1 – INTRODUCTION

This document serves to:

• Establish the rules concerning the personal information protection processed by EGOR Group as a result of its activity; and
• Inform the data subjects and the community on the personal data processing in connection with the EGOR Group activity, in a simple, clear and permanently accessible manner.

The Privacy Policy contains the following information:

• The identity and contacts of EGOR entity and other entity categories that may assume together with EGOR responsibility for personal information processing;
• The EGOR Group Data Protection Officer contacts;
• The purposes of personal information processing;
• The legal bases for the processing;
• The categories of the recipients with whom the personal information is shared;
• In case personal data is transferred to a country that is not a member state of the European Union or of the European Economic Area, information on the guarantees offered by such state for the protection of the personal information transferred;
• The personal data storage period or, if that is not possible, the criteria used to establish such period;
• In case the data processing is based on EGOR Group legitimate interests, information on such interests;
• In case the data processing is based on consent, the existence of the right to withdraw it without compromising the legality of the processing carried out based on the consent previously provided;
• The rights of the data subjects nd the means to exercise them in relation to the EGOR Group entity that acts as data controller;
• The right to submit a complaint to the control authority;
• The voluntary or compulsory nature of the communication of the personal data and the consequences of non-communication;
• The existence of automated decision, including profile definition, where applicable;
• In case the personal data is collected by a third person, EGOR Group provides information on the origin and categories of the data collected to the data subjects.

To obtain additional information or to clarify doubts on EGOR Group Privacy and Personal Data Processing Policy, the questions should be sent to its headquarters, whose addressed is indicated under “Presentation of EGOR Group” in this Privacy Policy.

The Data Controller may be contacted using the following email address: This email address is being protected from spambots. You need JavaScript enabled to view it.

Presentation of EGOR Group

EGOR Group is composed of a set of companies, legally autonomous, with a common Vision, Mission, Values and Quality and Privacy Policies.

The Privacy Policy is a public statement, shared through the available communication supports and applicable to all EGOR Group entities – Egor Portugal, Egor Empresa de Trabalho Temporário, Egor Outsourcing, Egor Consulting, RH Portugal, RH Norte, Medaute, Cross Jobs, Egor Alchemy, Egor People & Change e Egorgest SGPS, S.A., with headquarters at Avenida José Malhoa, 16F, 4.º piso, in Lisbon.

The Privacy Policy applies to the information collected by the following means:

• Egor institutional site;
• Job advertisements or unrequested applications;
• Social Media (Facebook, LinkedIn);
• Personally, by SMS, email, letter or other mean of communication.

The EGOR Group companies strive for the protection and guarantee of the security of the information they may access to, whether personal data, strategic, financial information, or other type of information, aiming at the provision of a service or participation in projects.

Any of the EGOR Group entities may act as Data Controller.

However, EGOR Group partners or clients may act, together with EGOR Group entity, data co-controllers.

This may be the case, for example, of the partners and clients that select the human resources in connection with the recruitment processes, the user of temporary work and the beneficiary of service provision. In this case, each of the entities shall provide the data subjects with the information on the data processing carried out under its respective responsibility.

In case of joint responsibility for the data processing, the EGOR Group entity and its clients or partners shall conclude a data processing agreement.

The agreement concluded between the EGOR entity and its partners shall appropriately reflect the rights and duties of the parties as regards the exercise of the rights by the data subjects and the information duties provided for in the applicable legislation. Irrespective of the terms of the agreement, the possibility of exercising the rights in relation to any of the parties is guaranteed to the data subject. The core content of such agreement shall be made available to the data subjects upon request.

The personal information of the data subjects may be processed by entities sub-contracted by EGOR Group. In this case, agreements on the personal data processing shall be concluded in accordance with the applicable legislation, to guarantee that data processing principles and legal rules applicable to processors are met. EGOR Group ensured that these entities are provided with the technical measures guaranteeing compliance with the legislation in force on the information security protection.

2. USE OF PERSONAL DATA

EGOR processes personal information for the following categories of data subjects:

• Job applicants;
• Workers signing an employment contract with any of the EGOR Group entities;
• Trainees participating in training programs in connection with contracts for the provision of Training services to clients;
• Trainees signing training contracts with any of the EGOR Group entities.

The Privacy Policy contains specific information on personal data processing in relation to the aforementioned personal data activities.

