TOKYO ELECTRON EUROPE Ltd.

Tokyo Electron Europe Limited
Candidate Privacy Notice
23 June 2021

Tokyo Electron Europe Limited1

TOKYO ELECTRON EUROPE Ltd.

CONTENTS

1. Introduction and Definitions
2. Why we collect your Personal Data
3. What Personal Data we might process
4. Who we share your Personal Data with
5. How we protect your Personal Data
6. Your Rights
7. Processing Conditions
8. How long we retain your Personal Data
9. How to contact us if you have any questions or concerns

Appendix 1 – Personal Data we may process

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TOKYO ELECTRON EUROPE Ltd.
1)Introduction and Definitions
This Candidate Privacy Notice (“Privacy Notice”) explains how the TEL Companies in Europe (which
includes Tokyo Electron Europe Limited (TEEL), (Tokyo Electron Limited Magnetic Solutions (TELMS)
and Tokyo Electron Israel Limited (TEY)”) (henceforth referred to as “the Company”, “we,” “our,” or “us”)
handles your Personal Data and can include Personal Data about others where you share their Personal
Data with us as part of our attraction, application, recruitment and selection process, henceforth referred
to as “recruitment”.
“Personal Data” means any information about an individual from which that person can be identified. It
does not include data where the identity has been removed (anonymous data). There are ‘special
categories’ of more sensitive personal data which, for example, includes information about your racial or
ethnic origin and your health, which we shall call “Sensitive Personal Data” in this Privacy Notice.
The Company entities responsible for the collection and use of your Personal Data for the purposes
described in this Privacy Notice are listed above. It details how we collect your Personal Data, why wecollect it, and with whom we may share it. Where you provide Personal Data about others directly to us,
you must obtain that individual’s express consent and you have an obligation to provide them with a copyof this notice before doing so, such as your referees.
This Privacy Notice also discloses your Personal Data rights. It applies to all of your Personal Data,
including Personal Data stored electronically or in hard copy.
We process this information for a range of purposes relating to the recruitment process and this may
include your application, assessment, pre-employment screening, and your worker permissions. This
document sets out:

Why we collect your personal information;
What information is collected; andHow it is processed within the recruitment process.

Throughout this Privacy Notice we use the term “processing” to cover all activities involving your Personal
Data, including collecting, handling, storing, sharing, accessing, using, transferring and disposing of theinformation.
Please read the following carefully to understand our practices regarding your Personal Data and how itwill be treated.

2)

Why we collect your Personal Data
In order to manage your application and recruitment, we need to process certain Personal Data aboutyou. The purposes for this are set out below. We only process your Personal Data as necessary for the
purposes of progressing your application and recruitment or as required by law or regulatory
requirements, so not all of the purposes set out below will apply to you all of the time.
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To assess your skills, qualifications and suitability for the role;
To carry out specific assessments: CV, psychometric tests (such as a situational judgement test,
ability or personality test), interviews (face to face, telephone or video), behavioural assessments(such as a role play, group exercises or presentations), technical assessments;
For pre-employment screening (PES). This may include carrying out background and reference
checks, where applicable;
To communicate with you about the recruitment process;To keep records related to our hiring processes; andComply with legal or regulatory requirements.

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3)

What Personal Data we might process
Here are some examples of the type of Personal Data we may process. There is a more detailed list in
the Appendix at the end of this Privacy Notice.
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Personal details such as name, address, contact details, gender, date and place of birth;Work history/job data; previous employers, positions, dates, etc.;
Compensation; basic salary, benefits, bonuses, etc.;
Education and work history including professional qualifications and skills;
Employer feedback / references, including regulated references where necessary;
Nationality / visa / right to work information (e.g. passport, national identification documents, driving
licence, proof of address, Work or Residence permits, National/Social Insurance numbers);
Photographs and images from recorded assessments or from on-site CCTV;
Results of pre-employment screening checks (e.g. credit history);
Assessment results e.g. Psychometric assessment results, results from testing and video or
telephone assessment.

