Privacy policy for recruitment using Teamtailor
The service for handling recruitments and simplifying the hiring
process (the "Service") is powered by Teamtailor on behalf of Global
Counsel ("Controller" “we” “us” etc.). It is important that the
persons using the Service ("Users”) feel safe with, and are informed
about, how we handle User's personal data in the recruitment process. We strive
to maintain the highest possible standard regarding the protection of personal
data. We process, manage, use, and protect User's personal data in accordance
with this Privacy Policy ("Privacy Policy").
1. General
We are the controller in accordance with current privacy
legislation. The Users’ personal data is processed with the purpose of managing
and facilitating recruitment of employees to our business.
2. Collection of personal data
We are responsible for the processing of the personal data that
Users contribute to the Service, or for the personal data that we in other ways
collect with regards to the Service.
When and how we collect personal data
We collect personal data about Users from Users when Users;
- make an application through the Service or otherwise, adding personal data about themselves either personally or by using a third-party source such as Facebook or LinkedIn;
- use the Service to connect with our staff, adding personal data about themselves either personally or by using a third-party source such as Facebook or LinkedIn; and
- provide identifiable data in the chat (provided through the website that uses the Service) and such data is of relevance to the application procedure.
We collect data from third parties, such as Facebook, Linkedin
and through other public sources. This is referred to as “Sourcing” and this
will be manually performed by our employees or performed automatically in the
Service.
In some cases, existing employees can make recommendations about
potential applicants. Such employees will add personal data about such
potential applicants. In the cases where this is made, the potential applicant
is considered a User in the context of this Privacy Policy and will be informed
about the processing.
The types of personal data collected and processed
The categories of personal data that can be collected through the Service can be used to identify natural persons from names, e-mails, pictures and videos, information from Facebook and LinkedIn-accounts, answers to questions asked through the recruiting, titles, education and other information that the User or others have provided through the Service. Only data that is relevant for the recruitment process is collected and processed.
Purpose and lawfulness of processing
The purpose of the collecting and processing of personal data is
to manage recruiting. The lawfulness of the processing of personal data is our
legitimate interest to simplify and facilitate recruitment.
Personal data that is processed for the purpose of aggregated
analysis or market research is always made unidentifiable. Such personal data
cannot be used to identify a particular User. Thus, such data is not considered
personal data.
The consent of the data subject
The User consents to the processing of its personal data with the purpose of Controller’s handling of recruitment. The User consents that personal data is collected through the Service, when Users;
- make an application through the Service, adding personal data about themselves either personally or by using a third-party source as Facebook or LinkedIn, and that Controller may use external sourcing-tools to add additional information; and
- when they use the Service to connect to Controller’s recruitment department, adding personal data about themselves either personally or by using a third-party source such as Facebook or LinkedIn.
The User also consents to the Controller collecting publicly available information about the User and compiling such information for use in recruitment purposes.
The User consents to the personal data being processed according to the below sections “Storage and transfer” and “How long the personal data will be processed”.
The User has the right to withdraw his or her consent at any time, by contacting Controller using the contact details listed under 9. Using this right may however, mean that the User can not apply for a specific job or otherwise use the Service.
Storage and transfers
The personal data collected through the Service is stored and processed inside the EU/EEA, or such third country that is considered by the European Commission to have an adequate level of protection, or processed by such suppliers that have entered into such binding agreements that fully comply with the lawfulness of third country transfers (such as Privacy Shield) or to other suppliers where adequate safeguards are in place to protect the rights of the data subjects whose data is transferred. To obtain documentation regarding such adequate safeguards, contact us using the Contact details listed in 9.
How long the personal data will be processed
If a User does not object, in writing, to the processing of their personal data, the personal data will be stored and processed by us as long as we deem it necessary with regards to the purposes stated above. Note that an applicant (User) may be of interest for future recruitment and for this purpose we may store Users’ Personal Data until such User is no longer of value as a potential recruit. If you as a User wish not to have your Personal Data processed for this purpose (future recruitment) please contact us using the contact details in paragraph 9.
