Global Data Privacy Notice for Recruitment
Updated: 30.04.2026
1. Introduction
We respect the privacy rights of individuals and are committed to handling Personal Data responsibly and in accordance with applicable law. It is important that you read this entire Notice carefully as it sets out how the Orbia group of companies handles your Personal Data when you apply for a job or other role with us and the rights you have in connection with that information. For example, when we contact you for job opportunities or when you apply for a job offered by us, use our recruitment channels, visit our job applicant websites, join our recruitment events, or otherwise interact with us in your capacity as candidate or job applicant. The term "applicants" is used in this Notice to refer to anyone who applies for a job role or who otherwise seeks to carry out work with or for us (whether on a permanent or non-permanent basis).
When this Notice mentions “Orbia,” “we,” or “us,” it refers to the controller of your Personal Data under this Notice, namely the Orbia group company, which may be interested in offering you a position or which otherwise decides which of your Data are collected and how they are used.
If you are in any doubt or have any comments or questions about this Notice, please contact us using the contact details set out in Section 8 below.
2. Types of Personal Data we collect when you apply
Information that we collect automatically
You can visit the recruitment section of our corporate websites and search for jobs without providing Personal Data. You can also apply for a job through our job applicant website https://careers.orbia.com
All of these websites collect certain information automatically from your device when you visit our Website. For further information, please see the privacy notice that applies to the use of our corporate websites or our job applicant website.
Personal Data collected from you
The types of Personal Data we collect and process that we only use for the internal recruitment process when you apply for a role with us, may include (but is not limited to):
- Identification data and contact details – including your name (and, in some countries, your mother's maiden name), address, email address, phone number and other contact information, gender, date and place of birth, nationality/ies, national identifiers (such as national ID/passport, social security number(s)).
- Employment history – such as previous employers and job titles/positions.
- Background information – such as academic/professional qualifications, job qualifications, education, details included in your CV/résumé (which might include details of any memberships or interests constituting sensitive Personal Data), transcripts, and employment references.
- Details of any nominated professional references (including their name, contact details, employer, and job role).
- Details of your immigration/visa status.
- Previous applications/roles (information relating to previous applications you have made to the Orbia group and/or any previous employment history with the Orbia group).
- Salary expectations – your desired compensation or salary range.
- Notice period – information regarding your current contractual notice period.
- Other information you voluntarily provide throughout the process, including through assessment centers/exercises and interviews.
As a general rule, during the recruitment process, we intend not to collect or process any of the following: information that reveals your racial or ethnic origin, religious, political or philosophical beliefs, or trade union membership; genetic data; biometric data for the purposes of unique identification; or information concerning your health/sex life ("Sensitive Personal Data"), unless authorized by law or where necessary to comply with applicable laws.
However, in some circumstances, we may need to collect, or request on a voluntary disclosure basis, some Sensitive Personal Data for legitimate recruitment-related purposes: for example, information about your racial/ethnic origin, gender, and disabilities for the purposes of equal opportunities monitoring, to comply with anti-discrimination laws, for government reporting obligations (where allowed or required by law); or information about your physical or mental condition to consider accommodations for the recruitment process and/or subsequent job role. We ask you not to provide other Sensitive Personal Data during the recruitment process. We do not collect or request Sensitive Personal Data where it is not allowed by law.
Personal Data collected from other sources
In some circumstances, we collect Personal Data from other sources such as:
- Information provided by professional references.
- Other background information provided or confirmed by academic institutions and training or certification providers.
- Criminal records data obtained through criminal records checks, where allowed by local law.
- Information provided by background checking agencies and other external database holders (for example credit reference agencies and professional/other sanctions registries), where allowed by local law.
- Information provided by recruitment or executive search agencies.
- Information collected from publicly available sources, including any social media platforms you use or other information available online, where allowed by local law and relevant to the position you have applied for.
In each case, we collect Personal Data only where permissible and in accordance with applicable law.
If you provide us with details of professional references, you confirm that you have informed them in advance that Orbia may contact them, collect and process their Personal Data for recruitment‑related purposes, and that they have been directed to or otherwise informed of this Notice and their data protection rights.
