TOMRA recruitment privacy notice

Pursuant to Art. 13, 14 and 21 GDPR this Privacy Notice informs you about how we, TOMRA, process your personal data when you apply for a job advertised by us. This Privacy Notice also describes your choices regarding use, access, and correction of your personal information if you apply for a job advertised by us. Furthermore, the Privacy Notice describes the information we collect from you and how it may be stored and processed in the TOMRA Recruit system. The TOMRA Recruit system is the Applicant Tracking System for the TOMRA Group.

What information we collect

TOMRA Recruit collects the following job seekers data where this is provided to us:

All job seekers::

  • Campaign engagement insights and analytics
  • Name of candidate
  • Address
  • Email address
  • Contact details
  • Work experience history
  • Education history
  • CV
  • Notice period
  • Salary expectations
  • Driver’s license
  • Previous information if worked for TOMRA (all countries except Germany)
  • Legal right to work (all countries except Germany)

For some countries::

  • Criminal convictions (only for China, New Zealand, and Australia)
  • Injury and medical conditions (only for United States, China, New Zealand and Australia)


Information collected only for regulatory reporting purposes::

  • Gender (for United States, New Zealand, and Australia)
  • Ethnicity (for United States, New Zealand, and Australia)
  • Veteran status (for United States)
  • Disability (for United States, New Zealand, and Australia)

Purpose and legal basis for the processing of personal data

We process your personal data to make a decision on the establishment of an internship, apprenticeship or employment relationship with us. The legal basis for this is Art. 6 (1) lit. b GDPR for the initiation or implementation of contractual relationships. Furthermore, your personal data will be processed if this is necessary to fulfill legal obligations (Art. 6 (1) lit. c GDPR) or to defend legal claims against us (Art. 6 (1) lit. f GDPR) is required. With your freely given consent, we may process your data to analyse candidate engagement during recruitment campaigns for improved outreach. The legal basis for this is Art. 6 (1) lit. a GDPR. You can withdraw this consent at any time without giving any reason for it, and your data will then be deleted.

Requirement to provide personal data

You are not obliged to provide information about your personal data. However, please note that if you do not provide certain personal information for the application process, we will not be able to establish an employment relationship with you. We recommend that you only provide personal data in your application that is necessary to carry out the application.

Talent pool

If we initially must reject your application, we may ask for your consent to store your personal data in our talent pool beyond the end of the specific application process. This enables us to maintain contact with talented applicants and to inform them about suitable job vacancies in the future.

The storage and processing of your applicant data in our talent pool is based on the legal basis of Art. 6 (1) lit. a GDPR, your consent. You can withdraw this consent at any time without giving any reason for it, and your data will then be deleted.

When and how we share your personal data with others

We only pass on your personal data within our company to those departments and persons who need the data to fulfill contractual and legal obligations or to implement our legitimate interests.

The data will be visible to the hiring manager for the position, the local HR/P&O department and assigned system administrators. If the hiring process is administered through an agency, your data will be visible for the assigned person in the agency. TOMRA does not intend to transfer personal data to a third-party system.

Transfer to a third country

The applicant management system is delivered by a company outside EEA/EU. To ensure the necessary safeguards for transfer of your personal data to countries outside your home jurisdiction, we have put in place appropriate security precautions and safeguards (among them, the conclusion of a Data Processing Agreement or contract and the latest Standard Contractual Clauses and additional security measures) to ensure the protection of your personal data and compliance with laws on data protection.

No automated decision-making

TOMRA Recruit does not use automated decision-making within the meaning of Art. 22 GDPR.

How long we keep your personal data

category of information: information is deleted after:
Applications outside Norway (rejected or withdrawn) Six months
Applications within Norway (rejected) One year based on candidate's consent
Applications within Norway (withdrawn) Six months
Information about hired candidates Two years
Record of talent pool candidates One year

Users that leave TOMRA will be de-activated in TOMRA Recruit, making the data invisible for direct managers. The data will then automatically be deleted 1 year after de-activation. Assigned system administrators will have access to data of de-activated users until it is deleted.

Talent pool candidate campaign engagement insights and analytics are kept up to a year after signing up, after which they will be automatically deleted along with candidate records.

If your application is successful, we will store your personal data for the duration of your employment in accordance with the Employee Privacy Policy, which we will provide to you upon acceptance of employment.

Your rights concerning your personal data

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

  • You can request access, correction, erasure, or updates of your personal information.
  • You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.
  • You have the right to complain to a data protection authority about our collection and use of your personal information. Contact details for data protection authorities in the EEA, Switzerland, and certain non-European countries (including the US and Canada) are available here.

To exercise any of these rights, please contact us at [email protected] or by mail to TOMRA Systems ASA, Drengsrudhagen 2, 1385 Asker, Norway, Attn: Privacy – Data Protection Officer. We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken.