Personal Data Processing and Protection Policy
The present internal founding regulatory documentation lays out our service provider company, Jobsgarden Kft.’s policy on personal data processing and protection manifesting through our website jobsgarden.hu.
The Privacy Statement has been prepared in accordance with the General Data Protection Regulation (from here on: Regulation) numbered 2016/679.
Our contact details: Jobsgarden Kft.
Address: 1134 Budapest, Dévai street 19. VIII/811
Email address: email@example.com
The scope of data to be processed, the legal basis and aim of data management, the time period of data management
Data Management in terms of Placements
The Description of Data Management, the Scope of Data to be processed
One of our main profiles incorporates placements, which can be manifested in two ways. On one hand, you have the possibility to apply for job advertisements through our website, on jobsgarden.hu, on the other hand, you can be contacted by us with definite job advertisements on Linkedin, Facebook or through referrals given by a third party.
If you decide on applying for a job advertisement on our website with the intention of fulfilling a position of your choice, you are requested to give us your full name, email address along with your CV. In this case, data management is an indispensable element for the accomplishment of employment placement.
In case of being contacted by us, after having your consent to managing all your personal data, you are to give us your full name and email address along with your CV, should you be interested in fulfilling a position of your choice.
We record all your data in our CRM software.
During our placement processes, your application will be pre-screened and after having a successful personal interview with our HR professionals, your application might be forwarded to the employer advertising the position. In the personal job interview we record the date of the encounter as well as your name, giving a comprehensive assessment, and thus, our professional and highly objective observations to our clients on how suitable we think you are for the position advertised.
If the name of the employer is not indicated in the specific job advertisement on our website, we will inform you about it in the personal interview so that you know where your data of application will be forwarded to.
If you are already an existing candidate in our database contacted by us, we will inform you who your data will be forwarded to, should you be interested in the position in regard to which you have been contacted.
If the position to be applied for requires foreign language knowledge, you might be obligated to take language tests executed by our partner. To enable our partner to test, and thus, assess language skills, we are to provide them with your personal data (name, email address, telephone number).
The Legal Basis and Aim of Data Management
The legal basis of data management is based on Article 6 paragraph (1)(a) of Regulation claiming your willing consent in this matter.
The Time Period of Data Management
We store your data in line with the principles appointed below:
· If the present candidates fail to give us their consent for their data to be stored, it will be deleted after the job advertisement has been closed, which is a period of 6 months.
· If you agree to be contacted about a job opportunity in the future as well, then, in accordance with our main principle, your data will be treated for 3 years, except for having been informed antecedently on your intent to have your data deleted from our database. We will send you a kind reminder on your obligation to inform us about any changes that might have occurred in your personal data after 1 year. It is only to ensure our high-quality service as we would like to contact you about job opportunities that might suit you best.
If you wish to have your data deleted from our database, please send us an email to: firstname.lastname@example.org. We will send you a notification on the erasures as soon as possible, within 30 business days the latest.
'Contact us' Dropdown Menu
The Description of Data Management Case
We can be contacted through the ' Contact us’ dropdown menu that is to be found on our website, jobsgarden.hu. On the form, please give us your name, email address and the message to be sent. By filling out a form with your name and email address you can send us a message.
The legal basis and aim of data management
The legal basis of data management is a voluntary agreement based on Article 6 paragraph (1)(a) of Regulation.
The time period of data management
After contacting you, your data will be deleted after 30 days except when we enter into a contractual relationship or when your placement process begins. In latter cases you will be informed on our policy on data management.
Registration for participation in an event
Description of Data Management Case
Participation in some events (e.g. workshops) hosted and organized by Jobsgarden Kft. is only feasible in case of prior registration.
The legal basis and aim of data management
The legal basis of data management based on Article 6 paragraph (1)(a) is regarded as your voluntary consent, the aim of which is the identification and differentiation of the ones concerned, contacting as well as maintaining the relationship with candidates and last but certainly not least sharing information on upcoming events.
