Job applicants




For the Processing of Your personal data, Controller is Aurubis Bulgaria AD, a joint stock company, registered in the Company Register with the Registry Agency under uniform ID code 832046871, having its registered seat and management address in:


Aurubis Bulgaria AD

            Industrial zone

            2070 Pirdop



Aurubis Bulgaria AD is represented by Tim Kurt, Executive Director.



Contact details of the Data Protection Officer


Data Protection Officer, Security and Risk Management department, Aurubis Bulgaria AD, Industrial zone, 2070 Pirdop

Tel.:        +359 7286 2280

Fax:        + 359 7286 2646

E-mail:   d.temelkova(at)



Collection and processing of personal data of job applicants/ apprenticeship in Aurubis Bulgaria AD




























Personal data, collected directly from the data subject in written or verbal prior to entering into employment or in civil contract:

  • Identification data: names, personal address, personal phone number, personal email add., date of birth, Civil Number, ID number, photo, marital status;
  • Other Data: In compliance with the Conflict of Interests policy in the Company, are collected names and position of family members, as family members we consider spouses or persons who are in a real spouses cohabitation, relatives in a straight line and a collateral line - up to the second grade inclusive, and kinship by marriage - to a second grade inclusive;
  • CVs, summaries, applications, referrals, offers.


 Personal data, generated by the Company in written or verbal:


·         Information for the interview performance, tests results, expected salary level, reference checking and others.


When issuing an access card, as part of the security and safety measures, review and transfer of the personal data from the identity document is performed, via reader, into the access control system, or the personal data is entered manually into the system. We collect and process the following data:


  • Name;
  • Personal identification No;
  • Photo;


Video Surveillance – on the territory of the company are located cameras for 24-hour video surveillance designed for security and operational purposes; on the entrances of the company are located cameras for 24-hour body temperature measurement that aim is to prevent epidemic/ pandemic disease spreading.



The processing of personal data in p. III (1-3)  is necessary for the following purposes:

  • Viewing of job application / internship at the company and assessing whether the job applicant meets the relevant requirements. The processing of the personal data for these purposes is based on job applicant consent, which he express unambiguously through his voluntary submission of application documents to the company. The processing of the personal data is also carried out for the purpose of taking, per his request, selection and recruitment steps prior to the conclusion of a labor or civil contract.
  • Personnel management – including but not limited to customary business practices related to planning and recruitment inclusive apprenticeship and trainees. The processing of personal data for these purposes is based on the legitimate interests of the company related to the necessity to develop its business in a sustainable manner and to increase its efficiency as well as the necessity to ensure compliance with the applicable legal requirements;

·         Security management – including but not limited to activities related to access control, video surveillance, ensuring security of the premises, assets and information held by the company, and for the purposes of preventing and investigating theft, fraud, abuse, conflict of interest, audits and controls, protection against serious cross – border  threats to health. The processing of personal data for these purposes is based on the legitimate interests of the company to ensure the safety and security of its assets as well as its employees against any possible risks;


Personal data provided as mentioned in p. III (1 and 2) is processed for up to 6 months.

Personal data entered into the access control system is processed and kept for up to 3 years.

Video records are processed and stored for up to 2 months of creation in compliance with the Private Security Services Legislation. The video records of sites under the Waste Management Act are processed for up to 1 year.


Video records and indicators of body temperature measurements are processed for up to 2 weeks.


Job applicants provide their personal data to the Company on a voluntary basis. If they do not provide their personal data, the company will not be able to execute the procedure for recruitment and to take steps for conclusion of a labor contract or to enter in civil contract with them.


The grounds for processing the personal data under p. III (1-3) are based on Regulation (EU) 2016/679 as follows: Article 6 (1) (a) of Regulation (EU) 2016/67 and Article 6 (1) (b) of Regulation (EU) 2016/679 and Article 6 (1) (e) of Regulation (EU) 2016/679 and Article 6 (1) (d) of Regulation (EU) 2016/679, in relation with Article 9 (2) (i) of Regulation (EU) 2016/679.



Collection and processing of personal data in other cases


In other cases, different than the mention in p. III, personal data is collected and processed only if provided voluntarily, as follows:



Written consent of the job applicant for the storage and processing of his personal data for up to 1 year.


The processing in this case is based on staying in touch with the job applicant for the above mentioned period of 1 year if in the company are opened new vacancies that matches his profile.

Personal data processing for these purposes is based on the job applicant consent, which is expressed unambiguously, by voluntary provision of documents and information necessary for the purposes of the certain case. Job applicant may withdraw the consent at any time that will not affect the lawfulness of the processing prior to the withdrawal of the consent.


