Privacy Statement

Privacy Statement concerning the use of the „vodafone-institut.de“ website

Content

1. Subject matter of this Privacy Statement
2. Controller and service provider
3. Processing your data
3.1 Use of the Website for purely informational purposes
3.2 Contact form
3.3 Invitation to events
3.4 Livestream
4. Duration of processing
5. Data transfer to third parties, transfer to third countries
6. Cookies and similar technologies
6.1. Strictly necessary cookies
6.2. Analytics cookies
6.3. Cookie Settings
7. Embedded YouTube videos and YouTube Livestreams
8. Data security
9. Data subjects rights
10. Contact

1. Subject matter of this Privacy Statement

Thank you for your interest in the “vodafone-institut.de” website (hereinafter referred to as the “Website”). We take the privacy of your personal data very seriously. This privacy statement serves to inform you about the data we collect when you use this Website and how we use that data. It provides information about the technical and organisational measures we have taken to protect your data. This Privacy Statement may be accessed at any time by clicking on the “Privacy” link on the Website.

2. Controller and service provider

The controller within the meaning of the EU General Data Protection Regulation (GDPR) and the German Federal Data Protection Act (Bundesdatenschutzgesetz – BDSG) and the service provider within the meaning of the German Telemedia Act (Telemediengesetz – TMG) is Vodafone Institut für Gesellschaft und Kommunikation GmbH, Ferdinand-Braun-Platz 1, 40549 Düsseldorf (hereinafter also referred to as the “Vodafone Institute for Society and Communications” or the “Vodafone Institute”).

3. Processing your data

This Website offers you the opportunity to learn more about the Vodafone Institute. We process your data solely for the purpose of making the Website available to you (Article 6 (1) sentence 1 (f) GDPR). The purpose of the processing is to enable the proper display of the Website and use of available functions. This includes the following, in particular:

3.1 Use of the Website for purely informational purposes

When using our Website for purely informational purposes, you generally do not need to provide us with any information. We collect and use only that data which is transmitted to us automatically through your browser, such as

• date and time that you access one of our Website pages;
• type and settings of your browser;
• your operating system;
• the web page you last visited;
• your IP address.

When you visit our Website for purely informational purposes, we collect this data in non-personal form to enable you to use the web pages you have accessed, to improve the functionality of our Website and for statistical purposes. The IP address is stored only for the duration of your visit. Personal data is not analysed.

3.2 Contact form

Our Website contains a contact form. If a data subject contacts us via the contact form, the data transmitted by that data subject will be automatically stored and forwarded to the person responsible for processing the request. This data will only be stored for the purpose of processing the request or contacting the data subject. The personal data will not be disclosed to any third parties.

3.3 Invitation to events

We regularly hold events on digitization and digital technologies and their responsible use for innovation, growth and sustainable social impact. For this purpose, we send invitations to the participants by e-mail or by post. In the case of an invitation, you can of course decide if you would like to register. We only ask for such data which are necessary for the registration and execution of the event.

We usually receive your contact details directly from you because you have taken part in a Vodafone Institute event. In some cases, we obtain your contact details from publicly accessible sources. Data processing in both cases is based on our legitimate interest in the invitation to our events (Art. 6 Para. 1 f) GDPR). You may object to the use of your data at kontakt.institut(at)vodafone.com with effect for the future.

3.4 Livestream

For some of the events that we organize, we offer a live stream on our website. This live stream enables you to follow the event in real time via a video function in your Internet browser. Only your IP address, statistical data via cookies and data log files are processed. This is used to recognize the capacity outflow and usage of the stream and for the correct billing as well as for the implementation of technical and organizational procedures for security purposes.

4. Duration of processing

We process your data only for as long as necessary to provide the Website services. The only time this would not be the case is if we are required by law to retain the information, in particular for tax or accounting reasons. In that case, we would erase you data as soon as the relevant retention periods expire.

5. Data transfer to third parties, transfer to third countries

No data is transferred to third parties. Nor will your data be transferred to any third country outside the European Union or the European Economic Area or to any international organisation. A transmission to other recipients may be necessary if we instruct companies, for example technical service providers, with the performance of corresponding services. In this case, data protection agreements exist to safeguard this transmission.

6. Cookies and similar technologies

We use so-called cookies, pixels and similar technologies on our websites to provide you with a comfortable and optimal user experience on our website.

Cookies are small text files that we store on your computer or smartphone. They are used, for example, to determine the frequency of use of a website and the number of users, thus making the website more user-friendly and effective. There are so-called “session cookies” – these are only stored temporarily for the duration of your use of the website and are then automatically deleted. We also use “persistent cookies” where appropriate. These are stored for a longer period of time.

