Candidate privacy notice

1. What is the purpose of this recruitment information notice?
2. Data protection principles
3. The kind of information we hold about you
4. How is your personal information collected?
5. How we will use information about you and on which legal bases we rely
6. How we use "sensitive" personal information
7. Data sharing
8. Data security
9. Data retention
10. Rights of access, correction, erasure, and restriction
11. Right to withdraw consent
12. Contact details
13. Country specific deviations

What is the purpose of this recruitment information notice?

This notice explains how Ingredion uses personal information about job applicants.  Ingredion is responsible for deciding how we hold and use personal information about you as a job applicant. You are being provided with this notice because you are applying for work with an Ingredion company (whether as an employee, worker or contractor). This notice applies to applications submitted via Ingredion’s careers website, including via the third-party system named Workday; through other recruitment routes, such as recruitment agencies, job boards and other means, such as by post or email.  This notice is to make you aware of how and why your personal information will be used, namely for the purposes of the recruitment exercise, and how long it will usually be retained for. It provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR) and applicable law of European Union countries and/or the UK, where relevant. The section "Local Country Deviations" below identifies the data controller of your data if you apply for a job with an Ingredion company in the EU/EEA, including the UK. The term "Ingredion", "we" or "us" in this notice therefore refers to your data controller. The section "Local Country Deviations" also specifies where certain information in this notice would not apply to you.

Data protection principles

We will comply with data protection law and principles in relation to your personal information, which means that:

• We will use your personal information lawfully, fairly and in a transparent way.
  
• We will collect your personal information only for valid legitimate business purposes that we have clearly explained to you, and we will not use that recruitment information in any way that is incompatible with those purposes.
• We will use your personal information as is relevant to the purposes we have told you about, and which is limited only to those purposes – i.e. not excessive.
• We will keep your personal information, accurate and up to date.
• We will keep your personal information only for as long as is necessary, for the purposes we have told you about.
• We will keep your personal information secure; we protect it against accidental or unlawful destruction or accidental loss, alteration, unauthorised disclosure or access, using appropriate technical and organisational measures; we process it in accordance with your applicable legal rights.

The kind of information we hold about you

In connection with your application for work with us, we will collect, store, and use the following categories of personal information about you:

• The information you have provided to us in your CV and covering letter or email.
  
• The information you have provided on our application form which will generally tell us who you are and help us decide if you are suitable for certain positions within the organisation.  This type of information may include: your name, title, address, telephone number, personal email address, date of birth, gender, employment history, qualifications, previous employment history, personal interests, information about the type of work and projects you have been involved with, documentation such as work permits, details of residency, and proof of citizenship if necessary to determine your eligibility to work for the Ingredion group, and any other information you may wish to provide to us as part of your application.
• Any information you provide to us, or which is collected during an interview or otherwise, for example information contained in your social media accounts or personal websites or other online accounts (e.g. LinkedIn or Twitter); information on your performance at assessment centres and information provided by your referees (to the extent we are permitted to contact them); performance and behavioural evaluations, in each case, to the extent permitted by applicable law.
• Future or other opportunities information (subject to your consent): This is information collected during your initial application to us and we may retain it in order to keep in touch with you about future or other job opportunities within the Ingredion group and to identify such suitable opportunities for you, this information includes your name, personal email address, location, field of expertise and the kind of role you are interested in; there may be opportunities within the Ingredion group worldwide for which you may be suitable, but which are not in the same country as the role which you have applied for originally, or the country where you live.
• Careers website information: This is information related to your use of Ingredion’s careers website or the website of the third-party service provider which Ingredion uses (eg Workday); for example, your IP address, date and time of website usage, referral pages, type of browser, browser settings. This information may be collected using cookies and similar technology. For more information about how Ingredion uses cookies and similar technologies please see Ingredion’s Website Privacy Notice.
• Screenings against the relevant sanction lists: Information resulting from the screening of your name and other personal details against the relevant sanctions lists, such as a match of your name with a listed person.

In certain countries, we may also collect, store and use the following types of more sensitive personal information, as permitted by applicable law:

•  Information about your race or ethnicity, citizenship, sexual orientation and trade union membership
• Information about your health, including any medical condition, health and sickness records.
• Information about your disability if you disclose such information in your application. 

