Data privacy statement for the job application process at the Hannover Re Group through SAP SuccessFactors
We are hereby informing you about the processing of your personal data by the Hannover Re Group (Hannover Rück SE and E+S Rückversicherung AG – hereinafter Hannover Re) in Hannover and the rights to which you are entitled under data privacy law.
Hannover Re, with its registered office in Hannover, operates the human capital management system "SAP SuccessFactors Recruiting" worldwide to manage job applications and publish vacant positions for its headquarters in Germany and for its Group companies worldwide.
The human capital management system is used in particular as support for personnel recruitment, i.e. to fill vacant positions within the Hannover Re Group – both in Germany and around the world – with suitable candidates.
1. Who is responsible for data processing and data privacy?
a. Responsible for data processing in Germany
Hannover Rück SE
Candidate & Employee Relations
Karl-Wiechert-Allee 50
30625 Hannover
Germany
Tel. +49 511 5604-0
Fax +49 511 5601-1618
E-mail: personnel@hannover-re.com
b. Responsible for data privacy in Germany
Hannover Rück SE
- Data Protection Officer -
Karl-Wiechert-Allee 50
30625 Hannover
Germany
Tel. +49 511 5604-0
Fax +49 511 5601-1618
E-mail: datenschutz@hannover-re.com
2. What categories of data do we use and where do they come from?
The categories of personal data processed by us include, in particular, your master data (e.g. name or citizenship), contact information (e.g. address, phone number or e-mail address) and the data from the entire application process (in particular curriculum vitae, references, questionnaires/interviews, details of your qualifications and previous employment). We do not require special categories of personal data (such as health-related data, religious affiliation, degree of any disability) to process your application. We use these data solely if you have provided them to us voluntarily as part of the application process and usage is justified by your consent or a legal basis granting permission. In the event of a face-to-face job interview, we also record your data in the context of video surveillance at certain premises, such as the entrance to the main building, at the barriers or the parking garage entry/exit.
Generally speaking, your personal data are collected directly from you as part of the recruitment process. In addition, we may have received data from third parties (e.g. recruitment agencies) which you provided with your data for forwarding.
3. For what purposes and on what legal bases are your data processed?
We process your personal data in conformity with the provisions of the EU General Data Protection Regulation (GDPR), the Federal Data Protection Act (BDSG) and all other relevant legislation (e.g. Works Constitution Act, General Equal Treatment Act and, as applicable, other local legal requirements in connection with an application for a position in the international arena).
Data processing principally serves the implementation and management of the recruitment process and the evaluation of suitability for the vacancy in question. Processing of your application data is necessary in order to be able to decide on establishment of an employment relationship. The primary legal basis for this is Art. 6 (1) b) GDPR in conjunction with § 26 (1) BDSG.
In sub-areas we use as a basis consent that is provided separately by you pursuant to Art. 6 (1) a), 7 GDPR and § 26 (2) BDSG (e.g. in order to use your application documents additionally for other vacant positions in the Hannover Re Group, potentially also worldwide). Where such consent is given, you have the right to withdraw it any time with effect for the future.
The Hannover Re Group is a globally positioned group in which other persons – along with a disciplinary supervisor (hiring manager) – are necessarily involved in the application process due to their role, e.g. recruiters, Employee Council and the Representative Body for Disabled Employees.
In the context of individual job interviews, members of staff who do not belong to the aforementioned groups may also be selectively involved in the application process at this point in time, if this is necessary for evaluation of the applicant. We base this forwarding of your data on legitimate interests of the Group (Art. 6 (1) f) GDPR).
Any processing of special categories of personal data is based on the permission elements in § 22 (1) No. 1 b) BDSG and § 26 (3) and (4) BDSG, insofar as we have not separately obtained your consent (Art. 9 (2) a) GDPR, § 26 (2) BDSG) for this.
In addition, we process your data in order to fulfil our legal obligations as a potential employer, e.g. due to supervisory requirements or in connection with crosschecking your data against sanction lists in order to satisfy legal provisions governing the fight against terrorism (e.g. EU Regulation 2580/2001). This takes place on the basis of Art. 6 (1) c) GDPR and § 26 BDSG respectively.
Furthermore, we also use your data for statistical purposes (e.g. analyses of surfing/navigation on our webpages). Statistics are compiled solely for our own purposes and the results of such analyses are in no way personalised but are rather anonymised. For further information please see: https://www.hannover-re.com/182774/data-privacy
Should we wish to process your personal data for a purpose not specified above, we shall inform you in advance of this within the scope of legal provisions.
4. Who receives your data?
Your application data are treated confidentially at all times. Within our company your personal data are provided only to persons and offices (e.g. Human Resources Department, Requesting Department, Works Council, Representative for Disabled Employees) requiring them for the hiring decision and to fulfil our (pre-)contractual and legal obligations.
If we are unable to offer you a vacant position in the context of an application that you have submitted, but take the view that – based on your skills profile – your application could potentially be interesting for a position that becomes vacant within our corporate group in the future, we shall – depending on whether you consent to it being visible and discoverable – consider your application profile for the relevant application process and get in touch with you to arrange an interview.
Insofar as the vacant position is at one of our company's locations in another country, your data may also be passed on to supervisors at other entities of our global group. The job description in question specifies the country in which the vacant position is to be filled within our corporate group.
Our platform for online applications is operated by the external service provider SAP, which in turn makes use of other IT service providers.
