Data Privacy Notice

The European entities of Mondelēz International Group of companies, herein listed, (“Mondelēz International”) take your privacy seriously.

Mondelēz International is committed to process any personal data we collect (hereafter referred to as “Personal data” or “data”) in full transparency, in accordance with applicable laws and regulations, in order to ensure the accuracy, confidentiality and security of your data.

This privacy notice applies to the data Mondelēz International collect from you as an individual seeking to be employed, currently employed or that was employed by Mondelēz International (in which case this notice applies to the data that was processed during the term of your employment with Mondelēz International).

Mondelēz International collects and uses Personal Data which you provide as part of the recruitment and onboarding processes, together with additional personal data collected throughout the course of your contractual relationship with us (for example, in relation to performance reviews, disciplinary processes, participation in benefit schemes).

The Personal Data that Mondelēz International collects is primarily used for managing its workforce and complying with its contractual obligations. The data may be stored in systems based around the world, even in territories such as the USA that do not provide an equivalent level of protection to privacy. Personal data may be processed by third party service providers acting on Mondelēz International's behalf.

What is personal data?

Personal Data are data about you. They are defined as data which relate to

An identified individual

One who can be identified from that data or

An identifiable individual

One who can be identified from that data in combination with other information which the business has access to.

Why and what data does Mondelēz International collect?

Your Personal Data we process has been provided primarily by you, however we also receive information about you from other employees (for example, with respect to performance reviews) or from your activity (for example, through time attendance systems).

Whenever we process your Personal Data, we do so on the basis of a lawful purpose.

In the majority of cases, the processing of your Personal Data will be justified on one of the following bases:

it is provided for in your contract with us, and therefore necessary to give effect to that contract (for example, collecting bank account details to pay your salary);

it is necessary for us to comply with a legal obligation (for example, disclosing insurance data to social security companies); or

it is in our legitimate interest as a business and/ or as your employer, and our interests are not overridden by your interests, fundamental rights or freedoms (for example, technical Information Technology (IT) security measures)

In exceptional cases, for optional activities not covered by one of the previous bases, we may request your consent to process data.

For further information select the link.

Who might Mondelēz International share your data with?

Mondelēz International may disclose and share some of your data with the following entities during the lifecycle of your employment:

  • Companies of the Mondelēz International Group

  • Third Party suppliers

  • Regulators & Government agencies (for example, Tax or Social Security Authorities)

For further information select the link.

What does Mondelēz International do with your data?

The global nature of our business means that your Personal Data may be disclosed to members of the Mondelēz International Group outside of the European Union (EU). Certain suppliers and service providers may also have personnel or systems located outside of the EU.

Mondelēz International takes steps to ensure that the data collected under this privacy notice are processed according to the provisions of this notice and the requirements of applicable law wherever the data is located.

When Mondelēz International transfers data from the European Economic Area and Switzerland to other countries, some of which have not been determined by the European Commission to have an adequate level of data protection, Mondelēz International shall only do so in accordance with the law.

How long does Mondelēz International keep your data?

Mondelēz International retains your personal data only for as long as it believes is necessary to fulfill the purposes for which the personal data was collected, usually for the duration of your employment and for a period thereafter as legally required or permitted by applicable law.

For further information please select the link

How does Mondelēz International secure your data?

Mondelēz International is committed to protecting the security of your personal data. Mondelēz International uses a variety of security technologies and procedures to help protect your personal data from unauthorized access, use, modification or disclosure to an appropriate level depending upon the sensitivity of the data.

Mondelēz International further contractually ensures that any third party processes your personal data in a secure way, in order to ensure its confidentiality and integrity.

What rights do I have about the data Mondelēz International holds about me?

Should you have any questions relating to this privacy notice or to the extent entitled by applicable law,

or to exercise your right to access your data

or to otherwise rectify, erase, restrict processing of; object to the processing of, or benefit from the portability of your data,

you may contact Mondelēz International in one of the following ways:

By sending an email to: DataProtectionOfficeMEU@MDLZ.com

Or by writing a letter to your local Human Resources Department

Who is Mondelēz International's Data Protection Officer?

You may contact Mondelēz International's Data Protection Officer (DPO) or the DPO office securely and confidentiality at any time if you have general concerns about the processing of your Personal Data, or any data protection issue. You may contact the DPO in the following way:

By sending an email to: DataProtectionOfficeMEU@MDLZ.com

Mondelēz International draws your attention to the fact that you are entitled to lodge a complaint with a supervisory authority should you consider that Mondelēz International does not process your data in accordance with applicable laws and regulations and did not respond to your request in a satisfactory way.

Why and what data does Mondelēz International collect?

Whenever we process your Personal Data, we do so on the basis of a lawful purpose.

In the majority of cases, the processing of your Personal Data will be justified on one of the following bases:

it is provided for in your contract with us, and therefore necessary to give effect to that contract (for example, collecting bank account details to pay your salary);

it is necessary for us to comply with a legal obligation (for example, disclosing insurance data to social security companies); or

it is our legitimate interest as a business and/ or as your employer, and our interests are not overridden by your interests, fundamental rights or freedoms. (for example, technical Information Technology (IT) security measures)

In exceptional cases, we may request your consent to process data.

