Compliance & Privacy Notice for Recruitment at Envalior

1. What is recruitment compliance?

Recruitment compliance ensures we at Envalior GmbH follow legal and ethical standards when hiring.

Being compliant means making sure we abide by laws and regulations related to fair and nondiscriminatory hiring practices, ensuring no job applicant or employee experiences discrimination against nationality, ethnicity, gender, age, religion, language, or past salary range during the hiring process.
Being recruitment-compliant helps us make sure we are not willingly or unwillingly offending a candidate or violating their rights in any way during the entire hiring process.

Note: some links and references in this document are part of the exiting service level agreement between Envalior and DSM/Firmenich, these will be updated as we exit from these agreements.

2. Privacy notice for recruitment

At Envalior (formerly DSM Engineering Materials and LANXESS High Performance Materials), transparency is paramount. With this ‘privacy notice for recruitment’, we want to inform you how we use your personal data when you look for a job or apply for a position at Envalior.com. This privacy notice has been intentionally written in simple and clear language so that everyone can easily understand what data we collect, why, and how we use and protect it.

This Privacy Notice for Recruitment is in addition to our existing Privacy Notice for Business Partners and Visitors, which gives you specific information on how we process personal data (and cookies) obtained from you when you navigate the Envalior website.

Please read it in full to understand our policy and your individual rights.

2.1. What does this Privacy Notice for Recruitment cover?

This Privacy Notice applies to anyone looking and/or applying for a job at Envalior, including current Envalior employees who are exploring new career moves, and describes what data we collect, why this information is collected and processed, as well as how it is protected.

In this Privacy Notice, “Envalior”, “we”, “us”, “our”, “Group”, each refers to Envalior and not DSM/Firmenich or LANXESS

2.2. What do we mean by personal data?

When we talk about “personal data” we mean any information related to you as an individual. With this data, we could potentially identify you directly (e.g. your name) or indirectly by matching that information with other information we may already hold. 

2.3. What data do we collect from you?

During your search for a new job at Envalior or after you have applied, we may gather personal data about you. This will include the following:


·         Name and surname

·         Salutation

·         Email address

·         Home address

·         Language

·         Postal/Zip Code

·         City of residence

·         Phone number

·         Gender

·         Date of birth

·         Passport details, visas, work permits

·         CV and application letter

·         Education and or employment certificates

·         Job title and specialty

·         Background checks (if applicable)

·         Your motivation Letter

·         Disability information (if applicable)

·         Desired salary (if applicable)

·         Bank account number and similar financial details

·         Data from online and in-person assessments (e.g. personality tests, cognitive ability tests)

·         Data provided to us by your referees (the people that you give us to contact)

·         Manager/Cost Centre/ Department/ Skills/ Time in position and data added to your employee profile

·         We collect personal data from you or from external partners (e.g. LinkedIn, job boards and external recruitment agencies) but only to the extent that is relevant to your professional life for the purpose of approaching you for a job offer or confirming information we received during the recruitment process. 

2.4. Why do we use your data?

We use your personal data for one or more of the following purposes:


·         To assess your application for a job and to communicate with you during the recruitment process.

·         To inform you about the status of your application and possible future opportunities (unless you have told us that you do not want us to keep your personal information for such purposes).

·         For general Human Resources administration and management (in case you are or become an Envalior employee).

·         To verify employment reference(s) that you have provided, background checks and related assessments.

·         To protect the health, safety, security and the integrity of dsm-firmenich and its visitors, (IT) facilities and assets, including occupational safety and health when you visit a site; and/or;

·         To comply with corporate and legal requirements (for example, to monitor diversity).

2.5. Updates and local legislation

This Privacy Notice for Recruitment may be modified from time to time to keep up with local and international laws and regulations. In case a conflict rises between this Privacy Notice and local legislation and/or standards, the latter will prevail. English is the official business language of Envalior but this policy will be fully translated to local languages soon.

3. What are labor laws?

For Europe, Envalior complies with the labor laws as set out by the European Union’s recruitment compliance guidelines. In the United States Envalior complies with two main governing bodies who regulate recruitment compliance, the Equal Employment Opportunity Commission (EEOC) and the Office of Federal Contract Compliance Programs (OFCCP).

4. External candidates

If you are an external candidate and you apply for a job posted on the career page of Envalior, your data is processed by our applicant tracking system (ATS) provider ‘Workable’ to allow you to directly upload job application information, including resumes and to connect with Envalior recruiters and hiring managers. The data will also be analyzed, summarized, displayed and processed for your application to be processed in different stages of your recruitment process. 

5. On what legal basis?

For the activities described above and for the recruitment, selection, evaluation and appointment of new employees and the management and administration of the recruitment and HR process, we have the following legal basis for processing our personal data:

·         Our legitimate business interest;

·         To enter into and manage a labor agreement with you;

·         To comply with the law and legal obligations (for example to the extent the law requires the monitoring equality of opportunity and diversity); and/or

·         With your free, specific and informed consent.

