CANDIDATES PRIVACY STATEMENT

 

Europe

 

When applying for a job position at Foot Locker in Europe or when using our Career Site, you will be sharing certain personal data (“Personal Data”) with us. With this Candidates Privacy Statement (“Statement”) we inform you on how we process your Personal Data.

 

This Statement has the following chapters:

1.           Introduction

2.          Who are we?

3.          What Personal Data do we collect from you?

4.          Why do we use your Personal Data?

5.          How long do we retain your Personal Data?

6.          Who do we disclose your Personal Data to?

7.          Do we transfer your Personal Data outside of the European Economic Area (“EEA”)?

8.         How do we protect your Personal Data?

9.         What are my rights?

10.       How can I file a complaint?

11.       Updates to this Privacy Statement

12.       Contacts

 

 

1.           Introduction

 

Transparency is one of the key principles of data protection legislation. With this in mind, we inform you on how your Personal Data is being processed and we promote the objective of strengthening your rights as an individual, our accountability and the lawful and fair processing of Personal Data.

 

This Statement contains information on how we process your Personal Data when you apply for a position at Foot Locker within Europe and/or when you visit our site for Candidates www.career.footlocker.com (“Career Site”). This Statement applies to all Personal Data of job applicants collected by Foot Locker Europe B.V. or any of its European affiliates or brands, including Kids Foot Locker and Sidestep (“Foot Locker”).

 

 

2.           Who are we?

 

Foot Locker Europe B.V. is the Data Controller responsible for Personal Data in respect of Candidates that are subject to the EU General Data Protection Regulation (“GDPR”).

 

Foot Locker Europe B.V. is incorporated under Dutch law and has its principle address at Ir. D.S. Tuijnmanweg 3-5, 4131 PN, Vianen. Foot Locker Europe B.V. is registered at the Dutch chamber of commerce under the registration number 23067735.

 

 

3.           What Personal Data do we collect from you?

 

3.1        Personal Data you share with us directly

 

We collect the following categories of Personal Data when you apply online or otherwise for a job position at Foot Locker:

 

        a.     Identifiers: candidate ID, full name, royal prefix/suffix, home address, email-address, phone number;

        b.     Personal Data about education, diplomas, certifications;

        c.     Professional or employment-related Data: working career, skills, jobs interests, qualifications, experience details, eligibility (including nationality, country of residence, and                  visa, immigration status, work permit), jobs in which you have expressed an interest or for which you would like to submit an application, CV and attachments (including                  photographs), employment references, compensation details and background Data, interview notes;

        d.     Jobs contract info: details or preferences about the contract, such as full/part time, location, starting date and job level/category;

        e.     Exclusively for store positions, Professional Assessment and Fit Score: we request the completion of a questionnaire for screening the Candidates most suitable for the                      positions available. The questionnaire will be compared against a control group that includes answers to the questionnaire along with historical performance data.                              Through this process, we are able to correlate attributes with performance and assess the extent to which the candidate possesses the attributes of a high performer;

        f.      Inferences: regarding problem solving abilities, motivations, working with others, work style, leadership and other personal attributes; and

        g.     At the end of the recruitment process, the Additional Personal Data request form: social security number, national ID document copy, permit details when relevant,                              nationality, gender, bank details, emergency contact, marital status and tax category.

 

3.2        Special categories of Personal Data

 

We collect the following categories of Personal Data when you apply online or otherwise for a job position at Foot Locker:

 

        a.    Health data: in Italy, Spain, Portugal, Germany, Austria, Poland, Hungary and Czech Republic, it is mandatory by law to hire a certain number of people with disabilities. To                comply, the candidate has to provide a specific certificate in order for us to assess the truthfulness of the document and the % of disability. This document is securely

               stored with limited access; and

        b.    Foot Locker does not collect ethnic origin, religious or philosophical belief, sex life or sexual orientation, political opinions or trade union membership during the hiring                         process.

 

3.3        Personal Data we collect from you indirectly

 

We collect the following categories of Personal Data when you apply online or otherwise for a job position at Foot Locker:

 

        a.     Internet or other electronic network activity: we and third parties collect Personal Data indirectly from you regarding your online activity, browsing history and search                 history, preferences and location through the use of cookies, web beacons, pixel tags, log files or other similar technologies when you use our Career Site. For more                 information, please read our Cookies Statement; and

        b.    Service providers and other third parties: we collect Personal Data indirectly from you when we use service providers and third parties, such as recruitment agencies,                         background screening providers, social media, that provide web platforms, data storage and processing, recruitment services, background screenings, professional                               assessments, talent analytics services or managing the application process.