During the recruitment process we also capture some Sensitive Personal Data about you when it is legal
to do so. We do this in order to make reasonable adjustments to enable candidates to apply for jobs withus, to be able to take online/telephone assessments, to attend interviews/assessment centres, to prepare
for starting at the Company (if successful) and to ensure that we comply with regulatory obligations
placed on us with regard to our recruitment.
Please note that specific national legislation and requirements take precedence over this Privacy Noticein the event of a conflict with the requirements of this Notice.
If you fail to provide Personal Data

If you fail to provide Personal Data when requested, which is necessary for us to consider your application(such as evidence of qualifications or work history), we will not be able to process your application
successfully. For example, if we require references for the particular role and you fail to provide us with
relevant details, we will not be able to take your application further.
Also, any offer made to you may be conditional upon you providing evidence of your identity and your rightto work. This is a legal requirement. If you fail to provide this Personal Data we may not be able to offer you
work.
Automatic Processing
We do not envisage that any decisions will be taken about you using automated means, however we will
notify you in writing if this position changes.

4)

Who we share your Personal Data withYour Personal Data will only be shared if it is necessary or required (for example, in order to carry out PES).
The Company will need to share your Personal Data internally (both in the country where you may work
and in other countries in which we have central operations) and may need to share it with some external
parties or associates of the Company. Some of these third parties and associates will be located outside
the European Economic Area (“EEA”).
Your Personal Data may be shared internally, but the information shared will always be limited to what isrequired by each individual to perform their role in the recruitment process. Your Personal Data may beshared internally with the following people:
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Those employees who would have managerial responsibility for you or are acting on their behalf;

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Employees in HR who have responsibility for certain HR processes (for example recruitment,
assessment, PES);
Employees in Legal, Risk, HR and Finance with responsibility for investigating issues of noncompliance with laws and regulations, policies and contractual requirements;
Employees in IT and system owners who manage user access;Managers with responsibility for approving recruitment decisions;Audit and Investigations employees in relation to specific audits/investigations; andSecurity managers for facilities / premises.

The Company may also need to share your information with certain external third parties including:
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5)

Recruitment companies who have introduced you to the Company;
Companies who provide candidate interview and assessment services to the Company;
Previous employers or your other named referees in order to verify information you have given us;
Suppliers who undertake background screening on behalf of the Company
Academic institutions (Universities, colleges, etc.) in validating information you have provided; andOther third-party suppliers (or potential suppliers), who provide services on our behalf.

How we protect your Personal Data
Our HR systems are protected to ensure that unauthorised or unlawful processing of personal
information, accidental loss or destruction of, or damage to, personal information does not occur.
Where we share information with other parties located outside your country, as a minimum, the Company
will require that such personal information is protected as required by the laws of the country where you
work. All recipients of the Personal Data are contractually obliged to comply with applicable laws or
regulations, including having a valid EU Personal Data cross-border transfer mechanism in place to receive
EU personal data, which can include an “adequacy” determination by the European Commission and/or
executing EU Standard Contractual Clauses with us.
For more information about our cross-border transfers of your Personal Data, please contact us using theinformation as described in Section 9 below.
The Company also requires its third party suppliers or recipients of Personal Data to guarantee the samelevel of protection as it would provide. We will require that these recipients protect the confidentiality andsecurity of your Personal Data that are shared with them. These third parties must contractually agree
that they will not use or disclose your Personal Data for any other purposes than necessary to provide us
with services, perform services on our behalf or directly to you, or to comply with applicable laws or
regulations.

6)Your Rights
You have a right to request to see the information the Company holds about you. You can also request
changes to be made to incorrect information. You can also request that we erase your Personal Data
when it is no longer needed for the purposes for which you provided it, restrict how we process your
Personal Data to certain limited purposes, or object to our processing of your Personal Data where ourprocessing of your information is based solely on our legitimate interests. In certain circumstances you
may be able to request that we send a copy of your Personal Data to a third party of your choice.
You have the right to withdraw your consent for processing where you have given your specific consent toprocessing of Personal Data. Once we have received notification that you have withdrawn your consent,
we will, subject to our retention policy as set out at Section 9 below, dispose of your personal data
securely.
You also have the right to lodge a complaint with a supervisory authority if you consider that theprocessing of your personal data infringes applicable law.

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To exercise any of these rights, or if you have any queries about this notice or your Personal Data
generally, including questions about accessing your Personal Data or correcting it, you should contact theCompany’s HR Department in the first instance using the details contained in Section 9 below.
We need to make you aware that even where you exercise a right detailed above, we may not be able tocomply with that request if an exception in law applies. Where this is the case we will notify you and explain
why we’re unable to meet your request.
As this document is updated, the latest version will be posted on our site.

