Privacy Policy

1. Privacy statement for applicants

KPN recognizes the importance of your privacy and therefore processes the personal data you provide to us in a proper manner. On this page you can read the privacy statement that we use for applicants (1.1 to 1.10) and the privacy statement for employees (2.1 to 2.8).

1.1 Who is responsible?

If you share data with us because you are interested in working at KPN, KPN BV, Wilhelminakade 123 in Rotterdam is responsible for the processing of your data.

1.2 To whom does this statement apply?

This privacy statement applies to the personal data of applicants and potential candidates that are processed in the recruitment process of KPN. This includes visitors to the jobs.kpn.com website. It does not apply to personal data of our employees, partners, customers or to personal data that KPN collects for other purposes.

1.3 What do we use your data for?

If one of our recruiters approaches you or you apply for one of our vacancies via our website, we will include the personal data you provide in our records. We use your data during the recruitment process based on a legitimate interest or consent for the following purposes:

• Recruitment and selection of suitable candidates. We use this information to be able to maintain contact with you and to assess whether you are suitable for the vacant position or assignments. If this is necessary for the position or assignment, an assessment or psychological assessment is part of the assessment.
  
• Improving our recruitment process. Your personal data will be processed by us during the recruitment process so that we can carry out the process efficiently and effectively. We process your personal data or pseudonymised data to improve our recruitment process.
  
• Protection of KPN's property and image. Security and integrity risks can lead to personal and business damage and damage our image. We therefore take various measures to protect our property and employees as well as possible. For example, we use personal data to know who is present in our buildings, we apply camera security at our locations and we screen all employees before they are employed by KPN.
  
• HR management. We also use your data for statistical research and to improve our services. Examples include monitoring how diversity is applied within recruitment and analysis of the impact of the HR strategy pursued. If data is used for this purpose, we will pseudonymise your data , so that the results and advice can no longer be traced back to an individual person.
  

• Inform candidates about other options within KPN. Only when you have given permission for this will we store your data that you have shared with KPN in our system after the recruitment procedure. With the aim of informing you in the future about other available and suitable positions. You can always withdraw your consent.

1.4 Who do we share your data with?

We only provide your personal data to those who are charged with the execution of the above-described purposes, such as intended managers, employees of the HR department, and / or discussion partners if you are invited for an interview. Your information will be treated as confidential. When required for the position, we provide personal data to third parties who assist us in assessing your suitability for the position:

a. (assessment or screening) agencies; b. the psychologist or the person in charge of the assessment if the applicant undergoes a psychological examination or assessment and only if necessary for the examination or assessment; c. others if necessary as part of a background check. Also see point 2.4.

We handle your personal data with care, you can rest assured that your data is safe with us and that it will be processed in accordance with laws and regulations. Your data will not be resold.

1.5 Which data do we process?

Personal data that we process about you include your name, address, gender, contact details, curriculum vitae, training courses received and any test results. In addition to the personal data provided by you, we may also process personal data provided by third parties, such as recruitment, assessments or screening agencies, references provided by you and former employers. While searching for suitable candidates, we may consult and use public sources such as search engines and areas of social media that are not private to contact suitable candidates. We do not process special personal data such as ethnic origin, health, trade union membership, political or religious beliefs, sexual orientation as well as other categories that are recognized by law.

The various personal data that you provide to us will be processed in accordance with the General Data Processing Regulation (AVG) as it applies in the Netherlands.

1.6 Incomplete / incorrect information

Please note that you are not required to provide all the information requested by us, but that your application for a vacancy to which you apply may not be included in the recruitment process because not all of the requested information has been made available to us. We assume that you provide us with accurate and complete information in good faith and that you do not omit any relevant information. Providing incorrect or incomplete information may result in your ineligibility to fill the position for which you are applying.

1.7 What do we do during a screening / appointment investigation?

The moment you accept the appointment offer from KPN. The information you have shared with us will be used to carry out a screening. We call this an appointment investigation. A standard appointment investigation is carried out by KPN recruitment or external recruitment or screening agencies and consists of:

• identity check, by submitting a copy of proof of identity,
• checking the diploma (s) obtained;
• applying for a Certificate of Good Conduct (VOG);
• employee's own statement, stating whether you have worked for KPN before and whether you have been in contact with the police during the past 5 years;
• on the basis of your resume, employment history checks of the last five years;
• check whether your details are included in the dismissal file or in the security registration system of KPN.
  

