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Policy on Protection and Processing of Personal Data of Employee Candidates
OF EMPLOYING CANDIDATES

POLICY OF PROTECTION AND PROCESSING OF PERSONAL DATA




1 - INTRODUCTION

The Law on Protection of Personal Data ("Law") introduces important regulations regarding the protection of personal data and processing in accordance with the law. Protection of personal data, Bross Tekstil San. Ve Tic. A.Ş, Yako Tekstil San. Ve Foreign Trade Inc. and Innovatech Otomasyon Sistemleri San. Ve Tic. A.Ş. (hereinafter referred to as the "Company"), and it is among the priorities of our company. The most important pillar of this issue is the Policy for the Protection and Processing of Personal Data of Employee Candidates (the "Policy"), which is written in line with the principles set out in the Personal Data Protection and Processing Policy published on www.bross.com.tr and www.brossocks.com. . Although the processing and protection of the personal data of employee candidates ("Employee Candidates") who have applied for a job to our company are generally regulated within the scope of the Personal Data Protection and Processing Policy, detailed explanations and regulations on the subject are in line with the principles set out in the Personal Data Protection and Processing Policy. is managed under this Policy. The fact that our Company has appropriate processes in the processing of personal data will ensure that it acts in accordance with the law, and this will affect all related activities.

2- PURPOSE OF THE POLICY

In this Policy, the rules to be followed when processing the personal data of Employee Candidates are regulated. Therefore, the purpose of this policy is to determine how the personal data of Employee Candidates will be processed. Another purpose of this policy is to inform Employee Candidates about the processing of their personal data.

3- SCOPE OF THE POLICY

This Policy covers the Employee Candidates and finds an application area for the personal data of the Employee Candidates processed automatically or non-automatically provided that they are part of any data recording system.

4- DEFINITIONS

Explicit Consent: Consent on a specific subject, based on information and declared with free will,

Anonymous Rendering: Making personal data unrelated to a certain or identifiable natural person under any circumstances, even by matching other data,

Personal Data: All kinds of information regarding an identified or identifiable natural person,

Processing of Personal Data: Obtaining, recording, storing, preserving, changing, reorganizing, disclosing, transferring, taking over, making available, through fully or partially automatic means of personal data or non-automatic means provided that it is a part of any data recording system, All kinds of operations performed on data such as classification or prevention of use,

Data Processor: The natural or legal person who processes personal data on behalf of the data controller, based on the authority given by the data controller,

Data Recording System: The recording system in which personal data are structured and processed according to certain criteria,

Data controller: refers to the natural or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system.

Special Quality Personal Data: Data on race, ethnicity, political opinion, philosophical belief, religion, sect or other beliefs, dress code, association foundation or union membership, health, sexual life, criminal conviction and security measures, and biometric and genetic data. data of special nature.

Company Authority: Company board member and other authorized real persons.

Company Shareholder Company shareholders are real persons.

5- EFFECTIVENESS AND UPDATABILITY

This Policy may be updated from time to time in order to adapt to changing conditions and legislation. In case of an update, the updated Policy text will be published on www.bross.com.tr and www.brossocks.com.

6- PROCESSING PERSONAL DATA OF EMPLOYED CANDIDATES DURING RECRUITMENT and PLACEMENT PROCESS

Under this section, there are special regulations regarding the processing of personal data of Employee Candidates during the recruitment process.

6.1 Personal Data Collected and Processed During the Recruitment Process

According to the law and relevant legislation, the following information can be collected and processed from the Employee Candidates who apply for a job:

Name-surname, TR identity number, gender, marital status, place and date of birth, military service status (exemption reason), number and ages of children, driver's license, class, date of receipt, spouse's name, workplace, mobile phone and other contact information, residential address, height and weight,

Educational information (School of study, department, degree, start-end date, city)

Former workplace address, telephone, position at the old workplace, entry-exit date at the old workplace, reason for leaving, salary

Computer knowledge, used programs

The department you want to work in

Name, surname, title, work place, phone number of the reference you have indicated in your job application.

The department you want to work, the ability to work in shifts, wage expectation, date of start

In case you give explicit consent, special quality personal in Article 6 of the relevant Law; If there is a criminal record, the reason, if there is a health problem, the surgeries and treatments performed, if there is a disability, the rate

6.2 Methods of Collecting Personal Data of Employee Candidates and Purposes of Processing

Personal data collected about the candidate through the Job Application Form and special quality personal data given explicit consent, for the purposes of evaluating the job application request and its suitability for the relevant position, conducting and finalizing the recruitment processes within the framework of the human resources policies of our Institution and contacting the candidate within this scope, and also In order to ensure the fulfillment of legal and commercial obligations with our company and those who are in business relations with our company; In order to determine and implement our commercial and business strategies and to develop and improve the recruitment principles applied by our Company, personal and special quality personal data can be processed within the terms and purposes specified in Articles 5 and 6 of Law No. 6698.