7)

Processing Conditions
The Company’s entitlement to process your Personal Data is governed by a number of processing
conditions. This processing will always be fair and lawful and will at all times comply with the principles ofapplicable privacy laws in the country where you have applied to be employed.
This means that we may rely on more than one of these conditions in order to process elements of your
Personal Data throughout the recruitment process.
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The Company will process your Personal Data for the administration of your application. It is in ourlegitimate interests to decide whether to appoint you to a role since it would be beneficial to ourbusiness to appoint someone to that role.
We also need to process your Personal Data to decide whether to enter into a contract of
employment or services with you.
The Company will also process your Personal Data where it is required by law or regulation, suchas carrying out a right to work check. Furthermore the Company processes your Personal Data forthe legitimate interest to ensure compliance requirements.
During the course of your application it may also be necessary for the Company or its suppliers toprocess your Sensitive Personal Data as per the detail in section 2 and Appendix 1 of this Privacy
Notice. This processing will be carried out with your express consent which is captured as part of
the recruitment process.
If required by the local law we will ask for your consent.

Whenever the Company processes your personal data we do so on the basis of a legal basis or
justification for that processing. Processing of special categories of data is always justified on the basis ofan additional lawful condition. In the majority of cases, the processing of your personal data will bejustified on one of the following bases:The processing is necessary for compliance with a legal obligation to which the Company issubject; orWhere there is no legal obligation we will process your data where the processing is necessary forthe performance of a contract to which you are a party or in order to take steps at your request
prior to entering into such a contract;
Where the above two grounds do not apply we may process your personal data where theprocessing is necessary for the legitimate interests pursued by the Company, except where suchinterests are overridden by your interests or fundamental rights and freedoms which require
protection of personal data.

We may process your personal data for the purpose of legitimate interests pursued by a third party,
except where such interests are overridden by your interests or fundamental rights and freedoms which
require protection of personal data (for example to meet the security requirements of our customers.)
There may be circumstances where we may carry out the processing on the basis of your consent.
Where we rely on consent we will make this clear at the time.
We have set out below the purposes we may use your personal data for and the legal basis we rely on ineach case:6

TOKYO ELECTRON EUROPE Ltd.
Purpose for processing
Recruitment andselection
Considering yoursuitability to work for us in
the role you have appliedfor, comparing you toother candidates andmaking recruitment
decisionsPre-employment
verification andscreening
Appropriate preemployment screening
including, where relevant
and appropriate, identity
check, right to work
verification, reference
check, credit check,financial sanction check,
relevant employment
history, relevant
regulatory status andrelevant professional andeducational qualifications.
Offers of employment
and on-boarding
Making job offers,
providing contracts of
employment or
engagement andpreparing to commence
your employment or
engagement where you
accept an offer from us

Future job opportunities
To contact you if you are
not successful in yourinitial application should
another potentiallysuitable vacancy arise
during the six months
following completion of
the recruitment process

The lawful basis we rely on
Some of this processing is necessary for the compliance with legal obligations
to which the Company is subject including the requirement to makereasonable adjustments or accommodations where appropriate in the eventthat you choose to disclose that you have a disability.
Some of this processing is necessary for takings steps at your request toenter into a contract with you.
Additional processing is necessary for the purpose of the legitimate interests
pursued by the Company.
The Company has a legitimate interest in fully assessing applicants to ensurethat only suitable and appropriate candidates are selected, to compare
candidates and make a fair decision on the most appropriate candidate forthe position.
The Company aims to recruit the best person for each vacancy through fair,systematic, effective recruitment and selection procedures. This willcontribute towards the Company continuing to meet its business objectives,maintain its reputation and attract high calibre employees.
Some of this processing is necessary for the compliance with legal obligations
to which the Company is subject including establishment of the right to workin the country in which you are employed.
Screening which is not legally required is necessary for the purpose of thelegitimate interests pursued by the Company.
The Company has a legitimate interest in ensuring that candidates for
employment or engagement do not pose an unacceptable risk to the businessand considers the verification carried out necessary to prevent crime andother unlawful acts and to protect the business from fraud, dishonesty or
incompetence.