6. Who has access to your personal data?

Your personal data will be accessed by the following groups:


  1. Employees of Envalior
    Within Envalior, your personal data will be accessed only by those employees who really need to in order to perform their tasks and duties with a legitimate business need, and only to the extent necessary for the realization of said purposes. Envalior can also share it among its group companies, always on a “need-to-know” basis and only to execute the purposes listed above. Said employees can then only access this data through the ‘workable’ ATS after being provided access to do so.
    Envalior Employees with Access to your personal data; Human Resources (Recruitment, Business Partners, Mobility and Compensation and Rewards), Hiring Managers, interviewers and assessors.
  2. Access by other 3rd Parties
    We may share certain personal data also outside of Envalior and if we do, we have in place, when necessary, technical and organizational measures to ensure that your data is processed exclusively for said purposes and under confidentiality obligations.
    Such third parties are, for example:
  • IT services providers, such as security, hosting, data analysis, email delivery, customer relation management, identity management and other services;
  • Relocation agencies and recruitment agencies;
  • Background checking services (Hireright and Stirling);
  • External suppliers, like Manpower Staffing which supports Envalior with recruitment and acquisition management.

    In case you access other websites from links you find on Envalior.com, please remember that the privacy and cookie notices of these companies are applicable, not ours. Please note that we do not sell your personal information to any third parties.

6.1. Workable (supplier of the Application Tracking System)

Workable is a 3rd Party software as a service (SaaS) technology company that provides the applicant tracking system to Envalior. This is a web based software application that enables the electronic handling of recruitment and hiring needs. This system is accessed by authorized Envalior personnel by Single Sign On via the Intranet. Access is not possible outside of the Envalior IT Network.

6.2. How are applicants made aware of the Privacy Statement and their rights?

In accordance with GDPR, Workable will display a link to the Privacy Notice:

· on Envalior’s careers page

· in the acknowledgement email sent to candidates when an application is received

· in the signature of the email sent to direct contacted candidates, (non-applicants or induvial who have yet to apply)

6.3. Applicant consent to use data

All applicants will be required to read and consent to the privacy notice by checking a box at the end of every application. If this is not checked the application will be cancelled and data will NOT be saved or retained. Applications cannot be submitted without consent.

6.4. Data retention

We will keep your personal data only for the time required to serve the purposes for which it was obtained (and/or to comply with legal requirements). Afterwards, your personal data will be removed, deleted or de-identified.

Application data (see section 2.3) will be automatically deleted following 12 months from date of application. This will include archived applications where candidates are contacted for similar or other suitable opportunities.

If a candidate has been in contact with an Envalior representative within a period 6 months of current date, either by email, events or other activity captured within their application these will excluded from automatic deletion. At any point a candidate has the opportunity to update or revoke consent by connecting to their Workable account. Data will be immediately deleted.

6.5. International transfers

Envalior protects your rights and only stores and transfers your personal data in countries with established appropriate safeguards (such as a recognized legal adequacy mechanism or using standard contractual clauses with third parties) and ensures that it is treated securely and in accordance with this Privacy Notice for Recruitment.

6.6. How do we ensure safety of your data?

Envalior handles your personal data with the utmost care. We have taken various technical and organizational measures to protect your personal data against loss or alteration, unauthorized disclosure, or misuse. In this way, we secure our systems according to the applicable security controls from information security standards. Additionally, we make sure that these measures are in compliance with applicable data protection and data security laws.

7. What are your data protection rights? Can I delete my profile from Envalior?

Your rights include the right to access, modify or delete your personal information (unless it is legally required to retain the information). If you wish to exercise any of these rights, please log in to your account on the Envalior career website or send an email to: Privacy@envalior.com When exercising your rights, the more specific you are, the better we can assist you with your request.  Whether you are our employee or an external candidate, you can always choose to opt out from the Workable system.

External candidates can opt out by just deleting their profiles in the Envalior “Workable-ATS” self service portal or wait for automatic deletion, in case of inactivity for more than 12 months (and by not responding to the reminder via email).

Envalior Employees can raise a ticket in “Ask Eva” to have their data removed from Workable. Please note that if you have your data removed from Workable you will not be able to logon to the system, since the system does not recognize you anymore. If you are concerned about the way Envalior handles your data, please contact us and we will investigate your query. Please also remember that you have the right to lodge a complaint against Envalior with a supervisory authority competent for your country or region.

Note: Employee data will only be within the ATS system if they have applied or are applying for a vacancy. 

8. Your Responsibilities

Please consider that you are responsible for the information you provide to Envalior. We trust that it is truthful, updated and not misleading in any way. If you provide information concerning any other person, such as your referees, you remain responsible for providing such information and ensuring your referee consents to Envalior collecting and processing that information as described in this Privacy Notice.

9. How do you contact us about this Privacy Notice for Recruitment?

If you have a question about Envalior use of your personal data or about this Privacy Notice, we invite you to send an email at Privacy@envalior.com