The scope of the data treated: date, full name, email address and telephone number. By registering to the events and participating in them, the candidates give their consent to being taken video and audio recordings of in the course of the event with devices the data controller wishes to, regardless of territorial restriction for an indefinite time period and freely. These items can be recorded by the data controller or a third party, serving marketing purposes. The candidates are requested to give their license to the preparation, advertising, publication and dissemination of the marketing materials related to the training.
In the course of data management, we use the following systems as data processors:
· Hosting service provider: E-distribution Ltd.
· Salesforce/Target Recruit the operator of CRM system
· Mail server: Microsoft O365
IT Operations: Qualysoft Ltd.
All your data will be processed to a third party in accordance with the procedure elaborated on in our placement policy.
Cookie data management
Your rights in terms of data management
You are granted the following rights based on the Regulation within the period of the data management:
· access related to information on personal data and data management
· right to rectification
· limitation of data management
· right to erasure
· right to data portability
· right to object
· right to the withdrawal of consent
If you intend to exercise any of the rights, you will be subjected to identification, which means that we need to communicate with you. To ensure smooth and effective identification, you are requested to give us your personal data. (These items of data can only be ones you have already provided us with.)
Your complaint regarding data management will be accessible and stored in our email inboxes within the period appointed in our policy on data processing in terms of complaints.
The complaints concerning data management can be sent to the email address given in the introductory part.
We will reply to these complaints on data management within 30 workdays the latest.
Right to the withdrawal of consent
You are entitled to withdraw your consent to data management any time you wish to. In such cases all data given to us will be deleted from our systems. Please note that if you intend on having your data deleted from our systems during the selection process, we are obligated to inform our partner on it, which results in unsuccessful application.
Access to personal data and information
You are entitled to receive feedback on the progress of your data management. If the management of your personal data is in progress you are entitled to:
· get access to your personal data treated and be informed on the following:
o the purposes of data management;
o the categories of your personal data treated;
o information on the addressees or the categories of the addressees we have shared, or we will share your personal data with;
o the planned time period within which we store your personal data, or if, to any extent, it is not possible, the aspects of determining the exact length of the duration;
o your right to request the rectification and the deletion of your personal data or even the limitation on its management. In case of data management based on legitimate interest, you are entitled to object to the handling of your personal data;
o your right to lodge a complaint to the supervisory authority;
o if your data has not been collected from you, you are entitled to be given all the information accessible in terms of its source;
o on the automated decision (if there is a procedure to be applied existing), including the creation of profile, and the logics to be applied as well as the sets of clear information at least in these cases, highlighting the significance of data management and all the anticipated consequences they bear.
The aim of exercising the right can only be purported to stating and controlling the legality of data management, therefore, in case of requesting to be informed multiple times, we may charge you reimbursement in exchange for the accomplishment of comprehensive information provision.
We ensure the access to your personal data after identifying you. All the data and information treated will be sent to you in email.
We kindly ask you to indicate your request to be granted access to your personal data or the information related to data management.
Right to rectification
You are entitled to request the rectification of any inaccurate data of yours without any delay.
Right to the limitation of data management
You are entitled to the limitation of data management, if any of the following conditions are fulfilled:
· the accuracy of the data is contested by you. In such cases the limitation relates to the period that enables us to check the accuracy of personal data. If there is no need for any control, then we will not apply any limitations;
· the data management is unlawful and instead of insisting on the deletion of your data, you just ask for the limitation of its use;
· we no longer need your personal data for the purposes of data management appointed formerly, but you require them for the plea and protection of civil-law claims.
· you have objected to data management. Since our legitimate interest may also justify our claim to handle your personal data, if it is not officially stated which party’s legal justification should priority be given to, data management is to be limited.
If data management is subjected to restrictions, your personal data can only be managed by having your consent to it or through the plea and protection of civil-law claims including the protection of rights of natural or legal persons. Moreover, data management is allowed when it serves the interest of the European Union or any other common interests.
