Privacy Policy SAP SF | External applications

1. Scope

This Privacy Policy applies to all personal data collected through the SAP SuccessFactors (“SAP SF”), as well as through the website https://recrutamento.slbenfica.pt  (“Website”) – ") - together, the "Platform". 

Benfica may process the personal data of users of the Platform ("Users" or "User"), namely those who express their interest in the opportunities of employment and/or internship provided and that formalize their interest by submitting their application ("Candidates" or "Candidate"). 

The references in this Privacy Policy to "Benfica", "we" or "our" mean the entity of the Benfica Group acting as the controller, as described below. 

This Privacy Policy aims to clarify how Benfica treats and protects your personal data, providing the legally required information. 

In this sense, Benfica complies with the applicable legislation on the protection of personal data, namely Regulation (EU) No 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of individuals regarding the processing of personal data and the free movement of such data ("GDPR"), and Law 58/2019 of August 8, which ensures the enforcement in the national legal order of the GDPR. 

This Policy should be read together with the Platform Terms and Conditions. Accessing it implies knowledge and acceptance of the provisions of the applicable documentation. Otherwise, you should not use the Platform. 

2. Recruitment Process

  • Management and provision of the Platform

The entity responsible for processing the personal data of Platform users, collected during their browsing, is Sport Lisboa e Benfica with tax identification number 500 276 722, with headquarters at Avenida Eusébio da Silva Ferreira - Estádio Sport Lisboa e Benfica, 1500-312 Lisboa.

  • Recruitment process

Whenever you submit your application for a job or internship opportunity, the entity responsible for processing your personal data is, generally, the Benfica Group company that promotes the respective recruitment process and to whom you provide your data for the purposes of the application. 

However, in the event that, when registering on the Platform, and if the option is available, the Applicant chooses to include his/her profile in the Benfica Group's pool of candidates, for the purposes of recruitment and selection processes for any function and company of the Benfica Group, thus allowing access to his/her data - through SAP SF - to other companies of the Group, these entities will also be responsible, autonomously, for the processing of your personal data. 

The Benfica Group currently consists of the following companies, all based at the Estádio Sport Lisboa e Benfica, Avenida Eusébio da Silva Ferreira, 1500-313 Lisboa: 

a.    Sport Lisboa e Benfica, NIPC 500276722; 
b.    Sport Lisboa e Benfica - Futebol, SAD, NIPC 504882066; 
c.    Sport Lisboa e Benfica SGPS, S.A. NIPC 505270048; 
d.    Sport Lisboa e Benfica - Multimédia, S.A., NIPC 505564424; 
e.    Benfica TV, S.A., NIPC 508517494; 
f.     Benfica FM, S.A., NIPC 514631228; 
g.    Benfica Estádio - Construção e Gestão de Estádios, S.A., NIPC 505813378; 
h.    Parque do Benfica - Sociedade Imobiliária, S.A., NIPC 506807410; 
i.     Clínica do SLB, Unipessoal, Lda., NIPC 508205360; 
j.     Sport Lisboa e Benfica - Seguros, Mediação de Seguros, Lda., NIPC 508797404;
k.    Identiperímetro Sociedade Imobiliária, S.A. NIPC 508992770; 
l.     Red Up Sports, Lda., NIPC 514395931; e 
m.   Fundação Benfica, NIPC 509259740. 

3. Personal data? What does it mean?

Personal data is any information of any nature and regardless of its support, including sound and image, relating to an identified or identifiable individual ("data subject"). A person is considered identifiable if he/she can be identified directly or indirectly, namely by reference to an identification number or more specific elements of his/her physical, physiological, psychic, economic, cultural, or social identity. 

