Privacy policy for recruitment using Teamtailor
The service for handling recruitment and simplifying the hiring process (the "service") is powered by Teamtailor on behalf of Glitnor Group ("controller" "we" "us"etc). This Privacy Policy applies to all your Data collected by the Group. 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 legislations. 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 the Users contributes to the Service, or for the personal data that we in other ways collects 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; and
- 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.
- provides 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 be manually performed by our employees or 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 with the purpose of aggregated analysis or market research is always made unidentifiable. Such personal data cannot be used to identify a certain User. Thus, such data is not considered personal data.
Who can access the User's data
1. The user's information may be shared internally for the purpose of the recruitment. This includes;
- Human resources
- Interviewers
- Managers of the department which is offering the vacancy.
- Director/s
- IT staff if access to the data is necessary for the role in question.
2. The Data Controller may disclose the User’s personal data to third-party entities under the following scenarios;
- To comply with the data controller’s legal obligations or contracts, or to respond to a court order, administrative or judicial process, such as a subpoena or search warrant;
- In response to lawful requests by public authorities (such as national security or law enforcement);
- As necessary to establish, exercise or defend against potential, threatened or actual litigation;
- The Data Controller, shall not share your data with any other third parties (unrelated to the recruitment process), unless we request and obtain your explicit consent.
The User consents to the processing of its personal data with the purpose of Controller’s handling recruiting. 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 publically available information about the User and compiles them for use in recruitment purposes.
The User consents to the personal data being collected in accordance with the above a) and b) will be 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, 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 complies with the lawfulness of third country transfers (as Privacy Shield) or to other supplies where the adequate safeguards are in order 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 10.
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 for twelve (12) months. 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 10.
3. Users’ rights
Users have the right to request information about the personal data that is processed by us, by notifying in writing, using the contact details below under paragraph 10 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.
The User has the right to access. The data subject may request information about his or her personal data that the data controller processes, the legal basis and the processing purposes. The User has the right to object. If the user objects the controller will no longer process that user’s personal data unless the controller must process such personal data to assert, exercise or defend any legal claims.
The User has the right to rectification of inaccurate personal data concerning that User, via a written request, using the contact details in paragraph 10 below.
The User has the right to erasure. The User can demand deletion or restriction of processing, and the right to object to processing based on legitimate interest under certain circumstances. If there is no other legal basis that justify their retention.
The User has the right to restrict processing. The user can 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.
The 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.
If you require to exercise any of these rights, please contact the Company at privacy@glitnor.com. We will respond within thirty (30) days with the possibility of extending this period in accordance with the applicable law.
In order to verify your identity and check your right to exercise any of the above mentioned rights, the Company may request specific information from you. This is a security measure that ensures that your personal data is not given to any person who has no right to receive the personal data in question.
4. Security
We take the security of your data very seriously. We have control and internal policies in place to protect your data loss, misuse and unauthorized access, alteration, disclosure, or destruction.
If your personal data is shared with third parties, we require that all third parties to take appropriate technical and organizational security measures to protect your personal data and to treat it subject to a duty of confidentiality and in accordance with data protection law. We make sure that third parties are only allowed to process your personal data for specific purposes and in accordance with our instructions.
In the case of a suspected data security breach, the company has procedures in place so that we will notify the Supervisory Authority and yourself of any suspected data breach, where we are legally required. However, transfers of information over the internet and mobile networks can never occur without any risk. It is important that the Users 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 authority’s injunction.
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 regards to suppling the Service.
6. Aggregated data (non-identifiable personal data)
We may share aggregated data to 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 geological location for 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 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;
Glitnor Services Limited
Data Protection officer: Privacy@glitnor.com
