CET-DIGITAL PRIVACY POLICY
CET-Digital Takes Privacy & Security very seriously
We are committed to protecting the privacy and security of your personal information.
This privacy policy governs the collection, storage and use of personal information collected by CET-Digital s.r.o ("CET-Digital", "we" or "us"):
• via our website at www.cet-digital.com (the "Site"), or as a result of you responding to an advertisement posted by us on a job board, online CV library or via social media; or
• as a result of us matching your CV, as uploaded by you onto a job board, online CV library or a social media site, to a vacancy we are seeking to fill for one of our clients; or
• as a result of personal recommendations; or
• from company websites;
• from your business card;
• in the course of us providing permanent and/or temporary recruitment and resourcing services to you ("Services").
Where "you" are a candidate, potential candidate, consultant, client contact or contact at any other organization involved in the introduction and/or supply of a candidate's services, such as a contact at a recruitment process outsourcing company, personal service company or Umbrella Company.
REFERENCES IN THIS POLICY TO:
• "hirer" and "client" mean any hiring organization to which we offer and/or provide temporary and/or permanent recruitment services;
• "client contact" means a hiring manager at a client;
• "candidate" means a potential or actual candidate for a permanent or temporary role;
• "Consultant" means a person whose services are supplied via CET-Digital to work on temporary assignment with a hirer.
Specifically, this privacy policy provides you with details about the personal information we collect and hold about you, how we use your personal information, and your rights regarding your personal information. It does not cover any use of your personal information by:
• an actual or potential employer or hirer;
• an umbrella company; or
• any other organization involved in the supply of your services via us to a hirer, to whom we may provide your personal information as part of the recruitment process. That use will be governed by the relevant employer's or hirer's privacy policy.
PLEASE READ THIS PRIVACY POLICY CAREFULLY
OVERVIEW
We respect your right to privacy. Our overall aim is to ensure that our collection and use of personal information is appropriate to the provision of services to you and our clients and is in accordance with applicable data protection laws.
Further details of how we do so are set out in each section of our privacy policy as follows:
• Who we are
• What is the purpose of this statement?
• Our legal basis for using your personal data
• What personal data will we collect from you?
• 1. Personal data you give us
• 2. Special category personal data
• 3. Information automatically collected
• 4. Personal data we receive from other sources
• How will we use your personal data?
• How will we share or disclose your personal data?
• Where is your personal data stored?
• How long do we keep your personal data?
• Use of automated profiling tools
• Transfer of data outside of the EEA
• Access to and correction of your information
• Your duty to inform us of changes
• Your rights in connection with personal data
• Changes to our privacy statement
• Links to other sites
• Passwords
• Cookie policy
• How will we contact you?
• How can you contact us?
• How can you contact the supervisory authority?
PRIVACY POLICY
CET-Digital understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our connections and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
This privacy policy governs the collection, storage and use of personal information collected by CET-Digital s.r.o (“CET-Digital”, “we” or “us”):
• via our website at www. cet-digital.com (the “Site”), or
• as a result of you responding to an advertisement posted by us on a job board, online CV library or via social media; or
• as a result of us matching your CV, as uploaded by you onto a job board, online CV library or a social media site, to a vacancy we are seeking to fill for one of our clients; or
• as a result of personal recommendations; or
• from company websites;
• from your business card;
• in the course of us providing permanent and/or temporary recruitment and resourcing services to you (“Services”).
Where “you” are a candidate, potential candidate, consultant, client contact or contact at any other organisation involved in the introduction and/or supply of a candidate’s services, such as a contact at a recruitment process outsourcing company, personal service company or umbrella company.
References in this policy to:
• “hirer” and “client” mean any hiring organisation to which we offer and/or provide temporary and/or permanent recruitment services;
• “client contact” means a hiring manager at a client;
• “candidate” means a potential or actual candidate for a permanent or temporary role;
• “consultant” means a person whose services are supplied via CET-Digital to work on temporary assignment with a hirer.