If you do not want to cooperate in the appointment investigation or if a negative advice is given on the basis of the investigation, you cannot enter employment with KPN. At that moment, the offer of appointment will expire and your data will be deleted.

How long do we keep your data?
Your ( pseudonymized ) personal data will be kept for as long as is necessary to complete the recruitment process and to convert the data into static information for analysis and improvement of our recruitment process.

If KPN decides to make you an offer and you accept our offer, all relevant personal data collected during the recruitment process will form part of your personnel file. These personal data will be kept in accordance with the specific requirements that apply.

If we do not make you an offer, we will delete your personal data within four weeks of the end of the recruitment process or keep a minimal pseudonymised set of personal data from you in order to perform analysis and to register your application activity with us (maximum 1 year).

1.8 How do we collect your data?

Depending on your employment relationship, either directly employed by KPN or as an external employee, you and / or your supplier provide personal data during the commencement of employment (“ onboarding ”). Our experience is that the more you can do yourself, the less mistakes are made.

We would like your employment to be flawless, fast and safe. The KPN Onboarding app helps you with this. If you want to use this, you have to go through a few steps. Your onboarding is done in two minutes . First of all, you will receive a QR code from us. If you scan this with the app, the app knows which data you do, but especially do not have to share with KPN for your recruitment. Think of your personal data, copy of ID, BSN, passport photo, control photo, but also your choice of your call sign and / or surname of your partner. Everything you still need to do by post or email at other companies. And that is less safe and prone to errors.

The KPN Onboarding app removes this information from your ID. You can then complete it.

Holder verification

We need to make sure that the user of the app is also the owner of the ID. We verify that with a selfie. The app has collected your passport photo from your ID. Then you take a picture of your face (selfie) with the app. We use this picture to verify whether you are the holder.

We do this via Microsoft Azure Face Verification. This service is designed to answer the question: are these two images of the same person? In order to check this, your passport photo and selfie are both encrypted. Microsoft Azure Face Verification compares these two encrypted photos and returns a match score. If the score is high enough, the app allows you to continue to the latest step: validate all your information and send all data to KPN. All information is then deleted from the app and sent securely to KPN. So no picture or other data is stored in the app, at Microsoft nor used or disclosed for any other purpose than this one-time verification. Your selfie photo is temporarily stored at KPN for 7 days, in order to use it for a random human security check of the selfie and the passport photo. After 7 days, it is automatically deleted permanently. Your passport photo of the ID is the only photo that KPN keeps, and is used on your personal KPN Company Card, so you can identify yourself in accordance with KPN security policy. All of this has been extensively tested and found to be correct, according to our KPN Security Policy. And believe us, it is strict.

1.9 Your Rights

Under the GDPR, you have the right to request KPN to:

• to give access to your personal data,
• to have your personal data supplemented, corrected or deleted;
• to object to the processing of your personal data;
• restrict the processing of your personal data;
• transfer your personal data to you or to a third party.

If you wish to exercise your rights, you can submit a request via privacyofficer@kpn.com. KPN will inform you within one month of KPN receiving a request to exercise one of the aforementioned rights. In doing so, KPN will indicate whether and how the request will be followed up and, if not, why not. If necessary in connection with the request, KPN can extend the response period of one month. In that case, KPN will indicate within one month the term within which it will respond.

We do not use automated decision-making for recruiting or evaluating suitable candidates based solely on automated processing including profiling.

If you have a complaint about the way in which KPN uses your personal data or applies your rights, you have the right to submit a complaint to the Dutch Data Protection Authority (the AP). You can share your complaint via the AP website.

1.10 Contact

If you have any questions about this privacy statement or about the recruitment process at KPN, please contact your recruiter at kpn-recruitment@kpn.com . If you would like to contact the data protection officer of KPN, please contact mr. J. Jongenelen via privacyofficer@kpn.com.

