3.1. CANDIDATES FOR JOB OFFERS
Purpose and legal basis
- Purpose: Registration and conservation in the Egor Group databases of applications for available job offers.
For the Egor Group to process the personal information of candidates for job offers, their consent is necessary. Consent is conditional on prior reading of this Privacy Policy and must be unambiguous, free, and provided in writing or by validating an option digitally.
At any time, the holder may cancel the consent granted for the processing of their data, without this compromising the lawfulness of the previously consented processing.
In some cases of applying for a job offer, the Egor Group may understand that the processing of personal data is based on the company carrying out pre-contractual measures at the request of the data subject.
In these cases, it is considered that the submission of an application by the data subject on an online recruitment page constitutes a request, by the data subject, that the Egor Group take steps aiming to the possible conclusion of an employment contract.
For recruitment projects, Egor will request data such as academic qualifications and professional experience or other information relevant to open opportunities, and may, in certain situations, and to the extent current legislation determines, require additional data, such as data relating to possible criminal convictions or infractions.
The candidate’s personal data, including the CV made available through the Egor platform at the time of application, will be sent to Egor’s clients or potential clients, who maintain active recruitment processes compatible with the candidate’s professional experience. If the candidate has a profile on a public platform for strictly professional purposes (for example, LinkedIn), the information disclosed there may be considered by Egor and sent to Egor’s clients or potential clients, as complementary information to that made available by the candidate.
If the candidate is not selected within the scope of the recruitment process to which he/she has applied, the Egor Group will continue to look for employment opportunities compatible with the candidate’s qualifications and professional experience, under the legitimate interest of the Egor Group.
The recruitment of human resources for placement in available jobs in the structures of its clients or partners constitutes a fundamental part of the Egor Group’s commercial activity.
Experience in providing human resources placement services and daily contact with candidates leads the Egor Group to conclude that the significant majority of candidates for job offers seek placement in a job compatible with their qualifications – and not exclusively to the job offer for which they applied.
The possibility of keeping the data subject’s application for new job opportunities without the data subject necessarily being obliged to provide new consent and submit a new application corresponds to a legitimate interest of the Egor Group, both from the point of view of pursuing its activity and from an administrative point of view.
In any case, and at any time, the data subject may object to their candidacy being considered in future recruitment processes compatible with their professional experience.
The Egor Group will not require any conditions for the exercise of the right to object, other than the need for the holder to exercise this right in writing, so that the Egor Group can prove the exercise of the right by the legitimate holder of the personal data.
If the data subject exercises the right to object, the Egor Group guarantees the cessation of the respective processing and the deletion of the data.
Once the data has been deleted, the holder may, at any time, re-register on the application submission platform, having to register again for this purpose.
Recipient categories
- Egor Group employees authorized to process personal data;
- Customers or partner entities of the Egor Group that maintain active recruitment processes for jobs compatible with the candidate’s academic training and/or professional experience;
- Companies subcontracted by the Egor Group which ensure a processing that offers guarantees of security and compliance with current legislation regarding the protection of personal data
Transfers of personal data to countries outside the European Union or the European Economic Area.
- The Egor Group platform for submitting applications is called Bullhorn and is owned by the Bullhorn Group, Inc.
- The Bullhorn platform is domiciled in the United States of America.
- Upon submission of the application, the personal data provided by the holder will be transferred to the databases of the Bullhorn, Inc. group, in the United States of America.
- The transfer of personal data to the United States of America is carried out under the Commission Implementing Decision (EU) 2016/1250 of 12.07.2016 on the level of protection ensured by the EU-US Privacy Shield, based on the Directive 95/46/EC of the European Parliament and of the Council, under which an adequate level of protection is guaranteed to personal data whenever they are transferred from the Union to organizations in the United States that are on the “Data Protection Shield list”. Privacy”, as is the case with the Bullhorn Group, Inc.
Conservation period
- Candidates’ personal data will be kept for a maximum period of 5 years, during which the application may be considered for other job opportunities compatible with the candidate’s professional and academic experience.
- During this period, the candidate may be contacted regarding job offers compatible with their academic qualifications and/or professional experience.
- If the holder requests the deletion of their data and imposes a legal obligation on the Egor Group to preserve them or, if they are necessary within the scope of a legal process, the limitation of processing is guaranteed, and the deletion will occur once the legal deadline for retaining them or after the court decision transit period has elapsed.
Rights of data subjects and form of exercise
- The data subject has the following rights:
- Information about the processing of personal data concerning you;
- Access or Rectification;
- Deletion of data, as long as there are no valid grounds for its conservation (see the applicable Privacy Policy points, in the segment relating to the retention period);
- Portability of personal data, in cases where processing is carried out by automated means and is based on consent or a contract;
- Limitation to treatment or Opposition to treatment;
- Submitting a complaint to the supervisory authority, which, in Portugal, is the National Data Protection Commission;
- If applicable, the right to information about automated decisions and profiles that may be created, as well as about the terms of exercising the right to object;
- If the processing of data is based on the legitimate interests of the Egor Group, the holder will have the right to be informed about these interests;
- If data processing is based on consent, the existence of the right to withdraw it without compromising the lawfulness of the processing carried out based on previously given consent;
- The data subject may exercise his or her rights upon request to the Egor Group, whose contact details can be found in point 6.
- To ensure security in the process, proof of identity of the holder is required, to ensure the confidentiality of personal information.
Communication of data by the holder
- The communication of personal data for the purposes of the recruitment process is voluntary. However, the personal data requested by the Egor Group are necessary for the recruitment process(es) to which the holder applied, so the omission or refusal to communicate such data may impede their full continuation and consequently the eventual selection of the application presented, to conclude an employment contract.
