1. Purpose
This document about the personal data protection policy within the John Cockerill Group aims at explaining in a simple and clear way the processing of personal data made by John Cockerill Group’s companies (clients, suppliers, subcontractors, professional contacts, visitors, group website or group social network pages visitors…).
This policy is regularly updated. We invite you to regularly consult our website to consult the current version.
2. General information applicable to any personal data processing
2.1 Who is processing your data ?
The Company, member of the John Cockerill Group, with which you are in relation and of which you can find the exact contact details on our internet site https://johncockerill.com/en/contact/ (hereinafter referred to as “the company”), is responsible for the personal data processed.
In this policy, « John Cockerill » is referred to as the Group’s company you are in relation with.
As far as the processing of your data as visitor of the websites and as a visitor of the Group’s social network pages, the processor responsible is John Cockerill S.A., established at Rue Jean Potier, 1 at B-4100 Seraing, Belgium, company number 422 362 447, phone : +32 4 330.24.44, as it is the company which publishes the internet sites and social network pages.
You can contact our GDPR Officer via e-mail at [email protected].
2.2 Is your data transferred outside the European Union ?
Your data is in principle exclusively stored on servers located inside the European Union.
In the event of transfer outside the European Union, your data is transferred in a country which would not offer an adequate protection level only if the processing of your file requires data sharing with professionals from non EU countries. The same applies, for some processing operations, when we could use subcontractors located outside EU.
Under these circumstances, we see that the data recipient are obliged to respect the same data protection standards as in the EU through appropriate standard contractual clauses. A copy of these guarantees is available on request.
2.3 As a data subject, what are your rights ?
Information – this right may be exercized with this document. If, among the processing operations, data of your staff members are present, you are able to ensure they are aware of the content of this document.
Access and rectification – You have the right to access your data and to make them rectified if needed.
Object – You can object to any processing of your data that we are making on the basis of our legitimate interest.
Consent withdrawal – When data is processed under your consent, you can reverse this decision at any time, without calling into question the data processing made in the past.
Erasure – You can obtain the erasure of your data or the limitation of processing as mentioned in the articles 17 and 18 of the GDPR.
Portability – You can ask us to receive the data you provided in an electronic version.
2.4 Where can you obtain more information or file a complaint ?
You can contact the processor of your data (as defined in 2.1) and the responsible of the data protection ([email protected]) for any question and, joining a proof of identity, for any request related to the rights mentioned hereunder.
If you want more information, of if you want to file a complaint, you can contact the Data protection authority of your country or of the company you are in relation with : Our Members | European Data Protection Board (europa.eu)
3. Specific data processing depending on your quality
3.1 You are a client of John Cockerill
Categories of data collected – If you are a client of John Cockerill, the following personal data related to you can be processed : identification (name, surname), contact data (address, e-mail address, phone number), data related to the client file (correspondence…).
Purpose – This personal data is processed for the following purposes:
- For the contractual relation execution and management : order entry, communication, delivery, invoicing, claw back… Such data processing is necessary for the proper performance of the contract between you and John Cockerill. Without this data, John Cockerill can’t perform the contract.
- For direct marketing purposes: the legitimate interest of John Cockerill justifies to realize information or promotion operations about its service portfolio (which includes invitations to events).
Retention period – Your data is kept during 10 years after the end of the contract concluded with John Cockerill, except when a legal retention time would apply. For direct marketing operations, you have the right to object to the processing of your data at any moment.
Recipients – To fulfill the purposes mention hereunder, your data can be transferred to the following recipients:
- John Cockerill staff members (employees, private consultant, trainees…), as well as its partners if the processing of your data is necessary for them to do their tasks;
- Data processors (subcontractors) working for John Cockerill;
- Fiscal and social administration if the law so provides;
- John Cockerill credit insurers or project financing bodies.
3.2 You are a prospect of John Cockerill
Categories of data collected – If you are a potential client of John Cockerill, the following personal data related to you can be processed : identification (name, surname), contact data (address, e-mail address, phone number), data related to the profession (company, title…).
Purpose – This personal data is processed for the following purposes:
- For prospection : if you have consented to the processing of your personal data by John Cockerill (i.e. if you provide your personal data to John Cockerill), John Cockerill will evaluate the opportunities to make business with you.
- For direct marketing, based on your consent.
You can withdraw your consent at any time
Retention period – John Cockerill keeps your data as long as you ask us to stop.
