Privacy Notice for Job Applicants

Last updated: July 2022

1. Introduction

This Privacy Notice for job applicants (’Privacy Notice’) describes how ASML and its group companies (‘ASML’, ‘us’ or ‘we’) process the personal data of candidates we contact and applicants that apply to a position (‘you’) in connection with ASML’s recruitment process.

We have drafted this Privacy Notice thoroughly and in an easy and comprehensible way in order to inform you about what personal data we process about you, why we process it and what we do with it during our recruitment process. We encourage you to take some time to read this Privacy Notice in full.

Translated versions of this Privacy Notice are available on request. The translated versions are provided for convenience only. In the event of any difference in meaning between the English language version and any translated version, the English language version will prevail.

2. When does this privacy notice apply?

This Privacy Notice applies to the processing of personal data of job applicants or job prospects by ASML.

Some countries may have stricter or deviating local legal requirements. In case of a conflict between this Privacy Notice and such requirements, the latter will prevail.

3. Who is ASML?

ASML is a leading supplier of semiconductor manufacturing equipment and the innovator behind ever-advancing lithography systems. We provide chipmakers with everything they need – hardware, software and services – to mass produce patterns on silicon through lithography.

When this Privacy Notice mentions ‘we’, ‘us’, ‘our’, it refers to ASML Holding N.V. – based at De Run 6501, 5504 DR, Veldhoven, the Netherlands – as well as its group companies.

4. What is personal data?

It is important for you to know that ‘personal data’ (or: ‘data’, ‘personal information’, or ‘your data’), means: any information relating to an identified or identifiable natural person (‘data subject’).

An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier – or by reference to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

5. What personal data do we process about you?

During the recruitment process, we ask you to provide us with information that enables us to assess your suitability for certain positions.

We may process personal data about you, such as:

a. Your name and contact details;

b. Gender and date of birth;

c. All information contained in your CV/resume, motivation or cover letter and other documents you shared with ASML in your job application;

d. Information given by you during face-to-face and video interviews, via emails, phone calls and other means of communication;

e. Your job preferences;

f. Results of tests and analyses that you have performed at our request;

g. Information from pre-employment screening and background checks, such as educational checks and statements of conduct;

h. Names and contact details of your references;

i. On premise information collected through access control and CCTV recordings;

j. Feedback you provide in surveys around the recruitment process;

k. Account login information used to access company systems and applications, such as the recruitment portal; and

l. Network traffic data and other related data, such as IP address and information obtained from cookies and similar tracking technology used on our websites, from your use of our websites. For more information please read our Cookie Notice

Special categories of personal data and sensitive personal data
We may also process personal data that is considered as special categories of personal data or sensitive personal data. In the course of our application process, you may, for example, provide us with a photo that may reveal the following information about yourself: your race or ethnic origin, physical health (including disability) or religious beliefs. Furthermore, we may process personal data that is considered sensitive, such as veteran status or information relating to criminal convictions or offences (statement of conduct).

Please note that for the recruitment process, some required personal data may vary, depending on the position you apply for, the location (country) of this position and applicable rules and regulations. We may process special category or sensitive personal data taking into account local legal requirements.

How do we obtain your personal data?
We collect personal data directly from you when you apply for a position with us or when we contact you with a possible job offer. In addition, we may collect your personal data independently through different career orienting platforms and websites. We also collect your personal data from third parties, such as professional recruitment agencies, your references, prior employers, and pre-employment and background check providers, to the extent permitted by applicable law.

6. For which purposes do we process your personal data?

We process your personal data for recruitment and compliance purposes, in particular for:

a. Identifying and evaluating your qualifications for available positions;

b. Verifying the data you submitted and carrying out reference checks, pre-employment screening and conducting background checks (where applicable);

c. Informing you about the progress of your application or other vacancies at ASML that we consider suitable for you;

d. Recruitment marketing, such as custom audience, talent pool creation for future job openings and email communication concerning job openings;

e. Preparing a job offer and employment contract, where applicable, and for fulfilling onboarding activities in case of a successful application;

f. Assessing your fitness to work and for the provision of facilities in the workplace for any accommodation;

g. Managing your job application account in order for you to be able to track your application progress;

h. Business management and administrative purposes, including maintaining our IT systems, internal audits, record-keeping and improving our business processes;

i. Protecting the health, safety, security and integrity of ASML and its job applicants, (IT) facilities and assets, including occupational safety and health; and

j. Complying with the law, including the disclosure of personal data to government institutions or supervisory authorities, and to exercise or defend legal claims.

Secondary use of personal data
When we have collected personal data this data may be used for a secondary purpose, but only if the secondary purpose is compatible with the original purpose. For example, statistical analysis may constitute as a compatible secondary purpose.

