Recruitment Privacy Statement
Effective July 27th, 2021
Nokia Corporation, including its affiliates, is committed to respecting your privacy and complying with applicable data privacy laws.
This Recruitment Privacy Statement (“Statement”) describes how we collect and use personal data about you during Nokia’s recruitment activities where Nokia is the data controller, and what rights you have in relation to such data. Personal data means information about you or another identifiable individual.
We may provide you additional privacy information that are specific to certain areas of Nokia’s recruitment activities in Supplements to this Statement and in other notices you may see. If there is a difference between such notices and this Statement, the notices should be considered first.
You are not required to provide the personal data to Nokia. If you choose not to provide your personal data to Nokia, we may not be able to continue the recruitment process with you or to respond to queries you have. The latter does not apply to the section within the recruitment process that relates to a voluntary inclusion and diversity questionnaire – this questionnaire is at all times voluntary and your decision to complete it will not affect the overall recruitment process.
1. What Personal Data does Nokia collect and process?
Nokia collects personal data directly from you as well as from other available sources to the extent relevant and permitted by applicable law. Subject to applicable law and practice, the categories of personal data that are collected and processed in the recruitment context include:
- When you create an account in our recruitment management system or otherwise interact with us (either directly or through an agency or other third party), we may ask for information such as your name, street address, telephone number, email address, photo or video image, competences, qualifications, skills, work experience, education, and references, as well as user names and passwords for logging in our recruitment management system. We may also maintain records of your consents, preferences and setting in relation to, for example, job locations, compensation, types of positions and preferred ways to be contacted by Nokia.
- During the recruitment process, we will also ask you to provide (on a voluntary basis) gender identity and other diversity and/or inclusion monitoring information to allow us to undertake diversity and/or inclusion monitoring within our business. It is not mandatory to provide this information and you are free to decline to share it with us by selecting the ‘prefer not to say’ (or similar opt-out wording) on the applicable form (rather than selecting the relevant gender, i.e. male, female or non-binary (or analogous choice) and continue with your application. A failure to tick a relevant gender box will be assumed to be a ‘prefer not to say’ selection.
In any case, this information is used solely and exclusively for statistical purposes and will not be used in any way for recruitment or selection decisions. If you do provide this information, it will then be processed in accordance with this policy on the lawful bases identified below. Gender identity and other information provided to us in this manner will be anonymized wherever practicable and required by applicable law.
- Other information, such as information found from public sources as well as information related to vetting process (background or credit checks...), depending on the position for which you are applying, in the cases required or enabled according to Nokia Global Vetting SOP.
2. What will Nokia do with your Personal Data?
Nokia may process your personal data for the following purposes. One or more purposes may apply simultaneously.
- Communicating with you: We may use your personal data in our recruitment and resourcing activities to communicate with you, for example, to obtain additional information, to inform you about the status of your application or of available vacancies.
- Recruitment and resourcing activities: We may use your personal data to set up and conduct interviews and assessments with you and to evaluate you for the position you have applied for or for other open vacancies. We may use your personal data to conduct a vetting process and assessments as required or permitted by applicable local law as well as to communicate with third parties such as references concerning your skills, experiences, qualifications, work history and education.
- Development of services: We may use your personal data to perform data analytics, including analysis of our applicant pool in order to better understand who is applying to positions at Nokia and how to enhance Inclusion and Diversity and to develop and improve our recruitment and resourcing processes, websites and other related services. Where feasible, we use aggregated anonymous information in the development activities.
- Legal and regulatory compliance: We may use your personal data as required by law, regulation, judicial organizations or practice to comply with legal obligations imposed on us.
3. What is the legal basis for processing your Personal Data?
Nokia processes your personal data with your consent or as necessary to take steps to recruit you to a position you have applied or to complete any other transaction you have requested or authorized.
Nokia also processes your personal data on the basis of Nokia’s legitimate interests of ensuring that it recruits the appropriate employees and that it continually improves its recruitment processes. Where Nokia processes gender identity and any other diversity and/or inclusion monitoring information about you, we will do so:
- to comply with our legal obligations in this area (e.g. where required to carry out gender pay gap reporting or to provide a safe and healthy working environment, for instance, in relation to adjusting working conditions for those who are pregnant); or
- where not required to comply with legal obligations, for our legitimate interests to (on balance) ensure equality of treatment and ensure diversity and inclusion in our organization.
We may also process your person data to protect other applicants; to maintain the security of our recruitment related activities, systems, websites and services; and to protect the rights and property of Nokia.
4. Does Nokia share your Personal Data?
Nokia will not sell, lease, rent or otherwise disclose your personal data unless otherwise stated below.
- Consent: Nokia may share your personal data if you have given your consent for Nokia to do so.
