Privacy Notice for the Processing of Candidates’ Personal Data

Last updated: December 10, 2019

What is the purpose of this document?

Whirlpool is committed to protecting the privacy and security of your personal information.

This Privacy Notice describes how Whirlpool collects and uses your personal information, in accordance with applicable laws, including the EU General Data Protection Regulation (“GDPR”) and any other applicable local data protection laws (along with the GDPR, 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 (“Whirlpool”) is Controller of the processing of your Personal Data. This means that Whirlpool is responsible for deciding how it holds and uses your Personal Data.

Certain provisions of this Privacy Notice may only apply to candidates who are located in European Union (EU) member countries, UK, and Switzerland.

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

How is your personal information collected

Whirlpool collects personal information about candidates from the following sources:

  • you, the candidate
  • third parties such as for example recruitment agencies and your named referees
  • publicly accessible sources.

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:

  • the information you have provided to Whirlpool in your application, curriculum vitae and covering letter including name, title, address, telephone number, personal email address, date of birth, gender, employment history, qualifications
  • any information you provide during an interview
  • any test results

Special categories of Personal Data about you

During the process 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 – including health and sickness records -, sexual orientation, political opinions, disability and invalidity, pregnancy, injury, membership to protected categories), where this has been provided or made publically available by you or can be inferred from your CV. We may process certain special categories of information about you (e.g. information about a physical or mental health or condition) in order to make reasonable adjustments to enable our candidates to apply for jobs with us, to be able to take online/telephone assessments, to attend interviews/assessment centers, to prepare for starting at Whirlpool (if successful) and to ensure that we comply with regulatory obligations placed on us with regard to our hiring (e.g., in order to ensure Whirlpool compliance with law provisions concerning the hiring of people with disability). You are invited not to submit personal data included in the above special categories, unless it is necessary in order to achieve the above mentioned purposes.

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 law.

How Whirlpool will use your Personal Data

We will use the personal information we collect about you to:

  • assess your skills, qualifications, and suitability for the work and role
  • carry out reference checks
  • communicate with you about the recruitment process
  • keep records related to the hiring process
  • comply with legal or regulatory requirements (e.g., for the processing of certain personal data about you pertaining to special categories, in order to comply with the applicable laws and regulations concerning the hiring of people with disability)
  • comply with legitimate interests pursued by Whirlpool or a third party and your interests and fundamental rights do not override those interests
  • protect vital interests of a person
  • comply the public interest or for official purposes

We may use special categories of personal information in the following ways:

  • we may use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview
  • we will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting

We also need to process your Personal Data to decide whether to enter into an employment contract with you.

Having received your application form, your CV and covering letter and the results from tests, where applicable, Whirlpool will then process that information to decide whether you meet the requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to contact you for an interview, we will use the information you provided. If we decide to offer you the role, we may then take up references before confirming your appointment.

If you fail to provide your Personal Data

If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully.

Automated decision-making

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.

Data sharing

Your Personal Data may be shared on a need to know basis with:

  • the internal Whirlpool’s personnel, authorized to the data processing (for example, the personnel of the HR and the offices involved in
  • the evaluation procedures from time to time),
  • Whirlpool Group companies
  • external entities such as public entities and suppliers (e.g., recruitment agencies and other service providers)

Some of the above recipients may be located abroad, also outside the European Union in countries which do not guarantee an adequate level of data protection. Whirlpool allows access to data to recipients located in third countries for the purposes outlined above after implementation of the precautions provided by the GDPR for a secure data transfer. In particular, it must be noted that Whirlpool Corporation, established in the United States, joined the EU-US Privacy Shield program agreed by the European Commission and the United States Department of Commerce. In other cases, Whirlpool will verify the presence of an adequacy decision or that the third parties have group rules approved by the competent authorities or that they have entered into specific agreements with Whirlpool, such as the standard contractual clauses approved by the European Commission.

Data security

Whirlpool has put in place appropriate security measures 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.

Data retention

Personal Data is kept for the entire duration of the recruitment process and also afterwards for two years. After such time, your Personal Data will be deleted from the database or anonymized, unless you update your profile or unless litigations, competent authorities requests or applicable legal provisions.

Your rights under the Data Protection Laws

You 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 the Personal Data that Whirlpool holds about you. This enables you to have any incomplete or inaccurate information Whirlpool holds about you corrected, though Whirlpool may need to verify the accuracy of the new data you provide;
  • object to processing of your Personal Data where Whirlpool is relying on legitimate interests (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. 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, for example if you want Whirlpool to establish its accuracy or the reason for processing it;
  • request the transfer of your Personal Data to another party;
  • request erasure of your Personal Data. This enables you to ask Whirlpool to delete or remove Personal Data where there is no good reason for Whirlpool continuing to process it. You also have the right to ask Whirlpool to delete or remove your Personal Data where you have exercised your right to object to processing; note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;
  • withdraw given consent, where you may have provided your consent to the processing of special categories of personal information. Once Whirlpool has received notification that you have withdrawn your consent, Whirlpool will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
  • lodge a complaint with the Data Protection Authority of Italy or the country where you are based.

If you want to review, verify, correct, object to the processing, request erasure or that we transfer a copy of your Personal Data to another party, to withdraw your consent please send an e-mail to talent@whirlpool.com

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.

Also, you may

  • update, correct or modify your data file by clicking the “Update Application” link displayed on the careers website
  • instruct the Company to remove you from its programs you have subscribed to by clicking on the “eRecruiting Data Privacy” link found at the bottom of the careers page.

Data Controller and Data Protection Officer details and contacts

The data controller of your data will be Whirlpool Corporation, with registered office in 2000 North, M63, Benton Harbor, MI, USA.

If you have any questions about this Privacy Notice please contact talent@whirlpool.com. You may also contact the Whirlpool Chief Privacy Officer by sending an email to whirlpool_privacy@whirlpool.com, or the EMEA Data Protection Officer at data_protection_emea@whirlpool.com.