Recipients – To perform the purposes listed hereunder, your personal data can be provided to the following recipients:
- John Cockerill staff members (employees, private consultant, trainees…), as well as its partners if the processing of your data is necessary for them to do their tasks;
- Data processors (subcontractors) working for John Cockerill (i.e. direct mail providers);
3.3 You are a supplier of John Cockerill
Categories of data collected – If you are a products or services supplier of John Cockerill, the following personal data related to you can be processed : identification (name, surname), contact data (address, e-mail address, phone number), data related to the profession (company, title), financial or accountancy data (bank account number, bank account holder), data related to the monitoring of services.
Purpose – This personal data is processed for the following purposes:
- For contractual relation management: price quotation, order and delivery management, invoicing, payment, possible supplier service evaluation. Such data processing is necessary for the proper performance of the contract between you and John Cockerill. Without this data, John Cockerill can’t perform the contract.
- For fighting against fraud and abuse: for some activities, John Cockerill has a legitimate interest to perform some checks and controls on the supplier to fight against fraud and abuse.
- For managing John Cockerill’s company: to set up possible data rooms, in the frame of a due diligence, your data could be processed. This processing is justified by the legitimate interest of John Cockerill to ensure a good management of its activities.
- For direct marketing purposes, based on your consent. You can withdraw your consent at any time.
Retention period – Your data is kept during 10 years after the end of the last contract concluded with John Cockerill.
Recipients – To perform the purposes listed hereunder, your personal data can be provided to the following recipients:
- John Cockerill staff members (employees, private consultant, trainees…), as well as its partners if the processing of your data is necessary for them to perform their tasks;
- Data processors (subcontractors) working for John Cockerill.
3.4 You are an on-site visitor of John Cockerill
Categories of data collected – If you are visiting one of John Cockerill’s sites, the following personal data related to you can be processed : identification (name, surname, license plate number, badge data, image), contact data (address, e-mail address, phone number), data related to the visit (visitor type, contact inside the company, purpose of the visit, date and time of the visit).
Purpose – This personal data is processed for the following purposes:
- To ensure the site security : arrival and departure management, parking management… John Cockerill has a legitimate interest to ensure the security of its sites, which requires the management of your visit.
- For statistics : on the basis of its legitimate interest, John Cockerill makes statistics of visits to ensure the correct staff at the welcome desk.
- For direct marketing purposes : on the on the basis of your consent. You can withdraw your consent at any time.
Retention period – Your data is kept during 3 months after your last visit at John Cockerill.
Recipients – To perform the purposes listed hereunder, your personal data can be provided to the following recipients:
- John Cockerill staff members (employees, private consultant, trainees…), as well as its partners if the processing of your data is necessary for them to perform their tasks;
- Data processors (subcontractors) working for John Cockerill.
3.5 You are a visitor of the websites of John Cockerill
Categories of data collected – If you visit one of the websites of John Cockerill, you don’t have to provide personal data. However, the websites require cookies collection.
If you contact John Cockerill through the form the « Contact us » page of the website, the following personal data can be processed: identification (name, surname), contact data (e-mail address), data related to the profession (company), data related to the request (sector to contact, purpose, message).
Purposes – This personal data is processed for the following purposes:
- For placing and reading cookies: some cookies are necessary for a correct internet surfing, and others are optional and you are free to accept them or not. For more information, please read the section related to cookies below.
- For the management of your request: to be able to answer your question or request, John Cockerill needs to know the collected data. Without it, John Cockerill can’t answer to you.
- For statistics: based on its legitimate interest, John Cockerill makes statistics of audience and use of its internet sites.
- For direct marketing purposes, based on your consent. You can withdraw your consent at any time.
Recipients – To perform the purposes listed hereunder, your personal data can be provided to the following recipients:
- John Cockerill staff members (employees, private consultant, trainees…), as well as its partners if the processing of your data is necessary for them to perform their tasks;
- Data processors (subcontractors) working for John Cockerill.
- Third parties mentioned in the section related to cookies management (hereafter).
3.6 You are a visitor of a John Cockerill social network page
Categories of data collected – If you visit one of the social network page of John Cockerill, the following data can be processed by the social network together with the page administrator: data linked to your account, data linked to contents or messages you shared with other persons.
Purposes – This personal data is processed for the following purposes:
- For placing and reading cookies. For more information, please read the section related to cookies below.
- For improvement by the social network, of its content management and advertising system.