Data subjects have the right to submit a complaint to a control authority concerning the data processing carried out by any of the EGOR Group entities.

In Portugal, it falls to the National Data Protection Commission to receive and handle the complaints submitted by data subjects.

3. INFORMATION ON THE PROCESSING OF DATA COLLECTED FROM THE DATA SUBJECT

3.1. JOB APPLICANTS

Purpose and legal base

• Purpose: Registration and conservation of the application to the available jobs by the GOR Group database.

In order to ensure EGOR Group is able to process the personal information of the job applicant, their consent is required. Consent requires the previous reading of this Privacy Policy and must be unequivocal, free and provided in writing or through the validation of a digital option.

The data subjects may, at any time, withdraw the consent provided for the data processing, without compromising the legality of the previously consented processing.

In case of job applications, EGOR Group may consider that the reason for personal data processing is the carrying out by it of pre-contractual proceedings at the request of the data subject.

In this case, EGOR Group considers that the submission of the applications by the data subjects on an online recruitment page constitutes a request by the data subjects for EGOR Group to carry out proceedings with a view to the potential conclusion of an employment contract.

For recruitment projects, Egor shall request data such as academic qualifications and work experience or other information relevant for the ongoing opportunities, and may, in certain situations and as it may be determined by the legislation in force, require complementary data, such as data concerning any convictions or infringements.

Personal data of the applicant, including the Resume made available through the Egor platform at the time of application, will be sent to Egor clients or potential clients who maintain active recruitment processes compatible with the applicant's professional experience.
If the applicant has a profile on a public platform for strictly professional purposes (for example Linkedin), the information provided there may be considered by Egor and forwarded to Egor clients or potential clients as additional information to that provided by the applicant.

In case the applicants are not selected from the recruitment process which they applied to, EGOR Group shall continue to look for employment opportunities compatible with the qualifications and work experience of the applicants, in accordance with a legitimate interest of the EGOR Group.

The recruitment of human resources for the placement in available jobs in structures of its clients or partners, constitutes a fundamental part of EGOR Group commercial activity.

The experience in the provision of services for the placement of human resources and the daily contact with applicants lead EGOR Group to the conclusion that a clear majority of the job applicants seeks for the placement in a job compatible with their qualifications – and are not exclusively interested in the job to which they have applied.

The possibility of conserving the application of the data subjects for new employment opportunities without the data subjects being forced to provide a new consent and to submit a new application corresponds to a legitimate interest of EGOR Group, both from the perspective of the carrying out of its activity and from the administrative perspective.

In any case, and at any moment, the data subjects may oppose to their application being considered in future recruitment processes compatible with their work experience.

EGOR Group shall not require any conditions for the exercise of the right of opposition other than the requirement for the data subjects to do so in writing, in order to allow EGOR Group to confirm that the right is exercised by the legitimate data subject.

In case the data subjects exercise the right of opposition, EGOR Group ensures that the respective processing is ceased, and the data are deleted.

After the deletion of the data, the data subjects may, at any time enrol again on the platform for the submission of applications; however, in that case, they must, for that purpose, register again.

Categories of recipients of personal data

• EGOR Group workers who are authorised to process personal data;

• EGOR Group clients or partners that keep active the recruitment processes for workplaces compatible with the academic qualifications and/or works experience of the applicants;

• Companies sub-contracted by EGOR Group ensuring a processing that guarantees security and compliance with the legislation in force on personal data protection.

Transfer of personal data to countries outside the European Union and the European Economic Area

• The EGOR Group platform designed for the submission of applications is called Bullhorn and is owned by Bullhorn Group, Inc.

• The Bullhorn platform is domiciled in the United States of America

• On submission of the application, the personal data provided by the data subjects shall be transferred to the Bullhorn Group, Inc. databases, in the United States of America

• The transfer of personal data to the United States of America is carried out in accordance with the Implementing Decision (EU) 2016/1250 of the Commission, of 12.07.2016, on the Adequacy of the Protection Provided by the EU-US Privacy Shield, pursuant to Directive 95/46/CE of the European Parliament and the Council, according to which an adequate protection level of the personal data is guaranteed when it is transferred from the Union to organisations in the United States figuring in the “list of the Privacy Shield”, as it is the case of Bullhorn Group, Inc.

