Proton Recruitment & Hiring Privacy Notice

Last modified : 13 May 2026.

1. Introduction

Thank you for your interest in joining Proton. This Recruitment & Hiring Privacy Notice (the "Notice") explains how we collect, use, and protect your personal data throughout the recruitment process, from the moment you apply for a job until a final hiring decision is made or you are onboarded.

Proton is the Data Controller of your personal data. We are committed to the highest standards of data protection, complying with the Swiss Federal Act on Data Protection (FADP) the EU General Data Protection Regulation (GDPR), and other applicable laws.

2. What Data We Collect

We collect data voluntarily provided by you or obtained through legitimate recruitment activities. This includes:

• Application Data: Resume/CV, cover letter, portfolio, and answers to initial application questions.

• Identity & Contact: Name, date of birth, email, phone number, address, and LinkedIn profile (if provided).

• Employment History & Qualifications: Details of your past roles, education, professional certifications, licenses, and registrations.

• Assessment Data: Results from skills tests, coding challenges, or interviews (including notes taken by interviewers).

• Reference Data: Contact details and feedback from referees you authorize us to contact.

• Pre-Employment Verification Data: If you receive a conditional offer, we collect specific data via the Pre-Employment Questionnaire to finalize your offer and prepare for potential onboarding. This includes:

  • Right to Work: Documentation proving your legal authorization to work in the required jurisdiction.

  • Legal Restrictions: Information on any current court orders, regulatory sanctions, or legal restrictions that would prevent you from fulfilling the essential duties of the role.

  • Regulatory Proceedings: Details of any ongoing regulatory investigations or professional disciplinary proceedings relevant to your qualifications or the role.

  • Financial Compliance: Confirmation of your current status on international sanctions lists (EU, UN, OFAC, HMT) and any relevant bankruptcy restrictions.

  • Conflicts of Interest: Disclosure of existing relationships, financial interests, or outside employment that could create a conflict with your role or Proton.

  • Role-Specific Financial History: For roles with financial authority, limited history of financial regulatory enforcement actions (last 10 years).

  • Previous Employment Conduct: History of dismissal or resignation due to substantiated findings of gross misconduct, fraud, or breach of fiduciary duty (last 7 years)

3. Why We Process Your Data 

We process your data based on the following legal grounds under the GDPR:

4. Who We Share Your Data With

We do not sell your data. We share it only with:

• Proton Internal Teams: HR, Hiring Managers, Legal, IT Security, and Interviewers involved in the selection process (on a strict "need-to-know" basis).

• Service Providers (Processors):

  • Greenhouse: Our Applicant Tracking System (ATS) provider, which hosts applications, questionnaires and resumes
  • HiBob: Our Human Resources Information System provider, which receives your data upon successful hire to manage your employee record, benefits, and ongoing employment administration.
  • Assessment Tools: Third-party vendors used for skills testing or coding challenges (if applicable).
  • Reference Check Providers: Provider for specific, role-required verifications (e.g., reference checks, credential verification etc.), where permitted by law.
  • Government Authorities: Tax authorities, immigration services, or regulatory bodies as required by law.

• Affiliates: Other Proton Group entities for internal coordination.

5. International Data Transfers

Proton operates globally. Your data may be transferred to countries outside the European Economic Area (EEA) or Switzerland, for example to our Affiliates in Taiwan or North Macedonia.

Where transfers occur to countries without an adequacy decision (such as Taiwan), we rely on Standard Contractual Clauses (SCCs) approved by the European Commission and implement supplementary technical measures (such as end-to-end encryption) to ensure your data remains protected.

6. Data Retention

We retain your data only for as long as necessary:

• Successful Hire: Data is transferred to your employee file and retained for the duration of your employment and for a period thereafter (typically 6 to 10 years) to comply with legal obligations (tax, labor, social security).

• Unsuccessful Application: If you are not selected, your data is retained for 2 years (or up to 2.5 years) if you have consented to be kept in our talent pool) to consider you for future roles. After this period, your data is securely deleted or anonymized.

• Withdrawn Application: If you withdraw your application, your data is deleted upon 2 years unless we have a legal obligation to retain it.

• Pre-Employment Data: If an offer is withdrawn or declined after the questionnaire is submitted, the specific verification data is retained for 2 years to handle potential legal disputes, then securely deleted.

Proton is dedicated to safeguarding your data privacy. Should you require the early deletion of your personal data prior to the applicable retention schedule, please direct your inquiry to careers@proton.ch.

7. Your Rights

You have the following rights regarding your personal data:

• Right to Access: Request a copy of the data we hold about you.

• Right to Rectification: Correct inaccurate or incomplete data.

• Right to Erasure: Request deletion of your data (subject to legal retention obligations).

• Right to Restriction: Limit how we use your data.

• Right to Portability: Receive your data in a structured, machine-readable format.

• Right to Object: Object to processing based on legitimate interests.

• Right to Withdraw Consent: If we rely on consent (e.g., for talent pool retention), you may withdraw it at any time.

• Right to Lodge a Complaint: You have the right to complain to your local Data Protection Authority.

8. Automated Decision-Making

We do not use automated decision-making or profiling that produces legal effects concerning you during the recruitment process. All decisions regarding your employment are made by our Talent Acquisition (TA) department and hiring managers.

Proton may employ technologies, including artificial intelligence and automated processing tools, to support and optimize our recruitment workflows. Such tools are used solely to assist human decision-makers and are subject to strict security protocols and human oversight. We ensure that any data processed through these systems is handled in compliance with our privacy standards and is not used to train external models.

9. Complaints

If you believe your data protection rights have been violated, you have the right to lodge a complaint with the relevant supervisory authority:

• Switzerland: Federal Data Protection and Information Commissioner (FDPIC).

For other questions about your data, you can contact our careers team at careers@proton.ch 

10. Modifications 

We reserve the right to periodically review and change this policy. Continued consent and application will be deemed acceptance of such changes.