In addition, we may transfer your personal data to other recipients outside the company insofar as this is necessary to establish the employment relationship (e.g. Chamber of Industry and Commerce as well as Institute for Professional Apprenticeship for the German Insurance Industry) or if this is necessary for smooth operation of the process. This may occur, for example, for purposes of system maintenance or server provisioning.
In this context the data are processed solely by contractually bound service providers. Personal data are passed on for a specific purpose in the context of commissioned data processing in accordance with the relevant data privacy provisions. Such vacant positions are located in Germany / the European Union and are subject to German law / European Union law. You can enquire about the contractors and service providers deployed by us by writing to our human resources department at the address specified in Item 1 with the additional line – Recruiting Advisor Team – or in the case of applications for positions at international Group companies by contacting the locally responsible HR departments.
Consultants such as tax advisers, independent auditors or attorneys who support us in the fulfilment of our legal obligations or in the safeguarding of our legal or economic interests may also receive access to your data only to the extent necessary.
5. How are your identification data handled?
When you access the SAP SuccessFactors Recruiting potentially identifying data and other particulars may be stored. Hannover Re shall treat this information as strictly confidential and reserves the right to use such information solely for statistical purposes. Hannover Re's application and job portals do not contain any ActiveX elements. Cookies are used solely for interactive functionalities, including for example in connection with the Applicant’s Portal or activation of the "Job Subscription" notification service. All other cookies are deleted automatically when the browser is closed. Personal data are always transferred using SSL (Secure Socket Layer) encryption.
Hannover Re does not guarantee the permanent availability of the SAP SuccessFactors Recruiting.
Further conditions for use of the Hannover Re website are contained in the disclaimer.
6. How do we transfer data to non-EU countries (third countries)?
If we transfer personal data to service providers or Group companies outside the European Economic Area (EEA), this is done only if the third country in question has been confirmed by the European Commission as having an appropriate level of data protection or if other appropriate data protection guarantees (e.g. mandatory internal company data protection regulations or EU standard contractual clauses (SCC)) are in place. Detailed information in this regard and about the level of data protection at our international Group companies as well as at our service providers in third countries can be requested using the aforementioned contact information.
7. How long are your data stored?
We erase your personal application data six months automatically after the conclusion of an ongoing application process, i.e. after receipt of a rejection, discontinuation of the application process or contract offer. This does not apply if legal provisions prevent erasure or further storage is necessary for evidentiary purposes or if you have consented to longer storage. The legal basis for this retention is Art. 6 (1) letter f) GDPR, Art. 17 (3) letter e) GDPR.
If you do not delete your personal account in the Hannover Re application portal, your personal data will remain stored in your application profile for 6 months from the last change or activity, provided your application status is not active. This means that you can use it for further applications to Hannover Re. If you neither change your data nor apply for another position at Hannover Re within these 6 months and your application status is not active, your application profile will be automatically deleted after this period in addition to your personal account in the portal. In this case, only anonymised data will remain on the portal.
The legal basis for this retention is Art. 6 para. 1 lit. f) DSGVO, Art. 17 para. 3 lit. e) DSGVO.
Invoices for any travel expense reimbursements are archived in accordance with commercial and tax law requirements. As a rule, they are stored for 10 years (§ 257 HGB, § 147 AO).
If you receive a positive answer, the data are transferred to your personnel file and are subject to the relevant retention periods.
8. What data privacy rights can you assert as a data subject?
a. Request for information
You can request information about the data stored on your person by writing to the aforementioned address.
b. Rectification of data
If you believe that your personal data are incorrect or incomplete, you can request corresponding rectification of these data or make such rectification yourself through the SAP SuccessFactors Recruiting.
c. Erasure of data
Under certain conditions set out in Article 17 GDPR you can request the erasure of your data or erase them yourself through the SAP SuccessFactors Recruiting insofar as this is permissible under applicable law.
Data that relates or can be related to a specific person are normally automatically erased six months after conclusion of the application process through an appointment or rejection. Anonymised basic data continues to be kept for marketing purposes. This encompasses the place of residence, the salutation (if provided), the connection to the advertisement and the application history. These data cannot be used to make inferences about a person or personal information.
You may have a right to restrict the processing of your data as well as a right to have the data that you made available provided to you in a structured, commonly used and machine-readable format.
d. Right to object:
If we process your data to protect legitimate (Group) interests, you may register your objection to this processing at the aforementioned address if there are reasons associated with your particular situation that oppose such data processing.
We shall then discontinue this processing unless it serves overriding compelling legitimate interests on our part or the assertion, exercise or defence of legal claims.
9. Would you like to complain about the handling of your data?
You have recourse to our Data Protection Officer (contact details as above) or a data protection supervisory authority. The responsible data protection supervisory authority for Hannover Re based in Germany is:
Die Landesbeauftragte für den Datenschutz Niedersachsen (Data Protection Commissioner for Lower Saxony)
Prinzenstrasse 5
30159 Hannover
Germany
Phone: +49 (0511) 120 45 00
Fax: +49 (0511) 120 45 99
E-mail: poststelle@lfd.niedersachsen.de
10. Are you obliged to provide your data?
As part of your application you must provide the personal data necessary to conduct the application process and assess aptitude. Without these data we will be unable to conduct the application process or reach a decision on the establishment of an employment relationship.
Status of this information: January 2023
In case of relevant changes to this information we shall update you again as necessary.