Specifically, this privacy policy provides you with details about the personal information we collect and hold about you, how we use your personal information, and your rights regarding your personal information. It does not cover any use of your personal information by:
• an actual or potential employer or hirer;
• an umbrella company; or
• any other organisation involved in the supply of your services via us to a hirer, to whom we may provide your personal information as part of the recruitment process. That use will be governed by the relevant employer’s or hirer’s privacy policy.
This Privacy Notice explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data. Please read this privacy policy carefully
INFORMATION ABOUT US
CET-Digital is the data controller of the personal information that we collect from you. It is a company registered in England (registration number 09340698):
Registered address: 34 Kings Gate, Horsham, England, RH12 1AE
THE PERSONAL INFORMATION WE COLLECT ABOUT YOU
Candidates: the personal information we collect about you where “you” are a candidate or placed consultant.
When:
• you access and browse the Site (including when you submit personal information to us through data entry fields on the Site); or
• you respond to an advert posted by us whether via a job board, LinkedIn or other social networking site; or
• we download details uploaded by you onto a job board, LinkedIn or other social networking site in relation to a vacancy we are seeking to fill for one of our clients; or
• we download details uploaded by you onto a job board, LinkedIn or other social networking site in connection with our internal market research; or
• you contact us by phone, email or otherwise; or
• we provide Services to you or to an actual or a potential hirer of your services; or
• we contact you with a view to providing Services to you; or
• we provide on-boarding services to a hirer of your services,
We may collect some or all of the following personal data (this may vary according to your relationship with us):
• Name;
• Date of birth;
• Gender
• Postal address;
• Telephone number;
• E-mail address;
• a copy of your passport details including your passport photograph;
• your current and previous employment/work details, including job title and employer;
• recruitment-specific details such as any professional certifications, education and qualifications, skills, career history, salary range, right to work status, citizenship, location/relocation preferences, referee details and any other information relevant or required by law to enable us provide the Services;
• any other information which you include in your CV or a completed application form;
• any information which has been published or made available on a social media profile or job board (whether by you or a third party), or in any news media;
• details of your umbrella company or personal service company;
• the contract for services we hold with your umbrella company or personal service company relating to the work you do or will do for our client, including timesheet data and charge rates relating to the work you perform under that contract;
• references from third parties such as previous employers and nominated referees;
• the results of pre-employment screening or vetting checks which we are asked or required to undertake in relation to you (including the results of any Disclosure and Barring checks and any information you provide relating to current and/or spent criminal convictions carried out on behalf of the hirer during the on boarding process);
• any e mail communications, including attachments, which you send to us
• recordings of telephone conversations
• the results of right to work checks.
HOW WE USE YOUR PERSONAL INFORMATION AND OUR LAWFUL BASES FOR PROCESSING
Candidates and consultants
We collect, store and use information that we obtain in relation to you for our legitimate interests:
• so that we can contact you (via email, SMS, phone, WhatsApp or Skype) about opportunities and assignments that we believe you may be interested in;
• to help us to provide suitable candidates and consultants for our clients who engage us to assist them fulfil their recruitment and resourcing requirements;
• to provide a channel through which you may submit your CV for general applications, to apply for specific jobs or to subscribe to our job alerts;
• to match your details with vacancies, to assist us in finding a position that is most suitable for you and to send your information to clients for potential jobs. Please note that we will always obtain verbal or written consent before presenting your personal details to a client.
• to enter into contracts which are necessary in order for your service to be supplies or made available to a hirer;
• to carry out market research for our internal use;
• to develop an industry-relevant database of candidates and clients to help meet our clients’ resourcing requirements and connect candidates with work opportunities;
• for internal record keeping purposes;
• to carry out services that we, you or our client have requested including work-related references, qualifications and criminal references checking services, verification of the details you have provided from third party sources, psychometric evaluations or skills tests.
• This storage and use of your personal information allows you to be contacted about roles which may be of interest to you, now or in the future, and we do not believe that this storage and use will unduly prejudice your rights or freedoms.
• We will store and use your personal information in order to comply with relevant legal obligations to which CET-Digital is subject, including to carry out:
• verification of your identity to comply with The Conduct of Employment Agencies and Employment Businesses Regulations 2003;
• right to work checks to comply with relevant immigration legislation;
• In other, relatively limited circumstances, we will carry out further relevant background checks as may be requested by our client. In these circumstances we will be acting on behalf of our client and the handling of your personal data will be governed by the client’s privacy policy.
