Del Monte Saudi Arabia Factory Co. Ltd. & Del Monte Foods Saudi Arabia Co. Ltd. – Recruitment Privacy Notice

1.1 Your personal data is collected by Del Monte Saudi Arabia Factory Co. Ltd. & Del Monte Foods Saudi Arabia Co. Ltd. (“we”/”us”/”our”).

1.2 We care about the confidentiality and privacy of your personal data and recognise the need for applying the appropriate protection measures in accordance with relevant laws, regulations and policies.

1.3 This Privacy Notice has been formulated in accordance with the Personal Data Protection Law and Implementing Regulations in the Kingdom of Saudi Arabia (“KSA”) to help you understand the nature of personal data we collect from you and how this personal data will be treated by us.

1.4 Please read this carefully to understand how we use and protect the personal data which you provide. Throughout this Privacy Notice we use the terms “process” and “processing” to cover all activities involving your personal data including collecting, storing, sharing, accessing, using, transferring and disposing of the personal data.

2.1 Our contact details are as follows:

Name: Del Monte Saudi Arabia Factory Co. Ltd. & Del Monte Foods Saudi Arabia Co. Ltd.
Position: KSA Data Privacy Officer
Email: [email protected]

2.2 If you have any questions or complaints in relation to the use of your personal data or this Privacy Notice, you can contact us at these addresses.

3.1 We collect the information below about you during the recruitment process:

• Contact details, including: your name, title, business line, business title, personal email address, home address and personal phone number.
• Personal details, including: your gender, marital status, date of birth, bank details, past travel history, a photo image of you and national identifiers e.g. NI number and licences. We also collect information of any of your relatives and friends names if they are employed by us.
• Information provided during the application process in your CV (such as any application form, covering letter and information obtained during the interview process) which will include certificates and details of your expertise, experience, education, joining date, training, career and employment history, languages, referrals and interview feedback.
• Right to work information, including: background check information, residencies, immigration status, passport details, visa / right to work details, birth place and nationality details.
• Information collected or created by us during the recruitment process, including interview notes, salary information and correspondence between us.
• Background checks: we carry out background checks to identify if you have any criminal convictions / offenses as part of the recruitment process for specific employees.
• Information obtained in relation to your qualifications and employment history, including: employment history, educational certificates, training certificates, experience certificates and referral details.
• Sensitive data, including: health data (e.g. physical disabilities), racial information and information relating to religious beliefs which you have provided to us (e.g. through the completion of our job application form) or as required by law.

3.2 Information that you submit as part of your application must be true, accurate, complete and not misleading. If you fail to provide certain information when requested, we will not be able to progress your application.

4.1 The personal data that we collect is either:

• Provided by you during your application process;
• Obtained from recruitment and government portals;
• Obtained from government portals, company profiles and legal licences;
• Obtained from public resources such as business and employment orientated social networking services;
• Obtained from third parties engaged by us to assist with the recruitment process, such as background check providers;
• Provided by referees you have listed in your application; and
• Created by us in the course of the recruitment process..

5.1 We will use the personal data collected from you for the following specific purposes, including to:

• Undertake recruitment activities, such as determining the suitability of your qualifications, maintaining information on the status of your application;
• Progress your application through the recruitment process, assess and make a decision about your suitability for a role;
• Ensure the effective administration and management of the recruitment and onboarding process, including preparing HR modules and setting up internal profiles;
• Assist us in managing third party providers (e.g. background check providers) (landlords, service providers, embassies, etc.);
• To report and analyse our recruitment processes including managing our HR records and update our employee database;
• Allow for your registration into medical or social insurance;
• Manage any disputes, complaints or claims that may arise;
• Process your information in order to comply with our legal or regulatory obligations imposed;
• Receive legal or other professional advice; and
• Ensure the issuance of our residency and sponsorship transfer regulatory requirements.
• Legal basis for processing personal data

5.2 For the purposes of processing activity identified above the legal basis for the processing of your personal data will generally be for compliance with legal obligations, or for achievement of our legitimate interests, although we may also ask you to consent to such processing. However, where the processing of certain sensitive information such as health data, racial information, and criminal convictions/offenses is not required by law, we will rely on your explicit consent.

Potential consequences and risks that may arise from not collecting your personal data

5.3 You are under no obligation to provide data to us during the recruitment process, however, if you do not provide the information, we may not be able to process your application properly or at all.

6.1 We will only share your personal information with the following third parties (for the purposes indicated above at 5.1):

• Background check providers to obtain your suitability for the role;
• Cloud providers who store personal data on the cloud, such as SAP;
• External audit firms to meet our legal reporting obligations;
• Any referees which you have provided as part of your application to allow us to progress your application; and
• Regulators and competent authorities where we are required to disclose information by applicable law or at their request.

6.2 We will also share personal data internally within our group (for the purposes indicated above at 5.1) to the following internal functions: human resources, internal audit and compliance, legal and finance.

7.1 We treat your personal data with the utmost care and ensure that any personal data that we process is handled appropriately in line with the Personal Data Protection Law.

7.2 We implement the appropriate technical and organisational measures to safeguard your personal data, such as:

• Controlling access to our systems and networks (e.g. access to the company portal to only HR personnel);
• Providing employees with appropriate data protection training (e.g. new employees are trained on cybersecurity threats and password policy at the time of onboarding);
• Implementing appropriate data security controls (e.g. encryption);
• Regularly updating and upgrading our infrastructure and applications to ensure the latest security updates are installed (e.g. automatic patching through our vendors on a monthly basis); and
• Deleting and disposing personal data when it it’s no longer necessary to fulfil the purpose(s) for which it was collected or to comply with legal, regulatory and internal policy requirements.

7.3 We will only retain personal data as long as necessary to for the recruitment purposes identified in this Privacy Notice or to allow us to comply with legal, regulatory or internal policy requirements.

8.1 We will only transfer your personal data that we collect about you to countries outside the KSA where we have adequate protection and in compliance with the Personal Data Protection Law.

9.1 In accordance with the provision of the Personal Data Protection Law you have the following rights:

• The right to be informed of the legal basis for collecting your personal data, and the purpose of collecting it.
• The right to access your personal data held by us and request a copy of that personal data is in a format that is clear and readable.
• The right to request correction, completion or updating of your personal data held by us.
• The right to request the destruction of your personal data held by us, when such personal data is no longer needed.

9.2 It is important to understand that these rights may be subject to certain restrictions, exclusions or exemptions set by the law and will be assessed on a case-by-case basis in compliance with the Personal Data Protection Law.

9.3 To exercise the above rights at 8.1, by [Data Request Form].

10.1 We may amend or update this Privacy Notice from time to time to ensure compliance with the requirements under the Personal Data Protection Law or to reflect changes in our practice.