TP WorkForce Ltd (“We”) are committed to protecting and respecting your privacy.
We have put in place policies and procedures to protect any personal information we collect about you to comply with the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679; and any subsequent amendments. Details of how we collect, use and disseminate your personal data are described here to demonstrate our commitment to protecting your privacy.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
What is the GDPR?
The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679); is a new EU regulation which replaces the current Data Protection Directive of 1995 (Directive 95/46/EC). GDPR aims to harmonize data protection and data privacy laws across EU member states, giving back control to citizens over their personal data; and to simplify the regulatory environment for businesses by unifying regulations within the EU and by providing a clear legal framework for commercial organisations to operate within.
The GDPR will come into force in the EU from 25th May 2018.
Your Rights Under GDPR
For the purposes of data protection legislation in force from time to time the Data Controller is:
TP WorkForce Ltd of Nicolaou Skoufa 1, Office 202, Engomi, 2415, Nicosia.
Our nominated Data Protection Officer is Maria Titan.
Who We Are & What We Do?
We are a recruitment agency (“our business”). We also provide HR Consultancy services. We collect the personal data of the following types of people to allow us to undertake our business:
- Prospective and placed candidates for permanent roles
- Prospective and live client contacts
- Supplier contacts to support our services
We collect information about you to carry out our core business and ancillary activities.
Our Legitimate Business Interests
Our legitimate interests in collecting and retaining your personal data are described below:
- As a recruitment business and recruitment agency we introduce candidates to clients for permanent employment. The exchange of personal data of our candidates and our client contacts is a fundamental, essential part of this process
- In order to support our candidates’ career aspirations and our clients’ recruitment needs, we require a database of candidate and client personal data containing historical information as well as data pertaining to current resourcing requirements
- To expand, develop and maintain our business we need to record the personal data of prospective candidates and client contacts
Information We Collect About You
This is personal information about you that you supply to us by filling in forms on our website workforcecyprus.com (“our site”); or by corresponding with us by phone, e-mail or other communication channels. It includes information you provide when you register to use our site, to enter our database, subscribe to our services, attend our events, participate in discussion boards or other social media functions on our site, and when you report a problem with our site.
The information you give us, or we collect about you, including: your name, address, private and corporate e-mail address, phone number, financial information, compliance documentation and references verifying your employment history, experience and qualifications, your right to work in the EU, curriculum vitae (CV) and photograph and links to your professional profiles available in the public domain (LinkedIn, Twitter, Facebook or corporate websites).
What Kind Of Personal Information Do We Collect?
The information described below is, of course, in addition to any personal data we are required by law to process in any given situation.
We may collect some or all of the information listed below to enable us to offer you employment opportunities which are tailored to your circumstances and your interests:
- Contact details
- Education details
- Employment history
- Emergency contacts and details of any dependents
- Referee details
- Immigration status (whether you need a work permit)
- A copy of your driving license and/or passport/identity card
- Financial information (Payroll or financial background checks)
- Social Insurance number, ARC number and any other tax-related information
- Details of any criminal convictions if this is required for a role that you are interested in applying for
- Details about your current remuneration, pensions and benefits arrangements
- Information on your interests and needs regarding future employment, both collected directly and inferred, for example from jobs viewed or articles read on our website
- Extra information that you choose to tell us
- Extra information that your referees choose to tell us about you
- Extra information that our clients may tell us about you, or that we find from other third party sources such as job sites
- IP address and the dates, times and frequency with which you access our services
We collect Candidate personal data in four primary ways:
1. Personal data that you, the candidate, gives to us
2. Personal data that we receive from other sources
3. Personal data that we collect automatically
4. Personal data you give to us
WorkForce needs to know certain information about you in order to provide a tailored service. This will enable us to provide you with the best opportunities, and should save you time in not having to trawl through information about jobs and services that are not relevant to you.
