Who decides why and how we process your personal data?
Staffnode Limited, located at Sachtouri 18, Limassol, 3032, Cyprus (Staffnode or we), determines why and how we process your personal data.
What information do we collect about you?
- Personal information: Information such as your name, job title, postal address, business address, telephone number, mobile number, fax number and email address.
- Payment data: Data necessary for us to process payments including bank account numbers and other relevant billing details, under the circumstances when payments are being made by us to our employees, suppliers, clients or candidates.
- Business details: Business information which we necessarily process as part of our instructions or projects we are involved in or otherwise provided by you voluntarily.
- Information specific to candidates: We may hold information on candidates such as:
- name, city of residence, contact details (including email address and telephone numbers), date of birth, nationality.
- details of your qualifications, skills, experience and employment history, your entitlement to work in the EU, information supplied by you during a screening process or an interview in response to the questions typically and reasonably asked during an interview, such as your reason for wishing to leave your current employer, your current level of remuneration and benefits, your desired salary, your notice period, specific companies or industries that you wish to avoid, your preferred working hours;
- personal data collected directly from candidates as well as from other available public sources to the extent relevant and permitted under the GDPR;
- personal data such as the vacancies advertised by us for which you had applied and the date of such an application, interviews scheduled with potential employers and the result of any such interviews, and a log of all contact made between you and us, which would include telephone conversations, text messages and emails.
- Aggregated data: We may also collect aggregated personal data and statistics for the purpose of monitoring website usage in order to help us develop our website and our services.
When do we collect your personal data?
We may collect personal data about you in various cases, such as for example:
- When a client engages us to provide our services and you hold an office or an interest in or have certain relationships with that client; or
- When you or your organisation, such as a supplier, provide services to us, or otherwise offer to do so.
- When you or your organisation seek our services – i.e. to provide assistance in finding a suitable employee or a suitable employment opportunity;
- When you or your organisation make an enquiry through our website, in person, over email or over the telephone;
- When you attend an event we may organise, or sign up to receive communications from us;
- We may collect information about you from third parties in certain cases, such as references from former employers should a potential employer so require. This usually only occurs when a job offer has been made or is likely to be made. We will obtain such a reference only from a contact person supplied by you, and always with your consent.
What purpose do we collect and retain your information for?
- Staffnode Limited collects and retains your personal data in our capacity as a recruitment business.
- The personal data that we collect from you is integral to the process of recruitment, namely introducing you as a potential candidate to clients who are seeking employees for vacancies in their company, or communicating with clients in relation to such employees.
- Your personal data and the historic information that we retain on your record enable us to offer you an accurate and relevant service.
- We may utilise statistical data, such as information about qualifications and job sectors to monitor recruitment statistics, but such statistics would not contain identifiable information about any individuals.
What is our basis for collecting and retaining your information?
Depending on which of the above Permitted Purposes we use your personal data for, we may process your personal data on one or more of the following legal grounds:
- Because processing is necessary for the performance of a client instruction or other contract with you or your organisation or a Third Party Entity;
- To comply with our legal obligations (e.g. to keep pension records or records for tax purposes);
- Because processing is necessary for purposes of our legitimate interest or those of any third party recipients that receive your personal data, provided that such interests are not overridden by your interests or fundamental rights and freedoms;
- We may also process your data based on your consent where you have expressly given that to us.
How do we keep your personal data safe?
We take appropriate technical and organisational measures to keep your personal data confidential and secure, in accordance with our internal policies and procedures regarding storage of, access to and disclosure of personal data. We may keep your personal data in our electronic systems, in the systems of our contractors, or in paper files.
What do we do with your personal data?
- We use personal data in the first instance to communicate with you in relation to our business, either in relation to sourcing a suitable employee or employment position, or otherwise for the purposes of you providing services to us.
- In relation to candidates, we may assess data about you against vacancies which we believe may be suitable. This process is not done by an automated system since we do not undertake automated decision making.
