Jobs at Marelli Group

Privacy Policy for Recruiting and Onboarding Process

Dear Candidate,

We’re committed to protecting and respecting your privacy and to complying with data protection legislation. This policy sets out how we do that, and how we support your rights concerning any personal data (“Data”) that we process or store.

Marelli Holdings Co., Ltd. with registered office at 4-19 Miyahara-cho 2-chome, Kita-Ku, Saitama-city, Saitama 331-8501, Japan (“Marelli Japan”), Marelli Europe S.p.A. with registered office at Viale Aldo Borletti 61/63, 2011 Corbetta (MI), Italy (“Marelli Italy”) and the hiring Marelli company (hereinafter all three: “Data Controllers”) inform you that your personal data are processed with and without use of electronic tools, under logics and procedures consistent with the processing purposes below described and in compliance with the EU regulation 2016/679 ("GDPR”).

     1. Why does Marelli process your data?

Personal Data may be collected through interaction with the Marelli Recruiting and Onboarding Process, when you submit a CV, application, or related materials to Marelli through our internal careers page and/or on external career pages as well as through other external job boards such as e.g. LinkedIn etc., and when you otherwise explore or apply for a job with Marelli.

     2. Purpose of the Processing

Marelli processes your data to attract, select and onboard the candidates for Marelli.

     3. Categories of Personal Data

Marelli may collect, store, and use the following categories of personal data (“Personal Data”) provided by the candidate:

• Personal information, e.g.: Name, Contact information (phone number, email address, postal address), Work authorization status.
• Educational background: based on country/region, Education background with certification and validation.
• Work Experience: previous employment history (job titles, dates of employment and responsibilities, relevant skills/accomplishments from previous positions, references from previous employers or supervisors).
• Skills and qualifications: Specific skills, proof of proficiency in the skills and language proficiency.
• Additional information: such as cover letter, CV/Resume, portfolio, responses to application-specific questions or assessments Salary and compensation package, bonuses, fringe benefits, and image or official ID and/or voice: information relating to new joiner image and/or voice acquired with video and audio recording equipment and any other information we extract from your CV and/or you provide during the application, recruiting, interview, or hiring stages.

     4. Special Categories of Personal Data, acc. to Art. 9 GDPR

Throughout the Recruiting and the Onboarding process, depending on your jurisdiction and where permitted by law, we may also collect some special categories of Personal Data about you according to article 9 GDPR. You are invited not to submit Special Categories of Personal Data, unless it is necessary.

     5. Legal basis of the Processing

The Data Controllers process Personal  Data for the recruiting and onboarding process:

Legal basis for the processing is under GDPR:

• article 6 lit. b) GDPR: in order to take steps at the request of the candidate prior to entering into a contract,  
• furthermore, to the extend the candidate has given consent article 6 lit. a) GDPR: with given consent to the processing of his or her Personal Data for the Recruiting and Onboarding Process and
• if necessary according to article 6 lit. c) GDPR, for compliance with a legal obligation to which the Data Controllers or one of the Data Controllers are subject.

For clarification: Special Categories of Personal Data are only processed – if at all – in jurisdictions allowing the processing of Special Categories of Personal Data and where a legal basis for the processing  of Special Categories of Personal Data is required (e.g. under GDPR) only

• with the explicit consent of the candidate (article 9 para 2 lit. a) GDPR) and furthermore
• if processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the Data Controllers or of the candidate in the field of employment and social security and social protection law in so far as it is authorized by Union or Member State law or a collective agreement pursuant to Member State law providing for appropriate safeguards for the fundamental rights and the interests of the candidate (article 9 para 2 lit. b) GDPR).

Outside applicableness of GDPR the corresponding legal basis of local laws apply. If the other legal basis do not apply under local law, we base the processing on the consent of the candidate.

     6. Data Security

Marelli has introduced appropriate security measures in order to keep your Personal Data secure and to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. Our Service Providers will only process your Personal Data in accordance with our documented instructions and are subject to a duty of confidentiality.

The Personal Data of the candidates are stored on SAP servers located in Netherlands and Germany.

Part of the Pre-Onboarding process is an online training in the cloud of the provider Easygenerator B.V. with data storage in Germany and Ireland.

Personal data included in e-mails and processed for online MS-Teams meetings are stored in Microsoft Cloud in Japan.

     7. Data Sharing

The duly authorized personnel of the Data Controllers and their affiliated companies may access your Personal Data on a need-to-know basis only.

Marelli may share your Personal Data with third parties: (i) when the communication is necessary to comply with applicable laws and regulations, for example requests of judicial authorities; (ii) in case of extraordinary operations limited to executives (e.g. mergers, acquisitions, transfer of assets, etc.). The categories of data recipients are authorities, courts, potential buyers of Marelli's business operations, external consultants (law, accounting firms), the list of which could be provided upon request.

Your Personal Data are also shared with our service providers (e.g. providers of technical, administrative and / or organizational services, such as IT and hosting support, application providers, marketing providers) in particular SAP Italia S.p.A., Via Monza 7/A, 20871 Vimercate (MB), Italy (for the collection and processing of the data of the candidate for the recruitment and onboarding process), Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18 D18 P521, Ireland (for e-mail and MS Teams communication), Appian Software International LLC, Baarerstrasse 21, 6300 Zug, Switzerland (for communication on the pre-onboarding stage via e-mail), Google LLC, 901 Cherry Ave., San Bruno, CA 94066, USA or if you reside in the European Economic Area (EEA) or Switzerland: Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland (for viewing videos).

If you click on a job opening on a social media platform, you will be redirected to our service provider SAP Success Factors, where you can file all your job application documents and information. The social media platform only learns that the further link is being clicked on.

If you explicitly agree, your Personal Data will not only be transferred and processed on a need-to-know basis only for your job application, but be transferred to all companies within Marelli (worldwide) for other job offerings. Your consent is required, if you wish to be considered by other Marelli companies for further[SC(1]  jobs, promotions etc.

If you’re applying for a job with a company in the USA, please be aware that we may have to share Personal Data of you with a service provider, providing background checks.

     8. Data transfer outside the European Economic Area

We inform you that in case the Personal Data are transferred outside of the EEA the Data Controllers will use any appropriate contractual measures to guarantee an adequate protection of the Data based on suitable safeguards in accordance with GDPR, such as the standard contractual clauses adopted by the EU Commission to rule the transfer of Personal Data outside of the EEA and adequate additional safeguards, if required or an adequacy decisions by the EU Commission for reliable third countries.

     9. Data retention: For how long will we store your Data?

Your Personal Data shall be stored for the period of time strictly necessary to pursue the purposes for which they were collected and to comply with applicable laws and regulations. The timeline in which your Personal Data is deleted therefore is based on country and region.

When Marelli no longer requires your Personal Data for the above-mentioned purposes, Marelli will keep your Personal Data duly blocked and only for the period necessary for establishment, exercise and defense of legal claims. Once this period has elapsed, the data will be erased or made anonymous in a permanent and non-reversible way. This means that in the following countries the hiring company keeps your Personal Data

a. in the candidate profile for the country specific retention period in the table below, starting with last access to SuccessFactors (but will not anonymize it, while the candidate is participating in an open application process) and

b. in the candidate application data for the country specific retention period in the table below with the retention period starting with the closure of the job offer in the recruitment system: