- Account: an Applicant’s personal account or an Employer’s company account on Talentsquare;
- Applicant: a natural person whose CV is submitted to Talentsquare either by the Applicant himself or by an Employer;
- Basic CV: the Applicant’s CV, as submitted to Talentsquare by the Applicant and possibly amended afterwards, and as structured by the Talentsquare system;
- Controllers: decide the purpose of processing personal data (e.g. for an open position) and the means to do that. Controllers could be employers or recruitment agencies;
- CV: the curriculum vitae of an Applicant, as available on the Talentsquare website. A CV may, inter alia, include the Applicant’s personal information and information relating to the Applicant’s education, work and competencies, as well as any documentation and information supporting the content of the curriculum vitae. A CV can either be a Basic CV or an Enriched CV;
- Data subjects: would mean candidates in general;
- Employer: any natural person or legal person which is subscribed to Talentsquare for the purposes of screening CVs of employees and/or possible future employees. Employers also have an Account on the Talentsquare website;
- Enriched CV: a version of the Basic CV that is verified by Talentsquare (whether or not via Referees), enriched by Talentsquare with external data, and/or completed pursuant to On Demand Services (as applicable);
- GDPR: General Data Protection Regulation;
- Law: Directive 95/46/EC and/or any national laws implementing this Directive, such as the Belgian Data Protection Act of 8 December 1992. The General Data Protection Regulation (GDPR) was adopted in April 2016 to reinforce data protection laws for all citizens within the European Union (EU). Coming into effect on 25th May 2018, the GDPR will impact all businesses working with personal data from the EU;
- Means of Access: the username and password required for an Applicant to access his Account, or required for an Employer to use Talentsquare;
- On Demand Services: services provided by Talentsquare to an Employer or an Applicant with respect to a specific CV, including (but not limited to) language tests and competency tests;
- Processing: would mean any actions performed on personal data, such as collecting, recording, organizing, storing, using, and erasing;
- Processors: would be applicant tracking systems or any legal bodies that process personal data on behalf of a controller;
- Recruitment agency: any natural person or legal person which is subscribed to Talentsquare for the purposes of finding, screening CVs, evaluating, and present the right candidates for their customers. Recruitment agency also have an Account on the Talentsquare website;
- Referee: any natural person confirming an Applicant’s claims on his CV, and providing input with respect to the Applicant’s competencies upon Talentsquare’s request;
- Talentsquare SPRL, with registered offices at Rue du Maustichy 10, 1460 Ittre, Belgium, registered with the Crossroad Bank of Enterprises under company number 0641.685.385;
- the CV processing service and system operated by Talentsquare, available through www.Talentsquare.com.
2. Data collected by TalentsquareThrough Talentsquare, Talentsquare collects :
Candidate personal data :
- Academic Curriculum
- Personal details
- Personal identification data
- Electronic identification data
- Internal data – Other
- Internal data – Link / Id
- Professional experience
- Professional qualifications
- Use of the media
Others non-personal data :
- Data contained in the Account of the Applicants and Employer in particular the Means of Access;
- Browser data: standard information that a web browser sends to every website visited (such as the IP address, browser type and language, access times and referring website addresses);
- The purchase and use of credits;
- get their personal data (for you as a controller)
- process this data for recruitment purposes (for the processor acting on your behalf).
4. Enriched CVUpon an Employer’s request, Talentsquare may enrich Basic CVs via:
- Referees, which will confirm the Applicant’s claims on his Basic CV and/or provide input with respect to the Applicant’s competencies;
- On Demand Services, such as language tests, assessments or training sessions. These On Demand Services can also be independently requested by the Applicant; and/or
- Talentsquare’s own insights, such as the quality of education or career progression.
- The Applicant explicitly acknowledges and accepts that Talentsquare has the right to contact Referees in the Applicant’s name by e-mail or phone, in order to invite them to provide input with respect to the Applicant’s competencies.