 

 

4.           Why do we use your Personal Data?

 

We use your collected Personal Data for the following specific purposes and categories of use:

 

4.1        To manage the recruitment process

 

Your Personal Data is used to analyze your experience and expertise and match those with our employment opportunities, to evaluate your suitability for the position applied and to inform and contact you about your application or about any possible future jobs which may match with your profile.

Ground for processing: the processing of your Personal Data for recruiting purposes is based on our legitimate interest in finding the best person for a specific job in the context of the application procedure. Any processing of your (Special) Personal Data in connection with your job application is based on the purpose of carrying out the obligations and exercising specific rights in the field of employment and social security and social protection law.

 

4.2        To inform you on future job recommendations and information about Foot Locker

 

In case you would like to be kept informed about job opportunities at Foot Locker, we will ask your consent to communicate with you about any future job recommendations, based on your preferences, interests and profile, by emails.

Ground for processing: the processing of your Personal Data to keep you constantly informed is based on your consent. Please note that you can always withdraw your consent by using the unsubscribe link at the bottom of our emails. 

 

4.3        To operate our business and analyze, develop and improve our Career Site, and services

 

This includes maintaining security of our Career Site and helping us to enable your use of our Career Site to administer accounts.

Ground for processing: the processing of your Personal Data is based on our legitimate interest in operating our business in an efficient and appropriate manner and in enhancing the effectiveness, user experience, functioning and security of our systems and networks and services.

 

4.4        To comply with applicable laws and regulations

 

Ground for processing: the processing of your Personal Data for legal and regulatory purposes is necessary for compliance with legal obligations that we are subject to. For example, in some countries it is mandatory to have some Personal Data in the employee file, such as the copy of valid identity document.

 

4.5        To prepare and finalize your employment contract

 

We will process your Personal Data once we reach a verbal agreement.

Ground for processing: the processing of your Personal Data is necessary in order to take steps prior to entering into an employment contract with you.

 

4.6        Or otherwise as described to you at the point of collection

 

 

5.        How long do we retain your Personal Data?

 

In case you are hired by Foot Locker, your Personal Data gathered through the recruitment process will be uploaded in our HR related system. Once you have become an employee, we will inform you on how your Personal Data is processed through the Employees Privacy Statement.

 

In case you are not hired, Foot Locker will retain your Personal Data for one year starting from the last update of your profile in order to ensure you to maintain your profile (including the Professional Assessment and Fit Score) and to ensure us to find the best person for a specific job position. Your profile will be then automatically deleted.

With specific reference to the Additional Personal Data request form, it will be deleted within 15 days, while the rest of your profile will be stored as per our general retention period abovementioned.

Any interview notes taken during the recruitment process will be deleted at the end of the recruitment process.

 

As provided by applicable law, you have the right to request the deletion at any time of your profile in our Career Site as described in chapter 9.

Please note, to the extent permitted or required by law, we may delete your Personal Data at any time. As a result, you should retain your own copy of any information you submitted to us.

 

For information that you have provided to third parties directly as part of the application process, please visit their websites or contact such third parties for more information on their data retention and privacy practices.

In this regard, please note that as you will apply on our Career Site, your Personal Data will be stored on the server of our connected IT-vendors.

 

 

6.      Who do we disclose your Personal Data to?

 

We may disclose your Personal Data in the following ways:

 

6.1        With other Foot Locker entities that are part of the Foot Locker Group

 

We may share your Personal Data with entities that are part of our group organization, to the extent required for the respective recruitment and hiring process.

 

6.2        With third party vendors

 

We use third party vendors for business, professional and technical support as Processors (as meant in the GDPR). These companies only use your Personal Data on behalf of us and under our written instructions:

 

        a.     Specifically, we use third party vendors and their servers for web platforms, storage and processing your Personal Data. In limited circumstances these vendors might                 have access to your Personal Data when this required for maintenance or problem solving. For more information, please read our Third Party Vendors List;

        b.     In addition, we may select third party vendors who might assist us for certain technical, recruitment and human research related services such as background checks,                 professional assessments, talent analytics, or managing the application process.