- Nokia companies and authorized third parties: Nokia may share your personal data with other Nokia companies or authorized third parties who process personal data for Nokia for the purposes described in this Statement. Nokia authorized third parties may include, for example, recruitment agencies, professional advisors, external legal counsel, consumer credit reporting agencies, recruiting systems providers, and other third-party suppliers. These Nokia authorized third parties are not permitted to use your personal data for any other purposes. We require them to act consistently with this Statement and to use appropriate security measures to protect your personal data.
- If you were addressed to Nokia by RealLinks, we will let RealLinks know the status of your application with us. We will share the following information with them : your name, your email address, requisition number, application status.
- International transfers of personal data: Our recruitment and resourcing activities may make use of resources and servers located in various countries around the world. This means that your personal data may be transferred outside the country to where you are applying to as an applicant, including to countries outside the European Economic Area (EEA). Such other countries do not always have laws providing specific protection for personal data or they have different rules on privacy and data protection. In such cases we use measures to provide adequate protection for your personal data as required by applicable law, for example, by using standard agreements approved by relevant authorities (e.g. the European Commission) and by requiring the use of appropriate technical and organizational information security measures. Any other, non-EEA originating, international transfers of your personal data, will take place in accordance with the appropriate international data transfer mechanisms and safeguards.
- Mandatory disclosures: Nokia may be obligated by law to disclose your personal data to certain authorities or other third parties, for example, to government agencies responsible for employment activities or statistical information or to the police or other law enforcement agencies, for example in context of conducting a vetting process or diversity and/or inclusion monitoring. Nokia may also disclose and use your personal data in accordance with applicable law to defend Nokia’s legitimate interests, for example, in civil or criminal legal proceedings.
- Mergers and acquisitions: Where Nokia decides to sell, buy, merge or otherwise reorganize its businesses in certain countries, this may involve disclosing personal data to prospective or actual purchasers and their advisers.
5. What steps are taken to safeguard Personal Data?
Privacy and security are key considerations for Nokia. We have assigned specific responsibilities to address privacy and security related matters. We enforce our internal policies and guidelines through an appropriate selection of activities, including proactive and reactive risk management, security and privacy engineering, training and assessments. We take appropriate steps to address online security, physical security, risk of data loss and other such risks taking into consideration the risk represented by the processing and the nature of the data being protected. Also, we limit access to our data bases containing personal data to authorized persons having a justified need to access such information.
6. Data quality
We take reasonable steps to keep the personal data we possess accurate and to delete incorrect or unnecessary personal data. We will only retain your personal data for as long as necessary to fulfill the purposes outlined in this Statement or otherwise communicated to you, unless a longer period is required by law.
7. Data retention
We may delete your account and your image and video from our recruitment management system within 3 years from the end of the year during which you have last accessed it, updated it or applied for a position at Nokia. Where we have a legitimate interest to do so we may retain data for longer than 3 years.
If you are hired by Nokia, Nokia will retain your personal data for longer periods, in accordance with legal and regulatory requirements. As some countries have different timeframes for how long data must be retained, retention periods may vary to comply with local law.
8. Your rights
You have the following rights regarding personal data that Nokia processes about you:
- Access: You have a right to know what personal data we hold about you and to obtain a copy.
- Data portability: Subject to law, you have a right to obtain in machine readable format the personal data you have provided to Nokia.
- Rectification and erasure: You have a right to have incomplete, incorrect, unnecessary or outdated personal data about you updated or deleted.
- Withdraw your consent: You have a right to withdraw your consent for Nokia to process your personal data.
- Object: You have a right to request that we stop processing your personal data on grounds relating to your situation.
You may exercise your rights by managing your account and profile in our recruitment management system or, if that is not possible, by contacting us. Especially if you withdraw your consent or wish us to delete or stop processing your personal data, we may not be able to continue the recruitment process with you.
If you are not satisfied with what we provide when you exercise your rights, you can let us know by contacting us. If you are still dissatisfied, you also have the right to lodge a complaint with a relevant supervisory authority.
9. Who Is the controller of your Personal Data?
Nokia Corporation of Karaportti 3, 02610 Espoo, Finland is the controller of your personal data. You may contact us also by using contact information provided in the applicable Nokia websites.
In matters pertaining to Nokia’s privacy practices you may also contact us or our Group Data Protection Officer at:
P.O Box 226
FI-00045 NOKIA GROUP
10. Changes to This Statement
Nokia may change this Statement at any time with or without notice. However, if this Statement is changed in a material, adverse way, Nokia will post a notice advising of such change at the beginning of this Statement and in the recruitment management system for 30 days. We recommend that you re-visit this Statement from time to time to learn of any such changes to this Statement.
I have read the Nokia Recruitment Privacy Statement and I hereby grant my consent to Nokia processing my personal data in accordance with that Nokia Recruitment Privacy statement. I have the right to withdraw my consent at any time by contacting Nokia here.