How is your personal information collected?

We collect personal information about candidates from the following sources:

• You, the candidate (for example when you provide information as part of your application or during the recruitment process);
• The recruitment agency (if applicable for your application), from which we collect the following categories of data: your cv, name, address, date of birth, previous roles, copy of passport (to the extent permitted by local law), reasons for wanting to change roles or work.
•  A country’s immigration authority, from which we collect details of your right to work or live in a particular country;
• Your named referees, from whom we collect reference details such as your previous employer/contractor, details of the role or work carried out by you in the past (e.g. job title) and the dates during which you were employed or carried out that work / project (only to the extent we are permitted to contact your referees and to collect such information from your referees);
• The data from third parties from a publicly accessible source: for example, LinkedIn, or other business or employment-oriented services that operate via websites where you have added information about yourself; publications which you have written/contributed to, and which are publicly available.

How we will use information about you and on which legal bases we rely

To the extent permitted by applicable law, we will use the personal information we collect about you to:

• Assess your skills, qualifications, and suitability for the work or position, including through assessment centres, and generally to process your application, including validation of your information via your references (only to the extent we are permitted to contact your referees and to collect such information from your referees);
• In case of a positive hiring decision, screen  your name against the names listed in the relevant sanction lists in order to comply with relevant local legal requirements, for example to obtain and maintain Authorized Economic Operator certifications (AEO);
• Communicate with you about the recruitment process, including where applicable arranging travel / accommodation / travel cost payments, in respect of the interview process;
• Communicate with relevant Ingredion employees about the recruitment process, and also with the recruitment agency that referred you to us; 
• Keep records related to our hiring processes, and where applicable to further develop or improve any of our recruitment processes, including as to whether our careers website is user-friendly and contains appropriate and helpful information;
• Comply with legal or regulatory requirements, such as compliance with health & safety requirements (if applicable) and other legal or fiscal obligations, or in connection with litigation or an internal investigation or audit, as well as equal opportunities monitoring; security check requirements, such as matching your name against local and/or global sanctions lists as far as legally required;
• Enrichment of our data, including through usage or research of publicly available data to the extent this may be required and permitted for equal treatment/diversity purposes and/or for assessing the effectiveness of our recruitment process;
• Carry out relevant benchmarking, in particular as to the salary and other benefits which you may be offered as part of the role or work;
• Building and ensuring plant security (e.g. through access controls and video monitoring); IT Security.

In cases where we validate your information through your references as part of a "Pre-Employment Check": 

• You will be told in advance which aspects of your personal information will be verified and which references we would contact, including an explanation of how the Pre-Employment Checks will be carried out;
• To the extent required, we will ask for your consent to contact such references and for your permission for the reference to share personal information about you with us; and
• We will not ask the reference to provide information to questions which we are not allowed to ask an applicant (as a matter of law) during the recruiting process. 

We rely on the following legal bases to collect and process your personal data:

(i)  The processing is necessary for hiring decisions and in order to take steps at your request to enter into an employment contract.

(ii)  We have an overriding legitimate interest in processing your data, such as it is in our legitimate interests to decide whether to appoint you to a role or work, since it would be beneficial to our business to appoint someone to that role or work.  

(iii) The processing may be necessary to comply with our legal obligations, including those in the field of employment. 

(iv) At other times, Ingredion will be processing your personal information because you have consented to Ingredion doing so. In which case you can withdraw such consent at any point.

If you fail to provide personal information 

Your personal information is necessary for processing your application and/or for a pre-contractual relationship with us with the exception of the following information which is not necessary: future or other opportunities information. Without your necessary personal information, we are generally not able to continue the job application process or the selection procedure. If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully and continue with the application process. If we request personal information from you, which is more than is necessary as referred to in this notice, we will tell you separately, that this additional information is provided by you on a voluntary basis.  

How we use "sensitive" personal information

To the extent permitted by applicable law, we will use your particularly sensitive personal information in the following ways:

• We will use information about your disability status (if voluntarily disclosed by you) to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview or otherwise.
• We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.
• Details of trade union membership may be processed to ensuring that any relevant rights that you may have in connection with any Trade Union membership are complied with, as required to enable us to meet our obligations under any applicable employment law and to administer any Trade Union subscriptions paid direct from your salary.