Automated decisions
- In some Recruitment and Selection processes, Psychological Assessment, Assessments or other services, a psychological assessment of the candidate may be necessary. The assessment consists of carrying out tests aimed at perceiving the candidate’s cognitive and/or behavioral characteristics that are necessary and appropriate for the job position for which the holder has applied, or the nature of the service being provided;
- The tests are carried out using automated means but, under no circumstances, is the decision on the candidate’s behavioral and cognitive suitability made in an automated way;
- The Egor Group guarantees in all cases human involvement in the decision on whether to continue the evaluation process of the professional in question, regardless of the test result;
- Before carrying out any test using automated means, the Egor Group will provide information on the logic behind the test, as well as its importance within the scope of the recruitment process, or others involving psychological assessment, and the expected consequences of such processing for the data subject;
- Carrying out the test constitutes a legitimate interest, except in cases where the Egor Group considers that carrying out the test falls within the scope of pre-contractual measures at the request of the data subject;
- The Egor Group guarantees the holder’s right to object with regard to the definition of profiles, for reasons related to their particular situation;
- In addition to the right to object, the Egor Group guarantees the rights of access, rectification and deletion of data, as well as the right to limit processing;
- In cases where Egor acts as Subcontractor, the controller will provide the information inherent to data processing.
3.2. WORKERS
Purpose and legal basis
- Conclusion, execution and administrative management of the employment contract concluded with one of the Egor Group entities;
- Compliance with legal obligations of one of the Egor Group entities, as an employer.
Recipient categories
- Egor Group employees authorized to process personal data;
- Customers or partner entities of the Egor Group, which may be beneficiaries of services provided or companies using temporary work, in whose facilities the holders carry out their functions. The sharing of personal data with these entities is exclusively aimed at identifying you within the structure of these entities or fulfilling legally stipulated legal obligations.
- In specific cases where the provision of work implies or assumes the sharing of other workers’ data that is processed in the client or partner’s facilities or systems, the latter will be considered responsible for the processing of this data and will ensure all legal obligations inherent to such status;
- Companies subcontracted by the Egor Group that ensure processing that offers guarantees of security and compliance with current legislation regarding the protection of personal data;
- Entities to which the employer is legally obliged to communicate the holder’s personal data, such as courts, the tax authority or police or inspection entities (Authority for Working Conditions and Foreigners and Borders Service);
- Entities to whom, to fulfil legal obligations, the employer communicates the holder’s personal data, such as for the purposes of contracting occupational medicine services and insurance companies, to guarantee the conclusion of a contract of occupational accident insurance.
Transfers of personal data to countries outside the European Union or the European Economic Area
Professional data may be transferred to countries that are not Member States of the European Union or the European Economic Area, with the data subject being duly informed if this occurs.
Conservation period
- Candidates’ personal data will be kept for a maximum period of 10 years, which is based on the obligation set out in Article 123, no. 4 of the Corporate Income Tax Code, which provides that books, accounting records and respective supporting documents must be kept in good order for a period of 10 years;
- If the holder requests the deletion of their data before the 10-year period has elapsed or if they are necessary within the scope of a legal process, the limitation of processing is guaranteed, and deletion will occur once the legal period for retaining the data has been completed. same or after the deadline for transiting the court decision.
Rights of data subjects
- See point 3.1. of this Privacy Policy, in the section Rights of data subjects
Communication of data by the holder
- The communication of personal data is necessary for the employment contract, as the holder’s personal data are essential to its conclusion, execution and management, as well as to the fulfillment of legal obligations arising therefrom on the part of the employer. Consequently, the omission or refusal to communicate such data will prevent the conclusion of an employment contract.
Automated decisions
- Within the scope of the employment contract, no decision based on personal data provided by the holder is automated.
3.3. TRAINEES
Purpose and legal basis
- Conclusion, execution and administrative management of the training contract signed with one of the Egor Group entities;
- Training of human resources on a subcontracted basis, as a training entity certified by the Directorate-General for Employment and Labor Relations (DGERT) which has legal obligations.
Recipient categories
- Egor Group employees authorized to process personal data;
- General Directorate of Employment and Labor Relations (DGERT), as the public entity responsible for certifying training entities;
- Customers or partner entities of the Egor Group: the sharing of personal data with these entities aims exclusively to identify the holders for training and evaluation purposes;
- Companies or trainers subcontracted by the Egor Group who ensure processing that offers guarantees of security and compliance with current legislation on the protection of personal data.
Transfers of personal data to countries outside the European Union or the European Economic Area
- Trainee data will not be transferred to countries that are not Member States of the European Union or the European Economic Area.
Conservation period
- The personal data of Trainees will be kept for the period necessary to allow audits to be carried out by DGERT;
- If the holder requests the deletion of their data before this period has elapsed or if they are necessary within the scope of a legal process, the limitation of processing is guaranteed, and deletion will occur once the legal period has been met during which it is still possible to carry out audits by the competent public entity (DGERT).
Rights of data subjects
- See point 3.1. of this Privacy Policy, in the section Rights of data subjects
Communication of data by the holder
- The communication of personal data is necessary for the training contract, as the holder’s personal data are essential to its conclusion, execution and management, as well as to the fulfillment of legal obligations to which the certified entity is subject, so the omission or refusal to communicate that data will prevent the conclusion of a training contract.
Automated decisions
- Within the scope of the provision of Training services, no decision based on personal data provided by the holder is automated.