6.3 Research on Employee Candidates

If reference information is shared by the candidate, a reference search can be made by the Company. The reference search to be conducted will generally be aimed at confirming the accuracy of the information provided by the candidate. In addition, determining the information that the candidate keeps about himself and that may cause risks for the Company will be among the aims of the research. Candidates can contact the Company at any time about the reference search to be made regarding them.

6.4 Among the Personal Data Collected During the Candidacy Process, The Processes That Will Be Continued During Recruitment

All personal data collected and processed about the Employee Candidates during the recruitment process are transferred to the personal file if the Employee Candidate is decided to be employed in the relevant vacant position.

6.5 Security of Personal Data of Employee Candidates

There is no negative discrimination between the employees of the company and the security of the personal data of candidates who apply for a job in the Company.

7-PRINCIPLES ON THE PROCESSING OF PERSONAL DATA OF EMPLOYEE CANDIDATES

7.1 Processing in Compliance with Law and Good Faith

In the processing of personal data, the principles introduced by legal regulations and the general trust and honesty rule are followed. In this context, personal data are processed in proportion and limited to the purpose for which they are processed.

7.2 Keeping Personal Data Accurate and Updated When Required

Periodic checks and updates are made to ensure that the processed data are accurate and up-to-date, taking into account the legitimate interests of the Employee Candidates, and necessary measures are taken in this direction. In this context, systems for checking the accuracy of personal data and making the necessary corrections are established within the Company.

7.3 Processing for Specific, Clear and Legitimate Purposes

Personal data are processed based on clear and precise data processing purposes. Personal data are processed only as much as necessary for these purposes. The purpose for which the data will be processed is revealed before the personal data processing activity begins.

7.4 Being Related, Limited and Measured for the Purpose of Processing

Personal data are processed in a way that is suitable for the realization of the determined purposes and the processing of personal data that is not related to the realization of the purpose or is not needed is avoided.

7.5 Preservation for the Period Stipulated by the Legislation or Required for the Purpose for which they are processed

The company keeps personal data only for the period specified in the relevant legislation or for the purpose for which they are processed. In this context, first of all, it is determined whether a period is stipulated for the storage of personal data in the relevant legislation, if a period is determined, this period is treated in accordance with this period, and if a period is not determined, personal data are stored for the period required for the purpose for which they are processed. If there is no legal reason to allow them to be processed for a longer period of time, personal data are deleted, destroyed or anonymized in accordance with the policy principles implemented by our Company in this regard.

8-TERMS OF PROCESSING PERSONAL DATA OF EMPLOYEE CANDIDATES

The explicit consent of the personal data owner is one of the legal bases that make it possible to process personal data in accordance with the law. Apart from express consent, personal data may also be processed in the presence of one of the other conditions listed below. The basis of the personal data processing activity can be only one of the conditions stated below, and more than one of these conditions can also be the basis of the same personal data processing activity. In case the processed data is personal data of special nature, besides the rules written here; Below, under this section, the conditions under the heading "Conditions where Special Quality Personal Data May be Processed" are applied.

8.1 Processing of Employee Candidates' Personal Data Based on Explicit Consent

Personal data of Employee Candidates are processed based on explicit consent in cases where they are not processed on a different condition. Employee Candidates are informed about which personal data are processed, for what purposes and for what reasons their personal data are processed, from which sources their personal data is collected, with whom and how these personal data will be shared and their explicit consent is obtained in this way. Obtaining explicit consent is prepared specifically for each data collection source, taking into account the source from which personal data are collected.

8.2 Explicitly Stipulated in Laws

In cases where the processing of personal data is explicitly stipulated in the law, the Company processes the personal data without obtaining the explicit consent of the Employee Candidate to be processed.

8.3 Failure to Obtain Explicit Consent of the Relevant Person Due to Actual Impossibility

The data of the Employee Candidate, who is unable to disclose his consent due to the actual impossibility or whose consent is not valid, is required to protect the life or body integrity of the Employee Candidate himself or another person, without the explicit consent of the Employee Candidate.

8.4 Being Directly Related to the Conclusion or Performance of the Contract

Provided that it is directly related to the establishment or performance of a contract, the data may be processed if it is necessary to process the personal data of the parties to the contract.

8.5 Fulfilling the Company's Legal Obligation

In the event that processing is mandatory to fulfill legal obligations as a data controller, the data of the Employee Candidate can be processed without express consent.

8.6 Publicizing Personal Data of Employee Candidate

In the event that the personal data of the Employee Candidate is made public by him, the data can be processed without the need for explicit consent.

8.7 When Data Processing is Mandatory for the Establishment or Protection of a Right

If data processing is mandatory for the establishment, use or protection of a right, the data may be processed without the express consent of the Employee Candidate.

