Notice on the Collection and Processing of Personal Data
Regarding Employment and Applications for Employment
in Comel d.o.o. and Comel Transformatori d.o.o.

In accordance with the provisions of the Law on Personal Data Protection (“Official Gazette of RS”, No. 87/2018, hereinafter: the “Law”), Comel d.o.o. and Comel Transformatori d.o.o. Beograd (hereinafter collectively referred to in the singular as the “Company”) hereby inform you about the purpose and legal basis for the collection and processing of your personal data, the types of data we process, the recipients of such data, the manner in which the data is stored, as well as your rights regarding the processing and how you can exercise them.

  1. Company Information
    Comel d.o.o., registered at Pere Velimirovića 8a, Company Registration No. 07480636, tel. +381 (11) 2284-601, e-mail: office@comel.co.rs, and
    Comel Transformatori d.o.o. Beograd, registered at Put za koloniju 24, Beograd – Ripanj, Company Registration No. 21156302, tel. +381 (11) 3094-107, e-mail: office.transformatori@comel.co.rs,
    collect and process data on their employees and other engaged individuals (hereinafter: “Employees”), as well as potential employees, in a transparent manner. The Company also retains data on former Employees in accordance with the applicable regulations of the Republic of Serbia.

For the purposes of this Notice, “personal data” refers to any information relating to an identified or identifiable natural person, whether directly or indirectly. “Processing” means any operation or set of operations performed on personal data, whether automated or not.

  1. Why We Collect and Process Your Data – and Legal Basis

Your personal data is collected and processed for purposes including but not limited to:

  • evaluating job applications;
  • establishing employment or other contractual engagements;
  • maintaining employment records (e.g., payroll, expense reimbursements, and other employment-related payments);
  • complying with legal requirements for employing foreign nationals;
  • registering employees and family members for mandatory and voluntary insurance;
  • fulfilling tax, contribution, and other statutory obligations;
  • maintaining work attendance records, vacation and leave records, sick leave, workplace injuries, occupational diseases;
  • conducting occupational health checks;
  • ensuring compliance with workplace discipline and performance evaluation;
  • fulfilling contractual obligations between the Company and Employees;
  • identifying training needs and conducting performance reviews;
  • handling disciplinary, judicial, administrative, or arbitration proceedings;
  • granting employee benefits;
  • organizing events and holiday gift distribution for employees’ minor children;
  • employer branding and workplace satisfaction surveys.

The legal basis for processing may be:

  • the employment or service contract you have with the Company, or your request to enter into such a contract;
  • legal obligations under Serbian law;
  • your consent for specific purposes (e.g., photography at events);
  • the Company’s legitimate interests (e.g., ensuring security of people and property through CCTV, IT security, access control, internal reporting).

Where processing is based solely on your consent, you may withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.

  1. Types of Data Collected

Depending on your relationship with the Company, we may process:

  • Job applicants: CV information, educational history, work experience, interests, photographs, notes from interviews/tests, contact details, and publicly available professional profiles (e.g., LinkedIn).
  • Employees: full name, parental name, date/place of birth, address, personal ID number, citizenship, ID/passport details, contact information, gender, employment contract details, job role, working hours/location, leave records, sick leave, relevant health data, disciplinary and legal proceedings, family members’ data for insurance, minor children’s names/ages for holiday gifts, qualifications, training certificates, work history, salary and benefits details, bank account, court/administrative orders, company-assigned equipment use (car, phone, computer), and data on employment termination.
  • Former employees: identification data and any information required for mandatory social insurance and other legally required permanent records.

Photographs and videos from events are processed only with consent.

  1. Data Recipients

Your data may be shared with:

  • Company employees who need it for their job duties;
  • Service providers under contractual agreements ensuring data protection compliance;
  • State authorities (e.g., tax office, social insurance funds, employment service) when legally required;
  • Courts, prosecutors, police, enforcement agents, notaries upon lawful request;
  • Third parties providing employee benefits (e.g., insurance companies, telecoms, training providers).
  1. Data Transfers Abroad

The Company may transfer personal data to partner entities within Serbia and the EU that meet high data protection standards, as well as to countries deemed to provide adequate protection by the Government of Serbia. Data from travel documents may be shared with organizers of transport/accommodation abroad for official business trips, trainings, or seminars.

  1. Data Retention

Data is stored in both paper and electronic formats, either on Company premises or with contracted archival providers, with appropriate security measures.

  • Most employee data must be kept permanently under Serbian law.
  • Candidate data is retained for up to 3 years from application date.
  • CCTV footage is retained for 30 days to 6 months, unless needed for legal proceedings.

Data is periodically deleted or anonymized at least once per year after legal retention periods expire.

  1. Your Rights

You have the right to:

  • request confirmation whether your data is processed and access it;
  • request correction or completion of inaccurate/incomplete data;
  • request deletion of data when legally applicable;
  • request restriction of processing in cases specified by law;
  • receive information about recipients of your data;
  • request data portability;
  • object to processing based on legitimate interest or public interest;
  • file a complaint with the Commissioner for Information of Public Importance and Personal Data Protection.

The Company does not perform automated decision-making or profiling related to employment.

  1. Exercising Your Rights

Requests can be submitted by email to office@comel.co.rs or office.transformatori@comel.co.rs, or by post to the Company’s registered addresses. The Company will respond within 30 days (extendable by 60 days in complex cases) and generally free of charge, unless requests are manifestly unfounded or excessive.

  1. Obligation to Provide Data

For job applicants: providing personal data is necessary to consider your application.
For employees: providing certain personal data is mandatory under law and necessary for concluding an employment or service contract. Without such data, the Company cannot establish an employment relationship.

  1. How We Obtain Your Data

Data is collected directly from you, from publicly available sources (e.g., LinkedIn), or from third parties such as recruitment agencies, public health institutions, enforcement agents, courts, tax authorities, or your creditors.

  1. Contact

For any questions regarding this Notice or the processing of your personal data, you can contact the Company’s Data Protection Officer:

  • Comel d.o.o.: Pere Velimirovića 8a, tel. +381 (11) 2284-601, email: office@comel.co.rs
  • Comel Transformatori d.o.o.: Put za koloniju 24, Beograd – Ripanj, tel. +381 (11) 3094-107, email: office.transformatori@comel.co.rs

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