General Data Protection Regulation Privacy Notice

GDPR PRIVACY NOTICE

Scalable Global Solutions d.o.o.  is committed to protecting the privacy of our clients, candidates and users of our websites. This notice relates to candidates or potential candidates.

The Company means Scalable Global Solutions d.o.o.  (company VAT number :85470532354), its subsidiaries and its associated companies. 

The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new regulation replacing the Data Protection Regulation (Directive 95/46/EC) The Regulation harmonises data protection legislation across EU member states.

The Company is a recruitment process outsourcing business provider which provides Human Resources, Recruitment and Employment related services to its clients and candidates (work-seekers.) The Company must process personal data (including sensitive personal data) so that it can provide these services – in doing so, the Company acts as a data controller.

You may give your personal details to the Company directly, such as on an application or registration form or via our website, or we may collect them from another source such as a jobs board. The Company must have a legal basis for processing your personal data. For the purposes of providing you with work-finding services and/or information relating to roles relevant to you, the Company will only use your personal data in accordance with the terms of the following statement: 

  1.  Collection and use of personal data

       a)    What type of data the company collects

The Company is a recruitment business and an employment business, which provides work-finding services to its clients and work-seekers. The Company must process personal data (including sensitive personal data) so that it can provide these services – in doing so, the Company acts as a data controller. The Company collects the personal data of the following types of people to allow it to undertake its business:

  • Potential and current client contacts
  • Potential candidates and those placed in temporary, contract, or permanent or roles
  • Employees, consultants, temporary and self-employed workers
  • Supplier contacts

The information you give the Company or it collects about you may include:

Who you are and how to contact you

  • Name, address, post code, private and corporate e-mail addresses, telephone phone numbers
  • Information about your professional life
  • CV, photograph, employment details and preferences, professional profiles available in the public domain such as Twitter, LinkedIn, or a corporate website

Compliance and due diligence

  • Financial information, documentation and references verifying your qualifications and experience and your right to work in the workplace location, tax and national insurance information to pay you if you are a temporary worker, contractor or self-employed person.

Information obtained from other sources

This is information we may obtain sources such as LinkedIn, or other social media sources, corporate websites, job boards. In this case, and upon your request we will inform you, by sending you this privacy notice, the source the personal data originates from, whether it came from publicly accessible sources, and for what purpose we intend to retain and process your personal data.

          b)    Purposes of the processing and the legal basis for the processing

The Company uses information held about you in the following way to provide job finding and complementary services to our candidates.

The Company’s principal service is the introduction of candidates to its clients for temporary or permanent work assignments. This encompasses meeting candidates’ current needs and supporting them through the course of their careers. To do this, the Company will collect your personal data (which may include sensitive personal data) and will process your personal data for the purposes of providing you with work-finding services and ancillary services such as training for purposes of personal development. 

The Company only processes personal data for the specific purposes set out in this Policy (or for other purposes expressly permitted by the Regulation). The purposes for which we process personal data will be informed to Data Subjects at the time that their personal data is collected, where it is collected directly from them, or as soon as possible (not more than one calendar month) after collection where it is obtained from a third party.

The principal legal basis for the processing of personal data is our legitimate business interests, described below.

The Company will also rely on the following bases for specific uses of data:

  • legal obligation (for example to record your right to work in the destination country
  • contractual obligation (for example to process your information to pay you, or to provide your personal information to a client)
  • consent (for example your consent for your details to be passed to a client for a potential role)

        c)    Our Legitimate Business Interests

Our legitimate interests in collecting and retaining your personal data are as follows:

The Company introduces candidates to clients for permanent, temporary and contract roles, thereby furthering the careers of those candidates and providing an essential service to its clients. The processing of personal data relating to our candidates and our client contacts is critical to this process.

The Company maintains databases of candidate and client personal data containing historical information as well as current resourcing requirements.

To maintain and develop its business, the Company also records the personal data of potential candidates and client contacts.

To deliver its principal services, as well ancillary offerings, the Company contacts candidates on a regular basis, via various means such as email, phone, job alerts and other relevant notifications.

2)    Disclosure of your information inside and outside of the European Economic Area (EEA)

The Company may share your personal information with:

  • Any members of its group, whether in the EEA and outside of the EEA.
  • Candidates (if you are a client) to arrange interviews and engagements.
  • Clients to introduce candidates to them.
  • Clients, business partners, suppliers and sub-contractors for the performance and compliance obligations of any contract the Company enters into with them or you.
  • Subcontractors payment and other financial service providers.
  • Organisations that assist the Company in the improvement and optimisation of its websites.
  • Organisations that may assist the company in confirming your suitability for a role.
  • The buyer, in the event all or part of the company is sold.
  • Organisations where the Company has a duty to disclose or share your personal data in order to comply with any legal obligation.
  • Organisations that may assist the company in enforcing its contractual rights or meeting its contractual responsibilities.

The lawful basis for the third-party processing will include:

  • Their legitimate business interests in processing your personal data, for example in recruiting new permanent or temporary workers.
  • Satisfaction of their contractual obligations to the Company as a data processor;
  • For the purpose of a contract in place or in contemplation;
  • To fulfil their legal obligations.
  • Storing and processing your personal information

The Company may transfer only the information you provide to us to countries outside the European Economic Area (‘EEA’) for the purposes of providing you with work-finding services. We will take steps to ensure adequate protections are in place to ensure the security of your information. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein

3)    Retention of your data

The Company will retain your personal data only for as long as is necessary for its legitimate business interests or as required by contractual obligations or law. Different laws require different retention periods.