Data sharing

Why might you share my personal information with third parties?

We will only share your personal information with the following third parties for the purposes of processing your application: (i) third party services providers acting on our behalf and our instructions (for example Workday, providers assisting with the Pre-Employment Checks, recruitment agencies or providers for analytics and profiling); (ii) other companies within the Ingredion group (for example the Ingredion company offering the position that you are applying for, or Ingredion companies where the responsible HR managers or the hiring manager(s), for your application are located) for all processing purposes identified above; (iii) governmental authorities (local and foreign), courts, law enforcement agencies, external consultants to the extent required or permitted by law. All our third-party service providers and other Ingredion companies are required to take appropriate security measures to protect your personal information. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

Your personal information may be transferred to Ingredion companies  whenever such is necessary to meet a contractual obligation towards you, and/or in order to process your application and manage the recruitment process (e.g. application for a job in another country; or the position involves managing people in another country; or being managed by someone in that country; or the position you are applying for means managers in another country have a need to know about your personal information).  It is in our legitimate interests to decide whether the nature of the role or work, would involve Ingredion offices/people, in other countries. Should future or other opportunities arise in another country for which you are suitable as a candidate, a local Human Resources representative may contact you.

Where is my recruitment information stored?

Note that, your personal information gained during the recruitment process, may be transferred to, processed in and/or stored in countries outside of the country where you live, by an Ingredion company, our service providers or any other recipients identified above.  These countries may have less strict, or no data protection laws. We will take legally required steps to ensure that adequate safeguards are in place to protect your personal information and to make sure it is treated securely and in accordance with this notice. 

Data security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality. Recruiting@ingredion.com can provide you with further information if you need it.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data retention

How long will you use my recruitment information for?

We process and store your personal information for the duration of your application as part of our recruitment process. If you are unsuccessful in your application with us (or if you reject the position), Ingredion will retain your recruitment personal information for no longer than is necessary for the specific recruitment process, and in accordance with our internal retention policies and procedures, and applicable law.  For example, for data subjects who are covered by the GDPR (or equivalent local law in the EU/UK) your personal data is kept for a period of six months after we have communicated to you that your application was not successful, or you have declined the position. We retain your personal information for the relevant retention period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After the relevant period, we will securely destroy your personal information in accordance with our data retention policy, or applicable laws and regulations.

If you are unsuccessful in your application with us (or if you reject the position), but you would like us to retain your personal information on file for longer, on the basis that if another opportunity arises in future, you would like to be considered for that position, please let us know in writing – so that Ingredion or one of our third party service providers, can contact you.  Our policy is to allow the extension of time for up to 12 months. 

Rights of access, correction, erasure, and restriction

Your rights in connection with personal information

Under certain circumstances, by law you may have the right to:

• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal information, or request that we transfer a copy of your personal information to another party, please contact Recruiting@ingredion.com writing.  Any request to exercise one of these rights will be assessed by us on a case by case basis. There may be circumstances in which Ingredion is not legally required to comply with your request or because of relevant legal exemptions provided for in applicable data protection legislation.

As referred to above, you may have the right in certain circumstances, to file an objection at any time against the processing of your personal information. If you file an objection, we may not be able to continue to process your personal information – but in some cases we will still be able to: for example, if our use of your personal information outweighs your interests or the processing serves the purpose of asserting, exercising or defending legal claims.  You can, of course, withdraw your application at any time.

We will not use your personal information gained through the recruitment process, to carry out any direct advertising.

Right to withdraw consent

In some circumstances, where you have applied for a role or work, you may have provided consent to us, to enable the processing your personal information for the purposes of the recruitment exercise. You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact Recruiting@ingredion.com. Once we have received notification that you have withdrawn your consent, we will no longer process your personal information and, subject to our retention policy, we will dispose of your personal information securely. Note that in some cases, this may affect our ability to continue to process your application.

Contact details

If you have any questions about this privacy notice or how we handle your personal information, please contact Recruiting@ingredion.com.