The grounds for processing this personal data is based on Article 6 (1) (a) of Regulation (EU) 2016/679, Article 6 (1) (b) of Regulation (EC) 2016/679, Article 6 (1) (c) of Regulation (EU) 2016/679 and Article 6 (1) (f) of Regulation (EC) 2016/679.



Provision of personal data to third parties


Aurubis Bulgaria AD uses supplier services to process and store personal data ("Personal Data Processors" pursuant to Article 28 of Regulation (EC) 2016/679). In particular, this is applicable to the security company, recruitment companies and other services. These processors work only on contractual basis with Aurubis Bulgaria AD and store and process personal data according to the company's instructions.


The above mentioned data for the above purposes will be provided to other Aurubis Group companies only in the volume required for processing.


If you have entered the premises of the company and subsequently informed us that you have been infected in order to prevent the spread of a pandemic / epidemic disease, this information shall be disclosed to employees of Aurubis Bulgaria AD and employees of contractors who have been in contact with you and respectively may have been infected.


Out of these three circumstances, data will only be provided in individual cases and in a volume that is in accordance with a specific legal obligation of Aurubis Bulgaria AD, as well as in cases where You submitted consent to provide your data.



Job applicants rights as Data Subject


·         Right to withdraw consent at any time (Article 7 (3) of Regulation (EC) 2016/679). As a consequence, the company will not be able to continue processing this data if it was based on consent, and in particular the job applicant will prevent the possibility of the company  to review and assess his job/ internship application, respectively, to consider his application if there are new vacancies that match his profile within 6 (six) months of his application.

·         Right to request confirmation whether the company processes personal data, and if so, information on the storage and processing (Article 15 of Regulation (EC) 2016/679). In particular, information may be requested about the purposes of processing; categories of personal data; the categories of recipients to whom personal data will be or have been provided; storage period; the right to request correction, erasure and / or limitation of processing, to object to such processing and to lodge a complaint with a supervisory authority; information about the source from which the company have received personal data when it was not collected by the subject; information on the availability of automated decision making (including profiling) and, if applicable, relevant detailed information.

·         Right to request immediate rectification of the personal data (Art. 16 of Regulation (EU) 2016/ 679).

·         Right to request erasure of the personal data, unless its processing is necessary:

1) For exercising the right of freedom of expression and information;

2) For compliance with a legal obligation;

3) For reasons of public interest;

4) For the establishment, exercise or defense of legal claims (Art. 17 of Regulation (EU) 2016/ 679).

·         Right to request restriction of the processing of the personal data if: contest their accuracy; the processing is unlawful; the company does not need the personal data any more, but the data subject require them for establishment, exercise or defense of а legal claim; if the data subject has objected to processing pursuant to Article 21 (1) of Regulation (EU) 2016/ 679 (Art. 18 of Regulation (EU) 2016/ 679).

·         Right to receive the personal data in a structured, widely used and machine readable format or request the transfer of this data to another Administrator (Article 20 of Regulation (EC) 2016/679).


When exercising the right to receive personal data or to transfer it to another Controller, more than once within 24 months, Aurubis Bulgaria AD reserves the right, according to Ch. III, Art. 12 par. 5 (a) of Regulation (EU) 2016/679, to require payment of administrative costs of BGN 20 per set of paper copy and BGN 20 per electronic carrier.


In order to exercise his rights under the above points, the job applicant/ data subject must contact the Data Protection Officer designated by Aurubis Bulgaria AD:


Address:         2070. Pirdop, Industrial zone,

Tel :                + 359 886 131 999

E-mail:            d.temelkova(at)


The job applicant/ data subject has the right, under Article 77 of Regulation (EC) 2016/679, to lodge a complaint to the Commission for Personal Data Protection (CPDP) by the ways described in the Commission's website. The contact details of CPDP are:


Address:          1592 Sofia, Prof. Tsvetan Lazarov Blvd. 2

Fax:                  02 9153525

E-mail:              kzld(at)


Aurubis Bulgaria AD will cooperate to CPDP in the handling of such complaints and will comply with all recommendations and/ or instructions issued by the supervisory authority.


The job applicant/ Data subject has the right to lodge a complaint at Aurubis Group Headquarters by sending an email to dataprotection(at) .


Right of objection


If the personal data is processed on the basis of a legitimate interest of the company pursuant to Article 6 (1) (f) of Regulation (EC) 2016/67, the job applicant/ data subject has the right to object the processing of these data under Article 21 (1) of Regulation (EC) 2016/679. In this case, the company will not continue the processing of the personal data, unless there are convincing legal grounds for the processing that take precedence over the interests of the data subject, his rights and freedoms or are necessary for the establishment and/ or the defense of legal claims.

If the job/ applicant/ data subject wants to use the right to object, it is enough to send an email to d.temelkova(at)



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