the prospective employer's legal department (e.g. to the extent required in an employment/recruitment-related dispute).
- Other third parties processing your personal data on behalf of the prospective employer Outside CCBPI, the following categories of recipients will have access to all or parts of your personal data, limited to and subject to the purpose of the processing activities they are engaged for the prospective employer for the legitimate interests listed below:
- Recruitment agencies working with us in relation to your recruitment (legal basis for processing: legitimate interest to recruit and to efficiently manage the recruitment process; legal basis for international transfer: see section VII below);
- AppVault LLC, provides the recruitment platform for the applicant tracking system, talent community and recruitment marketing. With AppVault, your data is received, used and stored on a secure server and encrypt information using secure socket layer technology (SSL).
- Talegent LP, provides online assessment solution by psychometric science, data analytics, and technology for predicting human performance, with office at Auckland, 1143, New Zealand.
- Other service providers, such as Info-Vision Research Systems, Inc., which support the recruitment process for verification of your personal data for the purposes of the recruitment process as set out in this Notice, with office address at Trafalgar Plaza, #105 H.V. Dela Costa Street Salcedo Village, Makati City, Metro Manila, Philippines (legal basis for processing; our legitimate interest to efficiently run the recruitment process);
If you choose to join our talent community, AppVault will retain your information after the period of your registration to consider you for other current or future jobs at CCBPI and if applicable, to receive newsletters, employer branding campaigns and updates about CCBPI.
For more information you may read AppVault's Terms of Service here or Privacy Statement here. AppVault's office is located at 5565 Glenrdige Connector Suite 1000 Atlanta, GA 30342 U.S.A.,
To obtain any relevant information regarding any transfers of your Personal Data (including the relevant transfer mechanisms), please contact firstname.lastname@example.org.
VII. Rights and Questions
- What are your rights?
- the right to obtain confirmation as to whether or not your personal data are being processed and, where this is the case, access to the personal data and information
- the right to rectification of your personal data
- the right to obtain the erasure of your personal data
- the right to obtain restriction of processing
- the right to data portability
- the right to object to the processing of your personal data necessary for the purposes of legitimate interests or of a task carried out in the public interest or in the exercise of official authority vested in the controller
- How can you exercise those rights?
- Whom can you contact about this Notice?
- How can you contact the Data Protection Officer?
- Can you make complaints with the data privacy authority?
Subject to the relevant legislative provisions, you have the following rights:
To exercise these rights, please contact email@example.com for further contact information.
To see copies of any of the agreements referred to in section VI or address other questions about our processing of your personal data or related policies, please contact firstname.lastname@example.org.
You can contact the Data Protection Officer (DPO) at the following address:
COCA-COLA BEVERAGES PHILIPPINES,INC.
Six/NEO BUILDING, BONIFACIO GLOBAL CITY
TAGUIG CITY, METRO MANILA, PHILIPPINES
Yes, you also have the right, at any time, to lodge a complaint with the National Privacy Commission, if you are of the opinion that any of your personal data is processed in a manner constituting an infringement of theData Privacy Act of 2012.
- The references to data "relating to you" or "about you" or "your personal data" include references to data about third parties such as your spouse and children (if any) which you provide to us on their behalf (e.g., in your CV (where we encourage you not to provide any such information) or interview if you decide to disclose any such information, which is voluntary and without bearing on whether we consider your application).
- "CCBPI" means Coca-Cola Beverages Philippines Inc. with office at 27th floor, Six/NEO Bldg. 5th Avenue corner 26th Street Bonifacio Global, Taguig 1630, Philippines.
IX. Updates to this Recruitment Notice
You can find out when the Recruitment Notice was last amended by checking "Last revised" at the top of this document.
END OF PRIVACY NOTICE
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SUBMISSIONS AND CREATIONS
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On-Site Submissions and Off-Site Submissions shall, collectively, be referred to herein as “Submissions”; On-Site Creations and Off-Site Creations shall, collectively, be referred to herein as “Creations.”
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DISPUTE RESOLUTION TERMS
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- You may email us at: email@example.com
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