4. Personal Data Collected, Purposes and Grounds

Benfica collects and processes the following categories and types of personal data from Platform Users:  

Personal Identification Data
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First Name; Last Name; Gender; Date of Birth; Nationality

Contact Information
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E-mail address (personal and/or professional); Mobile phone number (personal and/or professional); Address; Zip code; City; Country of residence 

Applicant profile data, including Educational Qualifications and Professional Experience
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CCV; Cover letter and attached documents; Position(s) applied for; Linkedin profile; Academic qualifications and educational institution(s); Academic degree(s); Course(s), Educational Area(s) and Start and Finish Date(s) of Course(s); Other Training; Professional Experience and Indication of Company(ies), Position(s) and Country(ies); Geographical Availability; Computer and Language Skills (languages, oral, reading and writing skills) 

Data relating to the Job Opportunity Application(s) and respective procedures
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CV; Cover letter and attached documents; Application status, date and identification number; Other applications; Main motivations and reasons for the application; Salary expectations; Availability of working hours; Motivations for the project; Professional experience (including in the position to be filled); Current situation/existing contractual relationship; Club (when necessary due to the position to be filled); Strengths and areas for improvement; Computer skills; Willingness to start work; Insertion in other recruitment processes; Future projects and ambitions 

Data relating to the Application(s) for Internship Opportunity(ies) and respective processes
__________________________________________________________________________________________
CV; Cover letter and attached documents; Application status, date and identification number; Other applications; Main motivations and areas of interest for the internship; Motivations for the project; Internship duration and scheme; Availability of hours; Expected year of graduation and information on the protocol with the educational institution; Professional experience; Club (when necessary due to the role); Strengths and objective of the internship; Computer skills; Availability to start work; Supervisor and Internship Protocol 

Data on criminal convictions and/or misdemeanors
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Criminal record certificate (only when required) 

Data related to the Onboarding Process (only collected if accepted)
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Identification Documents (Document No., Expiry Date, and Issue); Photo; Social Security Number; Proof of Academic and Professional Certifications; Country and Place of Birth; Language; Full Name and Professional Name, if applicable; Marital Status; Other Documents, if applicable, and which may vary depending on the specific position (e.g. Residence Permit, Driving License; SNS User number, CGA Beneficiary Number; Professional Card; Affiliation Number; No. of SLB Member); Emergency Contact (Name; Relationship to Employee; Telephone Contact); Bank Details (Country; Type of Payment; Country/Region of Bank; IBAN; Amount; Proof); Tax Details (Tax Identification No. and other details for the specific position). Tax Identification Number and other data for compliance with the applicable tax regime, for IRS withholding purposes, such as tax marital status and other conditions, as well as the upload of Declaration 99 (to be completed and signed by Onboardee); Household Data (such as Household Composition, Household Identification Data (Name, Identification Document, Family Relationship and Date of Birth) and Data on Benefits Granted to the Household)) 

 Platform Usage Data
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Data collected through your interaction with the platform (e.g. recording of activity on the Platform (logs), IP address, location data, etc.) 

 

The User guarantees that he/she is of legal age and that the data provided is true, accurate, complete, and current, and is responsible for any non-compliance.  

The provision of some personal data is mandatory, as without it will not be possible to use the Platform and/or its functionalities. Mandatory fields are marked with an asterisk (*). Regarding the documents made available, the Applicants - both in the recruitment process and in the onboarding process - should restrict their availability to those that are specifically required, and not insert any others into the Platform. If you have any questions about the documents that should be provided, please contact the entity responsible for processing or the Human Resources Department, the latter through the following address: drh@slbenfica.pt. 

If third party data is communicated, the User guarantees that he/she has informed the third party of the conditions provided in this document and that he/she has been authorized to provide his/her data to Benfica for the purposes listed.  

Benfica processes the personal data provided, under the terms of the applicable legislation, for various purposes, including those listed below and on the following grounds: 

Registering on the Platform and creating an Applicant Profile                                                                     
Some personal identification and contact details (e.g. your name, e-mail address and mobile phone number) will be processed to create your account and Applicant Profile, allowing you to take advantage of the Platform's functionalities with regard to submitting applications for job(s) and/or internship opportunities at Benfica Group companies, as the Applicant Profile may be developed by you with additional data. 
____________________________________________________________________________________________

•  Execution of a contract with the Applicant (Terms and Conditions)
•  Legitimate interests in obtaining and organizing information on Applicants

Recruitment process
Your identification and contact details, relating to your Applicant Profile and application for the job and/or internship opportunity(ies) identified above, will be processed for the purposes of managing each recruitment and selection process, following the submission of your application(s) on the Platform. 
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•  Pre-contractual investigations requested by the data subject
•  Compliance with legal obligation