Some of this processing is necessary for the compliance with legal obligations
to which the Company is subject including the requirement to issue written
particulars or terms of employment and the requirement not to unlawfully
discriminate in the terms of any offer to you.
Additional processing is necessary to take steps to enter into the contract
between you and the Company and to perform that contract because we willneed information to make an appropriate offer to you and administer youremployment contract if you join us.
The remainder of the processing is necessary for the purpose of thelegitimate interests pursued by the Company.
The Company has a legitimate interest in ensuring the effective engagementof staff on appropriate terms and conditions of employment and that there is asmooth transition into employment for successful candidates and that
information supplied in the recruitment process which is relevant to ongoing
employment is maintained. This will contribute towards the Company
continuing to meet its business objectives, maintain its reputation and attract
high calibre employees.
This processing is necessary for the purpose of the legitimate interests
pursued by the Company.
The Company has a legitimate interest in maintaining an appropriate pool oftalent who have shown an interest in working for the Company and who arepotentially suitable candidates for employment. This will potentially benefit
both initially unsuccessful candidates and the Company. It will contributetowards the Company continuing to meet its business objectives, maintain its
reputation and attract high calibre employees.

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for the role you originallyapplied for
Recruitment feedback
and complaints
To deal with any query,challenge or request for
feedback received inrelation to our recruitment
decisions

Complaints, claims andlitigation
To enforce our legal rights
and obligations, and forany purposes inconnection with any
complaint or legal claim
made by, against orotherwise involving you
Legal or regulatory
disclosures
To comply with lawful
requests by publicauthorities (including
without limitation to meetnational security or law
enforcement
requirements), discovery
requests, or whereotherwise required or
permitted by applicablelaws, court orders,
government regulations,or regulatory authorities(including without
limitation data protection,
tax and employment),
whether within or outside
your country;

This processing is necessary for the compliance with legal obligations towhich the Company is subject including ensuring that the Company is able todemonstrate its compliance with data protection laws and anti-discrimination
laws
Beyond legal compliance processing is necessary for the purpose of thelegitimate interests pursued by the Company.
The Company has a legitimate interest in being able to provide feedback to
candidates and to be able to defend any challenge or claim made inconnection with our recruitment decision. This will assist the Company to
avoid the risk of financial exposure or costs incurred through challenges torecruitment decisions and to maintain its reputation.
This processing is necessary for the purpose of the legitimate interests
pursued by the Company.
The Company has a legitimate interest in protecting its organisation frombreaches of legal obligations owed to it and defending itself against litigation.
This is needed to ensure that the Company's legal rights and interests areprotected appropriately, to protect the Company's reputation and to protect
the Company from other damage or loss.
This is important to protect the business of the Company and ensure its
continued success and growth. This supports the Company's immediate andlong-term business goals and outcomes.
This processing is necessary for the compliance with legal obligations towhich the Company is subject where there is a legal obligation to disclose
information or a court or other legal order to provide information is place.
Where not legally required, processing is necessary for the purpose of thelegitimate interests pursued by the Company.
The Company has a legitimate interest in co-operating with relevant
authorities, government bodies or regulators for the provision of information
where appropriate. The Company wishes to maintain its reputation as a good
corporate citizen and to act ethically and appropriately in all the countries inwhich it does business.

Additional legal basis we rely on where we process special category data
The special categories of personal data that are processed by the Company are set out above. Where
we process special categories of data it will be justified by a condition set out above and also by one of
the following additional conditions:The processing is necessary for the purposes of carrying out the obligations and exercising therights of you or the Company in the field of employment law, social security and social protection
law, to the extent permissible under applicable laws;
The processing is necessary for the purposes of preventive or occupational medicine, for theassessment of your working capacity, medical diagnosis, the provision of health or social care ortreatment or the management of health or social care systems and services, to the extent permitted
by applicable laws;

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

The processing is necessary to protect your vital interests or of another person where you are
physically or legally incapable of giving consent (for example in exceptional emergency situations,such as a medical emergency);
The processing is necessary for purposes authorised by applicable law. This includes those
purposes set out below:
 ensuring equality of opportunity or treatment between people of different racial or ethnic
origins,of different ages and/or marital status, holding different religious or philosophicalbeliefs, people with different states of physical or mental health or people of different
sexual orientation with a view to enabling such equality to be promoted or maintained;or the processing is necessary for the prevention or detection of unlawful acts where it
must be carried out without consent so as not to prejudice those purposes.