Pixels are small pictures on a website or for example in an e-mail. They can set cookies and collect information about your browser or device.

6.1. Strictly necessary cookies

Strictly necessary cookies ensure the usability of our website. This enables basic functions of the website, such as page navigation or login during the session. Without these cookies a correct function of the website cannot be guaranteed.

This website uses the following strictly necessary cookies:

Cookie	Purpose	Responsible	Storage duration
vficonsent	Storage of cookie settings	Vodafone Institute	unlimited
video	Optimizing the display of the start page during a user session	Vodafone Institute	session

6.2. Analytics cookies

These cookies give us an understanding of how visitors act on our website (e.g. how long visitors stay on a page on average, or whether and how often they return). We use these cookies to optimize our websites and measure our success.

The following analysis cookies are used by us. The legal basis for the use of these analysis cookies is your consent (Art. 6 para. (1) lit. a) GDPR). You can agree to the use of these cookies or revoke your consent already given under point 6.3. Cookie-Settings below.

Google Analytics

Our website uses Google Analytics, a web analysis service provided by Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) (“Google”).

Cookies are set for this purpose. These store your anonymized IP address, which is then transmitted to a Google server in the United States of America and stored there. However, your IP address will be shortened in any case before Google saves it within the member states of the European Union or other signatory states of the Agreement on the European Economic Area and thus made anonymous. Only in exceptional cases will the full IP address be transferred to a Google server in the United States of America and shortened there. Such a possible transfer is legally secured by standard contractual clauses concluded with Google. On our behalf, Google will use this information to evaluate your use of our website, to compile reports on website activity and to provide further services related to the use of our website and the use of the Internet to us as the operator of our website.

The anonymized IP address transmitted by your Internet browser within the scope of Google Analytics is not combined with other data from Google.

You can call up Google’s data protection information and other information under http://www.google.de/intl/de/policies/privacy/ and https://support.google.com/analytics/answer/6004245.

Cookie	Purpose	Responsible	Storage duration
_ga	Is used to differentiate between users.	Google	2 years
_gid	Is used to differentiate between users.	Google	24 hours
_gat	Is used to throttle the request rate.	Google	1 minute

6.3. Cookie Settings

You want to see your Cookie settings? Here you can check and adjust everything:

 

7. Embedded YouTube videos and YouTube Livestreams

We embed videos and Livestreams from YouTube, Google’s video portal. Google generally sets YouTube-specific cookies and transfers information. This happens regularly already when a user enters our website. However, we have implemented the functionality of the so-called “two-click solution”. In this case, the setting of cookies associated with the embedding of the videos is only linked to an activation of the playback function of the video by the user himself. Previously, data processing by Google is prevented. The user can decide for himself if he wants to watch the videos and if he wants to allow data processing by Google. If the user chooses to, data can be transferred to Google. More information can be found in the Google Privacy Policy at https://policies.google.com/privacy?hl=de.

8. Data security

We have technical and organisational measures in place to protect collected data, in particular against accidental or intentional manipulation, loss, destruction or unauthorised access. Our security measures are continuously improved in line with technological developments.

9. Data subjects rights

You have the right to obtain information about the data processed when using our Website, or to have that data rectified or erased. You may also assert your right to restrict processing or to data portability. Finally, you have the right to lodge a complaint with a supervisory authority.

10. Contact

If you have any further questions or comments regarding data privacy or wish to exercise your rights as a data subject, please contact our data protection officer at the address below:

Dr Dirk Herkströter
Data Protection Officer/Datenschutzbeauftragter
Vodafone Institut für Gesellschaft und Kommunikation GmbH
Ferdinand-Braun-Platz 1
40549 Düsseldorf, Germany

Candidate Privacy Statement

Policy Standards Supported / Objective

The objective of this statement is to explain how Vodafone collects, use, shares and protects your personal information during our recruitment process.

This document supports the Privacy Risk Management Standard and the following principles:

• Vodafone is committed to process personal information honestly, ethically, with integrity, and always consistent to applicable law and our values
• Vodafone is transparent with potential employees about the personal information we collect, use, share and store about them

Candidates applying for a role at Vodafone understand how Vodafone collects and processes their personal information and their rights with respect to this personal information.

Owner Bettina Karsch
Author
Version DE Institut V1.5 EN
Contents

1 Our Privacy Promise

We aim to create a culture where everyone at Vodafone has a clear understanding of how important privacy is to our employees and how to ensure it is respected. Our Privacy Promise sets out the principles that govern our approach to privacy and how we communicate with employees, partners and other stakeholders on relevant issues – such as designing products to protect privacy or assisting with law enforcement.