- Where you apply through us or provide us with your CV for a specific vacancy, we may contact you to inform you of other opportunities which may be of interest to you. We will not in any event share your personal data with any person outside Staffnode Limited in relation to such other opportunities without first obtaining your express consent. You can at any time contact us to ask that we stop doing so by contacting us on email@example.com
- We will use your contact details to contact you by telephone call, text message or email about vacancies we believe you may be interested in.
Who do we share your personal data with?
- Personal data of candidates and clients, or individuals who have a relationship with our clients, is available and accessible to the recruitment consultants, administrators and IT staff employed by Staffnode, exclusively for the purposes of the recruitment procedure.
- We will share the CVs of candidates with potential employers only with the candidate’s explicit consent, and at first without any information which allows you to be identified, such as your name, address, telephone numbers or email address.
- Only when a potential employer wishes to meet with you in an interview and you have agreed that you wish to meet with potential employer, will we disclose your name to the potential employer.
Further persons/bodies we share your personal data with:
Where appropriate we may share your personal data, in various ways and for various reasons, with the following categories of people:
- Individuals and organizations who hold information related to your reference or application to work with us, such as current, past or prospective employers, educators and examining bodies and employment and recruitment agencies;
- Tax, audit, or other authorities, when we believe in good faith that the law or other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated litigation);
- Third party service providers who perform functions on our behalf (including external consultants, business associates and professional advisers such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems);
- Third party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place;
- Marketing technology platforms and suppliers;
- In the case of Candidates and our Candidates' and prospective members of Staff's referees: third parties who we have retained to provide services such as reference, qualification and criminal convictions checks, to the extent that these checks are appropriate and in accordance with local laws;
- If Staffnode Limited merges with or is acquired by another business or company in the future, (or is in meaningful discussions about such a possibility) we may share your personal data with the (prospective) new owners of the business or company.
How long do we keep personal data for?
- We retain personal data only for as long as we need it to fulfil the purposes for which it was originally collected and where you are happy for us to do so.
- The criteria we use to determine whether we should retain your personal data includes:
- the nature of the personal data;
- its perceived accuracy;
- our legal obligations;
- whether an interview or placement has been arranged; and
- our recruitment expertise and knowledge of the industry by country, sector and job role.
- Specifically in relation to candidate data, due to the nature of finding and continuing in employment, in our experience a candidate will typically apply for various vacancies as they become available over a period of time, and we continue to keep a candidate’s data in an active status, available to be taken into consideration for vacancies as they become available. We may reach out to candidates on our database after an initial inquiry, to inform such candidates of similar or other positions which may be of interest. Therefore, your personal data is retained until you wish for us to put your record into an inactive status on our database. We run routine data checks to deactivate records that we no longer have a reason to maintain.
- We may archive part or all your personal data or retain it on our financial systems only, deleting all or part of it from our main Customer Relationship Manager (CRM) system. We may pseudonymise parts of your data, particularly following a request for erasure of your data, to ensure that we do not re-enter your personal data on to our database, unless requested to do so.
Your Data Status
It is important for Staffnode Limited to correctly understand any requests you make regarding your data on our database. To avoid any confusion or misunderstanding, please take note of the following terms used in relation to the status of your data:
- Active / Activated
- Your record is in an active status.
- We will communicate with you by email, telephone call or text message regarding vacancies for which you had applied.
- We continue to consider your profile and CV also for any other current or future vacancies.
- If such a job opportunity might come up, we will contact you by an email, telephone call or text message to let you know.
- We will never submit your CV to a client unless you give us permission to do so.
- In-active / Deactivated
- Your record in is an in-active status.
- Your data is invisible when CVs are considered for vacancies and your CV will therefore not be considered for any vacancies and we will not contact you with any job opportunities.
- All your personal data remains on our records should you contact us in the future to make use of our service again.
- In keeping with the GDPR we will occasionally assess your record to decide whether to continue to store your data. We will contact you by email, telephone call or text message for your consent before taking any action such as erasing your data.
- You have invoked your right for your data to be erased from our records.
