The data controller is:
“MODUL” EOOD
UIC: 103846775
Registered office and management address: Aksakovo, Chanlaka locality, Property ID 00182.45.47
“MODUL” EOOD has appointed a Person Responsible for Personal Data Protection.
For matters relating to the processing and protection of personal data and the exercise of rights, applicants may contact the Person Responsible for Personal Data Protection at:
Email: signal@topmobility.eu
Correspondence address: 269 Tsar Osvoboditel Blvd., Floor 3, Varna
This document applies to natural persons who apply for a vacant position or otherwise participate in a recruitment and selection procedure at “MODUL” EOOD.
Where an applicant is hired, the personal data necessary for the establishment and performance of the employment relationship is processed in accordance with the separate “Information on the Processing of Personal Data of Workers and Employees of ‘MODUL’ EOOD”.
The specific scope of the data processed depends on the position and the manner in which the selection procedure is conducted. “MODUL” EOOD may process the following categories of personal data:
• names;
• telephone number and email address;
• address or place of residence, where provided and relevant to the application;
• other identification and contact data voluntarily included by the applicant in their documents.
• education and educational degrees obtained;
• professional qualifications and specialisations;
• professional experience, previous positions and employers;
• language, technical and other professional skills;
• certificates, qualifications, professional licences and other qualification documents where relevant to the position.
• curriculum vitae;
• cover letter, where provided;
• documents relating to education, qualifications and professional experience, where necessary;
• references or details of referees, where provided by the applicant;
• other information provided by the applicant in connection with the application.
• the position for which the person is applying;
• the date and result of an interview or another stage of the selection process;
• internal notes and assessment of professional suitability, to the extent relevant and necessary;
• results from practical assignments or professional tests where these form part of the specific procedure;
• correspondence relating to interview scheduling, feedback and other actions in the selection process.
Where provided or discussed as part of the selection process, data may be processed concerning the preferred position, place of work, availability to start work, expectations regarding employment conditions and other relevant information necessary for the assessment of the specific application.
“MODUL” EOOD does not request or process special categories of personal data or data concerning criminal convictions and offences as a standard part of every selection procedure.
Such data is processed only where this is necessary for the specific position, permitted or required by applicable legislation, and where the relevant legal bases and safeguards are in place.
In most cases, we obtain personal data directly from the applicant through a submitted application, documents provided, an interview, correspondence or other contact within the selection procedure.
Where the applicant has provided a referee, we may also obtain relevant professional information from that person.
Where data has been obtained from another lawful source, the applicant is provided with the applicable information regarding the processing within the time limits provided for by law, unless a statutory exception applies.
We process personal data in order to receive the application, assess whether the applicant meets the requirements for the specific position and organise their participation in the selection procedure.
Legal basis: Article 6(1)(b) GDPR – taking steps at the request of the applicant prior to the possible conclusion of an employment contract.
The data is processed for organising and conducting interviews, professional assignments and other applicable stages of the selection process, comparing applications and making a decision regarding the specific vacant position.
Legal basis: Article 6(1)(b) GDPR – taking steps at the request of the applicant prior to the possible conclusion of an employment contract.
We use contact details to schedule an interview, provide information about the procedure, request additional relevant documents or information and inform the applicant about the progress of the selection process.
Legal basis: Article 6(1)(b) GDPR.
Where, for a specific position or stage of the procedure, the law requires a check, document or other processing of personal data, the Company processes the necessary data in order to comply with the relevant statutory obligation.
Legal basis: Article 6(1)(c) GDPR – compliance with a legal obligation.
Following the final completion of the procedure, a limited amount of relevant personal data may be retained for the applicable period for the purpose of demonstrating the actions taken during the selection process and establishing, exercising or defending legal claims.
Legal basis: Article 6(1)(f) GDPR – the Company’s legitimate interest in documenting the lawful conduct of the procedure and protecting its rights in the event of a potential dispute.
Where “MODUL” EOOD wishes to retain an application after the expiry of the period applicable to the specific procedure in order to contact the applicant regarding suitable future vacancies, this is done only on the basis of separately provided consent.
Legal basis: Article 6(1)(a) GDPR – consent.