The purposes for which we process your Personal Data include:

To create an employee record and manage day-to-day aspects of your employment, including: administering working hours; paying salary, administering benefits; creating and maintaining records relating to your absence from work; creating and maintaining training records; reviewing and reporting on your performance at work; resolving grievances and conducting disciplinary processes; managing professional certifications; carrying out recreational or leisure activities;

To administer your employment relationship and employment termination, and provide references, where so requested or allowed by you;

  • Personal Details - such as your name and first name/s, degree/title, date and place of birth, gender, nationality, social security or national insurance number, personal contact details, marital status, family members/ dependents, citizenship;

  • Basic Work Details - such as your work contact details (corporate email address and telephone number), employee number, photograph, job title, job description, assigned business unit or group, reporting lines, primary work location, working hours, employment status, and your terms and conditions of employment;

  • Professional Qualifications - such as your professional certifications and language skills;

  • Recruitment/Selection Data - such as any Personal Data contained in your CV, resumes and application forms, references, record of interview or interview notes, and selection and verification documentation;

  • Disciplinary and Grievance Data - such as any personal data contained in records of allegations, investigations and proceeding records and outcomes;

  • Employee Claims, Complaints and Disclosures Data - such as personal data in the subject matter of employment based litigation and complaints, employee involvement in incident reporting and disclosures;

  • Termination Data - such as dates and reason for leaving, termination arrangements and payments, exit interviews and references;

  • Survey Data - such as data relating to surveys with regards to job satisfaction (such as position, superior, work atmosphere, company);

To assess your suitability for your current position or other position within the Mondelēz International Group, including staffing and planning as well as succession plans;

  • Performance Management Data - such as colleague and manager feedback, appraisals, outputs from talent programs and formal and informal performance management processes;

  • Training and Development Data - such as data relating to training and development needs or trainings received;

To administer your compensation and benefits and insurance and pension plans;

  • Remuneration and Benefits Data - such as details of your payment and benefits package, salary, bonus, long term incentives, currency, bank account details, cost center, company credit card data, tax data and third party benefit recipient data;

To maintain emergency contact data;

  • Emergency Contact Details - such as name and contact details of an emergency contact

To manage travel and expense affairs;

To manage health and safety at work and report on incidents;

To create and administer IT (including business telephones, email and internet use) access rights;

To create building access rights and to manage Closed Circuit Television (CCTV) footage;

To monitor employee use of IT and communications, consistent with the law and with internal Mondelēz International Group policies;

  • Monitoring Data - such as identifiable images contained in CCTV footage, system and building login and access records, keystroke, download and print records, call recordings, data caught by IT security programs and filters;

To enable the management of corporate transactions, such as any merger, sale, reorganization, transfer of Mondelēz International’ assets or businesses, acquisition or, any bankruptcy or similar event.

The purposes for what we may also process Special Categories of data may be:

To manage:

  • Criminal Records Data - where permitted/ required under local law in relation to recruitment for specific roles;

  • Equality and Diversity Data - where permitted under local law and provided voluntarily, data regarding race, religious belief and sexuality;

To manage and report on incidents such as medical records and personal data in incident reports;

We may also process any other Personal Data which you choose to disclose to Mondelēz International during the course of your contractual relationship with us, whether verbally or in written form (for example, in work emails).

Who might Mondelēz International share your data with?

Mondelēz International may disclose and share some of your data with the following entities during the lifecycle of your employment:

  • Companies of the Mondelēz International Group

  • Third Party suppliers

  • Regulators & Government agencies (for example, Tax or Social Security Authorities)

We routinely share your Personal Data with members of the Mondelēz International Group where required in order to run global processes, carry out group-wide reporting, or make decisions about hires or promotions. The Mondelēz International Group has an intra-group data transfer agreement in place which regulates cross-border transfers of your Personal Data within it.

We use a number of third party suppliers to help us provide business services. These third parties may have access to or merely host your Personal Data, but will always do so under our instruction and subject to a contractual relationship. When third parties transfer your Personal Data outside of the EU, within territories (including the USA) which may not offer an equivalent of protection to privacy as applicable within the EU, we will take steps to verify that your Personal Data receives an adequate level of protection either by entering into data transfer agreements or by ensuring that third parties are certified under appropriate data protection schemes (e.g. EU-US Privacy Shield).

Some third parties to whom we may provide Personal Data, for instance private health insurance providers, are data controllers in their own right, and you should refer to their own privacy notices and policies in respect of how they use your Personal Data.

We may also be required to disclose your Personal Data to third parties:

in response to orders or requests from judicial courts, regulators, government agencies, or parties to a legal proceeding or public authorities; or

to comply with regulatory requirements; or

as part of a dialogue with a regulator.

How long does Mondelēz International keep your data?

As outlined above, Mondelēz International retains your personal data only for as long as it believes it is necessary to fulfill the purposes for which the personal data was collected, usually for the duration of your employment relation and for a period thereafter as legally required or permitted by applicable law (including, for the purpose of meeting any legal, accounting or other reporting and regulatory requirements or obligations).

To understand further how these periods are defined please see the Records Management intranet site.

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