1. Introduction
This is a description of how your personal data is processed in our services (recruitment and headhunting, personnel leasing and staffing, job search advising, onboarding, outplacement).
The controller of your personal data is usually employer/potential employer as legal entity that uses CVO services, which means that also the privacy policy of specific Controller may apply. Please contact to employer/potential employer regarding this.
In above mentioned situations, CVO is usually data processor regarding your personal data and thus follows also controller’s instructions when processing personal data.
To some activities and related personal data processing, the data controller is “CVO”, meaning the legal entity Recruitment Estonia OÜ, registry code 11193077, address Narva mnt 5, Tallinn, Estonia. Such activities include the collection and storing of candidates and potential candidates interest to a specific job type or vacancy.
2. How we get the personal information?
CVO collects personal data from publicly available sources and other service providers (for example LinkedIn), also from you as a job candidate in case you provide us personal information during the process.
CVO storing and processing depends on the provided service.
In addition to this, CVO processes your personal data to keep and rise the CVO service quality. For this purpose and under the legal ground of CVO legitimate interest, we store your interest regarding specific job type. Generally, we do not store detailed candidate information and we collect necessary data every time the CVO service is used, from the above mentioned sources. We also generally do not store candidate contact information and contact the candidates through third party service providers (such as LinkedIn).
3. What kind of data is processed and why?
|
Processing activity |
Data categories |
Purpose |
Legal basis |
|
Data subject identification |
Name, education, work experience |
Candidate/potential candidate identification |
Contract |
|
Potential candidate headhunting |
Publicly available information (LinkedIn, CV-Online, CV Keskus, Äripäeva Infopanl, companys’ homepages) |
Finding the suitable candidate for CVO clients’s vacancy |
Contract |
|
Directing the candidate to personal tests if requested by the CVO client |
Data processing is dependant on testing service provider |
Finding the suitable candidate for CVO clients’s vacancy |
Contract |
|
Communication with the candidate during the application period |
Name, e-mail, phone number, content of the communication |
Finding the suitable candidate for CVO clients’s vacancy |
Contract/Legitimate interest |
|
Storing the interest to vacancies of candidates/potential candidates |
Name, job type |
Maintaining and rising the level of CVO service quality |
Legitimate interest |
|
Storing the information of successful employment |
Name, employer |
Fulfilling the contract between CVO and its client |
Contract |
|
Storing the application information after application proceedings |
Data collected and created during the application process |
Storing the application data for potential legal dispute of discrimination |
Legal obligation |
|
Website visitor behaviour |
Web browser information, IP address, analytical cookies |
Optimization of website visitor user experience |
Consent |
|
Newsletters and marketing |
Name, e-mail |
Marketing |
Consent |
4. Sharing your personal data
We share your personal data only to a specific employer/potential employer and if necessary, to service provider that conducts personal candidate tests. Our employees have the access to your personal data only on need to know basis, which means that they process only the personal data that is related to their specific tasks.
We use third party processors to help provide our services. Those sub-processors have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.
Why and with whom we share your personal data?
|
Categories of Recipients |
Reason for sharing |
|
Service providers |
We work with service providers that work on our behalf which may need access to certain personal data to provide their services to us. These companies include those we have hired to operate the technical infrastructure that we need to provide service and assist in protecting and securing our systems and services. |
|
Testing |
We use third party service providers as our partners to carry out individual candidate testing. CVO does not receive testing results, those results are sent directly to the employer/potential employer. |
|
Advertising partners |
We work with advertising partners to enable us to customize the advertising content you may receive. |
International transfers
Some of our processing is cloud based so your personal information might be sent outside the European Economic Area. In such instances we will ensure that the transfer of your personal data is carried out in accordance with applicable privacy laws and, in particular, that appropriate contractual, technical, and organisational measures are in place.
5. Ensuring the security of personal data
We have taken necessary technical and organizational security measures to protect your personal data against accidental or unlawful destruction, loss or alteration and against the unauthorized disclosure, abuse or other processing in violation of applicable law.
This includes: identity and access management; preventing unauthorized viewing of personal data; deliberately set password requirements; structurally safe network design and other relevant continuously updated security measures.
6. Retention and deletion of personal data
The storage period of personal data depends on whether we have legal obligations to store data (i.e accounting regulations), contractual obligations, legitimate interest to provide best services or your explicit consent.
|
Data Type |
Purpose |
Retention Time |
|
Data for identification of the candidate/potential candidate |
Identification |
End of application process+fulfilling the purpose under the legitimate interest or deletion request from data subject |
|
Name, e-mail, phone number, content of the communication |
Communication with the candidate during the apply process |
End of application process |
|
Fact of successful application that ended with hiring |
Fulfilling the contract between CVO and its client |
End of storing period derived from contract between CVO and client |
|
Data and documentation collected during the application proceedings |
Storing the application data for potential legal dispute of discrimination |
1 year after the end of application process ends |
|
Web browser data, IP address, analytical cookies |
Website visitor analytics to maintain and rise the high level of user experience |
Withdrawal of consent |
|
Name, e-mail |
Newsletters and marketing |
Withdrawal of consent |
7. Your rights and preferences
Under data protection law, you have certain rights. In some instances, you need to contact with data controller that may not be CVO:
- Right to be informed and to access. You may get information regarding your personal data processed by us.
- Right to data portability. You have the right to receive your personal data from us in a structured, commonly used and machine-readable format and to independently transmit those data to a third party.
- Right to erasure. You have the right to have personal data we process about you erased from our systems if the personal data are no longer necessary for the related purposes.
- Right to object and restrict. You have the right to object to the processing of your personal data and restrict it in certain cases.
- Right to rectification. You have the right to make corrections to your personal data.
- Right to withdraw consent. When you have given us consent to process your personal data, you may withdraw said consent at any time.
To exercise any of the abovementioned rights, please contact . We will respond to your requests within 30 days.
8. Other important information
Newsletter and direct marketing campaigns
With your explicit consent, we may send you our newsletter. You may opt out of these messages. Please note that email marketing messages include an opt-out mechanism within the message itself (e.g. an unsubscribe link in the emails we send to you). Clicking on the link in an email will opt you out of further messages. You can also write to us by e-mail to request the opt-out from messages. We may also use social media tools to market our products and services. As social media and web analytics providers act as joint processors, there might be consent or opt-out requirements also on their side.
Dispute resolution
If you have questions or concerns about our use of your personal information, please feel free to contact us at . You may lodge a complaint to the supervisory authority, the Estonian Data Protection Inspectorate
This Privacy Notice was updated in October 2021.