Vodafone’s privacy principles are:

How we operate

• Accountability: we are accountable for living up to these principles throughout our corporate family, including when working with our partners and suppliers. We have in place accountable privacy compliance measures and we monitor and enforce our compliance with these principles;
• Fairness and lawfulness: we comply with privacy laws and act with integrity and fairness. We will work with governments, regulators, policy makers and opinion formers for better and more meaningful privacy laws and standards;
• Openness and Honesty: we communicate clearly about actions we take that may impact privacy, we ensure our actions reflect our words, and we are open to feedback about our actions;
• Choice and access: we give people the ability to make simple and meaningful choices about their privacy and allow individuals, where appropriate, to access, update or delete their personal information.

How we manage and protect information

• Responsible Data Management and limited disclosures: we apply appropriate data management practices to govern the processing of personal information. We choose the partners who participate in processing of personal information carefully and we limit disclosures of personal information to such partners to what is described in our privacy statement or to what has been authorized by our employees;
• Security safeguards: we implement appropriate technical and organisational measures to protect personal information against unauthorized access, use, modification or loss.

How we design our products and services

• Privacy by Design: respect for privacy is a key component in the design, development and delivery of our products and services

How we make decisions

• Balance: when we are required to balance the right to privacy against other obligations necessary to a free and secure society, we work to minimize privacy impacts

2 Who we are

Vodafone Group Services GmbH is the controller of your personal information We are a member of the Vodafone Group and manage HR operations, including the processing of personal information about the employees and applicants to the Vodafone Company to which you are applying.

Our registered office is Ferdinand-Braun-Platz 1, 40549 Düsseldorf. We are registered in Handelsregister: Amtsgericht Düsseldorf, HRB 66570. We provide details of how to contact us in the How to contact us  section of this privacy statement.

3 Definitions

In this privacy statement:

“we/us” means Vodafone Institut für Gesellschaft und Kommunkation GmbH;
“third party” means someone who is not you or us or a part of Vodafone Group; and
“Vodafone Group” means Vodafone Group Plc and any company or other organisation in which Vodafone Group Plc owns 50% or above of the share capital

4 The Basics

4.1 Personal information we collect about you

4.1.1 Vodafone will process your personal information based on:

1. Vodafone’s legitimate business interest, when you apply for a role at Vodafone you provide us with your personal information so that we can use this information to assess your application, progress your application through the recruitment process, make a decision about your suitability for the role and contact you throughout the recruitment and onboarding process

2. Necessary for entry into, or the performance of a contract, we may ask you to provide personal information that is required to enter into an employment contract with the Vodafone company you are applying to;

3. Consent you provide, we may ask you to provide information voluntarily, including for example your age group and gender. You can withdraw your consent at any time by editing your candidate profile.

4. Compliance with the law, where certain information is necessary to satisfy a legal or regulatory requirement.

4.1.2 How we collect personal information about you

We collect personal information about you when you register a general interest in careers at Vodafone or when you apply for a specific role at Vodafone. Some of the information we collect about you is required to make an assessment on your application to Vodafone and contact you about your progress through the recruitment process, for example your telephone number, email address, CV. If you do not provide this information then we will be unable to assess your application or contact you to invite you to interview, or make you an offer.

We may collect information about you from recruitment agencies or from the public internet where you have made this information publicly available, for example, we may find your profile on LinkedIn and contact you about suitable roles.

4.1.3 The types of information we may collect about you, for example:

1) Personal details, such as name, personal email address, current address, telephone number;

2) Recruitment information, such as application form (website and paper), CV, resumes, interview notes of successful candidates, interview notes of unsuccessful candidates, video interviews, references from previous employer, psychometric test results;

3) Diversity information, such as your age group, gender or nationality;

4) Internal candidate information, such as references given by Vodafone, interview notes, internal transfer or promotion, succession planning documents;

5) Identification information, such as proof of identity;

6) Authentication information, user name and password for the recruitment portal;

We may also process sensitive personal information about you – but only where this is strictly necessary to assess your suitability for the role you have applied for or where we have a legal obligation. For example, we may collect records of criminal convictions or right to work in the country you are applying to in order to perform security background checks where it is required by local law;

4.2 How we use information about you

We may process the personal information that we collect about you for the following purposes

