Updated March 7, 2022
Privacy Notice for the Processing of Candidates’ Personal Data
Welcome! We are delighted that you may be interested in exploring a job opportunity with us. Whirlpool Corporation and its affiliated entities (collectively, “Whirlpool”) are committed to protecting the privacy and security of your personal information.
1. What is the purpose of this document?
This Privacy Notice describes how Whirlpool collects and processes your personal information when you use the website www.whirlpoolcareers.com, jobs.whirlpool.com, and other Whirlpool job-related websites linked from those sites (collectively, “Website”), when you submit a CV, application, or related materials to Whirlpool through other channels such as career fairs or through email, and when you otherwise explore or apply for a job with Whirlpool, in accordance with the EU General Data Protection Regulation (“GDPR”), the General Personal Data Protection Law (“LGPD”), and any other applicable local data protection laws (collectively, the “Data Protection Laws”). It is important that you read this Privacy Notice, so that you are aware of how and why Whirlpool is using your personal information and what your rights are under Data Protection Laws.
Whirlpool Corporation is the data controller of the processing of your personal data in connection with the Website and related backend databases and systems used to manage and maintain your candidate profile. This means that Whirlpool Corporation is responsible for deciding the purposes and means of the processing of your personal data on these systems. Should you apply for a job with or engage in recruiting interactions with a different Whirlpool company, your data will be processed also by that different company which will act as a joint data controller of your personal data processed in the context of the management of your application and recruiting. Please see section 12 below for data controller(s) and data protection officer details and contacts.
Certain provisions of this Privacy Notice may only apply to candidates who are located in European Union (EU) member countries, UK, and Switzerland.
2. Data protection principles
Whirlpool will comply with Data Protection Laws, which means that your data will be:
- used lawfully, fairly and in a transparent way
- collected only for valid purposes that Whirlpool has clearly explained to you and not used in any way that is incompatible with those purposes
- relevant to the purposes Whirlpool has told you about and limited only to those purposes
- accurate and kept up to date
- kept only as long as necessary for the purposes Whirlpool has told you about
- kept securely.
3. How is your personal information collected
Whirlpool collects personal information about candidates from the following sources:
- you, the Website user and/or candidate, either through the Website or other channels through which you submit application materials (such as by email or career fairs)
- third parties, such as for example recruitment agencies and your referees
- publicly accessible sources (e.g., business social networks)
4. The kind of information Whirlpool holds about you
In connection with your application, Whirlpool will collect, store, and use the following categories of personal information (“Personal Data”):
- Information related to your use of the Website, such as:
- your IP address
- navigation data on the Website
- information about your browser and device
- information collected through cookies, pixel tags and other technologies
- location information determined based on your IP address or other geolocation technologies
- information you submit to us through the Website
- your CV, including information we extract from your CV
- your application for a job with Whirlpool and other information you submit in relation to your application, as well as the information you have provided to Whirlpool in your application, CV, and covering letter including name, title, address, telephone number, personal email address, date of birth, gender, employment history, skills, and qualifications
- any information (including any survey or test results) you provide during the application, recruiting, interview, or hiring stages
- publicly available information about you on business social networks (such as LinkedIn or Indeed)
- Information related to your use of the Website, such as:
Depending on your jurisdiction, we may collect certain special categories of Personal Data about you, such as racial / ethnic origin or disability status, as described below under the “Special Categories of Data” section.
5. Purposes and legal basis for the processing
We will use the Personal Data we collect about you to:
- allow you to benefit from the features offered by the Website.
We will provide you with the functionalities offered by the Website, including the ability to browse and apply for job openings, find and receive recommendations for job openings that may be well suited for you, learn more about Whirlpool, and operate and navigate the Website. Whirlpool will process your Personal Data on the basis of its legitimate interest to maintain and improve the Website functionalities, the users’ interaction experience, and the effectiveness of Whirlpool’s HR program, which will be appropriately balanced with your interests
- allow you to create your account and apply for a job with Whirlpool.