2. Privacy statement for employees

Preface

The General Data Protection Regulation (hereinafter: the GDPR) has been applicable to the processing of personal data since 25 May 2018. KPN BV (hereinafter referred to as KPN) is the controller for the processing of personal data of its employees. KPN respects the privacy of its employees and only processes their personal data in accordance with the laws and regulations.

This privacy statement concerns the processing operations carried out by or for KPN as an employer. KPN is also responsible if the processing is done by third parties.

The purpose of this statement is to indicate how KPN handles the personal data of employees.

2.1 To whom does this privacy statement apply ?

For all employees employed by KPN (EP), for all external employees (both Other Personnel and Other Personnel and Temporary Personnel) and for all former employees.

2.2 Why do we use your data?

The GDPR stipulates that you as an employer must always have a legal basis (also a legal reason) for the processing of personal data.

At KPN, these are the legal grounds for processing data:

• the execution of the ( employment ) agreement
• comply with the legal obligation
• legitimate interest
• permission

Execution of (employment) agreement
KPN processes personal data to execute the employment agreement. Consider, for example, paying the salary.

Compliance with a legal obligation
In a large number of cases, KPN processes personal data in order to be able to comply with a legal obligation that rests on KPN. An example of this is keeping the Citizen Service Number for the income tax return for EP.

Legitimate interest
In cases where we have a legitimate interest, KPN may use your personal data for the realization of a number of goals referred to in point 2.4 of this statement. In that case, we must have assessed in advance that our interest outweighs your right to privacy. Some examples of this are protecting our properties through CCTV, coaching customer service employees based on telephone recordings, carrying out travel calculations in accordance with our social plan and investigating the integrity of our employees in specific situations.

Permission
Sometimes we ask for permission in advance to use your data. For example, whether you are happy with your photo being posted on TEAMKPN. You can always withdraw your consent yourself.

2.3 Which personal data do we process?

Within the employment relationship, KPN processes various personal data about you, such as:

• For personnel administration, such as: name and address details, contact details, (e-mail and telephone number), date of birth, place of birth, nationality, marital status, gender, partner details, photo, copy of identity document, copy of the Certificate of Conduct, BSN number, employee code and noise name , your position, information about the assessment, membership of the Works Council and any additional activities and all correspondence with you
• For payroll, such as: bank account number, salary, scale, data about the variable remuneration / bonus, pension data, annual statements, wage tax statements , data for tax and premiums, commuting distance, travel allowance, lease car data, employee discount, declarations, payment of union contribution , PvKPN contribution and use of CLA budget;
• The company name, Chamber of Commerce number and VAT number when you are hired by KPN
• Data about the use of the corporate resources that KPN makes available for the performance of your job, such as the consumption of data and calling minutes
• Data for the registration of the business assets that KPN makes available for the performance of your position, such as the type and serial number of a telephone or laptop
• Information about your personal development such as copies of diplomas or certificates of training courses you have taken, results from KPN Academy, use of your employability budget
• Data on health and safety and absenteeism, such as registration of absenteeism, reporting health and safety service, declaration of disability history
• Using postcode / house numbers to calculate travel times and distances to and from KPN offices and the impact of a location closure or change.
• GPS data from KPN company cars used by mechanics, also see point 2.4
• Audio or video recordings that are (periodically) made of employees with (direct) customer contact

2.4 What do we use your data for?

KPN processes personal data in order to be able to implement the employment contract that KPN has concluded with you. Your data is stored for various purposes in various applications such as personnel administration, absenteeism registration and payroll administration.