• Recruiting people into jobs, the information you provide to us will be shared with the Vodafone Company you are applying to in order to assess and progress your job application and to make any verifications required by local law. If you apply for more than one vacancy, your information will be shared with each Vodafone company where you have applied;
• Resourcing for jobs, if you register a general interest in pursuing a career with Vodafone, the information that you provide will be retained by us and searched by people who are employed by Vodafone to help us fill future vacancies. If you apply for a specific vacancy and you are unsuccessful, the information you provide to us will be retained so that we can consider you for future suitable vacancies – but only where we have collected your consent to do so;
• Creating an employee record, if your job application is successful, the information you give during the application process will form part of your employee record and will be used to administer your employment and manage your career at Vodafone;
• Contacting you about other roles, where we have collected your consent to do so;
• Analytics, we may use some of the personal information you provide for various reporting purposes including, for example, to report on our diversity targets or the type of candidates and volumes of applications made to Vodafone and related trends – you will not be personally identified from these reports;
• Screening, when it is required by law or to enter into a contract, we will make an automatic decision on the suitability of your application based on certain criteria, such as your qualifications. For example, graduates must be proficient in English and have completed a university degree to be considered for a role at Vodafone or retail employees must be able to work at weekends and national holidays. We will bring this to your attention wherever we collect personal information to make an automatic decision about you and you can contest a decision by exercising your rights (see 5. Your Rights).
• Cookies, we use cookies that are strictly necessary for the functioning of the Careers site and we may use cookies to understand how you use our recruitment website and how we can improve the customer experience.

4.3 Who we share information about you with

We may share personal information about you with:

• Other companies in the Vodafone Group, which will process your personal information solely and only, for the purposes in section 4.2;
• Third parties, such as recruitment agencies, test providers and others who help us fill vacancies and assess the suitability of candidates and progress applications. Where we use third parties, Vodafone ensures that there is a written agreement and that they meet the same privacy and security standards as Vodafone;
• Law enforcement agencies, government bodies, regulatory organisations, courts or other public authorities if we have to, or are authorised to by law;
• A third party or body where such disclosure is required to satisfy any applicable law, or other legal or regulatory requirement.

4.4 Where we process information about you

In doing the above, we may need to transfer personal information about you to other companies in the Vodafone Group or third parties located (or whose servers may be located) in countries outside of the country where you have applied, including countries outside of the European Economic Area (EEA). If we send personal information about you to a country that is not in the EEA, we will make sure that there is a legal basis for such transfer and that your personal information is adequately protected as required by applicable law, for example, by using standard agreements approved by relevant authorities and by requiring the use of other appropriate technical and organisational measures to protect your personal information. Please contact the local Privacy Officer if you would like to find out more about the way we comply with our legal obligations in relation to international data transfers. Their contact details are available under section 7 ‘How to contact us’ in this privacy statement.

4.5 How long we keep information about you

We will keep your information for as long as it is necessary for the recruitment process. If you are successful, we will keep your information for the duration of your employment, should you wish to apply for other roles within Vodafone.  If we are not able to offer you a  role, we may keep your information for up to 6 months to contact you about future roles that may interest you, but only where we have collected your consent to do so – you can withdraw your consent at any time in your candidate profile.

We will anonymise your information in accordance with our retention policy and may retain those anonymised records to monitor the effectiveness of our recruitment process. For example, we may create reports to understand what nationalities have applied for roles with Vodafone in the last 12 months – you will not be identifiable in these reports and you can withdraw your consent at any time by updating the information in your candidate profile.

5 Your rights

a) Right to correct or update information: you have the right to correct or update the personal information we process about you if it is not accurate. If the information we process about you needs updating, or you think it may be inaccurate, you can update your information in your candidate profile or contact us at any time to update this.

b) Right to access: you have the right to request a copy of the personal information we process about you. You can request a copy of your personal information by contacting: career.de@vodafone.com.

c) Right to object: you have the right to object to Vodafone processing your personal information where we rely on our legitimate interest to do so. If you wish to object to processing, you can change your preferences in your candidate profile at any time or you can make an objection request by contacting career.de@vodafone.com.

d) Right to deletion: in certain circumstances you have the right to request that we erase the personal information we hold about you. You can request for your information to be deleted here career.de@vodafone.com.

e) Right to contest an automated decision: you have the right to obtain human intervention and to contest an automated decision that has been made about you. You can contest a decision by contacting career.de@vodafone.com.

f) Right to restrict use of your information: if you feel the personal information we process about you is inaccurate or believe we should not be processing your personal information, you may have the right to ask us to restrict processing that information. You can request to restrict processing by contacting career.de@vodafone.com.

g) Right to data portability: in certain circumstances you will have the right to take the personal information you have provided to us with you.  You can request a copy of your personal information by contacting career.de@vodafone.com.

6 Changes to this Privacy Statement

This privacy statement gets updated from time to time, so we’d encourage you to check it regularly on the recruitment portal. If we make a major change, we’ll post this on the recruitment portal you will use to make your application.

7 How to contact us

If you have any further questions about this privacy statement or how we process your information, please contact datenschutz@vodafone.com
We will do our best to help but if you are still unhappy, you can contact:

Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen
Postfach 20 04 44
40102 Düsseldorf