1. REVISIONS

Revision No:Revised Article:Revision Reason:Effective Date

2. INTRODUCTION

The Personal Data Protection Law introduces several key provisions governing protection and legal processing of personal data.

Under the aforementioned law, personal data is defined as any information relating to an identified or identifiable natural person. Processing of personal data means any operation performed on personal data at any time between its collection and deletion.

Adequate personal data processing procedures will significantly enhance the Foundation’s capability of ensuring compliance with the law, which will in turn affect all other operations of the Foundation.

3. PURPOSE OF THE POLICY

This Policy governs the rules of processing personal data of the employees of the Foundation and its Commercial Enterprise. Therefore, the purpose of the Policy is to specify how the personal data of the employees, as well as other personal data that fall under the scope of the Policy, is processed. The other purpose of the Policy is to inform employees on the processing of personal data.

4. SCOPE OF THE POLICY

The Policy applies to Foundation employees. In addition to current employees, rules of this Policy also apply to former employees whose personal data is still being processed, and candidates who have applied for a job at the Foundation. For all purposes under this Policy, the term employee shall refer to former employees, candidates and interns wherever applicable.

5. EFFECTIVENESS AND REVISION

The Policy took effect on April 1, 2018. The Policy may be amended from time to time in order to adapt to changing conditions and legislation. Revisions shall be communicated to employees via various channels. In case the Policy is amended, either in part or in full, the effective date of the Policy shall be updated to reflect this change. The Human Resources Department is responsible for the implementation of this Policy.

6. PROCESSING OF PERSONAL DATA OF CANDIDATES DURING RECRUITMENT AND PLACEMENT

This section contains special provisions on the processing of personal data of candidates during recruitment processes. Special provisions concerning candidates are applicable alongside other provisions of this Policy that involve employees.

6.1. Personal Data Collected and Processed during Recruitment

The Foundation may process all or some of the information specified in the section “11. Categorization of Personal Data” depending on the nature of the job application. The Foundation also may collect and store the following candidate information during application:

•  Full name, address, date of birth, email address, telephone number and other contact information,
•  CV, cover letter, past or current work experience or other qualifications, education background, transcript, language proficiency test results or other supporting documentation,
• Records of information obtained during interviews, whether made through teleconference, over the phone, or face-to-face,
•  Recording of the video interview, on condition that the candidate is given prior verbal/written notification about and consents to the interview being recorded,
•  Results obtained from background checks and verifications concerning the information provided by the candidate, or other information obtained from the inquiries made by the Foundation,
•  Results of competency tests and personality inventories conducted during recruitment.

Depending on the position, the Foundation may request the candidate to submit sensitive personal data (e.g. criminal record, medical record). In such cases, the candidate shall be informed as to why sensitive personal data is requested and how it will be used, either via the application form or another explanatory note.

6.2. Purposes for Collecting and Processing Candidate Personal Data

The Foundation may process candidate personal data based on the nature of the application and the one or more purposes specified in this Policy’s section “12. Purposes for Processing Personal Data” to:

• Evaluate the candidate’s qualifications, experience and suitability for the open position,
• When necessary, perform background checks of the information provided by the candidate, or contact relevant third parties to verify their references,
• Contact the candidate with regard to the application and recruitment processes, or about any new domestic or international positions as they become available in the future,
• Fulfill statutory obligations or the requirements of a government agency,
•  Improve or develop the Foundation’s recruitment procedures.

6.3. Methods of Collecting and Processing Candidate Personal Data

During the recruitment process, candidate personal data may be collected in the following ways and means in addition to or as a supplement to the other ways and means as specified in this Policy:

• Written or digital application form on electronic media,
•  Candidate CV submitted to the Foundation via email, mail, reference or other methods
•  Employment or consulting firms,
•  During interviews, whether made through teleconference, over the phone, or face-to-face,
• Background checks and verifications concerning the information provided by the candidate, or inquiries made by the Foundation
•  Skill and personality tests administered and evaluated by experienced specialists during recruitment.

The Foundation processes the collected personal data automatically or manually through computer systems and human resources personnel. Personal data collected by the Foundation shall be stored in hard copy or digital form in the Foundation’s communications systems, corporate resource planning systems and electronic media.

6.4. Candidate Reference Checks

The Foundation may perform checks to verify the references of candidates. In general, the purpose of these checks is to validate the information provided by the candidate. Furthermore, the checks also aim to reveal any information the candidate might have withheld, which could conceivably pose a risk for the Foundation.

The reference checks may also involve obtaining data from third parties.

The candidates may contact the Foundation at any time to inquire about the reference check.

6.5. Candidates’ Rights Regarding Their Personal Data

Candidates who wish to exercise their rights under the law may contact the Foundation within the scope of the procedures and principles detailed in this Policy.

6.6. Candidate Personal Data That Will Continue to Be Processed After Recruitment

In case the candidate is hired for the open position, all personal data collected and processed during the recruitment process shall be transferred to the personal file

6.7. Candidate Personal Data Security

In terms of ensuring data security, no discrimination is made between Foundation employees and candidates who apply for a job at the Foundation. Please see the personal data security section of this document for detailed information about the security of personal data.