- We will erase all your personal data, except if it is required by law for us to keep it.
- We will have 30 days in which to comply with your request to erase.
- Please note that to have your record erased like this would mean that, should you decide in the future to make use of our service again, we will have no record at all of any vacancies for which you had previously applied, or any companies with whom you previously had interviews, any of your job search preferences, and so on.
If you wish to make any changes regarding the status of your data on the Staffnode Limited database, please contact us on firstname.lastname@example.org
What are your rights?
Subject to certain conditions under applicable legislation, you have the right to:
- request a copy of the personal data which we hold about you;
- have any inaccurate data we hold about you corrected;
- object to or restrict our use of your personal data;
- request that we erase your personal data;
- submit a complaint if you have concerns about the way in which we are handling your data.
To do any of the above, please contact us at email@example.com. To enable us to process your request, we may require that you provide us with proof of your identity, such as by providing us with a copy of a valid form of identification – this is to ensure that we appropriately protect the personal data we hold from unauthorised access requests and comply with our security obligations. In relation to complaints, we will promptly respond to your requests and complaints.
Equal opportunities monitoring and other sensitive personal data
We are committed to ensuring that our recruitment processes are aligned with our approach to equal opportunities. Some of the data we may in appropriate circumstances collect about you comes under the umbrella of “diversity information". This could be information about your ethnic background, gender, disability, age, sexual orientation, religion or other similar beliefs, and/or social-economic background. Where appropriate and in accordance with the laws of Cyprus & Malta, we'll use this information on an anonymized basis to monitor our compliance with equal opportunities. We may also disclose this (suitably anonymized where relevant) data to Clients where this is contractually required or the Client specifically requests such information to enable them to comply with their own employment processes.
This information is what is called ‘sensitive’ personal information and slightly stricter data protection rules apply to it. We therefore need to obtain your explicit consent before we can use it. We'll ask for your consent by offering you an opt-in. This means that you have to explicitly and clearly tell us that you agree to us collecting and using this information.
People whose data we receive from candidates and staff, such as referees and emergency contacts:
We use referees’ personal data to help our Candidates to find employment which is suited to them. If we are able to verify their details and qualifications, we can make sure that they are well matched with prospective employers. We may also use referees' personal data to contact them in relation to recruitment activities that may be of interest to them. We use the personal details of a Candidates or Staff member's emergency contacts in the case of an accident or emergency affecting that Candidates or member of Staff.
Subject to any applicable laws in Cyprus & Malta and requirements, we will not, as a matter of course, seek your consent when sending marketing materials such as our Salary Survey to a corporate postal or email address.
If you are not happy about this, you have the right to opt out of receiving marketing materials from us and can find out more about how to do so contact us at firstname.lastname@example.org
Our legal basis for processing your data
Article 6(1)(f) of the GDPR is the one that is relevant here – it says that we can process your data where it “is necessary for the purposes of the legitimate interests pursued by [us] or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of [you] which require protection of personal data."
We don't think that any of the following activities prejudice individuals in any way – in fact, they help us to offer you a more tailored, efficient service. However, you do have the right to object to us processing your personal data on this basis. If you would like to know more about how to do so, please contact us at email@example.com
What's a cookie?
A “cookie" is a piece of information that is stored on your computer's hard drive and which records your navigation of a website so that, when you revisit that website, it can present tailored options based on the information stored about your last visit. Cookies can also be used to analyse traffic and for advertising and marketing purposes.
Cookies are used by nearly all websites and do not harm your system. If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings. We do not use your cookies for any purpose whatsoever.
How to contact your local supervisory authority
Country in which you use Staffnode Limited services or supply Staffnode Limited with services: Cyprus or Malta
Details of your local supervisory authority: The Information Commissioner's Office. You can contact them in the following ways:
Office of the Commissioner
For Personal Data Protection
1, Iasonos Street, 1082 Nicosia
Tel: 22-818456, Fax: 22-304565
Information and Data Protection Commissioner
Level 2, Airways House
Sliema SLM 1549
+356 2328 7100
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