In exceptional circumstances the processing is carried out subject to your explicit consent (as explained
below).
The purposes we use special category personal data for and the additional legal basis that applies
We have identified a number of purposes for collecting and processing your special category personal

data. These are set out below together with the additional legal basis we rely on in each case:Purpose forprocessing

Additional lawful basis for special category data processing

Documentation suchas work permits,details of residency,
proof of citizenshipwill be processed toassess and review
eligibility to work for
the Company in thejurisdiction in which
you work

This processing is necessary for the purposes of carrying out the
obligations and exercising the rights of you or the Company in thefield of employment law, immigration, social security and social
protection law, to the extent permissible under applicable laws. In
particular the requirement to check that you are legally permitted towork in your jurisdiction.

Your racial or ethnic
origin, religion,
philosophical orpolitical belief, sexual
orientation or disability
status may be used
for the collection of
statistical data subject
to local laws, or whererequired to record
such characteristics tocomply with equalityand diversity
requirements ofapplicable local
legislation or to keep
the Company’scommitment to equal
opportunity underreview

This processing is necessary for the purposes of carrying out the
obligations and exercising the rights of you or the Company in thefield of employment law, social security and social protection law, tothe extent permissible under applicable laws. In particularcompliance with anti-discrimination legislation.
Where not legally required this processing is necessary for the public
interest of ensuring equality of opportunity or treatment between
people of different racial or ethnic origins, of different ages or marital
status, holding different religious or philosophical beliefs, people withdifferent states of physical or mental health or people of different
sexual orientation with a view to enabling such equality to bepromoted or maintained.

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Health and medical
information may be
used to comply with
employment, healthand safety or social
security laws. For
example, to makereasonableaccommodations or
adjustments andavoid unlawful
discrimination or
dealing withcomplaints arising inthis regard.

This processing is necessary for the purposes of carrying out the
obligations and exercising the rights of you or the Company in thefield of employment law, social security and social protection law, tothe extent permissible under applicable laws. In particular those laws
set out in this section.

Special category
personal data of any
type may be used in
the event of acomplaint, claim or
litigation or potential
claim or litigation by,
against or involving
you.

This processing is necessary to establish, exercise or defend legal
claims.

To the extent that this data is managed by our occupational healthadvisers, this processing is necessary for the purposes of preventive
or occupational medicine, for the assessment of your working
capacity, medical diagnosis, the provision of health or social care ortreatment or the management of health or social care systems andservices, to the extent permitted by applicable laws.

We may seek your consent to certain processing which is not otherwise justified under one of the above
basis. If consent is required for the processing in question, it will be sought from you separately to ensurethat it is freely given, informed and explicit. Information regarding such processing will be provided to youat the time that consent is requested, along with the impact of not providing any such consent. You
should be aware that it is not a condition or requirement of your recruitment to agree to any request forconsent from the Company.

8)

How long we retain your Personal DataYour Personal Data will be maintained for the duration of your relationship with us. We will then retain yourpersonal information for a period of six months after we have communicated to you our decision about
whether to appoint you to a role. We retain your personal information for that period so that we can show,
in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds andthat we have conducted the recruitment exercise in a fair and transparent way. After this period, we willsecurely destroy your personal information in accordance with applicable laws and regulations.
If we wish to retain your personal information on file, on the basis that a further opportunity may arise in the
future and we may wish to consider you for that, we will write to you separately, seeking your explicit writtenconsent to retain your personal information for a fixed period on that basis.
If your application is successful, we will keep ongoing Personal Data concerning your employment or
engagement by the Company in accordance with our Employee Privacy Notice, which will be madeavailable to you separately.

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9) How to contact us if you have any questions or concerns
You may contact the HR department in the country to which you applied for a role or to the HR Director,
Europe using the below information to:

Ask questions;File a concern or complaint;
Opt-out of a program or service; and/or
To exercise any of your rights listed above, including access, correction, portability, objection,
restriction, and erasure.