8.8 Processing of Data Based on Legitimate Interest

In case data processing is mandatory for the legitimate interests of the Company, provided that it does not harm the fundamental rights and freedoms of the Employee Candidate, the data may be processed without the express consent of the Employee Candidate.

9- CASES WHERE SPECIAL QUALITY PERSONAL DATA CAN BE PROCESSED

Some of the personal data are organized separately as "special personal data" and are subject to special protection. Special attention has been paid to these data due to the risk of causing victimization or discrimination when processed illegally.

9.1 Processing of Special Quality Personal Data Based on Explicit Consent

Special quality personal data can be processed with the express consent of the Employee Candidate. Explicit consent can be processed by taking the principles specified in this Policy and the necessary administrative and technical measures, depending on the nature of the personal data of special nature.

9.2 Cases Where Special Quality Personal Data Can Be Processed Without Explicit Consent

Special quality personal data are processed in cases where the Employee Candidate does not have express consent, provided that adequate measures are taken by the Personal Data Protection Board, in the following cases:

In terms of private personal data other than the health and sexual life of the employee candidate, in cases stipulated by the laws,

For the protection of public health, preventive medicine, medical diagnosis, treatment and care services, planning and managing health services and financing, persons or authorized institutions under the obligation of secrecy and if processed by organizations.

10- ENLIGHTENING AND INFORMING THE EMPLOYEE CANDIDATE

During the acquisition of personal data, personal data owners are informed by the Company. In this context, the identity of the Company representative, if any, the purpose for which personal data will be processed, to whom and for what purpose the processed personal data can be transferred, the method of personal data collection and the rights of the Employee Candidates for legal reasons are notified to them. If the Employee Candidates request information regarding their personal data, the necessary information is provided by the Company.

11- TRANSFER OF PERSONAL DATA TO THIRD PARTIES

Personal data and special quality personal data can be transferred to third parties by taking the necessary security measures in line with the processing purposes.

11.1 Third Parties to whom Personal Data are Transferred and Transfer Purposes

In line with the personal data processing conditions and purposes specified in Article 8 of the Law No.6698, it can be transferred to third parties shown as reference by taking the necessary security measures. Your personal data can be transferred within the scope of the evaluation of your suitability and competence and can only be processed for this purpose.

12- STORAGE PERIOD OF PERSONAL DATA, DELETION, DESTRUCTION, ANONYMIZING

The personal data you have shared with our Company through the channels mentioned in this Disclosure Text will be stored for a maximum of 1 year, in accordance with the Personal Data Protection Law No.6698 and the relevant legislation, for a period of up to the time when the curriculum vitae submitted by the Employee Candidate will become out of date. It will be destroyed and destroyed in the first June or December following the storage period.

13- SECURITY OF PERSONAL DATA

In order to ensure the security of personal data, reasonable precautions are taken to prevent unauthorized access risks, accidental data loss, deletion of data or damage to data. All kinds of technical and physical measures are taken in order to prevent access to personal data other than those authorized to access. In this context, the authorization system in particular is designed in a way that nobody will be able to access more personal data than necessary. Stricter measures are taken compared to other personal data while ensuring the security of special personal data such as health data. Authorized persons are passed through the necessary security checks. In addition, these people are trained about their roles and responsibilities. Access records of personal data are kept to the extent that technical possibilities allow, and these records are reviewed at regular intervals. In case of unauthorized access, an investigation is initiated immediately. Company employees who process personal data comply with the following obligations in order to ensure the security of the processed data:

Acting in accordance with the law and honesty in matters related to the protection of personal data,

Processing personal data accurately, completely and completely,

Carrying out the necessary work to update personal data that has lost its current status,

Informing the relevant manager whenever he / she notices any illegality in the processing of personal data,

Making necessary directions for the use of legal rights regarding personal data.

14- LEGAL RIGHTS OF EMPLOYEE CANDIDATES AND METHODS OF USING THESE

In this context, personal data owners;

Learning whether personal data is processed,

If their personal data has been processed, to request information regarding this,

Learning the purpose of processing personal data and whether they are used appropriately for their purpose,

To know the third parties to whom personal data are transferred domestically or abroad,

If personal data are processed incompletely or inaccurately, to request their correction and to notify third parties to whom personal data are transferred,

Although it has been processed in accordance with the provisions of Law No.6698 and other relevant laws, in the event that the reasons requiring its processing disappear, to request the deletion or destruction of personal data and to notify third parties to whom personal data have been transferred,

To object to the occurrence of a result against the person himself by analyzing the processed data exclusively through automated systems,

In case of damage due to unlawful processing of personal data, it has the right to demand the compensation of the damage.

Employee Candidates may submit their requests regarding the enumerated rights to the Company by the methods determined by the Board. In order to exercise these rights, the Company can be contacted using the "Data Supervisor Application Form" available at www.bross.com.tr and www.brossocks.com and the methods specified in this form.
Prepared by  T-Soft E-Commerce.