We have data processing agreements in place with such vendors where required by law.

 

6.3        With a competent public authority

 

In order to comply with a subpoena or other legal process or obligations, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to legitimate government requests, including public and government authorities outside your country of residence, for national security and/or law enforcement purposes.

 

 

7.      Do we transfer your Personal Data outside of the European Economic Area (“EEA”)?

 

Some of your Personal Data that we collect will be transferred and stored in countries outside of the EEA. The laws in those countries may not provide the same level of data protection compared to the country in which you initially provided your data. When we transfer your Personal Data to recipients in other countries, we will protect that Personal Data as described in this Statement and in compliance with applicable laws.

 

We use various measures to ensure that your Personal Data transferred outside of the EEA receives adequate protection in accordance with data protection legislation. This includes signing the EU Standard Contractual Clauses and verifying if the recipient adheres to the EU-US and Swiss-US Privacy Shield Framework.

 

Foot Locker Inc. is Privacy Shield certified. Click here to access our EU-U.S. Privacy Shield Policy. Foot Locker Europe B.V. and its affiliates in Europe have concluded a data transfer agreement (Controller to Controller) with Foot Locker, Inc. according to the Model of the European Commission. Foot Locker, Inc. has in its turn concluded a data transfer agreement (Controller to Processor) with its third party vendors according to the Model of the European Commission.

 

 

8.           How do we protect your Personal Data?

 

Foot Locker has implemented appropriate physical, organizational and technical security measures designed to protect your Personal Data against unlawful access, loss, misuse or alteration. Foot Locker uses a variety of secure techniques to protect your Data, including secure servers, firewalls, and encryption of application data and of your communications via the Internet.  Our recruitment systems will only be accessed by authorized staff involved in the recruitment or hiring processes.

 

 

9.           What are my rights?

 

You have the right:

 

9.1       Of access to your Personal Data that we process on you;

9.2       To rectification of inaccurate or incomplete Personal Data;

9.3       Of erasure of your Personal Data;

9.4       To restrict of processing of your Personal Data;

9.5       To move, copy or transfer your Personal Data (data portability). This right only applies when you have directly provided the Personal Data and where the processing relies on             consent or where it is necessary for entering into, or performance of, a contract between us;

9.6       To object to:

                a.      processing based on legitimate interests (including profiling);

                b.      direct marketing (including profiling); and

                c.      processing for purposes of scientific/historical research and statistics.

9.7       Not to be subjected to a decision based solely on automated processing, including profiling: (e.g. automated processing of Personal Data to evaluate certain aspects about                you), which produces legal effects concerning you or similarly significantly affects you unless it is:

                a.      necessary for entering into, or performance of, a contract between us; or

                b.      authorized by law (e.g. for the purposes of fraud or tax evasion); or

                c.      you provide your explicit consent; and

9.8       To revoke your consent for further processing of your Personal Data when such processing is based on your consent.

 

To exercise any of these rights, please use the following webpage www.footlocker-emea.com/privacy. We will provide you with information on the action taken within one month after the successful submission of your request via this webpage.

 

We are required to verify your identity including, but not limited to, the verification of your email address. If you do not allow us to verify your identity, we cannot proceed to process your request.

 

Please note that the above-mentioned rights, with the exception of the right to object to direct marketing, are not absolute. Under certain conditions and in line with applicable data protection legislation, we may refuse a request. When such a restriction (partially) applies to your request, we will inform you on the reason of our refusal to comply to your request.

 

 

10.       How can I file a complaint?

 

If you are unsatisfied with the way we have handled your Personal Data, please contact us at: privacy@footlocker.com.

Please note that you also have the right to lodge a complaint with the competent Data Protection Authority.

 

 

11.       Updates to this Privacy Statement

 

We amend this Statement from time to time to keep the information provided up to date. We encourage you to review this Statement periodically.

 

Last Updated: June 2020

 

 

12.       Contacts

 

If you have any questions, concerns or complaints regarding this Statement or the processing of your Personal Data, please contact us at: privacy@footlocker.com.

In case you desire to exercise any of your rights, please use the following webpage www.footlocker-emea.com/privacy.