NOTIFICATION OF CONFIDENTIALITY OF THE PERSONAL DATA PROCESSED BY HUMAN TO HUMAN Ltd, IN SELECTION OF WORKERS AND EMPLOYEES
The current notice is intended to inform data subjects on the circumstances of personal data protection in the process of selection of (1) our job applicants and the addressees of our Career Services and (2) the users of our e-page. Notification of confidentiality does not apply to our employees.
WHO ARE WE?
Personal Data Administrator is Human to Human Ltd. with UIC: 205873081 (“Personnel Recruitment Agency”), with headquarters and address of management: Sofia, 92 Vitosha Blvd., (“The Company”), with contact details office@dwp.bg or phone number +359892 266 206, with a Recruitment License No 2925 / 28.11.2019.
PERSONNAL DATA
The company processes the following categories of personal data of candidates participating in the selection procedure for employees through Human to Human Ltd., namely: Names, PIN/EGN or date of birth, citizenship, education, qualifications, career development and professional experience, username and password when registering on our sites, test data, driving license, address, phone number, etc. necessary to meet the requirements for the position or making the selection.
Described data can be collected through different channels – in the offices, through our site, from public information platforms for jobseekers (eg jobs.bg, zaplata.bg, rabota.bg, etc.), social network channels (e.g., Facebook and LinkedIn, etc.), through events, by phone or e-mail, through job applications and personal selection, and in the course of our relationship with clients and suppliers.
When visiting our offices, we can also collect and process visitors personal information.
LEGAL GROUNDS FOR PROCESSING DATA
The reason for processing the personal data when participating in the selection procedure and described in the previous point is an alternative (depending on the positions applied for, the storage period, etc.):
– legitimate interest of the Company under Article 6 (1) (f) of the General Data Protection Regulation – Regulation 2016/679.
– Consent according to Art. Article 6 (1) (a) of the General Data Protection Regulation – Regulation 2016/679.
We may also process the data in fulfillment of our statutory obligation when we act in compliance with the Regulation on the Terms and Procedure for Performing Intermediary Activities on Employment, related obligations, obligations to provide information to all state commissions and regulators, and to provide information to the court and law enforcement authorities.
Data processing based on our legitimate interest is present when we perform video surveillance in our administrative sites.
If necessary, we can seek your consent for the purposes of direct marketing.
OBJECTIVES OF THE PROCESSING
The purposes of data processing in the selection process are as follows:
– to find suitable candidates for work for clients of the Company;
– job search mediation;
– providing additional services such as training, career counseling and career guidance services.
The processing goals described are entirely related to the main scope of the company’s activities – selection, counseling, analysis and career support. The objectives are also in compliance with the statutory requirements, in accordance with the Regulation on the conditions and procedure for carrying out intermediary activity on recruitment, etc.
DATA RETENTION PERIOD
We store all the information we have collected for you and destroy it in a specified order within the statutory time limits and, if none, within the time limits set out in our Storage Restriction Policy.
Part of the terms are:
when the person has applied for a specific position, the retention period of the data collected is 6 months unless the subject has given his/her consent to processing for other future positions when the storage period expires with the explicit withdrawal of the entity consent.
In the event that the data subject applies for work via an online platform other than our website, then he / she should also respectively consider the Data Protection Policy of this online platform and its data retention periods for which the Company is not responsible.
Data retention period for the candidates who have concluded a selection contract, according to Article 41, paragraph 2 of the Regulation on the Terms and Procedure for Performing Intermediary Activities of Employment is 5 years.
Under the Accounting Act for the storage and processing of accounting data – 10 years;
For video surveillance data – 30 days of recording.
PROTECTION AND ACCESS TO DATA
The Company has taken legal, technical and organizational measures to protect personal data from accidental loss and unauthorized access, use, modification or disclosure. There are policies and procedures designed to protect information from loss, misuse and unlawful disclosure. The company does not transfer the data processed outside the EU / EEA.
The data available to employees or managers of the company to perform their assigned functions in connection with the selection.
Human to Human Ltd. uses third parties to support certain contractual activities or to fulfill a legal obligation. We do not grant your personal data to third parties before making sure that all technical and organizational measures are taken to protect this data as we seek to carry out strict control to meet this goal.
Some of the recipients of personal data may be:
• Courier firms, external consultants and specialists, collectors and law firms, banks, security firms, individuals who support equipment, software and hardware used by Human to Human Ltd.. for processing personal data, hosting companies and commercial agents and others.
• We may also share your personal data if you are a job seeker with clients who may have job offers or employment interest in our job candidates or whose selection process we are carrying.
• In some cases, providing personal data is required in order to comply with our legal requirements, such as regulators, state commissions, institutions and agencies, Employment Agency, NRA, NSSI, courts, prosecutor’s office, etc., to which we are obliged to provide personal data under current legislation.
YOUR RIGHTS
The Company provides all the rights provided by local and European legislation to the participants in the selection procedure, namely:
- If requested he or she has the right to receive all necessary information concerning the processing of the data provided, including a copy if possible;
- He or she has the right to request from the Company access to, correction or obliterating/ deletion of personal data or restriction of the processing of personal data, subject to the prerequisites;
- Has the right to object to the processing, as well as to file a complaint with CPDP in case of unlawful processing of the data;
- Has the right to withdraw his / her consent to processing his or her personal data at any time when the data are provided for consent;
- and is entitled to exercise its right of portability.
All requests related to personal data such as information, access, deletion, withdrawal of consent, etc. described above, shall be made in written, signed by the data subject and submitted for processing to the Company at the following address data.p@dwp.bg or at the management address of the Company. The request must contain information about three names and, in case the request is about specific personal data – to be specified, as well as exactly which right is exercised. With a consent to data processing, you can withdraw the same by emailing data.p@dwp.bg
It is possible for the company to provide optional applications for the exercise of the different rights, and we may request additional information to identify and / or clarify the request.
The company responds to the requests of the entities within 30 days, implements them if there are grounds for doing so, or makes a reasoned refusal, if there are reasons, indicating the right of the entities to follow up with the supervisors.
Requests will be considered excessive due to their repeatability and will be charged (only to cover processing costs) if they relate to static data that is not subject to change within the timeframe between requests.
More information regarding your personal information can be found on our website or by sending an inquiry to data.p@dwp.bg
This Privacy Policy has been updated for the last time on 1.November.2019.