5. Role of Talentsquare and EmployersApplicants should be aware that both Talentsquare and Employers use the CVs for their own purposes and in different contexts, as further described in this section 5. 5.1 Employers Employers can freely access the full content of CVs from Applicants whom they invited to submit their CV to Talentsquare. After payment, Employers can also obtain full access to CVs from other Applicants. Employers may use the CVs via the Talentsquare platform for various purposes, namely: soliciting their employment, comparing CVs by possible use of filtering and sorting mechanism, conducting online direct marketing campaigns by using the tools offered by Talentsquare and enriching Basic CVs (as described in section 4). In this context, Employers act as a “data controller” (as defined by applicable Law) with respect to any CVs they access, use or process in any other way via Talentsquare. Any such processing is performed for the Employer’s own purposes, and the Employers are solely responsible for complying with applicable Law in this regard (including with respect to its obligation to inform Applicants and to provide Applicants with a right to access and rectification). In case an Applicant is of the opinion that an Employer incorrectly uses his CV, the Applicant must contact the Employer. Accordingly, any claim relating to an Employer’s use of a CV must be directed to such Employer. 5.2 Talentsquare Talentsquare has different roles in the context of CVs:
- Talentsquare acts as a “data processor” (as defined by applicable Law) when it enriches a Basic CV at the request of a particular Employer, or when it filters and sorts CV-related data at the request of an Employer. If an Applicant questions such processing performed by Talentsquare at the request of a specific Employer, the Applicant must contact the Employer.
- After and outside this enrichment context, Talentsquare acts as a “data controller” when it operates the Talentsquare platform (e.g., to store CVs and to make CVs available to various Employers).
6. Purpose of the processingTalentsquare may process CVs, Referee feedback and Employer information for the following purposes:
- ensuring the correct functioning of the Talentsquare service;
- ensuring payment for the Talentsquare service;
- display of personalised advertisements on the Website;
- investigating and developing new functionality of the Talentsquare service;
- market intelligence (e.g. to calculate average employment durations in certain industries);
7. What are the rights of the applicant?No more personal data exchanged in their backs. Candidates will have a say in what happens to their data.
7.1) Right of access and inspection He has the right to receive free access to his personal data at any time, as well as the use we make of his personal data in accordance with the provisions applicable in the sector.
7.2) Right of improvement, deletion and limitation He is free to share his personal information with Talentsquare and the employers. In addition, he always has the right to correct, supplement or delete his personal data yourself. Thanks to his Talentsquare account, he has access to his personal data recorded about him. He may modify his personal data himself at any time, for example by making changes to his CV;
7.3) Right of opposition He also has the right to oppose the processing of his personal data for serious and legitimate reasons.
7.4) Data transfer right He has the right to obtain his personal data that he has provided us in a structured, standard and machine readable form and / or to transfer them to other responsible parties in accordance with the provisions in force in the sector.
7.5) Right of withdrawal of consent To the extent that the treatment is based on his prior consent, he has the right to withdraw that authorization.
7.6) Automatic decisions and profiling The processing of his personal data does not include any profiling and he will not be subject to automated decisions on our part either.
7.7) Exercising one’s rights He can exercise his rights by sending an e-mail to firstname.lastname@example.org
7.8) Complaints He has the right to file a complaint with the Belgian Commission for the Protection of Privacy: Commission for the Protection of Privacy.
8. Visibility of an AccountThrough his Account, an Applicant can at any time control whether Employers are able to view the content of the CV. The Applicant can choose to make his CV visible (hereinafter referred to as “Visible”) to Employers. This means that interested Employers will be able:
- to see the CV of the Applicant.
- to add the CV of the Applicant to their recruitment pool.
- to contact the Applicant.
10. Security and confidentialityWe have developed technical and organizational security measures to prevent the destruction, loss, falsification, alteration, unauthorized access or misrepresentation to third parties of personal data collected as well as any other unauthorized processing of these data. 10.1 Technical measures
- Using virus scans
- Controlling traffic through a firewall
- Access to data via VPN
- Redundancy of production servers
- Secure hard drives
- Secure and multiple backups
- Restricting and controlling access to servers and data
- Incident Management Procedure
- Employee training in security
- Confidentiality clauses
- Incident and data breach management