3. Users’ rights
Users have the right to request information about the personal
data that is processed by us, by notifying us in writing, using the contact
details under paragraph 9 below. Users have the right to one (1) copy of the
processed personal data which belongs to them without any charge. For further
demanded copies, Controller has a right to charge a reasonable fee on the basis
of the administrative costs for such demand.
Users have the right to, if necessary, rectification of
inaccurate personal data concerning that User, via a written request, using the
contact details in paragraph 9 below.
The User has the right to demand deletion or restriction of
processing, and the right to object to processing based on legitimate interest
under certain circumstances.
The User has the right to revoke any consent to processing that
has been given by the User to Controller. Using this right may however, mean
that the User can not apply for a specific job or otherwise use the Service.
The User has under certain circumstances a right to data
portability, which means a right to get the personal data and transfer these to
another controller as long as this does not negatively affect the rights and
freedoms of others.
User has the right to lodge a complaint to the supervisory
authority regarding the processing of personal data relating to him or her, if
the User considers that the processing of personal data infringes the legal
framework of privacy law.
4. Security
We prioritize the personal integrity and therefore work actively
so that the personal data of the Users are processed with utmost care. We take such
measures as can be reasonably expected to make sure that the personal data of
Users and others are processed safely and in accordance with this Privacy
Policy and the GDPR-regulation.
However, transfers of information over the internet and mobile
networks can never occur without any risk, so all transfers are made on the own
risk of the person transferring the data. It is important that Users also take
responsibility to ensure that their data is protected. It is the responsibility
of the User that their login information is kept secret.
5. Transfer of personal data to third party
We will not sell or otherwise transfer Users’ personal data to third parties.
We may transfer Users’ Personal Data to;
- our contractors and sub-contractors, acting as our Processors and Sub-Processors in accordance with our instructions, for the provision of the Service;
- authorities or legal advisors in case criminal or improper behaviour is suspected; and
- authorities, legal advisors or other actors, if required by us according to law or as directed by any applicable authority.
We will only transfer Users’ personal data to third parties that we have confidence in. We carefully choose partners to ensure that the User’s personal data is processed in accordance to current privacy legislations. We cooperate with the following categories of processors of personal data; Teamtailor, who supplies the Service, server and hosting companies, e-mail reference companies, video processing companies, information-sourcing companies, analytical service companies and other companies with regard to suppling the Service.
6. Aggregated data (non-identifiable personal data)
We may share aggregated data with third parties. The aggregated
data has in such instances been compiled from information that has been
collected through the Service and can, for example, consist of statistics of
internet traffic or the geographical location of the use of the Service. The
aggregated data does not contain any information that can be used to identify
individual persons and is thus not personal data.
7. Cookies
When Users use the Service, information about the usage may be
stored as cookies. Cookies are passive text files that are stored in the
internet browser on the User’s device, such as their computer, mobile phone or
tablet, when using the Service. We use cookies to improve the User’s usage of
the Service and to gather information about, for example, statistics about the
usage of the Service. This is done to secure, maintain and improve the Service.
The information that is collected through the cookies can in some instances be
personal data and is, in such instances, regulated by our Cookie Policy.
Users can at any time disable the use of cookies by changing the
local settings in their devices. Disabling of cookies can affect the experience
of the Service, for example disabling some functions in the Service.
8. Changes
We have the right to, at any time, make changes or additions to
the Privacy Policy. The latest version of the Privacy Policy will always be
available through the Service. A new version is considered communicated to the
Users when the User has either received an email informing the User of the new
version (using the e-mail stated by the User in connection to the use of the
Service) or when the User is otherwise informed of the new Privacy Policy.
9. Contact
For questions, further information about our handling of personal data or for contact with us in other matters, please use the below stated contact details; Global Counsel c.levine@global-counsel.com