Automatic Notifications about Recruitment Processes
Your identification and contact details, namely your name and e-mail address, will be processed in order to send you automatic communications (i) about the recruitment processes you take part in (such as, for example, thanking you for sending in your application, scheduling an interview, providing feedback on your application or even sending you an offer letter, etc.) and/or (ii) to inform you of new vacancies that may be of your interest, once you have consented to this and selected your areas of interest on the Platform. 
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• Legitimate interests in keeping Applicants informed of developments in the recruitment processes for which they have applied
•  Consent

Campaigns about other job opportunities
Your identification and contact details, in particular your name and e-mail address, will be processed in order to send you non-automated communications, such as e-mail campaigns relating to specific vacancies and aimed at a specific group of potential Applicants.
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•  Consent

Onboarding Process
Your personal data related to the onboarding process (identified above) will be collected and processed if you are one of the Applicants selected for the job or internship opportunity(ies) you applied for, without prejudice to the collection of additional data when and if you become a permanent employee.
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•  Pre-contractual diligences at the request of the data subject and execution of the contract concluded in this context
•  Compliance with a legal obligation
•  Consent (e.g. for the collection and processing of image data)

Compliance with Legal Obligations
Your personal data (as defined in the request sent to us) will be processed to respond to and report on court orders, administrative requests or requests for information submitted by public authorities with their own or delegated powers; or for the purposes of declaring, exercising, or defending a right in legal proceedings.
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•  Compliance with Legal Obligations

Platform Management and Maintenance
Your Platform usage data will be processed for the Platform management and maintenance (e.g. to ensure the continuity, integrity and security of our systems).
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•  Legitimate interests in keeping the Platform operational

Information Security
The Platform usage data may also be used to manage access, access logs and changes, as well as to carry out backups and to resolve any abnormalities in operation.
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   •  Legitimate interests in ensuring information security and keeping the Platform operational
    • Compliance with Legal Obligations                                    

5. Data retention periods

The personal data collected is processed in compliance with the provisions of the Law. 

The data collected through the Platform will be kept for the period appropriate and strictly necessary for the purpose for which it was collected, namely: 

  • For the purpose of recruitment, the data will be kept for a maximum period of 1 (one) year after the User's last interaction with the Platform or after the end of the recruitment and selection process, after which period they will be anonymized, without prejudice to the exceptions included below for the retention of data for longer periods. In the event of employment, the data will be processed for HR management purposes and retained for the periods applicable to employee data; 
     
  • Records of activity on the Platform (e.g. access logs) will be kept for a period of 1 year. 

Users' personal data will be kept for the periods defined above or, if they do not fall into any of the categories listed, for the period strictly necessary for the pursuit of the purpose for which they were collected, unless: (i) Benfica is obliged to keep them for a longer period by virtue of the Law; (ii) the retention of personal data is necessary to defend rights and interests in judicial or administrative proceedings, up to a limit of 6 months after the final judgment of the respective sentence; or (iii) one of the rights of the data subjects that prevent conservation (for example, the right to erasure) is exercised, to the extent permitted by law.  

Benfica may also keep the data beyond these periods for statistical purposes, and for this purpose must anonymize it. 

To ensure compliance with the retention periods, a data purge feature has been implemented on the Platform, which ensures that personal data is anonymized or deleted after the respective retention periods have elapsed. 

In any case, the Applicant can always, at any time and by his/her choice and decision, remove an application, delete his/her data, or delete his/her entire profile from the Platform. 

6. Data Subject Rights

Under the terms of the applicable legislation, the data subject may request at any time the following rights: 

Right of access: Benfica ensures the existence of means that allow the data subject to obtain confirmation of which personal data are being processed, to request access to them, to obtain information about the processing, as well as to obtain a copy of the personal data being processed. Benfica may apply an appropriate fee to the data subject, taking into consideration the eventual administrative costs.

Right to rectification: Benfica ensures the existence of means that allow the data subject to rectify their personal data, if they are incorrect/inexact, or complete them if they are incomplete.

Right to erasure (or "Right to be forgotten"): Benfica ensures the existence of means that allow the data subject to request the erasure of their personal data under the following circumstances: 

  • When personal data has been unlawfully processed.
     
  • When the data subject withdraws his consent to the processing of his data and there is no other legal basis for the processing.