We must also keep payroll records from in house employed candidates, holiday pay, sick pay and pensions auto-enrolment records for as long as is legally required by the domicil country law and associated national minimum wage, social security and tax legislation.

Where the Company has obtained your consent to process your personal and/or sensitive personal data, we will do so in line with our retention policy. Upon expiry of that period the Company will seek further consent from you. Where consent is not granted the Company will cease to process your personal and/or sensitive personal data.

Our current retention notice will be available upon request from 25th May 2018.

4)    Your rights

Please be aware that you have the following data protection rights:

  • The right to be informed about the personal data the Company processes on you;
  • The right of access to the personal data the Company processes on you;
  • The right to rectification of your personal data;
  • The right to erasure of your personal data in certain circumstances;
  • The right to restrict processing of your personal data;
  • The right to data portability in certain circumstances;
  • The right to object to the processing of your personal data that was based on a public or legitimate interest;
  • The right not to be subjected to automated decision making and profiling; and
  • The right to withdraw consent at any time.

 

Should you wish to exercise any of the above rights, you may do so by contacting the following email address: DPO@s-gsg.com. 

5)    Changes to the Company’s privacy notice

Any changes The Company makes to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail.

6)    Complaints or queries
If you wish to complain about this privacy notice or any of the procedures set out in it please contact the following email address:

DPO@s-gsg.com 

7)    Job Alerts and Career Advice

We may on occasion contact candidates stored in our database who are not actively looking for a new role. When you contact Scalable Global Solutions d.o.o.  you may be asked to tick a box indicating that you consent to us storing the personal data you have provided. By providing consent to our storage of your personal data you are also providing consent to us contacting you if we receive details of a role which specifically matches your career aspirations and, very occasionally, sending you career related information e.g. salary survey, interview advice etc.
If you do not wish to receive such information, please email DPO@s-gsg.com. 

SGS Promise to our candidates

We will never share our candidates’ personal details or Curriculum Vitae with a third party without the candidate’s explicit consent, and then we will only share the personal information with that one company or individual.

  • Contacting Recruitment Consultants directly

If you contact one of our Recruitment Consultants directly and request they consult with you regarding your job search, or regarding a particular job role, you are giving your consent to Scalable Global Solutoons d.o.o.  processing your email and the data contained within your email for lawful purposes. 

By sending an updated Curriculum Vitae directly to one of our Recruitment Consultants you are giving consent to Scalable Global Solutions d.o.o. processing and storing that information. We will not share your information with any third party without your explicit consent.

  • Request to have personal data amended

It is likely that over time your employment history will require updating as you transition to new roles or receive promotion. Scalable Global Solutions d.o.o. undertakes to update your registration within two weeks of receiving an updated Curriculum Vitae.

Under the GDPR you have the right to ask for access to your personal information. Once we have verified your identity we will provide the information you requested within 30 days.

In the unlikely event you find personal data stored about you by Scalable Global Solutions d.o.o. is inaccurate, you must advise us immediately. We will amend your personal registration within two weeks.

  • Request to have personal data removed or deleted

Upon receipt of a request to delete an individual’s personal registration, Scalable Global Solutions d.o.o. will ensure that your personal record is deleted within 30 days.

Where we have placed a candidate in a role, they are required to retain evidence of that placing so that contractual obligations can be met by the client. Scalable Global Solutions d.o.o. will however take steps to ensure only minimal personal data is retained and we will not make further contact with the candidate.

Where we have previously received permission to share personal information with a third party, for example for short listing for a role, we undertake to advise that third party of your wish to be forgotten if communication has been in the last 12 months.

In the event that you wish to be erased from our SGS ONE Database you should contact DPO@s-gsg.com. Please make it clear that you wish to be erased, rather than simply marked as no longer job seeking.

  • Notification of Breaches

Whilst we do not store, or at any time request, financial information from candidates, we do store highly personal information contained within your Curriculum Vitae. We are aware of our responsibility as a recruiter to protect your information and to only share details with third parties upon receipt of your explicit consent. All of our systems are protected and only our staff and consultants working for us have access to the personal information stored in your registration.

In the unlikely event that our computer systems are compromised and there is a potential loss of confidentiality we will report this breach to you.

In the unlikely event that personal data is taken or exposed from our records without our consent, we will provide reports surrounding that exposure within 72 hours of being notified of such an event and take any action necessary to restore security of your personal data.

  •  Access

If we receive a request for access to personal information we will verify your identify before releasing your personal data to you. We will not release information to any third party.

If you would like to make a request for access to your personal information please contact: DPO@s-gsg.com. 

Alternatively you can contact us by writing to us at:
GDPR Compliance Officer
Scalable Global Solutions d.o.o. 
Ulica Grada Vukovara 284
10-000 Zagreb, Croatia

  • Complaints procedure

If you have a complaint about the way your data is stored or handled by Scalable Global Solutions d.o.o. please contact us at: DPO@s-gsg.com. 
Alternatively you can contact us by writing to us at:
GDPR Compliance Officer
Scalable Global Solutions d.o.o. 
Ulica Grada Vukovara 284
10-000 Zagreb, Croatia

  • Changes to our Privacy Policy

This privacy policy may be changed at any time. Any changes to our Privacy Policy will be updated on our website. If you have any questions or concerns, please email us at DPO@s-gsg.com.