Recruitment and Selection Data Protection Policy



Aluminium Duffel, hereinafter referred to as the company, thanks you for your interest in our company and your application.

The company has prepared this current information note to inform you about the acquisition, use, and management of your personal data in the context of your application/selection procedure. The company understands your concern regarding the processing of your personal data and aims to fully inform you by clearly specifying the purposes for which the company processes your personal data, to whom they are transferred, and the appropriate safeguards provided in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act, and other applicable data protection legislation.

Every applicant of at least 15 years of age acknowledges having read this policy. Submitting the CV and continuing the selection process implies the acceptance of this policy and the processing of your personal data by the company.

The applicant is required to act in good faith throughout the selection process and provide all necessary information regarding professional and educational backgrounds that relate to the nature and conditions of the position. The applicant shall not disclose any confidential information obtained during the recruitment and selection procedure.

By applying to the company, the applicant acknowledges having read this policy and understanding how the company processes his or her personal data.

1.     Categories of Persons

This current information note applies to the following individuals irrespective of their nationality or place of residence:

  • Any natural person who, due to a job offer, submits his/her application to obtain the job as described in the job offer.
  • Any natural person who spontaneously applies with the aim of having their CV included in a database intended for recruitment and
  • Any natural person whose CV has been passed on to the company by a third party through a recruitment agency or The company will communicate the policy to the applicant upon initial contact.



2.     Categories of Personal Data

In the context of the application, particularly for the selection process, the company will process, among others, the following personal data:

  • Identification data such as your name, surname, marital status, address, place and date of birth, nationality, gender, telephone number, email address, interests,
  • Your photo if you voluntarily provide it (e.g., included in your CV).
  • Education and training-related data: education, training, diplomas,
  • Work-related information: current position and responsibilities, previous positions and work experience, departure date, reason for departure, employment conditions, gross salary, salary expectations, language skills, skills, and professional


  • Health assessment form for a safety function, a function with increased vigilance, or an activity with a specific risk (art. 4-46 of the codex on the well-being at work). This form does not contain health data.
  • If applicable, whether you possess a work and/or residence permit for the European Economic Area (EEA).
  • Mobility-related data (driver's license, transportation options).
  • Data obtained from a personality test: these data are processed only if your CV is selected for the sought
  • Our website uses cookies that may process your personal data such as IP address, website navigation, etc. More information about the processing of your personal data through cookies can be found in our internet and cookie policy.
  • The company aims to obtain all recruitment-relevant information directly from the If the company deems it necessary, solely with your consent, it will contact one or more previous employers to request information about you and your work experience.

The company will not request certified copies of diplomas, certificates, or attestations from the applicant before signing an employment contract. If the applicant has submitted documents with their application, such as transcripts or copies of diplomas, certificates, photos, etc., the company will keep them available for a reasonable period if the applicant is rejected. In case of doubt about the authenticity of the submitted copies, the company may request the original document from the applicant.

The company will only ask private life-related questions that are relevant due to the nature and conditions of the job.

It is possible that the company will process sensitive personal data in certain cases, but this will always be kept to a minimum. In any case, the company will not process so-called 'sensitive' personal data, such as racial or ethnic origin, political opinions, religious or philosophical beliefs, health, sexual orientation, during the recruitment process. The company will also not process an extract from the central criminal record (formerly: certificate of good conduct), except for specific roles that legally require it.

3.     Purposes and Legal Bases for Processing

The company will only collect and process your personal data as necessary for the purposes related to recruitment and selection. The processed personal data are proportionate to the job to be filled and are limited to the data necessary to assess whether your motivation, knowledge, skills, qualifications, and experiences correspond to the profile of the open position for which you are applying or eligible.

The company processes the above personal data based on various legal grounds as listed in art. 6, para. 1, (a), (b), (c), and (f) and 9, para. 2, (b) of the GDPR:

  • You have expressly given your
    • Example: forwarding of the CV
    • Example: adding    to    the    recruitment    database    as explained   further


  • The processing is necessary before the conclusion of an employment contract between you and the company to take measures to facilitate a smooth management of your employment, among other
    • Example: drafting the employment contract


  • The processing is necessary to comply with a legal obligation incumbent upon the
    • Example : attendance certificate drawn up by VDAB, Actiris, Forem at the applicant's request
    • Example: the company has to process certain personal data on the basis of a specific legal obligation such as the recruitment of a security guard. These specific cases will always be further explained in a separate interview with or note to the applicant.
    • Health assessment form for a security job, a job with increased vigilance or an activity with a defined risk (Art. 4-46 of the Codex on well-being at work).
  • the processing of your data is necessary for the protection of the legitimate interests of the company with a view to the proper assessment of your candidature, provided that the interests or the fundamental rights and freedoms of the applicant do not outweigh the interests or the fundamental freedoms of the applicant
    • example : forwarding your contact details to centres conducting tests or trials, processing results of tests or trials, forwarding your data to other services or affiliated companies that may be interested in your



4.     Processing of Your Personal Data



  1. General

The recruitment procedure and associated data processing start at the company when:

  • You apply for a specific
  • You apply spontaneously.
  • A third party recommends you (e.g., a recruitment agency).

The company uses various channels to find the suitable person for a vacancy. This may involve the company's website, as well as third-party platforms such as social media (LinkedIn, Facebook), job sites, or recruitment and selection agencies. For specific roles or profiles, the company may engage a specialized agency to find a suitable candidate.