3. Purposes for processing Personal Data
We collect and use this Personal Data primarily for recruitment purposes – in particular, to determine your qualifications for employment and to reach a hiring decision. This includes assessing your skills, qualifications, and background for a particular role, verifying your information, carrying our reference checks or background checks (where applicable), and generally managing the hiring process and communicating with you about it.
If you consent to it, we may also process your Personal Data to consider you for other suitable openings within Our companies.
If you are accepted for a role with Us, the information collected during the recruitment process will form part of your ongoing staff member record and will be processed in accordance with local employee privacy notice applicable in jurisdiction in which you are employed.
If you are not successful, we may still keep your application and information collected during the recruitment process to demonstrate compliance with anti-discrimnation laws and defend against legal claims.
4. Sharing Personal Data
We take reasonable steps to allow access to Personal Data only to those who require such access to perform their tasks and duties and to third parties who have a legitimate purpose for accessing it. We take reasonable measures for the security and confidentiality of the information we disclose to third parties, such as imposing contractual obligations on our vendors.
Transfers to other group companies
We will share your Personal Data within the Orbia group of companies in order to administer our recruitment processes and store data.
Transfers to third party service providers
We may make certain Personal Data available to third parties who provide services relating to the recruitment process to us, including:
- recruitment or executive search agencies involved in your recruitment,
- background checking or other screening providers and relevant local criminal records checking agencies (where allowed by law),
- data storage, shared services and recruitment platform providers, IT developers and support providers, and providers of hosting services in relation to our careers website, e.g. SAP SuccessFactors;
- third parties who provide support and advice including in relation to legal, financial/audit, management consultancy, insurance, health and safety, security and intel and whistleblowing/reporting issues.
We may also disclose Personal Data to third parties on other lawful grounds, including:
- Where you have provided your consent;
- To comply with our legal obligations, including where necessary to abide by law, regulation, or contract, or to respond to a court order or administrative or judicial process, including, but not limited to, a subpoena, government audit, or search warrant;
- In response to lawful requests by public authorities (including for tax, immigration, health and safety, national security, or law enforcement purposes);
- As necessary to establish, exercise, or defend against potential, threatened, or actual legal claims;
- Where necessary to protect your vital interests or those of another person; and/or
- In connection with the sale, assignment, or other transfer of all or part of our business.
In some cases, the sharing described above may result in your Personal Data being transferred internationally, including from the European Economic Area to a country outside it. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).
We have taken appropriate safeguards to require that your Personal Data will remain protected in accordance with this Notice. These include implementing the European Commission’s Standard Contractual Clauses, or other contractual clauses approved by applicable authorities in the context of our intra-company activities and with our third party service providers. You can request access to applicable safeguards by contacting Us.
5. Legal basis for processing Personal Data
Where European data protection law applies, our legal basis for processing your Personal Data as part of the recruitment process is:
- Our legitimate interests summarized above in Section 3, whenever they are not not overridden by your data protection interests or fundamental rights and freedoms, particularly taking into consideration the safeguards that we put in place;
- Our legal obligations to comply with applicable immigration and/or employment laws and regulations;
- Necessity to take steps prior to entering into an employment contract with you, where you are considered for employment;
- Your consent, where we obtained it to process your personal data.
If we ask you to provide Personal Data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data).
If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Data, please contact us using the contact details provided in Section 8 below.
6. Data retention periods
Personal Data will be stored in accordance with applicable laws and kept as long as needed to carry out the purposes described in this Notice or as otherwise required by applicable law. Generally, this means your Personal Data will be retained:
- In case your application was successful: in accordance with the retention periods set out in the local employee privacy notice applicable in jurisdiction in which you become our employee; or
- In case your application was not successful: for 6 months (or, in case of candidates applying for positions in the United States, for 3 years), unless local law requires a longer or shorter period,
- In case you request to consider you for recruitment processes in future – 6 months, or other period indicated in your consent.
7. Your rights
Where local data privacy laws provide, (including, for example if you apply for a role in the European Union or the United Kindom) you may have additional rights, such as:
- Right to access, correct, update, or request deletion of your Personal Data,
- Right to object to processing of your Personal Data, ask us to restrict processing of your Personal Data, or request portability of your Personal Data.
- If we have collected and processed your Personal Data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.
