PRIVACY NOTICE

For persons applying for a job

Effective from 06/05/2026

I. Controller details

II. Data protection officer details

III. Legislation underlying the processing

- Regulation (EU) 2016/679 of the European Parliament and of the Council 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 (hereinafter: GDPR)

- Act I of 2012 on the Labour Code (Mt.)

IV. Definitions

TermDefinitionLegal reference under the GDPR
Controllerthe natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State lawGDPR Article 4(7)
Processingany operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destructionGDPR Article 4(2)
Restriction of processingthe marking of stored personal data with the aim of limiting their processing in the futureGDPR Article 4(3)
Processora natural or legal person, public authority, agency or other body which processes personal data on behalf of the controllerGDPR Article 4(8)
Personal data breacha breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed (GDPR Article 4(12))GDPR Article 4(12)
Pseudonymisationthe processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data areGDPR Article 4(5)
Recipienta natural or legal person, public authority, agency or another body to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processingGDPR Article 4(9)
Data concerning healthpersonal data related to the physical or mental health of a natural person, including the provision of health care services, which reveal information about his or her health status.GDPR Article 4(15)
Personal health dataPersonal data concerning health include all data pertaining to the health status of a data subject which reveal information relating to the past, current or future physical or mental health status of the data subject. This includes: information about the natural person collected in the course of the registration for, or the provision of, health care services as referred to in Directive 2011/24/EU of the European Parliament and of the Council; a number, symbol or particular assigned to a natural person to uniquely identify the natural person for health purposes; information derived from the testing or examination of a body part or bodily substance, including from genetic data and biological samples; and any information on, for example, a disease, disability, disease risk, medical history, clinical treatment or the physiological or biomedical state of the data subject independent of its source, for example from a physician or other health professional, a hospital, a medical device or an in vitro diagnostic test.GDPR Recital (35)
Consent of the data subjectany freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or herGDPR Article 4(11)
Genetic datapersonal data relating to the inherited or acquired genetic characteristics of a natural person which give unique information about the physiology or the health of that natural person and which result, in particular, from an analysis of a biological sample from the natural person in questionGDPR Article 4(13)
Third partya natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal dataGDPR Article 4(10)
Filing systemany structured set of personal data which are accessible according to specific criteria, whether centralised, decentralised or dispersed on a functional or geographical basisGDPR Article 4(6)
Profilingany form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.GDPR Article 4(4)
Personal dataany information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.GDPR Article 4(1)

V. Description of the processing activity

Applying for an advertised job
Purpose of processingChecking whether the requirements for the position to be filled are met
Data processedData provided by the applicant in the CV, including education and qualifications, and contact details.

The source of the data processed is the Data Subject
Duration of processingUntil the data subject withdraws consent, but no longer than 3 days after the recruitment closes, including notification of the outcome.
Legal basis for processingConsent under point (a) of Article 6(1) GDPR

VI. Data transfers, processor

In the course of the above processing, the controller does not transfer data and does not use a processor. The CV sent by the applicant can be accessed by the Controller’s responsible staff in the manner and to the extent necessary for their tasks.

VII. Data protection rights of the Data Subject

The data subject may request from the Controller access to, rectification of and, except as provided for in the GDPR or Hungarian law, erasure or restriction of processing of personal data concerning him or her, may object to the processing of such personal data, and has the right to information. The Controller informs the Data Subject of any action taken concerning personal data without delay, but no later than within one month of receipt of the request ; where justified, this period may be extended by two months. If the Controller does not take action on the Data Subject’s request, it informs the Data Subject without delay, but no later than one month after receipt of the request, of the reasons for not taking action and of the possibility of lodging a complaint with the Authority and seeking a judicial remedy.

Right to rectificationAt the data subject’s request, the Controller rectifies inaccurate personal data concerning him or her without delay
Right of accessThe data subject has the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed and, where that is the case, access to the personal data and the information specified in Article 15(1) GDPR
Right to erasureThe data subject has the right to have the Controller erase personal data concerning him or her without undue delay at his or her request where one of the following grounds applies:
the personal data are no longer necessary for the purposes for which they were collected or otherwise processed,

the data subject objects to the processing and there are no overriding legitimate grounds for the processing,

the personal data have been unlawfully processed,

the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
Right to restriction of processingThe data subject has the right to have the Controller restrict processing at his or her request where one of the following applies:
a)
the accuracy of the personal data is contested by the data subject, in which case the restriction applies for a period enabling the Controller to verify the accuracy of the personal data;
b)
the processing is unlawful and the data subject opposes the erasure of the data and requests the restriction of their use instead;
c)
the Controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims; or
d)
the data subject has objected to processing, in which case the restriction applies pending verification whether the legitimate grounds of the Controller override those of the data subject.
Right to objectThe data subject has the right to object at any time, on grounds relating to his or her particular situation, to the processing of his or her personal data. In this case the Controller may no longer process the personal data unless the Controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or which relate to the establishment, exercise or defence of legal claims.
Right to data portabilityThe data subject has the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format, and has the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:
a) the processing is based on consent pursuant to point (a) of Article 6(1) or point (a) of Article 9(2), or on a contract pursuant to point (b) of Article 6(1); and
b) the processing is carried out by automated means.
(2) In exercising the right to data portability pursuant to paragraph (1), the data subject has the right to have the personal data transmitted directly from one controller to another, where technically feasible.

VIII. Lodging a complaint with the supervisory authority

If the data subject’s rights are infringed in connection with the processing of personal data, they may lodge a complaint with the National Authority for Data Protection and Freedom of Information.

Contact details of the authority:
Name of the authority: National Authority for Data Protection and Freedom of Information (NAIH)
Email: ugyfelszolgalat@naih.hu
Phone: +36 1 391 1400
Postal address: 1363 Budapest, P.O. Box 9
Website: http://www.naih.hu

IX. Bringing an action before a court

The data subject may go to court to protect their data. At the data subject’s choice, the action may be brought before the regional court competent for their place of residence or stay, or for the Controller’s registered office. The court proceedings are given priority.

X. Other provisions

The Controller reserves the right to amend these rules unilaterally.

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