What is the purpose of this document?

Panyelskaya Oil & Gas Company, a limited liability company whose registered office is at Office 180, House 3, Sovetskaya Str., Komi Republic, 169316, Ukhta, Russian Federation, main state registration number 1121106000938 is a “data controller”. This means that we are responsible for deciding how we hold and use personal data about you. You are being asked to consent to the processing of your personal data in accordance with this privacy notice because you are applying for work (whether as an employee or otherwise) with Panyelskaya Oil & Gas Company or one of its subsidiaries (together, the ”Group”). References in this privacy notice to “our”, “us” or “we” are to the Group. This privacy notice provides you with certain information that may be required under the General Data Protection Regulation ((EU) 2016/679) (GDPR).

Data protection principles

We will comply with data protection law and principles, which means that your data will be:

• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Kept only as long as necessary for the purposes we have told you about.
• Kept securely.

The kind of information we hold about you

In connection with your application for work with us, we will collect, store, and use the following categories of personal data about you:

• The information you have provided to us in your curriculum vitae and any covering letter.
• The information you have provided on our application form, including name, address, telephone number, personal email address, employment history, qualifications.
• Any information you provide to us during an interview.
• Any other information included as part of the application process, such as technical competence test results.

We may also collect, store and use the following types of more sensitive personal data:

• Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
• Information about your health, including any medical condition, health and sickness records.
• Information about criminal convictions and offences.

How is your personal data collected?

We collect personal data about candidates from the following sources:

• You, the candidate.
• Third parties, such as recruitment agencies that you have involved in your application or referees nominated by you.
• Our employees as a result of an internal recommendation or referral or as a result of our recruitment process.
• Information technology under our control, such as our website and email communications sent to and from us.

How we will use information about you

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

• Assess your skills, qualifications, and suitability for the role.
• Carry out background and reference checks, where applicable.
• Communicate with you about the recruitment process.
• Keep records related to our hiring processes.
• Comply with legal or regulatory requirements.

It is in our legitimate interests to decide whether to appoint you to a role since it would be beneficial to our business to appoint someone to that role.

We also need to process your personal data to decide whether to enter into a contract  with you.

If you fail to provide 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. For example, if we requires references for this role and you fail to provide us with relevant details, we will not be able to take your application further.

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

Why might you share my personal data with third parties?

We may share personal data we hold with third party providers of business, legal and professional services, judicial and other authorities.

If in the future we reorganize or transfer all or part of our business, we may need to transfer your personal data to third parties.

Cross border transfers of personal data

In order to deal with your application, we need your consent to transfer your personal data to locations outside the European Economic Area (“EEA”) which may not provide the same level of data protection as within the EEA. Where this is the case, we will implement appropriate measures to ensure that your personal data remains protected and secure.

Data security

We have 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, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data retention

How long will you use my information for?

We will not keep your personal data for longer than is necessary for the purpose. This means that data will be destroyed or erased from our systems when it is no longer required for a legal or business reason. For example, we will keep a record of any application submitted to us for at least twenty-four months.

Rights of access, correction, erasure, and restriction

Your rights in connection with personal data

Under certain circumstances, by law you have the right to:

• 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 we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
• Object to processing of your personal data where we are relying on a legitimate interest (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. You also have the right to object where we are processing your personal data for direct marketing purposes.
• Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal data to another party.

If you want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact the Human Resources Department in writing.

Data protection officer

We have appointed a data protection manager, (dpo@panyelskaya.ru) to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal data, please contact the data protection manager. You may also have the right to file a complaint with the local data protection authority.

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