Right to restriction: Benfica ensures the existence of means that allow the data subject to request the restriction of the processing of his/her data in certain situations, for example, if he/she contests the accuracy of the data, for a period that allows the controller to verify its accuracy, or if the controller no longer needs the personal data for the purposes of the processing, but such data is required by the data subject for the purposes of declaring, exercising or defending a right in legal proceedings.

Right to portability: Benfica ensures the existence of means that allow the data subject to receive the personal data concerning him and provided by him, in a digital and structured format, of current use and automatic reading, and to request that they be sent directly to another entity that becomes the new responsible for the personal data, if the treatment:

  • It is carried out with the consent of the owner or based on the performance of a contract; and 
     
  • It is carried out by automated means. 

Right to object: Benfica ensures the existence of means that allow the data subject to object at any time, and for reasons related to his/her particular situation, to the processing of his/her data on the basis of:

  • Pursuit of legitimate interests of the controller; and/or 
     
  • Compatibility of the initial processing with further processing of such data, including profiling. 

Right to withdraw consent: The data subject may, at any time, withdraw consent for the processing of the data on this basis, through the means set out in point 7. or through the Platform (if he/she has given consent through this means). In any case, the withdrawal of consent does not compromise the lawfulness of the processing carried out up to that date based on the consent previously given. Consent should be as easy to withdraw as it is to give. 

7. Exercise of Rights

Under the terms of the applicable legislation, data subjects may exercise their rights at any time by writing to Benfica at the following addresses:

  • E-mail: linhabenfica@slbenfica.pt;
     
  • Morada: Av. Eusébio da Silva Ferreira, Estádio do Sport de Lisboa Benfica;
     
  • E-mail of DPO: dpo@slbenfica.pt.

Benfica may request from the data subject proof of his/her identity or the elements necessary to allow his/her unequivocal identification, to the extent that it is appropriate, relevant, and limited to what is necessary to guarantee the response to the exercise of his/her right(s). 

Regarding the automatic communications on recruitment processes published on the Platform or campaigns on job opportunities, you can withdraw your consent at any time and change the settings of these alerts in the "Options/Job Alerts" menu. 

Regarding the inclusion in the Benfica Group's candidate pool, you may withdraw your consent at any time in the "Search and Privacy Options" area.  

The data subject also has, without prejudice to any other way or means legally available to him, the right to lodge a complaint with the National Data Protection Commission (CNPD) or any other competent supervisory authority, in accordance with the law. 

8. Third-party pages

Through the Platform, we provide links to third-party websites, which are subject to independent Privacy Policies. Examples of such links are hyperlinks to access networking platforms, such as social networking platforms, namely LinkedIn, where Benfica is registered. 

This Privacy Policy does not apply to any third-party website and Benfica is not responsible, nor can it be held liable, for the collection and processing of personal data by said third parties through their websites. Therefore, the User should carefully read the terms and conditions and privacy policies of these platforms or websites before sharing any information. 

9. Cookies and Other Tracking Technologies

The Platform uses cookies placed by SAP (the SAP SF provider) and, in some cases, by other third parties, to provide certain functionalities. Benfica is not responsible for the placement of these or other tracking technologies on your device, in the context of the use of the Platform, also not having access and not processing any personal data that may result from it. To learn more, we recommend consulting the information about the use of cookies on the Platform provided by SAP on its website. 

10. Security measures

Benfica is aware that the sending of personal information is a major concern for Users who access the Internet. Notwithstanding the security measures adopted by Benfica, namely those referred to herein, we warn all Users that when accessing the Internet, they should regularly take precautions and adopt additional security measures in this area, namely by using an up-to-date, protected computer and browser and beware of using shared computers. 

Benfica implements a set of technological measures to ensure the processing of personal data, whether carried out by Benfica or by companies contracted by it. 

Benfica makes its best efforts to ensure the security of personal data, including protection against unlawful access, appropriation, unauthorized tampering and/or disclosure, improper disposal, and the spread of malicious software (computer viruses), adopting the appropriate technical and organizational measures for this purpose. Benfica also uses SSL (Secure Sockets Layer) encryption of all the information provided by the User, to ensure privacy and security in the transmission and storage of personal data. 