If there is an error in your application (including an personal information which you have provided to us); or you would like to access the information it contains in a different format; or you want to extend the time for which Ingredion will hold your personal information if you are not hired for a particular position or work; or you believe your privacy rights have been violated; or you want to exercise any other rights you have under applicable data privacy laws, please contact us at: Recruiting@ingredion.com.

Country specific deviations

If you apply for a job at an Ingredion company in the EU/EEA, including UK:

The listing below identifies the Ingredion company that is the data controller of your personal data and to which the notice refers when using the term "we" or "us":

GERMANY

Country for which you apply for a job: Germany 

Ingredion company acting as your data controller: Ingredion Germany GmbH

Contact details of the Ingredion entity acting as your data controller

Contact: HR Manager Germany, Compensation, Benefits & HRIS EMEA
Address: Ingredion Germany GmbH
Gruener Deich 110
20097 Hamburg
Germany

Phone number: +49 40 239150

Contact Details of the DPO (if applicable)

HEC Harald Eul Consulting GmbH, Data Protection Officer of Ingredion Germany GmbH, Auf der Höhe 34, 50321 Brühl, Germany,

Email: DSB-Ingredion-Germany@he-c.de

UNITED KINGDOM

Country for which you apply for a job: UK

Ingredion company acting as your data controller

Ingredion UK Limited

Contact details of the Ingredion entity acting as your data controller

Contact: HR Manager, UK and Emerging Markets
Address: Ingredion UK Limited
Ingredion House
Manchester Green Business Park
339 Styal Road
Manchester, M22 5LW
United Kingdom

Phone number: +44 161 435 3200

OTHER COUNTRIES IN EUROPE

Country for which you apply for a job: Other countries in Europe

Ingredion company acting as your data controller

Unless otherwise indicated in any hiring documentation: Ingredion Germany GmbH

Contact details of the Ingredion entity acting as your data controller

Contact: HR Manager Germany, Compensation, Benefits & HRIS EMEA
Address: Ingredion Germany GmbH
Gruener Deich 110
20097 Hamburg
Germany

Phone number: +49 40 239150

Contact Details of the DPO (if applicable)

(if applicable) HEC Harald Eul Consulting GmbH, Data Protection Officer of Ingredion Germany GmbH, Auf der Höhe 34, 50321 Brühl, Germany,

Email address: DSB-Ingredion-Germany@he-c.de

If we collect data about you from social media accounts and websites, we will limit this to your professional life, professional social media accounts and websites relating to your professional experience.

We do not collect the following sensitive information about you in the context of the recruiting process:

• Information about your race or ethnicity, citizenship, sexual orientation, and trade union membership
• Information about your health, including any medical condition, health and sickness records.

The recipients of your personal information may be located in countries outside of the EU/EEA, including the UK, and Ingredion will take the appropriate safeguards as required by the GDPR. In particular:

•  Your personal information may be transferred to Ingredion companies and other recipients, such as service providers, which are located in countries outside the EU/EEA, in which case Ingredion will take the necessary measures to protect the personal information: For recipients located outside the EU/EEA, some are certified under the EU-U.S. Privacy Shield and others are located in countries with adequacy decisions pursuant to Art. 45 GDPR, and, in each case, the transfer is thereby recognized as providing an adequate level of data protection from a European data protection law perspective.
• Other recipients are located in countries which do not adduce an adequate level of protection from an EU/EEA or UK data protection law perspective. We will take all necessary measures to ensure that transfers out of the EU/EEA or UK, as the case may be, are adequately protected as required by applicable data protection law.
  For example, we will base the transfer on appropriate safeguards, such as standard data protection clauses adopted by the European Commission or by a supervisory authority (Art. 46(2)(c) or (d) GDPR), approved codes of conduct together with binding and enforceable commitments of the recipient (Art. 46 (2)(e) GDPR), or approved certification mechanisms together with binding and enforceable commitments of the recipient (Art. 46 (2)(f) GDPR). You can ask for a copy of such appropriate safeguards by contacting us at Recruiting@ingredion.com.

Depending on the data protection law applicable to you, you may have the right to make a complaint at any time to the relevant supervisory authority for data protection issues.  For example, in the UK this is the Information Commissioner’s Office (ICO) (https://ico.org.uk/make-a-complaint/ ).