We will assess your skills, qualifications, and suitability for the work and role you apply for by creating your account and populating your candidate profile. We may pre-populate aspects of your candidate profile by using data extracted from the CV you upload. We will process your Personal Data to decide whether to contact you, invite you for an interview, or carry out any other recruitment and hiring activities. If we decide to further consider or offer you a role, we may send you follow-up communications and take up references before confirming your appointment.Without prejudice to any legal obligation for the above purposes, Whirlpool will process your Personal Data on the basis of pre-contractual measures adopted on your request when you create your account and/or submit your application or CV for a position (i.e. taking steps at your request that are necessary for evaluating or entering a potential employment agreement with you). Failure to provide the Personal Data for these purposes may result in Whirlpool being unable to process your application or extend you an offer of employment
- allow you to use AI based functionality to create a candidate profile and browse potentially suitable roles by uploading your CV
We allow you to upload your CV in order to browse available roles for which you may be a match. When you upload your CV, we will create a candidate profile for you (even if you have not applied for a role) so that you can browse roles for which you may be well matched and so we can assess you for and recommend to you suitable current and future roles. We may recommend positions that we believe are well suited to your skills — these positions are determined based on artificial intelligence algorithms, including computer-determined correlations between aspects of your application and skills necessary for available positions, computer-determined correlations between aspects of your application and the applications of other prior candidates that were found to be well suited to particular types of positions, keyword-based matching and analysis, public information regarding you available on social media (e.g. LinkedIn) and other related functionality. We may communicate to you about current and future roles for which we think you may be a good fit.The use of this functionality will not have a significant impact on you, taking into account that it is provided as a benefit to help streamline your search and that you are also provided with the opportunity to search jobs on the Website through a selection of the relevant filters. Whirlpool will process your Personal Data for this purpose on the basis of your consent. Please see Section 11, below, for information on how to revoke consent. Failure to provide the Personal Data for this purpose will result in the inability for Whirlpool to provide you with the use of this functionality.
- identify the most suitable candidates and professionals for a given role.
We use automated or artificial intelligence-based systems to analyse the Personal Data we hold about candidates and other professionals and make decisions based on that data. Such technology is intended to significantly reduce the time needed to determine when candidates are a potential match for the jobs offered. We perform this automatic processing in order to help recruiters to match candidate/professional profiles to job opportunities by suggesting most suitable profiles; to this extent, decisions are not based solely on automated processing.Whirlpool will process your Personal Data on the basis of its legitimate interest to improve and make its HR processes more effective. Failure to provide the Personal Data for these purposes may result in Whirlpool being unable to identify suitable positions for you or extend you an offer of employment
- keep you updated on open positions that match your profile.
We send communications via email to update you on job positions that may be of your interest based on your candidate profile. Whirlpool will process your Personal Data for this purpose on the basis of your consent and you may unsubscribe at any time. Failure to provide the Personal Data for this purpose will have the result of you not receiving communications about new jobs offers by Whirlpool.
- other recruitment and (if you are offered a role) hiring related activities
We will assess your skills, qualifications, and interests against our current opportunities; collect public information regarding you available on social media (e.g. from LinkedIn and other similar sites); verify your information and carry out reference checks or background checks (where permitted) if you are offered a job; assist you upon request with issues related to immigration or permits; and conduct other activities related to recruiting or (if you are offered a role) hiring processes. Whirlpool will process your Personal Data on the basis of pre-contractual measures adopted on your request (i.e. taking steps at your request that are necessary for evaluating or entering a potential employment agreement) as well as our legitimate interest in making our HR processes more effective. Failure to provide the Personal Data for this purpose may result in Whirlpool being unable to process your application or extend you an offer of employment.
Whirlpool may also process the Personal Data as we believe necessary: (1) if we determine a policy violation has occurred, to enforce our rights, or to enforce agreements; (2) if we believe such processing is necessary to identify, contact, or bring legal action regarding the rights and property of Whirlpool or its affiliates; (3) to enforce our rights or protect against unauthorized access to our systems or other inappropriate use of our services, products, or other services; (4) to comply with laws, regulations, court orders and subpoenas or similar requests for information by authorities; (5) to protect your safety and the safety of others; and (6) to assist us in fraud prevention or investigation, all on the basis of its legitimate interest in the continuation of its commercial activities and the protection of its rights.
6. Special categories of Personal Data about you
Depending on your jurisdiction and where permitted by law, we may also capture some special categories of Personal Data about you (e.g. information relating to your racial or ethnic origin, religious of philosophical beliefs, trade union membership, physical or mental health or condition, sexual orientation, political opinions, disability and invalidity, pregnancy, membership to protected categories), where this has been provided or made publically available by you or can be inferred from your application materials. You are invited not to submit Personal Data included in the above special categories, unless it is necessary in order to achieve a specified purpose (to this extent, see below). In jurisdictions where we collect special categories of Personal Data and where a basis for processing is required, this data is processed based on either necessity for compliance with a legal obligation, or your explicit consent.
To this extent, we may process special categories of Personal Data where it is necessary to ensure that we comply with our regulatory obligations with regard to our hiring (e.g., in order to ensure Whirlpool compliance with law provisions concerning the hiring of people with disability, etc.), to ensure meaningful equal opportunity monitoring and reporting, to comply with other applicable legal or regulatory requirements.
Moreover, we may process special categories of Personal Data to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made to enable our candidates to apply for jobs with us, to be able to take online/telephone assessments, to attend interviews/assessment centers and to prepare for starting at Whirlpool (if successful).
