The Privacy Policy

Effective Date: [24th May 2018]

This privacy notice provides a framework for understanding the personal data collected by IT.HR Group Anna Gontarska from now on called the Data Controller"), as required by law, including the provisions of the European Union's General Data Protection Regulation (GDPR).

Data Controller

The Data Controller is IT.HR Group Anna Gontarska with the registered office in Warsaw 03-040, Kinowa Street 25/282

The personal data collected will be controlled and processed by the Data Controller. Additionally, personal data may be processed or jointly controlled by affiliates of the Data Controller listed: IT.HR Group Anna Gontarska. IT.HR Sp. z o.o Poland and IT.HR Agencja Pośrednictwa Pracy Agnieszka Gontarska – Poland

This privacy notice applies to:

Our job candidates and recipients of our career services,
Our associates, who are people we source or place on assignment with one of our clients, or individuals to whom we provide outplacement or career transition services,
users of the websites and apps: www.ithr.pl, www.ithr.com.pl, www.ithr.kr.co www.ithr.uk (the "Sites"), and
representatives of our business partners, clients and vendors.

This privacy notice does not apply to our headquarters and country-based staff employees who are individuals employed by IT.HR Ltd and who works directly for IT.HR Ltd and not directly with IT.HR client.

The privacy notice describes the types of personal data or personal information we collect, how we use the information, how we process and protect the information we collect, for how long we store it, with whom we share it, to whom we transfer it and the rights that individuals can exercise regarding our use of their data. We also describe how you can contact us about our privacy practices and exercise your rights. Our privacy practices may vary among the countries where we operate to reflect local practices and legal requirements. You can view specific local terms by going to local websites.

Click on one of the links below to jump to the listed section:

Privacy Notice:

Information We Collect
How We Use the Information We Collect
Cookie Policy
Legitimate Interest
How We Process and Protect Personal Information
How Long We Store the Information We Collect
Information We Share
Data Transfers
Your Rights And Choices
Updates To Our Privacy Notice
How To Contact Us

Information We Collect

We may collect personal data about you in various ways, such as through our Sites and social media channels; at our events; through phone and fax; through job applications; in connection with in-person recruitment; or connection with our interactions with clients and vendors. We may collect a selection of personal data depending on the nature of the relationship, including, but not limited to (as permitted under local law):

contact information (such as name, postal address, email address and telephone number);
username and password when you register on our Sites;
information you provide about friends or other people you would like us to contact. (The Controller assumes that the other person previously gave authorisation for such communication) ; and
other information you may provide to us, such as in surveys or
through the "Contact Us" feature on our Sites.

In addition, if you are an associate or job candidate, you apply for a position or create an account to apply for a position, we may collect the following types of personal data (as permitted under local law):

employment and education history;
language proficiencies and other work-related skills;
Social Security number, national identifier or other government-issued identification numbers;
date of birth;
gender;
bank account information;
citizenship and work authorisation status;
benefits information;
tax-related information;
information provided by references; and
information contained in your resume or C.V., the information you provide regarding your career interests, and other information about your qualifications for employment.

and where required by law and explicit consent has been provided by you:

disabilities and health-related information;
results of drug tests, criminal and other background checks.
Special categories of data, such as information about ethnic origin, sexual orientation or religion or belief, to monitor diversity in recruitment

In addition, we may collect the information you provide about other individuals, such as information related to emergency contacts.

