Jobradar
Recruitment Agency personal
data processing policy and data protection terms and conditions
This document
has been drawn up based
on the instructions of the Data Protection
Inspectorate of the Republic of Estonia and the European Union General Data Protection Regulation (GDPR) and the
Personal Data Protection Act of the Republic
of Estonia.
The document
is valid from 25 May 2018
Definitions
Personal data–
any information relating to a natural
person which makes it possible
to identify that natural person,
directly or indirectly, on the basis of various identifiers, whatever the form or
format of the information.
Processing of personal data means any operation performed
upon personal data, including collection, recording, storage, modification, disclosure, access, etc. of personal data.
A processor is a natural or
legal person, a branch of a foreign company, or a national
or local authority that processes personal data or on whose behalf
personal data are processed.
The controller is the company/body that determines the purposes and means of the
processing of personal data.
The data controller is the person who processes personal data on behalf of and for the
account of the controller.
Recipient is any person
or body to whom personal data are disclosed.
Main
principles of the processing of personal data by Turvax OÜ
· lawfullness;
· purposefulness;
· minimality;
· accuracy;
· storage for a limited period;
· security;
· accountability and transparency.
Jobradar Personal Data Processing Overview
Turvax OÜ, as
the owner of the Jobradar Recruitment
Agency (hereinafter simply Jobradar), is both the
data controller and the data processor
of personal data with its registered office in the Republic
of Estonia.
Jobradar's data processors are Jobradar's contractual partners, to whom
only the purposeful and minimal personal data
is transferred.
Recipients of personal data are representatives of Jobradar's customers and cooperation partners, to whom only
personal data of pre-selected
individuals are transferred.
The data
subjects are job applicants (candidates) and users of our job
search service.
The main
purpose of the processing of personal data is the processing
of orders from customers and the filling of job openings.
In
order to achieve this objective, automated data processing and profiling of candidates is carried
out, after which the data
subjects are significantly affected by the
suitability or unsuitability for a position. This means that the
processing of personal data
is one of the key activities
of Jobradar.
It is
a regular and systematic, but not extensive,
processing of data, which does not
require Jobradar to appoint a Data
Protection Officer.
Jobradar Basics of processing personal data:
· Consent of the data subject
(CV or otherwise sending data to
be added to the database
of jobseekers, permission to ask for
references from previous employers, etc.);
· Performance of a contract (entering into an employment
or other contract with a client or a cooperation
partner);
· statutory obligation (e.g. keeping original documents with personal data for accounting purposes, keeping employment contracts).
Information to be collected
Jobradar collects personal information in various ways, for
example:
· via the
feedback form on our website;
· job applications;
· telephone, e-mail or other communication
with the candidate, other candidates or referrers
nominated by the candidate;
· professional or publicly available
social networks (eg LinkedIn), blogs,
photo albums, Youtube, online comments;
· from agencies
involved in background checks;
· job portals
or other public databases;
· public registers
(e.g. business registers, court judgments, official notices);
· media sources.
The personal data
collected are:
· first and last name;
· photo
· personal
ID number or other government-issued identification
number;
· gender;
· date of birth
or age;
· contact details (postal address, e-mail address, telephone number, skype);
· nationality and residence permit information;
· educational background;
· previous work experience (including current employer);
· information on work certificates and work permits;
· tax information
· salary expectations
· information on references (name, position, organisation, contact details);
· any other
information included in the candidate's CV or relevant to the position (e.g.
country of destination, job preferences, field of work, occupation, etc.).
Jobradar expects candidates to provide only
relevant and truthful information
about themselves that will allow
an informed decision to be
made about their fitness for the
chosen position.
Jobradar's collection of personal data is purposeful and minimal, which means that
the data listed above will
not always be requested in its entirety unless
there is a need or legitimate interest
to do so.
Use of collected information
Jobradar will always process
personal data on the appropriate legal basis, which is
first of all the consent of the data subject. We
collect and use personal data for the
purposes set out below:
· assessing candidates' qualifications and skills;
· providing job opportunities to candidates;
· building a pool of candidates and job seekers;
· matching candidates with employers.
In
addition, Jobradar may process personal data for certain
legitimate purposes, such as:
· to optimise
and improve business processes;
· to detect
and prevent infringements;
· to analyse
and improve the security of information systems.
Preservation and protection of collected information
Jobradar will retain the
personal data collected for no longer than
is necessary to fulfil the
above purposes or is required
by the legislation
of the Republic of Estonia.
By submitting his/her CV to
Jobradar, the candidate gives his/her consent
to the processing
of his/her data for a minimum
period of 36 months, during which Jobradar
may make job offers to
the candidate according to the
data submitted.
At
the end of the relevant period, or when
the need to keep personal data ceases, Jobradar
will delete or anonymise the
candidate's personal data.
Jobradar implements a variety of security measures to protect candidates'
personal data from accidental, intentional, unlawful or unauthorized
disclosure or use. These security
measures are:
· organisational (e.g. internal company
rules etc.);
· physical (e.g. restricting physical access to the premises
of the Jobradar recruitment agency);
· technical (reinforced network infrastructure, data encryption, etc.).
Information sharing and disclosure
Jobradar does not disclose
personal data of job applicants, except in the following cases.:
· the consent
of the candidate, i.e. the data
subject;
· a
legal obligation to disclose.
Job Radar may
share the candidate's personal data with:
· Clients who have an
interest in the candidate or who
have potential job offers for
the candidate;
· business partners who have
an interest in the candidate or
who have potential job offers
for the candidate;
· business partners who carry
out additional ability and aptitude tests or background
checks (e.g. certification of welders by a partnering company);
· law enforcement
or other government officials (to prevent or
investigate illegal activity, fraud or harm).
Outside the European Economic
Area, Jobradar may transfer a candidate's personal data only if the
requirements of the General
Data Protection Regulation are met.
Data subject rights
The rights
of the data subject are set out in Chapter 4, Section 3 of the Personal Data Protection Act of the Republic
of Estonia (§ 24.-28) and in Articles 15-22 of Regulation 2016/679 of the European Parliament and of the Council:
· The right
to receive information and personal data concerning him or her;
· the right
to request the rectification and erasure of personal data concerning you;
· the right
to request the restriction of the processing of your personal data;
· the right
to be informed
of the rectification, erasure and restriction of the processing of personal data concerning them;
· the right
to apply to the Data
Protection Inspectorate.
NOTE: Where the processing of personal data is based
on consent in accordance with Article 7 of the GDPR, the data
subject may withdraw his or
her consent at any time, i.e.
request the erasure of the personal data. This rule
applies, for example, to an
individual who has sent his CV to Jobradar and has not yet
signed an employment contract with a partner.
It is worth remembering
that the withdrawal of consent does not have
retroactive effects.
To exercise
his/her rights,
the data subject must send a request to this
effect by e-mail to info@jobradar.ee.
Policy update
Jobradar may unilaterally and without notice update its personal data processing practices and data protection conditions at any time to
reflect changes or to comply
with applicable law. The updated
version of the document will be
available at www.jobradar.ee/policy.html and the date of the
change can be checked in the
header of the notice.
Jobradar contact information
If you
have any questions or comments
about Jobradar's processing of personal data and the data protection
conditions, please write to the
contact details below:
info@jobradar.ee
Turvax OÜ
Rüütli 23
Tartu 51005
Estonia