DATA PROTECTION POLICY

Data protection is a priority for Profile Group.

For this reason, we want to make sure that you understand the type of data we treat, how and why we gather it, who we share it with, how long we store it, your rights, and how we protect it.

We have done our best to be as clear as possible in this document. However, it is possible that you are not familiar with certain terms. With that in mind, please do not hesitate to contact us if you have any questions.

1. WHAT TYPE OF DATA DO WE DEAL WITH?

We gather and process the data needed for the purposes outlined below.

More specifically, this includes the following types of data:

1. Personal ID information, such as names and addresses;
2. Electronic ID information, such as email addresses, mobile phone numbers and cookies;
3. Personal details such as age, sex, date of birth, place of birth, marital status, nationality and language;
4. Immigration status, such as the existence of a valid work permit for Belgium;
5. Psychological descriptions, such as personality, thanks to a psychometric test;
6. Academic career;
7. Professional qualifications, including professional training and possession of a driving licence;
8. Professional experience;
9. Affiliation/involvement with professional organisations;
10. Publications;
11. Information about current employment;
12. Information about recruitment;
13. Information about the end of employment;
14. Career details;
15. Information about how work is organised;
16. Salary details;
17. Appraisal;
18. In-job training;
19. Images;
20. Security information, such as passwords;
21. Information about leisure activities and interests.

Profile Group has also decided not to ask applicants for so-called sensitive information as defined by privacy regulations, apart from specifically when required by law or authorised by a particular circumstance. This is why you are generally asked not to provide this type of information, in other words, details revealing your racial or ethnic background, political opinions, religious or philosophical beliefs or membership of a union, as well as genetic or biometric details, information about your health, or information about your sexual activities or orientation, criminal convictions and offences when you fill in a form or complete a profile on Profile Group’s website, or interact in any way whatsoever with Profile Group.

2. HOW IS YOUR DATA COLLECTED?

Your personal information is collected in different ways.

a. Sending an application

Profile Group processes all the information provided by applicants when they fill in a registration form, either in response to a job vacancy, or when submitting an ad hoc application.

To complete these registration forms, applicants are invited to provide their contact details (surname, first name, telephone number and email address), as well as send a CV.

Having sent this data to Profile Group, applicants may, if they want, sign in to their personal, secure profile to change the information already provided and/or add to their profile by providing other details needed for the purposes described below: professional experience, training, languages spoken, preferred salary, photo etc..

b. Telephone and/or video interview

If an applicant chooses to provide the abovementioned information via a registration form and/or an ad hoc application, he/she explicitly agrees that Profile Group will use these details to contact him/her by telephone and/or email to receive more information about the services offered by Profile Group and, if he/she would like, to provide more information about his/her professional expectations.

c. Recruitment interview

If an applicant agrees to have an interview with Profile Group, he/she explicitly agrees that Profile Group can use his/her personal data to invite him/her to this interview and to assess him/her during this interview, including with psychometric tests, as well as to check the references and information provided. The above implies, among other things, that Profile Group will, if applicable, get in touch with the businesses and/or organisations mentioned by the applicant.

3. WHY DO WE PROCESS YOUR INFORMATION?

This information is processed by Profile Group to offer its services relating to recruitment and career management, to analyse and manage applications, and to improve its services and communication tools on a continuous basis. This involves:

• Gathering data via a registration form or an ad hoc application, the applicant’s personal profile, a telephone or even video interview, a face-to-face interview, psychometric tests, personality questionnaires etc.;
• Saving this data;
• Viewing this data;
• Checking and analysing this data;
• Communicating this data to third parties – in other words, predominantly clients of Profile Group who have asked the latter to provide one or more job advertisements – in order to pass on applications for an existing job vacancy(ies) in which the applicants have expressed an interest;
• Producing statistics, market research etc. in order to improve the experience of users of Profile Group’s services;
• Proactive communication to applicants who have explicitly made this choice of new job vacancies, and so not only for the existing job vacancy(ies) in which the applicants have expressed an interest, that might meet the professional expectations expressed by the applicants when they filled in a registration form and/or their profile.

It is because you have given your permission for this that Profile Group can process this personal information. Profile Group needs to collect this data to fulfil the purposes mentioned above. In fact, if this data is not collected, Profile Group would not be able, for example, to manage incoming applications correctly. That having been said, as this data processing is based solely on your consent, you are free to withdraw your consent at any time, in writing, without detracting from the legality of any data processing carried out before this consent is withdrawn.

4. WHO DO WE SHARE THIS DATA WITH?

Applicants’ data is only shared with:

• The applicants themselves;
• Members of staff working for Profile Group;
• Clients who have appointed Profile Group for its services, and for the sole purposes of recruitment entrusted to Profile Group;
• Profile Group’s subcontractors (for example, hosting company) insofar as it is necessary for the fulfilment of their roles or if required by law;
• The public authorities in circumstances where it is required by law.

5. HOW LONG DO WE KEEP YOUR DATA?

When an applicant fills in a registration form, submits an ad hoc application and/or adds to his/her personal profile on a Profile Group website, he/she explicitly accepts that his/her data will be kept in a database managed by Profile Group.

The data is kept as long as is necessary to accomplish the goals for which the data was acquired and in accordance with our legitimate interests as a data controller. However, in exceptional circumstances, the data may be kept longer if a legal and administrative monitoring demands that it is kept for longer.

The applicants in question will be informed by email +/- 1 month before their data is due to be deleted. Applicants may then, if they want, explicitly ask Profile Group to keep their data longer, in order to allow Profile Group to contact them proactively to suggest a job vacancy that might be of interest to them. In this case, the same procedure will be applied before the end of this new period, and so on.

6. WHAT ARE YOUR RIGHTS?

By sending a dated, signed request (including electronically) by email to dpo@profilegroup.com or by standard post along with proof of ID, any applicant can get a free copy (including electronically) of his/her personal information from Profile Group, as well as being able to correct or delete incorrect or incomplete information, or limit how it is used, within 1 month of receipt of the request. All applicants also have the right to transfer their data. After this deadline of 1 month, if there is no response or reaction from Profile Group, the applicant can assume that his/her request has been rejected. Furthermore, applicants may exercise some of these rights by signing in to their personal profile.

If Profile Group has passed on targeted data to other people, for example clients who have appointed Profile Group for its services, Profile Group will take all reasonable measures to inform these people of the request to delete any link to this data or any copy or reproduction of it.

If an applicant would like to make a complaint, he/she can do so by contacting the Autorité de Protection des Données // Privacy Commission, rue de la presse, 35, 1000 Brussels, www.privacycommission.be

7. HOW DO WE PROTECT YOUR DATA?

Applicants’ personal information is processed in Belgium and stored in a data centre in the Netherlands.

Profile Group takes appropriate technical and organisational measures to protect applicants’ data, in particular against unauthorised handling and access, and will make every effort to make sure that these measures are as up-to-date as possible, given the state of knowledge, costs for implementation and the nature, scope, context and purposes of the processing as well as the risks for the applicants.

If Profile Group passes on data to clients who have appointed it, it undertakes to take all reasonable measures to safeguard the security and confidentiality of the data, in accordance with the applicable laws.

Legislation regarding privacy can sometimes be adapted and improved, so this document is also subject to change. Profile Group therefore recommends that you consult it regularly if you visit its websites, and will make sure that any changes, modifications and adaptations are clearly marked.