KPN processes your personal data for these purposes:

• Establishing and maintaining business contact by mail, telephone, e-mail
• Conducting correct personnel administration and payroll administration
• Comply with our legal obligations as an employer, based on the employment relationship, such as paying the salary, concerning absenteeism and reintegration, providing payslips and annual statements, tax payment, being able to apply for and receive any benefits and arranging for participation in a pension scheme and / or taking out insurance
• Implementing the employment contract, the collective labor agreement and the Social Plan
• Give substance to company schemes such as the employee discount scheme and compensation schemes
• Participation in benchmarks to test KPN's HR policy and employment conditions in the market, based on, as much as possible, nominated data
  
• Conducting surveys and making reports and analyzes to draw up, implement, monitor and, if necessary, adjust the HR strategy and policy.
• Calculating possible travel times and distances to KPN location and customer visits
• Processing your applications
• Inemployment screening advancement to pao functions; this includes matters such as: checking identification, extract from GBA, certificate of good conduct (VOG) etc. Prior to any screening, the employee is informed via a brochure from the screening agency which matters will be checked.
• Providing access to KPN systems, sites and buildings to guarantee your safety and that of other persons and goods
• Providing data on an aggregated level about the use of the premises and occupancy rates trough the use of data from the card reader
• The use of KPN's assets, such as a laptop and mobile phone
• As a result of a security report, data can be shared with KPN Security. This concerns data with regard to the use of company assets, such as a laptop, mobile telephone, lease car, fuel card and NS business card.
• Informing about developments within KPN
• Managing work stocks, division of work, staffing levels, timesheets and charging of hours worked to customers
• Optimizing the work schedules and planning of certain groups of employees, such as the technicians. The rules of conduct for the use of the GPS data for technicians are laid down in the GPS code of conduct
• For your coaching and development and for the management of the quality of the service. For the telephone entrances, this is laid down in the KPN Rules for Measuring, Monitoring and Listening in .

2.5 How long do we keep the personal data?

In accordance with the GDPR, KPN does not store your data longer than strictly necessary for the purposes for which your personal data is collected and / or processed. When personal data are no longer relevant for the aforementioned purposes, KPN will delete them.

KPN stores data from the payroll administration that is of fiscal importance for up to 7 years after you have left employment, in accordance with the legal retention period.

Wage tax statements and a copy of an identity document will be kept by KPN for 5 years after the end of the employment contract, in accordance with the Wages Tax Act 1964.

For more information about specific retention periods, see the document Retention periods list HR.

2.6 Who do we share personal data with?

KPN provides your personal data to those charged with the implementation of the purposes described above, such as managers and employees of HR, Finance and Security. Your data will only be shared with these employees if this is necessary for the position or activities. For example, a manager only has access to the personnel files of his own area of attention.

KPN shares data with other parties when this is necessary, for the provision of a service on behalf of KPN or because this is required by law. If these third parties have access to your personal data during the performance of their services, KPN has made agreements about how this data may be used and how it is secured and with what retention period. Even if KPN works with a party from outside the European Economic Area, we make clear agreements to ensure the protection of your data. In such cases, there are so-called standard clauses that have been approved by the European Commission. KPN shares data with the following recipients or categories of recipients:

• external payroll clerk Oracle
• external security services
• accountants
• (default) insurers
• pension provider TKP
• the tax
• the UWV
• recruitment agencies (only at the request of the employee concerned)
• KPN academy and underlying trainers
• suppliers of workplace services or HR systems (such as Beeline , Match!)
• health and safety service and underlying suppliers
• research agencies for performing benchmarks
• transport companies such as the Dutch Railways
• leasing companies for the delivery of company cars

2.7 What are your rights under the GDPR?

Under the GDPR you have the following rights over your personal data:

• the right to access and copy
• the right to rectification
• the right to be forgotten ( erasure )
• the right to restriction of processing
• the right to object to the processing
• the right to data portability
  

If you want to exercise your rights, you can submit a request to your HR advisor.

2.8 What do you do with questions or if you have a complaint about your privacy?

You may have questions about the way in which KPN processes personal data, despite the careful approach.

• If you have any questions, please contact your HR advisor or your manager.
• If you have questions about schemes that have been assessed by the works council, you can also contact your Works Council member.
• If you have a complaint, please contact the KPN Data Protection Officer (FG). This can be reached via the email address: privacyofficer@kpn.com .
• KPN has a complaints committee. You can also go there with your complaint (https://teamkpn.kpnnet.org/group/documents/groep-human-resources/kpn-onderdelen).
• You have the right to submit a complaint to the Dutch Data Protection Authority (AP). You can submit your complaint via the website www.autoriteitpersoonsgegevens.nl .

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