7. What is the legal basis for processing your personal data?

The legal bases (or justified reasons) for processing your personal data are:

  • The legitimate interest for recruitment and management purposes;
  • For entering into and managing a contract or employment relationship;
  • For compliance with our legal obligations;
  • Protecting your vital interest or that of another natural person, for example in case of a medical emergency; and
  • Your specific and informed consent.

In the event that the processing of your personal data is based on your consent, you have the right to withdraw you consent. We would like to draw your attention to the fact that the withdrawal of your consent does not affect the lawfulness of the processing of your personal data prior to the withdrawal of your consent.

8. Who has access to your personal data?

Access to your personal data within ASML
Our employees are authorized to access personal data only to the extent necessary to serve one or more of the purposes set forth in Section 6 above and in so far as necessary within the scope of their roles and responsibilities as ASML workers.

Access to your personal data by third parties
Your personal data may be shared with third parties for the purpose of providing their products and/or services to ASML or vice versa, including but not limited to:

  • Agencies and consultants that may assist us in performing our business processes; and

  • IT service providers.

  • Your personal data may also be shared with competent public authorities, governments, regulatory or fiscal agencies where it is necessary to comply with legal or regulatory obligations to which ASML is subject.

When we transfer personal data to third parties we will only do so under confidentiality obligations and where necessary, we will have an agreement concerning the processing of your personal data in place.

ASML does not sell your personal data to anyone.

International transfers of your personal data

Due to our company’s multinational nature, the data you provide to with us may be transferred to or accessed by ASML’s affiliates and trusted third parties from different countries around the world. Your personal data will only be transferred to a country other than your country of residence if this is necessary for the fulfilment of the purposes described in this Privacy Notice.

To protect your rights, we only transfer your personal data to a country where:


  1. An adequate level of protection for personal data is provided; or

  2. An instrument covers the requirements for the transfer of personal data
    such as:  
    a.  EU Standard Contractual Clauses; 
    b.  Codes of conduct; and
    c.  Certification mechanisms.

9. How long will we keep your personal data?

Your data will be kept only for the period required to serve the purposes mentioned under Section 6 above (and to comply with legal requirements – if any). After the applicable retention period your personal data will be securely deleted, destroyed or de-identified.

If you accept an offer of employment by us, any relevant personal data collected during your pre-employment period will become part of your personnel records and will be subject to our Privacy Notice for Workers. Personal data that is no longer required will be deleted.

10. How is your personal data secured?

We have taken adequate measures to protect the confidentiality, integrity and availability of your personal data. The implementation of appropriate technical, physical and organizational measures protects your personal data against the following incidents:


  • Accidental or unlawful destruction;
  • Accidental loss, damage, alteration;
  • Unauthorized disclosure or access; and
  • Any other forms of unlawful processing (including, but not limited to improper use).

We have procedures in place to deal with a (suspected) personal data breach. You and/or the applicable data protection authorities will be notified of a data breach, where we are legally required to do so. 

11. What about your rights?

You have the following rights in relation to your personal data:

  • The right to access the personal data we have about you;
  • The right to have your personal data corrected;
  • The right to have your personal data deleted (‘right to be forgotten’);
  • The right to restrict processing of your personal data by us;
  • The right to object to automated decisions;
  • The right to withdraw consent at any time and without detriment;
  • The right to object to certain data processing operations; and
  • The right to request a transfer of your personal data (‘right to data portability’).
  • • The right to copy, correct, delete your personal data by your relative in case of your death (if applicable).

If you wish to exercise any of these rights, please use our Privacy Rights Request Form, which can be found on the ASML website, ’Privacy’ Section. Alternatively, you may email [email protected]. Some countries in which ASML operates may have a single point of contact to direct privacy related questions or requests too. When sending your request to [email protected], we will forward that question or request to the relevant person.

We will always check your identity to ensure that it is you exercising your rights. If we cannot verify your identity, your request will be rejected. When exercising your right, the more specific you are, the better we can assist you with your request. In some cases, where permitted by law, we may deny your request, in which case we will notify you of the reason for denial.

If you feel we are not handling your request appropriately, you also have the right to lodge a complaint with the relevant data protection authority.

12. What about your responsibilities?

We would like to kindly remind you that you are responsible for providing us with accurate, complete and up-to-date data. In case you provide us with personal data of other individuals, comply with (local) legal and ASML requirements, including, informing the individuals concerned sufficiently about the processing of their data, providing them with this Privacy Notice and obtaining their agreement before sharing their data with us.

13. How to contact us

When you have a question about the use of your personal data or about this Privacy Notice, we invite you to send an email to our Privacy Office via [email protected].

This Privacy Notice may be amended from time to time. You can find the previous versions of the Privacy Notice in the Privacy Notice Archive.