PRIVACY

Protection of personal data under the General Data Protection Regulation (GDPR)

    • This policy (“Policy“) applies to personal data that Arthur Hunt Consulting Polska Sp. z o.o. (“Arthur Hunt“) conducting recruitment procedures for candidates for employees and associates.

The administrator of personal data will in each case:

Arthur Hunt Consulting Polska Sp. z o.o. with its registered office in Warsaw, office address: al. J. Ch. Szucha 16/17, 00-582 Warsaw, email: office@arthurhunt.pl, tel. +48 22 290 28 28

In this Policy, we inform you about the ways in which personal data is used, as well as the rights of individuals related to the collection and use of such data. If you have any questions or comments, please contact us at the email address above.

  • What does the privacy policy regulate?

This Policy applies to our collection and use of personal information submitted through paper personal questionnaires on forms used by Arthur Hunt, electronic forms on websites, or the submission of resumes (CVs) of candidates for employees or permanent associates, regardless of the legal basis of employment or cooperation relationship (“Candidates” or “you“) ).

  • What kind of personal data do we collect?
    • Mandatory Candidate Data

We collect from the Candidates the basic data indicated in Article 221 § 1 of the Labour Code, such as name(s) and surname, date of birth, education, employment history, as well as other personal data, when it is necessary to fulfil the employer’s obligation imposed by law. Providing this data by the Candidates is a statutory requirement (in the case of Candidates employed on the basis of an employment contract). The consequence of not providing data is the inability to establish employment.

Data on business activity

We also collect data on the business activity from Candidates for permanent associates who run their own business, such as the company, business address, correspondence addresses, numbers held in the relevant registers (e.g. NIP or REGON number) and bank account number.

Other data collected from Candidates

When you fill out paper personal questionnaires on forms used by Arthur Hunt, electronic forms on websites or submit resumes, you may also provide other data, such as your image captured in a photograph. Providing this data by the Candidates is completely voluntary, but it may contribute to a better understanding  of your candidacy by Arthur Hunt as well as the companies from the Arthur Hunt capital group.

Sensitive data

The personal data we process may also include special, particularly sensitive categories of data, such as information regarding the severity of your disability. They will be especially protected by Arthur Hunt. In particular, such data will not be made available to any unauthorized persons.

Contact

Arthur Hunt also collects information to contact you, such as your email address or phone number. In order to participate in the recruitment process, it is necessary to provide an e-mail address; providing a phone number can help to facilitate contact with you.

Data collected from other sources

Arthur Hunt may also collect personal data indirectly from cooperating entities, web portals enabling contact between employers and job candidates, or other persons (e.g. employees or associates  of Arthur Hunt in the case of recommending a Candidate), if there is an appropriate legal basis for doing so (e.g. you have consented to your application being sent to Arthur Hunt). By obtaining such information, Arthur Hunt will not unduly interfere with the Candidate’s privacy, will limit itself only to personal data from the professional area and will process such data only for purposes related to recruitment.

  • On what legal basis and for what purposes do we process personal data?
    • Legal basis for data processing

We only process personal data if:

  • processing is necessary for the fulfilment of contractual obligations towards you or, in accordance with your request, is necessary to take specific steps prior to entering into a contract (Article 6(1)(b) of the GDPR), including to carry out the recruitment process;
  • processing is necessary to comply with our legal obligations or when we are expressly required to do so by law, e.g. Article 221 of the Labour Code (Article 6(1)(c) of the GDPR);
  • we comply with a legal obligation incumbent on the co-controller, i.e. companies from the Arthur Hunt capital group in Austria, Romania, the Czech Republic and Hungary, the list of which with addresses can be found at arthur-hunt.com, as well as with our clients looking for employees (Article 6(1)(c) of the GDPR)
  • the processing is necessary for the purposes of the legitimate interests of Arthur Hunt or a third party and does not unduly affect your interests or fundamental rights and freedoms (Article 6(1)(f) of the GDPR). When processing personal data on this basis, we always try to strike a balance between our legitimate interest and your privacy;

Such “legitimate interests” are:

  • to allow Arthur Hunt to contact the Candidate;
  • to allow Arthur Hunt to verify the Candidate’s skills or qualifications using additional data voluntarily provided by the Candidate during the recruitment process;
  • establishing or pursuing civil law claims by Arthur Hunt as part of its business, as well as defending against such claims;
  • taking measures to maintain operational activities (e.g., Arthur Hunt workforce planning, budget planning, space planning, etc.);
  • in some cases, when we have obtained your prior consent (Article 6(1)(a) of the GDPR) – this applies to consent to the processing of data for the purposes of further recruitment.
  • in the case of securing information in the event of a legal need to demonstrate facts, which is our legitimate interest (basis under Article 6(1)(f) of the Regulation);
  • in the case of establishing, investigating or defending against claims, which is our legitimate interest (basis in Article 6(1)(f) of the Regulation);
  • for a specific purpose on the basis of your consent to the processing of your personal data for one or more purposes (basis under Article 6(1)(a) of the Regulation) – if you consent to the use of your data, the content of this consent will specify the specific purpose for which we will process this data. Please be advised that for the purposes indicated above, we will not perform profiling, i.e. automated analysis of your data and the development of predictions about preferences or future behaviour (profiling means, e.g. in the case of marketing profiling, determining which offer you may be most interested in based on your previous choices). In the event of a change in the decision regarding profiling, you will be informed about the above by supplementing this information and sending it to the e-mail address indicated by you.
    • Legal basis for processing sensitive data

Special categories of personal data may only be processed by Arthur Hunt in cases specified by law, i.e. where the processing is necessary for the performance of our employment, social security or social protection obligations – this applies to personal data including the degree of disability and related special rights.