- You have the right to file a complaint to a data protection authority regarding our collection and use of your Personal Data. For more information, please contact your local data protection authority. Contact details for data protection authorities in the European Economic Area, Switzerland, and certain non-European countries are available at:
https://edpb.europa.eu/about-edpb/board/members_en
https://ico.org.uk/make-a-complaint/
https://www.gov.br/anpd/pt-br/canais_atendimento/fale-conosco
https://www.argentina.gob.ar/aaip
In addition, in France specifically, following a person’s death, their heirs or a person designated by the deceased may exercise rights to access, update, obtain communication of, or request the deletion of the deceased person’s Personal Data, and to implement any instructions left by the deceased regarding the retention, deletion, or disclosure of such data, in accordance with French data protection law.
Under certain data protection laws, including without limitation, the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), the California Consumer Privacy Act (“CCPA”), the California Privacy Rights Act (“CPRA”), the Washington My Health My Data Act (“MHMDA”), the Colorado Privacy Act (“CPA”), the Virginia Consumer Data Protection Act (“VCDPA”), and the Minnesota Consumer Data Privacy Act (“MCDPA”), individuals (in this instance, employees and dependents) who reside within the United States are afforded certain data protection rights. The list below explains these to you.
CCPA, CPRA, CPA, VCDPA, MCDPA, and other U.S. consumer data protection laws:
The Right to Know: You have the right to know how your Personal Data is used, disclosed, or managed, including:
• The categories of Personal Information we collect about you;
• The categories, or sources, of the Personal Data we collect about you;
• Orbia’s business, or commercial purpose(s), for collecting your Personal Data;
• The categories of third parties with whom we share your Personal Data;
• The categories of Personal Data that each recipient received; and
• The specific pieces of Personal Data we collect about you
Right to Opt-Out of Sale: Some U.S. residents have the right to opt-out of the sale of their Personal Data by businesses that sell their Personal Data. The CCPA defines a “sale” as the disclosure of Personal Data for monetary or other valuable consideration. Orbia does not sell your Personal Data.
No Sharing of Personal Information for Direct Marketing Purposes: We do not share Personal Data with other people, or non-affiliated businesses, for their direct marketing purposes.
Non-Discrimination: Orbia does not discriminate against any relevant treatment for exercising any of your rights.
California and Delaware “Do-Not-Track” and “opt-out preference signal” disclosures: Where applicable when using a web browser, California and Delaware law may require Orbia to honor your web browser’s opt-out preference signals concerning targeted advertising. Orbia does not sell its employee’s Personal Data. If you access Orbia websites as a user, your Personal Data may be shared in accordance with the website’s privacy disclosures. In such cases, the privacy notice available on specific website shall apply and you may opt out of the sharing of Personal Data for targeted advertising.
Nevada Residents: Although Orbia does not sell Personal Data, Nevada residents have the right to submit a verified request directing Orbia not to sell their Personal Data. If you are a Nevada resident and would like to submit such a request, please contact dataprivacy@orbia.com.
Exercising Your Rights: If you are a U.S. resident and wish to request for us to provide you with your “Right to Know” or “Right to Delete,” please contact dataprivacy@orbia.com.
Authorized Agent: The CCPA permits California residents to use an authorized agent to make privacy rights requests. Orbia will require an authorized agent to provide us with proof of the California resident’s written permission (for example, a power of attorney) that shows the authorized agent has the authority to submit the relevant request. An authorized agent must follow the process described in our privacy notice and this Annex. The authorized agent must also verify his or her own identity. We will confirm the agent’s authority with the relevant California resident related to the request that was made.
Information Exempt from the CCPA: Please note that certain information that is governed under the California Confidentiality of Medical Information Act (“CMIA”), HIPAA, or is subject to the Federal Policy for the Protection of Human Subjects, also known as the “Common Rule,” under good clinical practice guidelines (issued by the International Counsel for Harmonisation) or under human subject protection requirements of the United States Food and Drug Administration (i.e., FDA), is not considered Personal Data with respect to CCPA rights listed above. However, additional rights might be available under those laws and standards.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
You can exercise these rights by contacting us using the contact details provided below.
8. Contact details
Please address any questions or requests relating to this Notice to dataprivacy@orbia.com.