How We Use the Information We Collect

The Controller collects and uses the data gathered for the following purposes (as permitted under local law):

providing workforce solutions and connecting people to work;
creating and managing online accounts;
processing payments;
managing our client and vendor relationships;
responding to individuals' inquiries and claims;
operating, evaluating and improving our business (including developing, enhancing, analysing and improving our services; managing our communications; performing data analytics; and performing accounting, auditing and other internal functions);
protecting against, identifying and seeking to prevent fraud and other unlawful activity, claims and other liabilities; and
complying with and enforcing applicable legal requirements, relevant industry standards, contractual obligations and our policies.
where permitted under law, consistent with the Data Controller's Cookie and Advertising Notice (which is incorporated herein by reference) and only if you have given your consent to send promotional materials, alerts regarding available positions and other communications;
where permitted under law and only if you have given your consent to communicate about and administer participation in special events, promotions, programs, offers, surveys, contests and market research;

In addition to the activities listed above, if you are an associate or job candidate and you apply for a position or create an account to apply for a position, as permitted under local law, we use the information described in this privacy notice for the following purposes:

Providing you with job opportunities and work;
providing HR services to you, including administration of benefit programs, payroll, performance management and disciplinary actions;
providing additional services to you, such as training, career counselling and career transition services;
assessing your suitability as a job candidate and your associate qualifications for positions; and
performing data analytics, such as (i) analysing our job candidate and associate base; (ii) assessing individual performance and capabilities, including scoring on work-related skills; (iii) identifying skill shortages; (iv) using the information to match individuals and potential opportunities, and (v) analysing pipeline data (trends regarding hiring practices).

All processing will be carried out based on adequate legal grounds, which may fall into several categories, including:

Explicit consent from the data subject, where required by applicable law, e.g. when you tick a box to receive email newsletters
To ensure that we comply with a statutory or contractual requirement (e.g. our client may require your data) and/ or a requirement necessary to enter into a contract, you must provide this data. If you do not, we cannot provide you with our services, e.g., job opportunities or processing your data to ensure your wages and taxes are paid.
it is essential for the Data Controller's legitimate interest, e.g., letting the user access the website to be provided with the services offered. Please see our section on Legitimate Interests below to learn more about these interests and when we may process information in this way.

We also may use the information in other ways for which we provide specific notice at or before the time of collection.

You may update your consent to marketing preferences anytime by clicking here.

Legitimate Interest

The Data Controller may process personal data for specific legitimate business purposes, which includes all of the following:

where the process enables us to enhance, modify, personalise or otherwise improve our services/communications for the benefit of our clients, candidates and associates;
to identify and prevent fraud;
to enhance the security of our network and information systems;
to better understand how people interact with our websites;
for direct marketing purposes;
to provide postal communications to you that we think will be of interest to you;
to determine the effectiveness of promotional campaigns and advertising

Whenever we process data for these purposes, we will ensure that we keep your rights in high regard and take account of these rights. You have the right to object to such processing, and if you wish to do so, please click here. Please bear in mind that exercising your right to object may affect our ability to carry out and deliver services to you for your benefit.

How We Process and Protect Personal Information

We process the personal data we collect for the purposes defined in this notice and for as long as necessary for the purposes we collect it. Different laws may also require us to keep different data for different periods.

We maintain administrative, technical and physical safeguards to protect the personal data you provide against accidental, unlawful or unauthorised destruction, loss, alteration, access, disclosure or use. To ensure the appropriate security and confidentiality of personal data, we apply the following security measures:

Encryption of data in transit;
Strong user authentication controls;
Hardened network infrastructure;
Network monitoring solutions;

How long we Store The Data We Collect

We will keep your data for the period necessary to achieve the purposes described in this Privacy Notice, taking into account applicable statute of limitation periods and records retention requirements under applicable law. Subject to applicable law, we will retain your data as the company requires us to meet our business and compliance obligations, such as our tax and accounting obligations.

We store in our systems the personal data we collect in a way that allows the identification of the data subjects for no longer than necessary in light of the purposes for which the data was collected or for which that data is further processed.

We determine this specific period by taking into account the following:

The necessity to keep stored the personal data collected to offer services established with the user;
To safeguard a legitimate interest of the Data Controller as described in the purposes;
The existence of specific legal obligations that make the processing and related storage necessary for a specific period;

Information We Share

We do not disclose personal data we collect about you, except as described in this privacy notice or separate notices concerning particular activities. We may share personal data with vendors who perform services on our behalf based on our instructions. We do not authorise these vendors to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. We also may share your data (i) with our subsidiaries and affiliates; (ii) if you are a job candidate, with clients who may have job opportunities available or interest in placing our job candidates; and (iii) with others with whom we work, such as job placement consultants and subcontractors, to find you a job.