Consent to the processing of data

If we process your personal data on the basis of consent, you can revoke it at any time as easily as you gave it. Failure to consent to the processing of data that you are not obliged to provide will not result in a refusal to establish a contractual relationship with the Candidate, and its withdrawal will not result in negative consequences for the Candidate.

Purpose of data processing

We always process your personal data for a specific purpose and only process the personal data that is necessary to achieve it. We process the personal data of the Candidates in order to:

  • undertaking recruitment activities, including contact with Candidates;
  • preparation of contracts concerning the employment of Candidates;
  • comply with any legal obligations imposed on Arthur Hunt in relation to Candidates;
  • use of data in other recruitments conducted by Arthur Hunt – if the Candidate gives consent.
  • Who has access to personal data and to whom it is transferred

We may transfer personal data to recipients and other third parties to fulfil the purposes listed in section 4.4 to the extent that they are necessary for them to perform the tasks we have instructed to do so, if we are required to do so by law or if we have another legal basis. The following may be considered recipients or other third parties:

  • entities processing personal data on behalf of Arthur Hunt, such as providers of IT tools and hosting services.

Such entities usually do not decide on their own how to process your personal data. Their processing of personal data takes place only to the extent that it is necessary for the operation of Arthur Hunt’  s business.Arthur Hunt controls the activities of such parties through appropriate contractual provisions to protect your privacy.

  • entities such as:
  • cooperating law firms providing legal services and entities providing tax and business advisory services to Arthur Hunt;
  • courier or postal service providers;
  • Recruitment service providers or employment agencies.

Such entities are usually independent data controllers, which means that Arthur Hunt has no control over how and to what extent they process your personal data. Arthur Hunt is not responsible for the compliance of such entities.

  • co-controllers of your personal data, i.e. companies from the Arthur Hunt capital group in Austria, Romania, the Czech Republic and Hungary, the list of which with addresses can be found at arthur-hunt.com, as well as with our clients looking for employees, these data will be processed on the basis of Article 6(1)(c) of the GDPR in order to comply with the legal obligation to which the joint controller is subject, regarding the provision of documents and information in the recruitment process.
  • any national public administration, authorities of other EU Member States (e.g. authorities appointed to protect personal data in other Member States) or courts if required by or at the request of applicable national or EU law.
  • How long do we keep your data?

We only retain personal data for as long as necessary to fulfil the purpose for which it was collected or to comply with legal requirements.

The personal data of the Candidates are processed throughout the recruitment process. After this period, the personal data of the Candidates in the scope of information about the recruitment will be processed for the periods of limitation of civil law claims in order to enable Arthur Hunt to  defend against possible claims or pursue such claims, if there is a risk of such claims being made by or against Arthur Hunt; as a rule, this period is not longer than 6 years from the end of the recruitment process.

If you give your consent, your personal data may be stored for the purpose of their use in further recruitment conducted by Arthur Hunt for the period indicated in the declaration of consent.

However, if you wish to have your personal data removed from our databases, you may make a request in accordance with Section 7, which we will consider as set out therein.

  • What are your rights and how can you exercise them?
    • Your rights

You have the right to access your personal data processed by Arthur Hunt. If you believe that any information concerning you is incorrect or incomplete, you also have the right to request that it be rectified as set out in section 7.2 below. Arthur Hunt will promptly correct such information.

You also have the right to:

  • withdraw your consent where Arthur Hunt has obtained such consent to process your personal data (provided that this withdrawal will not affect the lawfulness of any processing carried out prior to your withdrawal);
  • request deletion of your personal data;
  • request restriction of the processing of your personal data;
  • object, on grounds relating to your particular situation, to the processing of your personal data (including profiling) where such processing is carried out for the purposes of the public interest or the legitimate interests of Arthur Hunt;
  • data portability, i.e. to receive the personal data you have provided to Arthur Hunt in a structured, commonly used and machine-readable format and to request the transmission of such personal data to another personal data controller, without hindrance from Arthur Hunt, subject to its own confidentiality obligations.

Arthur Hunt will verify your requests, demands or objections in accordance with applicable data protection laws, including in particular the GDPR. However, it should be remembered that these rights are not absolute; the legislation provides for exceptions to their application.

Exercising your rights

To exercise the above rights, please contact us using the contact details provided in section 1 of this Policy.

If you are not satisfied with the way Arthur Hunt processes your personal data, please let us know and we will investigate any inaccuracies. Please report your concerns in the ways indicated above.

If you have concerns about Arthur Hunt’s reaction,  you can also lodge a complaint with the competent data protection authority. In Poland, this authority is the President of the Office for Personal Data Protection.

In order to keep your personal information up to date and accurate, we may from time to time ask you to review and confirm the personal information we hold about you or to inform us of any changes to that personal information (such as a change of address or contact telephone number). We encourage Candidates to regularly check the correctness, validity and completeness of the personal data processed.

Privacy Policy Updates

This Policy may be subject to further changes. Where required by law, any information regarding future changes or additions to the processing  of personal data  described in this Policy that may relate to you will be provided to you through the relevant form of communication normally used at Arthur Hunt.