There are numerous ways you can share your information with us. It all depends on what suits you. These may include:
- Entering your details on the WorkForce website as part of the registration process
- Leaving a hard copy CV at a WorkForce recruitment event, job fair or office
- Emailing your CV to a WorkForce consultant or being interviewed by them
- Applying for jobs through a job aggregator, which then redirects you to the WorkForce website
Personal data we receive from other sources
We also receive personal data about candidates from other sources. Depending on the relevant circumstances these may include personal data received in the following situations:
- Your referees may disclose personal information about you
- Our clients may share personal information about you with us
- We may obtain information about you from searching for potential candidates from third party sources, such as LinkedIn and other job sites
- If you 'like' our page on Facebook or LinkedIn or 'follow' us on Twitter or Instagram we will receive your personal information from those sites
- Personal data we collect automatically
- To the extent that you access our website or read or click on an email from us, we may also collect your data automatically or through you providing it to us
How Do We Use Your Personal Data?
Having obtained data about you, we then use it in a number of ways.
We generally use candidate data in three ways:
- Recruitment Activities
- Marketing Activities
- To help us to establish, exercise or defend legal claims
Here are some more details about each:
Our main area of work is recruitment – connecting the right candidates with the right jobs. We've listed below various ways in which we may use and process your personal data for this purpose, where appropriate and in accordance with any local laws and requirements. Please note that this list is not exhaustive.
- Collecting your data from you and other sources, such as LinkedIn
- Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to recruitment
- Providing you with our recruitment services and to facilitate the recruitment process
- Assessing data about you against vacancies which we think may be suitable for you
- Sending your information to clients, in order to apply for jobs or to assess your eligibility for jobs
- Enabling you to submit your CV, apply online for jobs or to receive alerts about jobs we think may be of interest to you
- Carrying out our obligations arising from any contracts entered into between WorkForce and third parties in relation to your recruitment
- Facilitating our payroll and invoicing processes
- Carrying out customer satisfaction surveys
- Verifying details you have provided, using third party resources (such as psychometric evaluations or skills tests), or to request information (such as references, qualifications and potentially any criminal convictions, to the extent that this is appropriate and in accordance with the laws of Cyprus)
- Complying with our legal obligations in connection with the detection of crime or the collection of taxes or duties
- Processing your data to enable us to send you targeted, relevant marketing materials or other communications which we think are likely to be of interest to you
We may periodically send you information that we think you may find interesting, or to ask for your help with connecting other candidates with jobs. In particular, we may wish to use your data for the purposes listed below, where appropriate and in accordance with laws and requirements. Please note that this list is not exhaustive.
- Enable us to develop and market other products and services
- Market our full range of recruitment services to you
- Send you details of reports, promotions, offers, networking and client events, and general information about the industry sectors which we think might be of interest to you
- Display promotional excerpts from your details on the WorkForce website as a success story (only where we have obtained your express consent to do so)
- We may need your consent for some aspects of these activities which are not covered by our legitimate interests and, depending on the situation, we'll ask for this via an opt-in or soft-opt-in (which we explain further below)
- Soft opt-in consent is a specific type of consent which applies where you have previously engaged with us (for example by submitting a job application or CV, or registering a vacancy to be filled), and we are marketing other recruitment-related services. Under ‘soft opt-in’ consent, we will take your consent as given unless or until you opt out. For most people, this is beneficial as it allows us to suggest other jobs to you alongside the specific one you applied for, significantly increasing the likelihood of us finding you a new position. For other types of e-marketing, we are required to obtain your explicit consent.
If you want to know more about how we obtain consent, please contact us at email@example.com. If you are not happy about our approach to marketing, you have the right to withdraw your consent at any time and can find out more about how to do so please contact us at firstname.lastname@example.org. Nobody's perfect, even though we try to be. We want to let you know that even if you have opted out from our marketing communications, it is possible that your details may be recaptured through public sources in an unconnected marketing campaign. We will try to make sure this doesn't happen, but if it does, we're sorry. We'd just ask that in those circumstances you opt out again.
All our marketing is based on what we think will serve our clients and candidates best, our intention is not to spam you but we know we won’t always get it right.
The data we collect about clients is actually very limited. We generally only need to have your contact details or the details of individual contacts at your organisation (such as their names, telephone numbers and email addresses) to enable us to ensure that our relationship runs smoothly. We also hold information relating to your engagement with candidate profiles and other material published by WorkForce, which we use to ensure that our marketing communications to you are relevant and timely. We may also hold extra information that someone in your organisation has chosen to tell us. In certain circumstances, such as when you engage with our finance and credit control department, and calls with you may be documented. If we need any additional personal data for any reason, we will let you know.
