Recruiting Privacy Notice
EU, EEA, Switzerland and UK
Effective Date: August, 2020
As part of its recruitment activities, Leggett & Platt, Incorporated and its EU, EEA (European Economic Area), Switzerland and the United Kingdom based companies (collectively referred to as the Company, “Leggett & Platt”, “we”, “us” or “our”) collects and processes your personal information (i.e. data which can be linked/attributed to an individual person, “Personal Data”). The privacy and protection of your Personal Data is of great importance to us.
This Recruiting Privacy Notice informs you as a candidate about why and how we process your Personal Data during and after your job application in accordance with the high standards of applicable data protection laws and regulations. This includes information on whom we will share your Personal Data with, how long we will retain it and which rights you have in relation to the processing.
Who is responsible for the processing of your Personal Data?
The Company is the responsible data controller, that means it is the entity collecting your Personal Data and deciding why and how to process your Personal Data.
If more than one Leggett & Platt company is responsible for the processing of your Personal Data, the respective Privacy Contact Person will forward your query to the relevant Leggett & Platt Group company that is primarily responsible. Typically, this will be the Leggett & Platt Group company you applied to directly. We kindly ask you to address any queries you may have directly to the contact details as set out in Section 10.
What Personal Data do we collect?
We collect the following types of your Personal Data in connection with your application:
- Personal information (e.g. your surname, first name, address, date of birth, gender, telephone number, email address and picture)
- Education-related information (e.g. your educational history, relevant skills and degrees)
- Job-related information (e.g. your employment history and relevant experience)
- Information in relation to legal issues (e.g. your work or residence permit)
As a matter of practice, we will not collect any sensitive Personal Data about you (for example data concerning health, racial or ethnic origin or political opinions). If there is a need for us to process such sensitive Personal Data for purposes of the recruitment process with you (for example where we would need to know about any disabilities to provide a suitable workplace environment), we will only process such sensitive Personal Data in strict compliance with applicable data protection laws and regulations.
Generally, we will collect the above mentioned Personal Data directly from you (for example, when you provided this information as part of your application letter, your CV or during an interview). In certain scenarios, we will also obtain your Personal Data from other sources such as references supplied by former employers, information from employment background check providers where legally applicable or public information. If so, we will do this in strict compliance with applicable data protection laws and regulations.
For which purposes do we collect process your Personal Data?
We collect and process your Personal Data for the following purposes:
- To create and maintain your personal recruiting file, and to manage and assess your application (for example, to evaluate and confirm your suitability for the position you have applied for);
- To document, analyse and improve our recruitment process (for example, by keeping recruitment statistics);
- To meet legal obligations (for example, financial and administrative obligations or checking your eligibility to work);
- Internal or external investigations where it is necessary to assess, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or our assets;
- To establish, enforce or defend against legal claims;
Who has access to your Personal Data?
To manage your recruiting process, we will share your Personal Data internally with members of the HR department, interviewers involved in the recruitment process and managers in departments with a vacancy, and in each case only if access to your Personal Data is necessary for the performance of their roles.
In addition, and only when necessary to fulfil the purposes mentioned above, we will disclose your Personal Data to the following recipients or categories of recipients, as the case may be:
- Third party agents, service providers and advisers (for example in connection with IT services, compliance vetting, background checks, medical examinations, payments, legal advice or postal services);
- Law enforcement, government authorities or courts where necessary to comply with applicable laws;
We will not disclose your Personal Data to any parties who are not authorised to process them.
On which legal basis do we process your Personal Data?
We use the following legal basis for the processing of your Personal Data:
- Your consent, where required under applicable data protection laws and regulations; in such a case, we will separately ask for your consent;
- Where the processing is necessary for us to decide about whether to establish an employment relationship with you;
- Compliance with legal obligations to which we are subject (for example, where we are legally obliged to check your work and residence permit);
- For some roles, we are obliged to seek information about criminal convictions and offences. Where this is the case, we will only do so because it is necessary for us to carry out our obligations and exercise specific rights in relation to employment; and
- Where the processing is necessary for our legitimate interests (such as to protect us from harm by preventing or detecting illegal activities, to establish, exercise or defend against legal claims, or to analyse and improve our recruitment processes), unless we determine in a case-by-case assessment that our interests are overridden by your interests or fundamental rights and freedoms.
Where will my Personal Data be processed?
Your Personal Data may be processed both inside and outside the European Union (“EU”) and the European Economic Area (“EEA”) by the Leggett & Platt Group.
Please note that EU / EEA Member States and other countries all have different laws regarding the protection of personal data. When your personal data is transferred from your own country to another country, the laws and rules that protect your personal data in the country to which your information is transferred to may be different (or less protective) from those in your country of residence. For example, the circumstances in which law enforcement can access personal data may vary from country to country.
If you are resident of the EU or EEA and your Personal Data is transferred outside the EU or EEA, we will ensure that the recipient of the Personal Data provides for an adequate level of data protection, in particular, by implementing appropriate safeguards such as the EU Standard Contractual Clauses.
How do we protect your Personal Data?
The Company maintains appropriate technical and organizational security measures designed to protect your Personal Data against accidental, unlawful or unauthorised destruction, loss, alteration, access, disclosure or use. All our employees and contractual partners are bound by confidentiality and may only process your Personal Data based on the "need-to-know" principle.
How long do we keep your Personal Data?
We will not retain your Personal Data longer than necessary to fulfil the purposes the data was collected for or to fulfil our legal obligations. Afterwards, we will delete your Personal Data.
If your application for employment is unsuccessful, we will retain your Personal Data on file for up to 6 months after you have been notified of our decision for legitimate interest purposes (e.g. to prove compliance with law if needed). If your application for employment is successful, your Personal Data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. If your application is unsuccessful and we wish to keep your Personal Data to match future job offerings, we will explicitly ask for your consent to retain your data for a period longer than 6 months.
What are your rights in respect of your Personal Data?
To the extent permitted by applicable data protection laws and regulations, you have the following rights in relation to your Personal Data:
- Request the update or correction of your Personal Data so that it is always accurate;
- Obtain your Personal Data in an electronic format;
- Request the deletion of your Personal Data if it is no longer needed for the purposes indicated above;
- Restrict the processing of your Personal Data in certain circumstances, for example, where you have contested the accuracy of your Personal Data, for the period enabling us to verify its accuracy;
- Withdraw your consent at any time where your Personal Data is processed with your consent, without affecting the lawfulness of processing based on consent before its withdrawal.
In the event and to the extent that we process your Personal Data based on our legitimate interests as set out in Section 5, you have the right to object to the processing on specific grounds relating to your particular situation. In such case we will no longer process your Personal Data unless we have compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
You may exercise above mentioned rights by sending a request to the recruiting contact or to contact set out in Section 10 below and providing your name, the Leggett & Platt company you made an application to, your email address and a description of your request.
If you believe we have not complied with our obligations under applicable data protection laws and regulations, you have the right to lodge a complaint with a competent data protection authority.
How can you contact us?
If you have any queries about this Recruiting Privacy Notice or how we use your Personal Data, please contact our Privacy and Data protection team via firstname.lastname@example.org.
You may also write the Company at:
L&P Automotive Europe Headquarters GmbH
Attn: Data Protection Officer
Leggett & Platt, Incorporated
Attn: Associate General Counsel – Privacy & Data Protection
No. 1 Leggett Road
Carthage, Missouri 64836