Mailing Address:
Susan Stockton
HR Director Europe
Tokyo Electron Europe Ltd
Pioneer, Crawley Business Quarter
Fleming Way
CrawleyWest Sussex
RH10 9QL
UK
Email Address: susan.stockton@europe .tel.com
For more information about your privacy and data protection rights, or if you are not able to resolve a
problem directly with us and wish to make a complaint, please contact your country-specific data protection
authority or the Company’s lead data protection supervisory authority:
Austria
Oesterreichische Datenschutzbehoerde
Hohenstaufengasse 31010 Wien
Austria
Tel: (+43) 1 531 15 202525
Email: dsb.dsb.gv.at
Belgium
Commission de la protection de la vie privee
Rue de la Presse 35
1000 Bruxelles
Belgium
Tel: (+32) 2 274 48 00
Email: commission@privacycommission.be
FranceCommission Nationale de l’Informatique et des Libertés (CNIL)
3 Place de Fontenoy
TSA 80715
75334 Paris
Cedex 07
FranceTel: 00 33 1 53 73 22 22
Fax: 00 33 1 53 73 22 00
www.cnil.fr
Germany

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Sächsischer Datenschutzbeauftragter
Bernhard-von-Lindenau-Platz 1
01067 Dresden
TEL: 0049 351 4935401
www.datenschutz.sachsen,deEmail: saechsdsb@slt.sachsen.de
Ireland
Data Protection Commissioner
Canal House
Station Road
Portarlington
Co. Laois
IrelandTel: (+3530 57 868 4800
Email: info@dataprotection.ie
IsraelPrivacy Protection Authority
Tel Aviv Government Complex
P.O. Box 7360
Tel Aviv 6107202
ppa.justice.gov.il
Italy
Garante per la protezione dei dati personali
Piazza di Monte Citorio n. 121
00186 Romawww.gpdp.it – www.garanteprivacy.it
E-mail: garante@gpdp.it
Fax: (+39) 06.69677.3785
Telephone: (+39) 06.69677.1
Netherlands
Autoriteit Persoongegevens
Postbus 93374
2509 AJ DEN HAAG
Tel: (+31) 070 888 85 00
UK
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
CheshireSK9 5AF
UK
www.ico.org.uk
Tel: 0303 123 1113 (local rate) or 01625 545 745

This Privacy Notice was last updated on 23 June 2021.

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10) Israeli specific provisions
With respect to the processing of Personal Data by Tokyo Electron Israel Limited ("TEY"), thefollowing provisions shall apply in addition to the provisions of the above Statement.
The applicable Data Protection Legislation are the Protection of Privacy Law, 1981 and theregulations enacted thereunder.
Legal Obligation to provide us with your Personal Data
You have no legal obligation to provide us with your Personal Data. When you do provide us withyour Personal Data, you are doing so under your own free will and consent.

Appendix 1
List of Personal Data we may process
N.B Specific national legislation and requirements take precedence over this Privacy Notice.
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Name, work and home contact details
Date and place of birth
Education and work history
Individual demographic information in compliance with legal requirements (such as marital status,
national identifier, passport/identity card/visa information, nationality, gender, citizenship, military
service, disability, work permit, date and place of birth or gender)
Health issues requiring adaptations to working environment
Job title, grade and job history
Employment contract related information (including compensation, location, hours of work and soon)
Reporting and managerial relationships
Leaves of absence (such as maternity leave, sickness absence)
Photograph(s)Disciplinary / grievance records
Time and attendance details
Bank account details for salary payment purposes
Expenses such as travel and expenses claimed from TEE
Skills and qualifications
Training history and plans
Results of original and ongoing employee screening, where relevant
Details provided in relation to Conduct policies (such as conflicts of interest, personal accountdealing, trade body membership and so on)
Health & safety incidents, accidents at work and associated records
Building CCTV images
Audio recordings of telephone interviews
Video recordings of interviews
Notes from face to face interviews
Psychometric test results and associated reports
Results from behavioural assessments (e.g. Assessment Centre exercises)
Results from technical assessments
Details of your referees
Driving licence

These categories of information might potentially include some Sensitive Personal Data. Sensitive Personal
Data is not routinely collected about all applicants. It may be collected where the Company has a legal
obligation to do so, or if you choose to disclose it to us during the course of your relationship with the Company.

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