We collect client personal data in three ways:
1. Personal data that we receive directly from you
2. Personal data that we receive from other sources
3. Personal data that we collect automatically
4. Personal data that we receive directly from you
We both share the same goal – to make sure that you have the best staff for your organisation. We will receive data directly from you in three ways:
- Where you contact us proactively, usually by phone or email
- Where we contact you, either by phone or email, or through our consultants' business development activities more generally
- Personal data we receive from other sources
Where appropriate we may seek more information about you or your colleagues from other sources generally by way of due diligence or other market intelligence including:
- From third party market research and by analyzing online and offline media (which we may do ourselves, or employ other organizations to do for us)
- From delegate lists at relevant events
- From other limited sources and third parties (for example from our candidates to the extent that they provide us with your details to act as a referee for them)
- Personal data we collect via our website
- To the extent that you access our website or read or click on an email from us, where appropriate we may also collect your data automatically or through you providing it to us
We don't collect much data about suppliers – we simply need to make sure that our relationship runs smoothly. We'll collect the details for our contacts within your organisation, such as names, telephone numbers and email addresses. We'll also collect bank details, so that we can pay you. We may also hold extra information that someone in your organisation has chosen to tell us. In certain circumstances, such as when you engage with our finance and credit control personnel, our calls with you may be documented.
People Whose Data We Receive From Candidates And Staff, Such As Referees And Emergency Contacts
All we need from referees is confirmation of what you already know about our candidate or prospective member of staff, so that they can secure that job they really want. Emergency contact details give us somebody to call on in an emergency. To ask for a reference, we'll obviously need the referee's contact details (such as name, email address and telephone number). We'll also need these details if our candidate or a member of our staff has put you down as their emergency contact so that we can contact you in the event of an accident or an emergency.
Information We Collect When You Visit Our Website
When you visit our website there is certain information that we may automatically collect, whether or not you decide to use our services and this is essentially your IP address. We collect your data automatically via cookies, in line with cookie settings in your browser. We collect a limited amount of data from our website users which we use to help us to improve your experience when using our website and to help us manage the services we provide.
With respect to each of your visits to our site, we will automatically collect the following information:
- Technical information, including the Internet protocol (IP) address used to connect your computer to the internet
- Your login information (if applicable), browser plug-in type and version
- Your operating system and platform, information about your visit, including the full Uniform Resource Locators (URL)
- Clickstream to, through and from our site (including date and time)
- Services and job vacancies you viewed or searched for, page response times and download errors
- Length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs); and methods used to browse away from the page
- Any phone number used to call our work number
Information We Obtain from Other Sources
This is information we obtain about you from other sources such as LinkedIn, corporate websites, job board websites, your business card and personal recommendations.
In this case we will inform you, by sending you this policy notice, within a maximum of 30 days of collecting the data of the fact we hold personal data about you, the source the personal data originates from, whether it came from publicly accessible sources, and for what purpose we intend to retain and process your personal data.
We work closely with third parties, including business partners, sub-contractors in professional and other services, third party recruitment agencies, external job boards, third party clients, advertising networks, analytics providers, search information providers and professional advisors. We may receive information about you from them for the purposes of our recruitment services and ancillary support services.
Purposes of the Processing and the Legal Basis for the Processing
We use information held about you in the following ways:
- To carry out our obligations arising from any contracts we intend to enter into (or have entered into between you and us); and to provide you with the information and services that you request from us or we think will be of interest to you because it is relevant to your career or to your organisation
- To provide you with information about other services we offer that are similar to those that you have already purchased, been provided with or enquired about
- The core service we offer to our candidates and clients is the introduction of candidates to our clients for the purpose of permanent engagement. Our services also involve supporting individuals throughout their career and supporting businesses’ recruitment needs and strategies
- Our legal basis for the processing of personal data is our legitimate business interests, described in more detail below, although we will also rely on contract, legal obligation and consent for specific uses of data
- We will rely on contract if we are negotiating or have entered into a placement agreement with you or your organisation or any other contract to provide services to you or receive services from you or your organisation
- We will rely on legal obligation if we are legally required to hold information on to you to fulfil our legal obligations
- We will in some circumstances rely on consent for particular uses of your data and you will be asked for your express consent, if legally required. An example of when consent may be the lawful basis for processing include gaining permission to introduce you to a client if you are a candidate
Who Do 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: potential employers and other recruitment agencies/organisations to increase your chances of finding employment and third party partners, job boards and job aggregators where we consider this will improve the chances of finding you the right job
- 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 WorkForce 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.