• Where you are successful in securing temporary assignment work with one of our clients we will store and use your personal information for the purposes of completing and administering contracts with your chosen personal service company or umbrella company and for processing payment to such company in respect of services you have performed for our client. Such processing will be for our legitimate interests so that we can provide Services to you and our client. We do not believe that this storage and use of your personal information will unduly prejudice your rights or freedoms.
• Such processing will also be necessary for the performance of a contract to which you are party (i.e. your contract with the umbrella company or your personal service company relating to the supply of assignment services) and/or in order to take steps prior to you entering into such contract.
• If our client requires us to collect, store and use your health data and/or any Disclosure and Baring Checks we will, on our client’s behalf, seek your consent to processing such data. You can withdraw your consent at any stage but this may prevent us from being able to deliver our recruitment services to you.
Client contacts and other third parties involved in the supply of resourcing services (e.g. umbrella companies and personal service companies)
We collect, store and use your name and contact details for our legitimate interests, so that we can:
• send you the details of candidates and consultants and contact you about our Services; and
• maintain our business relationship with you.
This allows you to be contacted to receive and administer any Services which you or your organisation have requested.
In the case of contacts at umbrella companies and personal service companies this allows you to be contacted to receive, on behalf of your employer, details of current and future assignments, related timesheet data and payment details.
We do not believe that this storage and use of your personal information will unduly prejudice your rights or freedoms.
All users of the Site and our Services
We collect, store and use your personal information for the following purposes:
• to make the Site available to you; and
• to provide any Services that you request.
Sometimes, our use of your personal information is for purposes which are ancillary to the provision of the Site and then Services, or which are desirable in order to make them to operate more effectively. In those circumstances, we believe we have a legitimate interest in handling your personal information, and do not believe that this storage and use of your personal information will unduly prejudice your rights or freedoms.
The relevant circumstances are:
• detecting and preventing fraud;
• keeping our Site, apps, products and IT systems secure;
• ensuring that our own processes, procedures and systems are as efficient as possible;
• analysing and enhancing the information that we collect;
• determining the effectiveness of our promotional campaigns and advertising; and
• contacting with products and services which we think may interest you.
• In some, relatively limited, circumstances we need to handle your personal information in a certain way to be able to comply with our legal obligations. For example if we:
• are requested to disclose your personal information to regulatory bodies;
• need to demonstrate our compliance with applicable law;
HOW WE SHARE YOUR PERSONAL INFORMATION AND WHO WE SHARE IT WITH
The information we collect about you is used to provide our services to you in our capacity as an recruitment agency to find you suitable work whether on a temporary or permanent basis based on your requirements. Information given freely by yourself when applying for a position or registering an interest with CET-Digital is only used for the recruitment process. We will not divulge any information to a prospective employer without first obtaining your consent to approach a prospective employer.
We will disclose information under the following circumstances:
• Service and Site usage information: When we share anonymous information generated by our Services with our clients.
• Third-party service providers: When we share information with third-party service companies for themto facilitate and support us in the provision of the Services. This includes:
• IT support service providers;
• providers of credit reference, vetting and screening services;
• payment processors and software providers;
These organisations are appointed by CET-Digital as data processors and authorised to use your personal information only as necessary to provide the relevant services to us. These organisations are required to process such information based on our instructions and in accordance with this privacy policy. They do not have any independent right to share this information.
• Group companies: We provide your personal information to our subsidiaries or affiliated companies for the purpose of processing personal information on our behalf to provide the Site and the Services. These parties are required to process such information based on our instructions and in accordance with this privacy policy. They do not have any independent right to share this information.
• Compliance with laws and legal proceedings: When we respond to court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. When we believe it is necessary to share information in order to investigate, prevent or take actions against illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our terms of use, or as otherwise required by law.