We will inform you on the removal of data management restrictions in advance. (at least 3 days before the removal of the restrictions enters into force)
Right to erasure and to ’be forgotten’
You are entitled to request the deletion of your personal data without any undue delay if any of the following conditions listed below are fulfilled:
· we no longer need your personal data for the same purpose for which they were collected or managed;
· you withdraw your consent to data management and it does not bear any other legal grounds;
· you expressed your objection to data management based on legitimate interest and there is not any legitimate reason (legitimate interest) taking precedence for data management;
· your personal data has been treated unlawfully and your complaint is regarded as righteous;
· the personal data is to be deleted in compliance with the legal obligation laid down by Union or Member State law.
If we have disclosed any of your personal data on legal grounds, and still, we are obligated to delete it due to any of the reasons indicated by you, we will take reasonably expected steps to accomplish it. We will do it by considering the cost of technology available including any other technical measures necessary to inform the data managers on your request to delete the copy and the duplicate of your personal data as well as the links indicating them. As a general main rule, we do not disclose any of your personal data.
Deletion is not to be applied in case data management is a necessity:
· for the purpose of exercising the right to freedom of expression and information;
· the accomplishment of the legal obligation laid down and regulated by Union or Member State law on the management of personal data (for instance, data management in the framework of invoicing, as keeping invoices is regulated by law) and for the purposes of executing tasks performed by the data manager representing public authority as well as public interest.
· for the plea and protection of civil-law claims (for instance, if we have a claim not settled by you or in case the administration of consumer or data management complaints is in progress)
The right to object
You are entitled to object to the management of your personal data based on righteous interest due to personal reasons. In these cases we cannot manage your personal data any longer except for special cases when we can prove that there are compelling and valid reasons justifying our grounds to manage your data including the plea as well as the protection of civil-law claims. These reasons take precedence over your interests and rights to freedom.
Right to data portability
If data management is inevitable for the performance of the contract, or if it is based on a voluntary consent, you are entitled to request the data having been sent to us as a digital content, in a machine readable form, provided to you in a csv format. If the aforementioned process is technically feasible, then you can request all your data to be processed to other data managers using this form.
In case we have violated any of the legislative provisions on data management or failed to accede to your request then in order for the presumptive and unlawful data management to be ceased, you are entitled to initiate a formal investigation procedure executed by the Data Protection Commissioner’s Office. (address: 1363 Budapest, Pf. 9 e-mail: email@example.com).
We hereby would like to inform you on your right to initiate civil proceedings before the court.
In the course of operating information systems, we ensure solutions related to authorization, internal organization and technology in order to guarantee data security. Due to our strict policy on data security we will prevent your personal data from falling into unauthorized hands, getting deleted or modified, or simply obtaining it from our database, risking that it might be saved by them. We will also assert our claims on data protection and data security to our own data managers.
We keep records of incidents on data protection and if necessary, you will be informed about any occurrent incident affecting you.
We reserve the right to modify our policy on data processing and management not affecting its legal grounds and purpose.
In case of intending to perform data management regarding the data having been compiled for purposes other than those for which they were collected, we will inform you on the purpose of data management as well as the information listed below prior to further data processing and management:
· the time period of storing your personal data or, if it is not possible, the aspects of determining this time period;
· your right to request access to all your personal data including the deletion, rectification, or the limitation of its management. You are also entitled to object to managing your personal data based on righteous interest and request the assurance of your right to data portability based on your consent or a contractual partnership;
· on your right to withdraw your consent in case of data management based on your prior consent;
· on your right to lodge a complaint to the supervisory authorities;
· on the provision of personal data indicating the type of contract along with the obligation it brings forth that may be either of a statutory or a contractual one. Our policy clearly states whether the contract is considered to be a prerequisite or if you are obligated to give your personal data and what consequences you might expect in case of failing to provide it;
· on the automated decision (in case there is any procedure to be applied existing) including the creation of profile and the logics to be applied as well as the sets of clear information at least in these cases, highlighting the significance of data management and all the anticipated consequences they bear.
Data management can only be launched in case the legal grounds of data management is based on consent. Besides being informed on our policies on data processing and management, you are also obligated to give your consent to us to proceed with your application.