If your CV is processed by these third parties, it is recommended to read their terms and privacy policy to ensure how they handle your personal data. The company cannot be held liable for the way these third parties handle your personal data or for the content published on their websites.

The company requests you to verify the accuracy and completeness of your data and to contact us if there have been any changes or if you are no longer interested in a job at our company during the selection process.

  1. Specific Processing during the Selection Procedure

In the initial phase of the selection procedure, the company analyzes your CV to determine if it meets the job requirements.

Applicants who do not meet the requirements and whose CVs will not be further considered will be informed of this in writing or by phone. Personal data and CVs of applicants not selected will be stored in our database.


In the second phase, depending on the job and your profile, a number of tests or assessments may be conducted as the company values an objective recruitment and selection process.

These tests, which will not last longer than necessary to assess the applicant's competence, may include:

  • Practical case studies
  • Personality tests
  • Competency tests
  • Intelligence tests

These tests will always serve as an objective guide in the selection process and will always be accompanied by a professional assessment and extensive analysis by Human Resources/the intended supervisors. The company may engage an external assessment agency to conduct these tests.

The company will explain the results of these tests and/or assessments orally or in writing, allowing you the opportunity to express your comments and experiences.

Candidates who meet the requirements of the position but whose test results do not meet the criteria will be informed within a reasonable period. The data of applicants not further considered will be retained. If a specific profile is of interest, the company will retain your data for a reserve list, giving you the option to accept or decline.


5.     Recipients of Your Personal Data

The company may need to process your personal data internally and externally in the context of your recruitment and selection. Access to your personal data is limited to persons with a function that requires the processing of that information and is generally transmitted on a need- to-know basis to recipients performing various processing activities for the aforementioned purposes.

  1. Internal

The Human Resources Team will process your personal data within the framework of your recruitment and selection procedure and will, therefore, have access to the personal data listed under article 2.

As part of the selection, the intended supervisors of the department in which the vacancy exists will also have access to your personal data to assess the suitability of your profile within the company and the specific department (position, work experience, education, etc.).

  1. External

The company is compelled to disclose your personal data to various external companies providing services, such as offices specialized in recruitment and selection that recommend candidates, conduct initial interviews, and administer personality and competency tests.

These companies are directly subject to the legal obligations of the GDPR. This implies that your personal data will be protected by these organizations according to the obligations imposed by the GDPR.

Sometimes, the employer is also required to disclose your personal data to government agencies, with the employer always verifying whether the (legal) conditions for this have been met.


We do not transfer your personal data to third parties (companies) outside the European Economic Area.

6.     Retention Period

The employer processes your personal data for as long as necessary to achieve the purposes for which we need them. We apply different retention periods depending on the context of the selection procedure.

If the candidacy does not result in an agreement, your personal data will be retained for three years after the end of the selection procedure for the purposes mentioned above.

  1. Application for a Specific Vacancy

The Human Resources Team of the company will retain your personal data processed in our recruitment and selection procedure for the period necessary in view of your application.

The company will retain your personal data for a maximum period of 6 months after filling the vacancy. This allows the company to still contact you in case the selected person is not ultimately hired or if it is decided to terminate this cooperation prematurely.

  1. Reserve List

If the company has selected a third party for a specific position but your profile may be interesting for a similar or another position within the company, it wishes to contact you in the future for a vacancy that may interest you. The company will inform you that it will keep your profile for 3 years if it is interesting for the company's future. You always have the option to decline, and the company will then delete your personal data.

  1. Spontaneous Application

Any CV sent through a spontaneous application will be kept for 3 years.

  1. Employment

In case of employment, the processing of your personal data by the company will be necessary for personnel management and payroll administration. The processing will be necessary for the execution of the employment contract, compliance with the legal obligations of the company, and the company may rely on its legitimate interest. You will be further informed about the processing of your personal data by the company for personnel management and payroll administration upon commencement of employment.

  1. Storage Location and Request for Deletion

Your personal data will be stored on the server of Talent Finder & Cebir, external service providers of the company that provide sufficient guarantees to protect your personal data.

If you wish, you can explicitly request the deletion of your CV before the end of this retention period by following the procedure described in Article 7.



7.     Your Rights



The company aims to provide as much information as possible through its current policy to be as transparent as possible about the processing of your personal data during a recruitment


and selection procedure. However, we understand that you may still have questions or require further clarification.

You have the right to access or request a copy of your personal data (file), correct or erase your data if it is inaccurate or incomplete, and, in some cases, restrict its processing. Where applicable, you can also request the transfer of your data to another data controller. The exercise of these rights must comply with the provisions of the GDPR.

To the extent that the processing is based on your consent, you have the right to withdraw that consent at any time, affecting only future processing. The company does not engage in automated individual decision-making with legal effects.

You can exercise your rights – and, if within the conditions outlined in the applicable legislation (GDPR), the employer will fulfill these – by contacting the Privacy Officer at

If you believe your rights have been violated, you also have the right to lodge a complaint with the Data Protection Authority.



8.     Safeguards

The company places significant importance on safeguarding your personal data, thus implementing appropriate technical and organizational measures to secure and protect your personal data from loss, alteration, or unauthorized access.

Access rights to your personal data are limited to those services and/or individuals who require access to fulfill the aforementioned purposes, such as the Human Resources Team and the intended manager(s) of a specific role. Ensuring that only necessary personal data is disclosed reduces the risks of data loss or unauthorized access.

Individuals with access to personal data have received or will undergo training regarding the processing of personal data and handling of your information. They are bound by confidentiality clauses to ensure the integrity and confidentiality of your data.