- For statistics : on the basis of its legitimate interest, John Cockerill makes statistics of audience and use of its social network pages.
Your data will only be processed by the page administrator (John Cockerill) based on its legitimate purpose to collect statistics on the visitors of its pages to promote it in an adequate way. The audience statistics made by the social network are only transmitted to the page administrator in an anonymous form.
Retention period – Your data is kept or could be kept as long as the page exists and is visited by you.
Recipients – To perform the purposes listed hereunder, your personal data can be provided to the following recipients:
- John Cockerill staff members (employees, private consultant, trainees…), as well as its partners if the processing of your data is necessary for them to perform their tasks;
- Data processors (subcontractors) working for John Cockerill.
- To the concerned social network.
3.7 You apply for a job, an internship or a temporary post
Categories of data collected – If you apply for a job – internship – temporary post at John Cockerill, the following data can be processed: identification (name, surname, image), contact data (e-mail address, phone number), data related to the career path (experience, CV, former employers, language skills…), data related to the hiring interview and questionnaire (evaluation, comments) and, in exceptional cases, sensitive data (an extract from the applicant’s police record or equivalent document under the law of the applicant’s country of origin).
Purposes – This personal data is processed for the following purposes:
- To assess your application: John Cockerill analyzes your application to assess the possibilities for a contractual relationship.
- For security reasons: for some jobs or some projects, John Cockerill may ask you to provide some sensitive data. In that case, the legitimate interest of John Cockerill to hire trusted people to ensure the security of its activities, allows it to process such data.
- To constitute a reserve for future recruitments: the legitimate interest of John Cockerill consists in contacting you later for the job offer or if a vacancy for another similar job appears. If you don’t want to be included in the reserve for future recruitments, you always can object.
Retention period – Your data is kept during 3 months after the selection process has been completed, except if you ask us to keep it longer.
Recipients – To perform the purposes listed above, your personal data can be provided to the following recipients:
- John Cockerill staff members (employees, private consultant, trainees…), as well as its partners if the processing of your data is necessary for them to perform their tasks;
- Data processors (subcontractors) working for John Cockerill (i.e. recruitment agencies).
4. In any case
In any case, John Cockerill can process your personal data in the following cases:
4.1 Possible legal dispute
Your data can be processed in the frame of the management of a possible legal dispute: in compliance with the article 6 of the European Convention of Human Rights, if a dispute appears between you and John Cockerill, John Cockerill will be allowed to process your personal data to avail himself of a material and technical defense.
To perform this purpose, your personal data can be provided to the following recipients:
- John Cockerill staff members (employees, private consultant, trainees…), as well as its partners if the processing of your data is necessary for them to perform their tasks;
- Lawyers, advisors, debt collection companies, bailiffs of John Cockerill
- Police and/or judicial institutions
- Data processors (subcontractors) working for John Cockerill (i.e. recruitment agencies).
4.2 Fight against fraud and abuses
Your data can be processed to fight against fraud and abuses (only for processing relying on a contract between you and John Cockerill): John Cockerill has a legitimate interest to perform some checks and controls related to the reputation and solvency of his co-contractors, to protect itself against risks of fraud and abuses.
To perform this purpose, your personal data can be provided to the following recipients:
- John Cockerill staff members (employees, private consultant, trainees…), as well as its partners if the processing of your data is necessary for them to perform their tasks;
- Lawyers, advisors, debt collection companies, bailiffs of John Cockerill
- Police and/or judicial institutions
- Data processors (subcontractors) working for John Cockerill (i.e. recruitment agencies).
4.3 Direct marketing
Your data can be processed for direct marketing purposes:
- If you are a client of John Cockerill, the legitimate interest of John Cockerill justifies the performance of service information or promotion (including the possible invitation to events). Nevertheless, you always have the right to object your data processing at any time.
- If you give your consent, your personal data can be processed to send you direct marketing messages. You can withdraw your consent at any time.
4.4 Video-surveillance
Your image may be be captured by one of our video-surveillance camera when you enter the offices of John Cockerill.
Your data is processed based on the legitimate interest of John Cockerill to ensure the security of its buildings and offices (art. 6.1.f of the GDPR).
Your data is kept for 30 calendar days.
The communication of your data could be necessary regarding service providers and subcontractors (ICT services providers, security services providers…).
In some cases, the communication of your data could also be necessary regarding competent authorities (i.e. police services).