Storage period

• The personal data of the applicants shall be stored for a maximum period of 5 years, during which the application may be considered for other employment opportunities compatible with the work experience and academic qualifications of the applicants.

• During this period, applicants may be contacted in connection with job opportunities compatible with their academic qualifications and work experience.

• In case the data subjects request the deletion of their data and the EGOR Group has a legal obligation of conserving them or, if they are required in connection with legal proceedings, the limitation of the processing shall be guaranteed, and the data shall be deleted after the legal deadline for its retention or after the legal decision has become final.

Rights of data subjects and means of exercising them

• The following rights are recognised to the data subjects:
  • Information on the personal data concerning them o Access o Rectification
  • Deletion of the data, provided that there are no legal reasons to conserve them (see the applicable contents of the Privacy Policy, in the part related with the storage period)
  • Portability of the personal data, in the cases where the processing is carried out by automated means and based on consent or on a contract
  • Limitation to processing o Opposition to processing
  • Submission of a complaint to the control authority, that, in Portugal, is the National Data Protection Commission o If applicable, the right of information on automated decisions and profiles that may be created, as well as on the terms for the exercise of the right of opposition

• In case the data processing is based on legitimate interests of EGOR Group, the data subjects shall have the right to be informed on such interests
• In case the data processing is based on consent, the existence of the right to withdraw it without compromising the legality of the processing carried out based on the consent previously provided
• The data subjects may exercise their rights by sending a request to EGOR Group, whose contacts are provided in point 6.
• In order to guarantee the security of the process, the data subjects shall be required to prove their identity so that the confidentiality of the personal information is ensured.

Communication of the information by the data subjects

• The communication of the personal data for purposes of the recruitment process is voluntary. However, the personal data requested by EGOR Group are required for the recruitment process(es) to which the data subjects have applied, and therefore omission or refusal to communicate such data may prevent the full carrying out of the process and the subsequent potential selection of the application submitted with a view to the conclusion of an employment contract.

Automated decisions

• In some processes of Recruitment and Selection, Psychological Evaluations, Assessments or other services the psychological evaluation of the applicants may be required. The evaluation consists of tests aiming at analysing cognitive and/or behavioural characteristics of the applicants which are considered necessary and adequate to the job they have applied to or to the nature of the service provided;

• Tests are carried out making recourse to automated means but the decision on the behavioural and cognitive adequacy of the applicants is not, in any case, taken automatically;

• EGOR Group ensures in all cases the human involvement in the decision on the continuation of the evaluation process of the professional in question irrespective of the test result;

• Before any test making recourse to automated mean, EGOR Group shall provide information on the underlying logic of the test, as well as on its importance within the recruitment process, or others involving psychological evaluation and the foreseeable consequences of such processing for the data subjects;

• The carrying out of the test constitutes a legitimate interest, except where EGOR Group considers that the tests are carried out in connection with pre-contractual proceedings at the request of the data subjects;

EGOR Group has implemented automatic technical mechanisms for preservation, elimination and control and the daily management of security copies and retention of information on external servers that guarantee security, as well as the minimisation of the use and conservation of personal data taking into consideration their purposes.

It also implemented administrative and organisational measures, in order to enable its employees or sub-contracted entities to process the personal data in such a way that the data processing principles are respected, as is the case of legality, limitation of purposes and conservation, minimisation, integrity, confidentiality and accuracy of the data.

EGOR Group strives for strict respect of the respective Code of Ethics, which includes the adequate practices aimed at implementing the values defended by the Group.

It has thus implemented an Acceptable Use Policy, aimed at applying and implementing the Code of Ethics in force in the company, and has ensured the full knowledge of the best practices in force by all human resources authorised to access and process personal data.

All the EGOR Group human resources are bound by confidentiality duties and are instructed to adopt a preventive attitude in relation to personal data they may become aware of due to the carrying out of their functions.

In order for the principle of accuracy to be understood, EGOR Group assumes that the personal data provided by the data subjects are true and accurate, and undertakes to change or rectify them when requested by the data subjects to do so.

6. CONTACTS OF EGOR GROUP AND OF THE DATA PROTECTION OFFICER

In case you have any doubt, question or suggestion to submit about this Privacy Policy, please contact EGOR Group or the Group Data Protection Officer.

• In person or by mail to the following address:

• Email