In addition, we may disclose personal data about you (i) if we are required to do so by law or legal process; (ii) to law enforcement authorities or other government officials based on a lawful disclosure request; and (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual fraudulent or illegal activity. We also reserve the right to transfer personal data about you if we sell or transfer all or a portion of our business or assets (including in the event of a reorganisation, dissolution or liquidation).

Data Transfers

We also may transfer the personal data we collect about you to countries outside of the country in which the information was initially collected. Those countries may have different data protection laws than those where you initially provided the personal data. When we transfer your information to other countries, we will protect that data as described in this privacy notice, and such transfers will comply with applicable law.

The countries to which we may transfer the personal data we collect about you may be:

Within the European Union
Outside the European Union

When we transfer personal data from within the European Union to countries or international organisations that are based outside the European Union, the transfer takes place based on:

An adequacy decision by the European Commission;
In the absence of an adequacy decision, other legally permitted grounds (a) legally binding and enforceable instrument between public authorities or bodies; (b) binding corporate rules; (c) standard data protection clauses (formerly called the Model Clauses) adopted by the Commission, etc.

Your Rights as Data Subject

When permitted by applicable law, a data subject can exercise under Articles 15 to 22 of the GDPR the following specific rights:

Right of access: A data subject has the right to access his or her data concerning which to verify that the law processes his or her data. Should you wish to exercise your right to access, please click here and complete the form.
Right to rectification: A data subject has the right to request the rectification of any inaccurate or incomplete data held about him or her to protect the accuracy of such information and to adapt it to the data processing.
Right to erasure: A data subject can request that the Data Controller erase information about him or her and no longer process that data. Should you wish to exercise your right to access, please click here and complete the form.
Right to restriction of processing: A data subject has the right to request that the Data Controller restricts the processing of his or her data.
Right to data portability: The data subject has the right to request data portability, meaning that the data subject can receive the originally provided personal data in a structured and commonly used format or that the data subject can request the data transfer to another Data Controller.
Right to object: The data subject which provides a Data Controller with personal data has the right to object, at any time to the data processing on several grounds as set out under GDPR without needing to justify his or her decision.
Right not to be subject to automated individual decision-making: The data subject has the right not to be subject to a decision based solely on automated processing, including profiling, if such profiling produces a legal effect concerning the data subject or similarly significantly affects him or her.
Right to complain with a supervisory authority: Every data subject has the right to complain with a supervisory authority, in particular in the EU Member State of his or her habitual residence, place of work or place of the alleged infringement if the data subject considers that the processing of personal data relating to him or she infringes GDPR.

Whenever the processing is based on consent, as under Art. 7 of the GDPR, the data subject may withdraw their consent at anytime. There may be circumstances where we will still need to process your data for legal or official reasons. We will inform you if this is the case. Where this is the case, we will restrict the data to only what is necessary for meeting those specific requirements.

If you believe that any of the data we process needs to be corrected or completed, please get in touch with us, and we will take reasonable steps to check its accuracy and correct it where necessary.

Please refer to the How to Contact Us section below for more information about processing your data.

Updates to Our Privacy Notice

This privacy notice (including any addenda) may be updated periodically to reflect changes in our privacy practices and legal updates. We will notify you of significant changes by posting a prominent notice on our Sites indicating at the top of each Notice when it was most recently updated.

How To Contact Us

If you have any questions or comments about this privacy notice, or if you would like to exercise your rights, please write to:

The Data Privacy Officer,

Agnieszka Grabowska (agnieszka.grabowska(at)ithr.pl

Kinowa Street 25/282

or use e-mail adress: gdpr@ithr.pl