Where We Store & Process Your Personal Data
The data that we collect from you will be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It will be transferred to third parties outside of the EEA for the purpose of our recruitment services. It will also be processed by staff operating outside the EEA who are employed there.
By submitting your personal data, you agree to this transfer, storing or processing. TP WorkForce Ltd will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this policy.
Our international partners responsible for our Applicant Tracking System have already taken steps in acquiring adequate levels of protection in the transferring of data between the EU and US. Their certification under the new EU-US Privacy Shield Framework deems them suitable and highly secure for the handling of personal data.
All information you provide to us is stored on our secure servers based in the United States. Where we have given you (or where you have chosen), a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Our site has security measures in place to protect the loss, misuse and alteration of the information under our control. All personal data including candidate CVs are stored on a secure database; a firewall is in operation to prevent hacking. Only current authorised TP WorkForce Ltd employees have access to the database, and a unique ID and Password controls the access rights of these employees.
Unfortunately, the transmission of information via the internet is not completely secure. We will do our best to protect your personal data, but we cannot guarantee the security of your data transmitted to our site. Any transmission is at your own risk. Once we have received your data, we will use strict procedures and security features to try to prevent unauthorised access.
Retention of Your Data
We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you are happy for us to do so. Accordingly, we have a data retention notice and run data routines to remove data that we no longer have a legitimate business interest in maintaining. We take the following action to try to ensure our data is accurate:
Prior to making an introduction we check that we have accurate information about you.
We keep in contact with you so that you can inform us of changes to your personal data.
We segregate our data so that we keep different types of data for different time periods. The criteria we use to determine whether we should retain your personal data include:
- The nature of the personal data
- Its perceived accuracy
- Our legal obligations
- Whether an interview or placement has been arranged
- Our recruitment expertise and knowledge of the industry by country, sector and job role
- We may archive part or all of your personal data or retain it on our financial documents only, deleting all or part of it from our main Customer Relationship Management (CRM) system.
Any CVs we receive from May 25th 2018 onwards, will be automatically stored for a period of 36 months (unless we receive instructions from you to delete your data). After 36 months, you will be contacted and will have the option to either continue being represented by TP WorkForce Ltd or to delete your data.
How Do We Safeguard Your Personal Data?
We are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorized access. We do this by having in place a range of appropriate technical and organizational measures. These include measures to deal with any suspected data breach.
If you suspect any misuse or loss of or unauthorized access to your personal information, please let us know immediately by contacting us at email@example.com
Should we want or need to rely on consent to lawfully process your data, we will request your consent orally, by email or by an online process for the specific activity we require consent for and record your response on our CRM system. Where consent is the lawful basis for our processing, you have the right to withdraw your consent to this particular processing at any time.
You have the right to ask us not to process your personal data. We will inform you if we intend to use your data or if we intend to disclose your information to any third party for such purposes. We will collect express consent from you prior to using your personal data.
You can also exercise this right at any time by contacting us at: firstname.lastname@example.org or calling us on +357 22679800.
Our site may contain links to / from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please be aware that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies directly before you submit any personal data to these websites.
The GDPR Provides You with the Following Rights
Accuracy – request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Deletion – request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Objection – object to processing of your personal information where we are relying on a legitimate interest (or those of a third party); and there is something about your particular situation which makes you want to object to processing on these grounds.
Restriction – request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you. For example, if you want us to establish its accuracy or the reason for processing it.
Transfer – request the transfer of your personal information to another party in certain formats, if practicable.
Complain – make a complaint to a supervisory body. In the EU, https://edps.europa.eu/node/75
Access to Information
The GDPR and Data Protection Act 1998 (DPA), give you the right to access information held about you. You are also welcome to contact us to ensure your data is accurate and complete. Your right of access can be exercised in accordance with the DPA and the GDPR once it is in force.
A subject access request can be submitted to: email@example.com.
Changes to Our Privacy Notice
Any questions, comments or concerns regarding this policy (and our data protection processes in general), can be addressed for the attention of the Data Controller at firstname.lastname@example.org