In terms of privacy and protection of personal data, Benfica's obligations to implement technical and organizational security measures are obligations of means (and not of result), which is why by accessing the Platform and the contents, the User acknowledges and accepts, in the same way, to run the risks inherent to such activity in the digital and electronic environment, namely, illegitimate access, appropriation, unauthorized tampering and/or disclosure, improper deletion and the spread of malicious software (computer viruses). 

The User also acknowledges and accepts that Benfica, its administrators, directors, and employees, cannot be held responsible for unlawful acts committed by third parties, including other Users, namely those referred to in the previous paragraph, even in cases where such acts cause damage, whether of a patrimonial or moral nature, unless Benfica is at fault or seriously at fault. 

11. Under what circumstances is data communicated to other entities?

Benfica uses the services of third parties (i.e. recruitment agencies; digital business and human resources management service providers, belonging to the technology sector and located in the [European Union/Germany], for the provision, implementation, and maintenance of the Platform; and consulting service providers in the technology sector, located in Portugal, for assistance and advice in the implementation of the Platform), as well as to other entities of the Benfica Group, located in Portugal, which may provide some support services (for example, management of recruitment and selection processes) and which process the data based on a subcontracting relationship. 

Any subcontractor of Benfica will process the personal data of the data subjects in the name and on behalf of Benfica, under the strict obligation to follow our instructions. Benfica ensures that its subcontractors offer guarantees of implementation and maintenance of relevant technical and organizational measures so that the processing complies with the provisions of the Law and guarantees the security and protection of the personal data of Applicants and Users, under the terms of the subcontracting agreements entered. 

To increase the visibility of your profile, and with your consent, given when you register on the Platform, your personal data may be communicated to other entities of the Benfica Group, for recruitment and selection processes for any function and company of the Group. 

Benfica may also transmit personal data to third parties when it deems such data communications to be necessary or appropriate (i) under applicable law, (ii) in compliance with legal obligations/court orders, or (iii) to respond to requests from public or governmental authorities. 

In any of the above situations, Benfica undertakes to take all reasonable measures to ensure the effective protection of the personal data it processes. 

Benfica undertakes to guarantee the security and integrity of the data in cross-border transfers (outside the European Economic Area - "EEA") and to inform the data subject of these transfers whenever they occur. In addition, Benfica is responsible for implementing the necessary mechanisms to obtain the legal basis for carrying out any cross-border transfer, where applicable (for example, the conclusion of standard contractual clauses approved by the European Commission). 

12. Data Transfers to Third Countries

Benfica has opted for servers located in the EEA to support and operate the Platform, thereby guaranteeing that data processing takes place in the EEA. 

However, exceptionally, the processing of your data for the purposes indicated may involve its communication to entities established in third countries, i.e., outside the EEA. Such transfers will be made (i) when there is an adequacy decision by the European Commission for the country receiving the data, (ii) to entities based or located in the United States of America (USA) that are certified under the EU-US Data Privacy Framework mechanism, or (iii) in other cases, based on the implementation of appropriate guarantees, such as standard contractual data protection clauses adopted by the European Commission, with the responsible entities undertaking to adopt the additional protection measures necessary to ensure, as far as possible, that the level of protection of the personal data transferred is essentially equivalent to that existing in the European Union. 

If the data subject wishes to obtain further information on the processing of personal data carried out outside the EEA, including on the appropriate safeguards and additional protection measures adopted for the transfer of their data, they may contact the controller(s) at the contact details provided in this Policy, in the following section.  

13. Doubts and requests for information

You can contact Benfica for more information on the processing of your personal data, as well as for any questions related to the exercise of the rights granted to you by the applicable legislation and, in particular, those referred to in this Policy, using the following contact details: 

  • Phone number: 217 219 500;
     
  • E-mail: linhabenfica@slbenfica.pt;
     
  • Address: Av. Eusébio da Silva Ferreira, Estádio do Sport de Lisboa Benfica, 1500-313 Lisboa.

14. Changes to the Privacy Policy

Benfica reserves the right to make changes or updates to this Privacy Policy at any time, and these changes will be duly updated on the Platform and notified to data subjects. We suggest that you check our Policies regularly to be aware of any changes that may be made. 




 

Last updated: February, 2024