Policy for applicants

Date of last change: 25 July 2022

Part 1. Introduction

AREGA Pharma BV, company number 0722.544.585, with registered office at Laarstraat 16, B, 2610 WILRIJK (hereinafter ‘Arega’, ‘we’, ‘us’) undertakes, as processing manager, to comply with applicable legislation on the protection of personal data including but not limited to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (‘GDPR’), and any other applicable national legislation implementing it (‘Applicable Privacy Legislation’).

This Privacy policy for Arega job applicants (hereinafter ‘Privacy policy’) explains how we process your personal data when you (hereinafter ‘applicant’, ‘you’ or ‘your’) apply for a position at Arega, what your rights are and how you can exercise them. If you still have questions after reading this Privacy Policy, please contact us using the contact details in Part 7 below.

For the purposes of this Privacy Policy, terms such as ‘personal data’, ‘processing’, ‘processor’ and ‘processing manager’ have the meaning ascribed to them stipulated in the Applicable Privacy Legislation.

Part 2. Outline of the processing of personal data of job applicants

An outline of the processing of your personal data as an applicant is provided below to make it as clear and understandable as possible for you:

Selection and recruitment

Finality	Selection and recruitment: selecting and assessing the suitability of applicants for a position at Arega	Legal basis Justified Arega interest
Involved parties	Applicants seeking a position at Arega
Personal details	Personal identification data (as stated on application): – name, job title, private address, communication address, phone number (landline and mobile); – personal email address; – contact person in case of emergency Personal characteristics (as stated on application): – age, gender, date and place of birth, civil status, nationality; Education and training (as stated on application): – academic curriculum: overview of schools, institutions, universities attended, content of courses taken, degrees obtained or ongoing, exam results, other degrees obtained, assessment of progress made in studies; – professional skills: certificates and professional training, special licences (driver, etc.); – professional experience: professional interests, research interests, academic interests, specialisation in undergraduate studies, teaching experience; – membership of professional organisations: association details, committees or commissions participated in, roles taken, interests and participation record; – publications: books, articles, reports, published audiovisual materials; Hobbies, leisure activities, interests and memberships in the context of selection and recruitment. Career: previous jobs and experiences at other employers, periods without work
Receivers	Employer staff in charge of HR administration.
Retention period	In principle, your personal data will be deleted or anonymised if you are not engaged for a position at Arega However, your personal data will be kept for one year after the application when you are not engaged in a position at Arega, provided you give your consent to the retention for the purpose of contacting you for any future recruitment opportunities.
Transfer of personal data to third countries or international organisations (outside the EEA)	No

Entering into an employment contract (if applicable)

Finality	Entering into an employment contract	Legal basis Necessity for performance of contract
Involved parties	Applicants recruited as employees at Arega
Personal details	Personal identification data (as stated on application): – name, job title, private address, communication address, phone number (landline and mobile); – personal email address; – contact person in case of emergency Personal characteristics (as stated on application): – age, gender, date and place of birth, civil status, nationality; Education and training (as stated on application): – academic curriculum: overview of schools, institutions, universities attended, content of courses taken, degrees obtained or ongoing, exam results, other degrees obtained, assessment of progress made in studies; – professional skills: certificates and professional training, special licences (driver, etc.); – professional experience: professional interests, research interests, academic interests, specialisation in undergraduate studies, teaching experience; – membership of professional organisations: association details, committees or commissions participated in, roles taken, interests and participation record; – publications: books, articles, reports, published audiovisual materials; Career: previous jobs and experiences at other employers, periods without work
Receivers	Employer staff in charge of HR administration.
Retention period	For the duration of employment with Arega and thereafter for a period in accordance with the statutory obligations and legitimate interests of Arega, as further clarified in the Privacy policy for Arega employees.
Transfer of personal data to third countries or international organisations (outside the EEA)	No

If you are recruited as an employee at Arega, we will provide you with the Employee Privacy Policy that contains additional information on all processing in this regard.