Consent is voluntary and may be withdrawn at any time. Refusal to provide such consent does not affect participation in the current selection procedure.
The provision of data necessary to identify the applicant, establish contact and assess their compliance with the requirements for the position is necessary for participation in the respective selection procedure.
If the applicant does not provide the necessary information, it may not be possible to review the application or complete the relevant stage of the procedure.
The applicant should not provide data that is not relevant to their professional suitability or that has not been requested for a lawful purpose.
Within “MODUL” EOOD, access to applicants’ personal data is provided only to persons for whom such access is necessary in connection with the specific selection procedure, including employees performing human resources management functions, managers and other persons involved in the assessment and the decision on hiring.
Outside the Company, personal data may be disclosed to competent state, administrative or judicial authorities where required by law, as well as to other recipients only where a specific legal basis exists and the disclosure is necessary for the respective lawful purpose.
“MODUL” EOOD applies the principle that personal data should not be retained for longer than necessary for the purposes for which it was collected.
| Category of data/documents | Retention period | Starting point |
|---|---|---|
| CV, cover letter and other documents provided or collected for the specific selection procedure | Up to 6 months | From the final completion of the selection procedure, respectively after expiry of the applicable appeal periods |
| Notes, assessments and other information created during the specific procedure | Up to 6 months | From the final completion of the selection procedure |
| Originals or notarised copies of documents requested from an unsuccessful applicant | Returned within 6 months, unless special legislation provides otherwise | From the final completion of the selection procedure |
| Application retained for future vacancies | For the period specified when consent is provided, or until its earlier withdrawal | From the provision of consent |
| Data of a successful applicant necessary for the employment relationship | In accordance with the retention periods applicable to workers and employees | From the commencement of the employment relationship |
After expiry of the applicable period, documents and data for which there is no other legal basis for retention are erased or destroyed.
Where a specific dispute or proceeding has arisen before expiry of the retention period, only the relevant data may continue to be processed where there is a separate legal basis and for the period necessary for the relevant proceeding or the defence of legal claims.
Subject to the conditions and limitations of applicable legislation, applicants have the right:
• of access – to obtain information as to whether their personal data is being processed and the applicable information regarding the processing;
• to rectification – to request correction of inaccurate personal data and completion of incomplete personal data;
• to erasure – where the statutory conditions are met and there is no other basis for continuing the processing;
• to restriction of processing – in the cases provided for by law;
• to data portability – where the statutory conditions are met;
• to object – where the processing is based on legitimate interests;
• to withdraw consent – where the specific processing is based on consent, without affecting the lawfulness of processing carried out before the withdrawal;
• to lodge a complaint and seek judicial remedy – with the Commission for Personal Data Protection and before the courts under the conditions of applicable legislation.
The rights are not absolute and are exercised where the relevant statutory conditions are met. For example, a request for erasure may not be granted in respect of data that is necessary for compliance with a legal obligation or for the establishment, exercise or defence of legal claims.
A request relating to personal data may be submitted to “MODUL” EOOD or to the Person Responsible for Personal Data Protection. Use of a specific form is not mandatory.
Where there are reasonable doubts concerning the identity of the applicant making the request, the Company may request additional information necessary to confirm their identity.
Information on the action taken is provided without undue delay and, as a rule, within one month of receipt of the request. Where necessary, the period may be extended by up to two additional months, with the applicant being informed of the extension and the reasons for it within the initial one-month period.
The applicant has the right to lodge a complaint with the Commission for Personal Data Protection if they consider that their personal data is being processed in breach of applicable legislation, as well as to seek judicial remedy in accordance with the procedure provided for by law.
“MODUL” EOOD applies appropriate technical and organisational measures to protect applicants’ personal data against unauthorised access, disclosure, alteration, loss or destruction.
Access to applications and information from selection procedures is provided only to persons who need such access for the performance of their official duties and participation in the specific procedure.
This information is reviewed and updated where necessary, including in the event of changes to applicable legislation, the organisation of selection procedures, the purposes and legal bases for processing, the categories of personal data, recipients or retention periods.
Where a material change is made, affected applicants are informed in an appropriate manner.