• Merger or acquisition: When we need to transfer information about you if we are acquired by or merged with another company. If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified by email and/or a prominent notice on our site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
• Recruitment and resourcing services: When we are using your personal information in the context of our recruitment and resourcing services, then we may share your personal information with clients where we believe that you may be appropriate for a particular role or vacancy with that client.
• Umbrella companies and personal service companies: When you inform us that you are supplying or intend to supply your services via CET-Digital to a client through an umbrella company or personal service company.
• Recruitment Process Outsourcing and Managed Service Providers: In certain cases, there may be an organisation such as a managed service provider acting as a gateway for the supply of Services made via CET-Digital to the hirer. Where this is the case, we will share your information with such organisations to the extent that it is necessary for the purposes of the supply.
• Where personal information is shared with clients, hirers, umbrella companies, personal services companies or managed service providers in the circumstances described above, then those organisations will handle your personal information in line with their own privacy policies.
INTERNATIONAL TRANSFERS
We may transfer personal information that we collect from you to clients located in countries that are outside of the UK or the European Economic Area in connection with the above purposes.
Please be aware that countries which are outside the European Economic Area may not offer the same level of legal protection for your personal information as under UK law, although any collection, storage and use of your personal data by us (or on our behalf) will continue to be governed by this privacy policy.
Where we transfer personal information to such third parties, we will ensure that we have measures to ensure it is afforded appropriate protection.
HOW LONG DO WE KEEP YOUR INFORMATION FOR?
We will retain information (including personal information) about you for a period of up to 7 years from the date on which you last received Services from us.
We will delete it after that time except where we need to keep any personal information to comply with our legal obligations, resolve disputes, or enforce our agreements.
In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
HOW WE USE COOKIES
Technologies such as cookies, beacons, tags and scripts are used by us and our affiliates, or analytics or service providers. These technologies are used in analysing trends, administering the Site, tracking users’ movements around the Site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
We use cookies, for example, to remember users’ settings (e.g. language preference) and for authentication. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our Site, but your ability to use some features or areas of our Site may be limited.
Please read more about how we use cookies and what information is collected using cookies in our cookie policy on our website.
SECURITY
All of the personal data we have is stored on our secure database which is controlled by a third party provider in the U.S. The third party participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, respectively.
For internal administration purposes, your data is held on various password protected spreadsheets and stored on Google Drive with their servers also being located in also in the U.S. More details of how Google protect your data can be found here: https://cloud.google.com/security/infrastructure/design/?utm_medium=et&utm_source=google.com%2Fcloud&utm_campaign=gdpr&utm_content=commitments_to_the_gdpr.
Finally to ensure the proper processing of our obligations to our clients, your name will also be held within our Accounting system. Similar to many SaaS providers, they use a top-tier, third-party data hosting provider (Amazon Web Services) with servers located in the U.S., to host their online and mobile services. For more information about AWS’s approach to compliance with the GDPR, please see: https://aws.amazon.com/compliance/gdpr-center/.
Please note that the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk.
YOUR RIGHTS TO YOUR INFORMATION
You have the following rights in relation to the personal data we hold on you:
• the right to be informed about the data we hold on you and what we do with it;
• the right of access to the data we hold on you. More information on this can be found in the section headed “Access to Data” below and in our separate policy on Subject Access Requests”;
• the right for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known as ‘rectification’;
• the right to have data deleted in certain circumstances. This is also known as ‘erasure’;
• the right to restrict the processing of the data;
• the right to transfer the data we hold on you to another party. This is also known as ‘portability’;
• the right to object to the inclusion of any information;
• the right to regulate any automated decision-making and profiling of personal data.
You can see more about these rights at:
If you would like to exercise any of these rights in relation to your personal data. This is known as a “subject access request”. All subject access requests should be made in writing and sent to the email or postal addresses shown below. There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 30 days of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try and resolve it for you.
CHANGES TO OUR PRIVACY POLICY
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be made available on our website.
CONTACT US
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
For the attention of Natalia Borisova:
• Email address: Compliance | CET-Digital
• GDPR / Data protection: ico. certified: reference number: ZA924088
• Professional Indemnity @ liability Insurance, up to 2.000.000 EUR / Year. Allianz, Policy number: 5054008861
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