Please note that where the processing of personal data is a legal or contractual requirement, the refusal or inability to provide this personal data may prevent us from considering you as a candidate for a position or entering into an employment contract with you.

Part 3. Receivers

As also clarified in the chart above (Part 2), your personal data may be shared for the purposes specified above with:

authorised Arega personnel (including staff and external consultants), professional advisers and consultants who need access to the personal data (‘need to know’);
authorised service providers and processors who help us manage our operations;
related companies of the Arega group of companies, including Arega Health BV, with registered office at Laarstraat 16, 2610 Antwerp, company number 0721.744.435 and Arega Medical BV, with registered office at Laarstraat 16, 2610 Antwerp, company number 0728.941.538;
buyers or potential buyers of all or part of Arega’s business (and their professional advisers);
government agencies, regulatory authorities and enforcement authorities, if required for the purposes specified above, if required by law, or if required to protect our legitimate interests in accordance with applicable laws, including Applicable Privacy Legislation.

Part 4. Applicant’s rights

In accordance with Applicable Privacy Legislation, you may exercise the following rights:

Right to information: You have the right to be informed about how your personal data is processed (in particular, what personal data is processed, for what purposes and on what legal basis). The Privacy Policy that you are reading now aims to do exactly this.
Right of inspection: You have the right to access your personal data and request a copy of the personal data.
Right to rectification: You have the right to have incorrect personal data corrected, or incomplete personal data completed.
Right of erasure: You can request the erasure of personal data held about you. The request to erase your personal data cannot always be granted, for example, due to contractual or statutory obligations.
Right to object: You have the right to object to the processing of your personal data, for example, if the processing is carried out based on legitimate interest or the public interest of Arega processing your data. If your personal data is used for direct marketing purposes, you have an absolute right to object to this processing activity.
Right to withdraw your consent: You may withdraw your consent at any time for the processing of your personal data collected by Arega with your consent. However, the withdrawal of your consent will not apply to processing carried out by Arega prior to your withdrawal.
Right to restrict processing: You have the right to obtain the restriction of processing in certain situations, for example, if you dispute the accuracy of personal data, for a period of time that allows Arega to verify the accuracy.
Right to data portability: You have the right to receive personal data concerning you, processed by Arega, in a structured, commonly used and machine-readable format and/or to transfer such data to another processing manager.
Right to file a complaint: In the event of problems, we encourage you to contact Arega to reach an amicable agreement. However, if you consider that an amicable settlement is not possible or desirable, you can exercise your right to lodge a complaint with the Belgian Data Protection Authority: Data Protection Authority, Rue du Printing Press 35, 1000 Brussels, Tel +32 (0)2 274 48 00, email: contact@apd-gba.be.

If handling your request requires unreasonable measures (e.g. it is technically or organisationally virtually impossible or extremely costly), Arega may charge you a reasonable fee in light of the administrative costs involved in handling the request. Arega may also refuse to process requests that are excessive, in particular, due to their repetitive nature.

You can exercise these rights by sending an email to the following address aregaprivacy@arega.com. We will respond to your request in accordance with Applicable Privacy Legislation.

Part 5. How long we keep your personal data

In accordance with Applicable Privacy Legislation, your personal data will be kept for as long as we have a legitimate business need to process it, e.g. to consider you as a candidate for a specific position or to enter into an employment contract with you.

When we no longer have a legitimate business interest in processing your personal data and there is no legal requirement for retention, we will either anonymise or delete it, or in case this is not possible, we will store your personal data securely and isolate it from further processing until deletion is possible.

The retention periods for specific processing activities can be found in the chart above (Part 2).

Part 6. Contact details

For questions regarding this Privacy Policy or the exercise of your rights please contact us at aregaprivacy@arega.com

Part 7. Changes

We may update this Privacy policy from time to time to reflect business, legal or technical developments. When we update our Privacy Policy, we will take appropriate measures to inform you, depending on the significance of the changes and the legal requirements in this regard.