Who are we?
We are a member of Philip Morris International. Our details (name, address, etc.) will have been given to you separately at the time of (or to confirm) the collection of information about you, for example, in a notice on an app or a website or in an e-mail, containing a link to this notice.
How do we collect information about you?
We may collect information about you in various ways.
- You may provide us with information directly (e.g. when creating an account, creating a candidate profile, applying for a job, attending an interview, completing a test/assessment, sending an e-mail, or making a call to us).
- We may collect information automatically (e.g. when you use a PMI app or website).
- We may acquire information from third parties (e.g. from recruitment agencies, reference providers, (where permitted by law) background screening providers and publicly-available sources, such as a company website, internet searches or social media platforms such as LinkedIn).
In this notice, we refer to all the methods by which you are in contact with us as “PMItouchpoints”. PMI touchpoints include both physical (for example, offices, retail outlets and events), and digital (for example, apps and websites).
What information about you do we collect?
We may collect various types of information about you:
- information necessary to manage and administer our relationship with you (including, where we agree, to reimburse certain expenses to attend interview) and to run our business, including to meet our legal and regulatory obligations (e.g. verifying your identity, your right to work, application details and, where permitted by law, your suitability for a job using background checks)
- information you give us in your candidate profile, job application, forms or surveys
- information necessary to assess your eligibility for a role, shortlist and select candidates
- information about your visits to our offices and attendance at events
- where applicable, information necessary to offer you a job and on-board you (such as issuing an offer, drafting an employment contract, providing benefits information and arranging access to systems)
- information gathered as part of our monitoring of the recruitment process
- information you give us in calls you make to us or e-mails you send to us
- information about your preferences, interests and career aspirations
- information gathered as part of business analytics and improvements
For what purposes do we use information about you, and on what legal basis?
In this section, we describe the purposes for which we use personal information. However, this is a global notice, and where the laws of a country restrict or prohibit certain activities described in this notice, we will not use information about you for those purposes in that country.
Subject to the above, we use information about you for the following purposes:
- perform checks on identity, role eligibility and right to work
- verify employment history, qualifications, experience and references
- where permitted by law, perform candidate vetting and background screening
- perform recruitment and selection, including interviews, assessments, and psychometric profiling, shortlisting, job offer and benefits (where applicable)
- business administration, including record keeping obligations
- where applicable, administration of reimbursement of expenses to attend interview
- where applicable, pre-employment administration and management, including preparation of contractual and non-contractual documents, and arranging systems and building access
- monitoring of the recruitment process
- for business analytics and improvements, including for our recruitment process, events, digital PMI touchpoints, PMI systems and devices and the information that we (or our affiliates) provide to job candidates
The legal basis for our use of information about you is one of the following (which we explain in more detail in the “find out more” section):
- compliance with a legal obligation to which we are subject
- to take steps at your request prior to entering into a contract
- a legitimate business interest that is not overridden by interests you have to protect the information
- where none of the above applies, or where law requires it, your consent (which we will ask for before we process the information)
Do we make any automated decisions?
We may make automated decisions on any of the matters set out in this notice (for example, whom to include on a shortlist for interview). If we do this, we will draw this to your attention at the time, together with information about the logic involved in the decision, as well as the significance and the envisaged consequences for you of such use of information about you.
Where might information about you be sent?
As with any multinational organisation, PMI affiliates transfer information globally. When you upload information to the job search platform, you provide it to all PMI affiliates, each of which may process it for its own recruitment purposes. This is the case even where you respond to a job posting that mentions a particular PMI affiliate. Accordingly, information about you may be transferred globally (for example, if you are in the European Economic Area ("EEA"), your information may be transferred outside the EEA; if you are in Australia, you information may be transferred outside Australia).
How do we protect information about you?
We implement appropriate technical and organisational measures to protect personal information that we hold from unauthorised disclosure, use, alteration or destruction. Where appropriate, we use encryption and other technologies that can assist in securing the information you provide. We also require our service providers to comply with equivalent data privacy and security requirements.
How long will information about you be kept?
We will retain information about you for the period necessary to fulfil the purposes for which the information was collected. After that, we will delete it. The period will vary depending on the purposes for which the information was collected. Note that in some circumstances, you have the right to request us to delete the information. Also, we are sometimes legally obliged to retain the information, for example, for tax and accounting purposes.
What rights and options do you have?
You may have some or all of the following rights in respect of information about you that we hold:
- request us to give you access to it;
- request us to rectify it, update it, or erase it;
- request us to restrict our using it, in certain circumstances;
- object to our using it, in certain circumstances;
- withdraw your consent to our using it;
- data portability, in certain circumstances; and
- lodge a complaint with the supervisory authority in your country (if there is one).
We offer you easy ways to exercise these rights, such as “unsubscribe” links, or by contacting people.culture@pmi.com or by using the contacts in the paragraph “who should you contact with questions?” at the end of this notice.
Country-specific additional points
According to which country you are in, you may have some additional rights.
Who should you contact with questions?
If you have any questions, or wish to exercise any of your rights, you can
- contact us at people.culture@pmi.com, or (if you are an employee in Malaysia) you can contact Manager MOD on tel.: +603 2080 5500; or
- contact the relevant PMI affiliate’s data protection officer (if it has one), whose contact details you can find here .
Contact details will also be given in any communications that a PMI affiliate sends you and on the relevant OnePlace intranet homepage.
If your country has a data protection authority, you have a right to contact it with any questions or concerns. If the relevant PMI affiliate cannot resolve your questions or concerns, you also have the right to seek judicial remedy before a national court.
Changes to this notice
We may update this notice (and any supplemental privacy notice), from time to time. Where the law requires it, we will notify you of the changes; further, where the law requires it, we will also obtain your consent the changes.
Last modified 29 March 2019. You can find previous versions of this notice here.