As far as it is permitted under applicable laws, Whirlpool may process special categories of Personal Data in support of its diversity and inclusion objectives. This may include making inferences about the gender or racial or ethnic origin of a candidate based on application materials.
7. Information about criminal convictions
If we would like to offer you a specific role, we may process information about your criminal convictions history, if the law requires us to do so and to the extent permitted by the applicable law.
8. Data sharing
Your Personal Data may be shared on a need to know basis with:
- Other Whirlpool companies
- suppliers (e.g., recruitment agencies, IT service providers, and other service providers).
- individuals that you name as references or individuals that referred you for a position
- other businesses in connection with a merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings)
- law enforcement or governmental authorities to comply with laws, regulations, court orders, subpoenas, and similar requests
Any transfer of your personal data outside of your local jurisdiction will be carried out in compliance with applicable Data Protection Laws. For transfers of personal data outside the European Union in particular (both within and outside Whirlpool), such transfers are carried out based on the following suitable safeguards in accordance with GDPR:
- When the European Commission has issued an adequacy decision; or
- appropriate safeguards have been provided by or to the Whirlpool company exporting your personal data including but not limited to standard data protection clauses. Without prejudice to the foregoing, transfer based on standard data protection clauses is accompanied by additional organizational and technical measures, designed to ensure an adequate level of protection of your personal data.
9. Data security
The security of your data is a priority for us. Whirlpool has put in place appropriate security measures designed to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, Whirlpool limits access to your Personal Data to those employees, suppliers and other third parties who have a business need-to-know. They will only process your Personal Data in accordance with our instructions and subject to a duty of confidentiality.
10. Data retention
Personal Data is kept for the entire duration of the recruitment process and also afterwards for a period considered adequate, consistent with the laws of the applicable jurisdiction (for example, 2 years after conclusion of an unsuccessful job application process for Italy), and not exceeding what is necessary to pursue the purposes of the processing. For more information on the applicable retention periods, please contact us using the contact information provided below. After such time, your Personal Data will be deleted from the database or anonymized, unless you obtain a job at Whirlpool, update your profile or unless litigations, competent authorities requests or applicable legal provisions.
11. Your rights under the Data Protection Laws
To the extent this is provided for under the applicable Data Privacy Laws for your location, you may have the right to:
- be informed on the purposes and methods of the processing of your Personal Data
- request access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Data Whirlpool holds about you
- request of update or correction of your Personal Data that is incomplete or inaccurate
- object to processing of your Personal Data on grounds relating to your particular position where Whirlpool is relying on legitimate interests (or those of a third party). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms
- request the restriction of processing of your Personal Data. This enables you to ask Whirlpool to suspend the processing of Personal Data about you where one of the grounds under art. 17 GDPR applies
- receive in a structured, commonly used and machine-readable format Personal Data concerning you and provided by you, as well as to transmit those Personal Data to another controller, in the cases and within the limits referred to in art. 20 GDPR, where applicable
- request erasure of your Personal Data, where one of the grounds under art. 17 GDPR applies
- withdraw given consent to the processing of your Personal Data and/or special categories of Personal Data at any time. without prejudice to the lawfulness of the processing based on your consent before its withdrawal.
- obtain information about third parties with whom your data has been shared.
Where available, these rights (as well as any other right provided for by applicable Data Protection Laws) may be exercised by sending an e-mail to:
Whirlpool may need to request specific information from you to confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is another appropriate security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.
Without prejudice to any administrative or legal remedy, you also have the right to lodge a complaint to the competent supervisory Authority, if you believe that processing of your data breaches the Data Protection Laws.
12. Data Controller and Data Protection Officer details and contacts
The data controller of the Personal Data of the Website users is Whirlpool Corporation, with registered office in 2000 North, M63, Benton Harbor, MI, USA. Should you apply for a job at a different Whirlpool company, the data controller of the Personal Data is Whirlpool Corporation jointly with that different company.
- As for candidates in Europe, this is Whirlpool EMEA SpA with registered office in Via Carlo Pisacane, 1 Pero, 20016
- As for candidates in Brazil, this is Whirlpool S.A with registered office in Rua Olympia Semeraro, 675 – Jardim Santa Emilia, Sao Paulo – SP 04183-901, Brazil
If you have any questions about this Privacy Notice please contact firstname.lastname@example.org (Europe, Middle East, and Africa users), email@example.com (Brazilian users), or firstname.lastname@example.org (all other users).
13. Amendments and Updates
We keep this Privacy Notice under regular review. We may update this Privacy Notice to reflect changes to our privacy practices. We encourage you to periodically review our Privacy Notice for the latest information on our privacy practices.