Status: 2024-07-07
Introduction
- Responsible: Contauro AG, datenschutz@contauro.com, (hereinafter: “we”, “us” or “Contauro”) as operator of the website www.contauro.com is the person responsible for the personal data of the users (hereinafter: “you”) of the website within the meaning of the FADP.
- This Privacy Policy explains what we do with your personal data, whether we are in the process of helping you find a job, continuing our relationship with you once we have found you a role, providing you with a service, receiving a service from you, using your data to ask for your assistance in relation to one of our Candidates, or you are visiting our website.
- This Privacy Policy describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are com-mitted to protecting and safeguarding your data privacy rights.
- This Privacy Policy applies to the personal data of the following categories of people: Candidates, Temporary Workers, Clients, Suppliers and Third Parties, Website Users, and other people whom we may contact in order to find out more about our Candidates or whom they indicate is an emergency contact. It also applies to the emergency contacts of our Staff.
- This privacy policy is designed to meet the requirements of the EU General Data Protection Regulation (“GDPR”) and the revised Swiss Data Protection Act (“revDSG”). However, whether and to what extent these laws are applicable depends on the individual case.
- It is important to point out that we may amend this Privacy Policy from time to time. Please just visit this page if you want to stay up to date, as we will post any changes here.
- If you are dissatisfied with any aspect of our Privacy Policy, you may have legal rights and, where relevant, we have described these as well.
How To Use This Privacy Policy
- This Privacy Policy tells you a few things about how we use your personal data, and perhaps more importantly, what your rights are in relation to this (you have, for example, the right to ask us to Delete or confirm the nature of information that we hold about you at any time, withdraw any consents that you may previously have given and/or lodge a complaint with our Data Protection Officer or a supervisory authority if you are not happy about something we have done).
- The Privacy Policy is broadly divided into two sections:
- Context-specific privacy information that applies to the different categories of person covered by this Privacy Policy, as follows:
- General privacy information that applies to all of the different categories of people covered by this Privacy Policy, including:
- Who do we share your personal data with?
- How do we safeguard your personal data?
- How long do we keep your personal data for?
- How can you access, amend or take back the personal data that you have given to us?
- Who is responsible for processing your personal data when you access the Contauro website?
- How do we store and transfer data internationally?
- Cookies Policy
- Use of third party services
- This Privacy Policy applies in relevant countries throughout our international network. Different countries may approach data privacy in slightly different ways and so we also have country-specific parts to this Privacy Policy. You can find country-specific provisions for your jurisdiction here. This allows us to ensure that we are complying with all applicable data privacy protections, no matter where you are.
- This Privacy Policy also contains a number of defined terms (which we distinguish by starting them with a capital letter), so we have included a Glossary at the end of this document.
Context-Specific Privacy Information
1. Candidates
This section of the Privacy Policy applies to Candidates.
Candidates include individuals with whom Contauro has not had prior contact, but whom Contauro reasonably considers would be interested in, or might benefit from, Contauro’s services and being considered for any roles advertised or promoted by Contauro including permanent, part-time and temporary positions and freelance roles with Contauro’s Clients (including those individuals who want to become Temporary Workers). Candidates also include applicants for such roles as well as people who have supplied a speculative CV to Contauro not in relation to a specific job and/or who have engaged with Contauro about Contauro’s services and/or any roles advertised or promoted by Contauro. Individual contractors, freelance workers and employees of suppliers or other third parties put forward for roles with Contauro’s Clients as part of an MSP offering or otherwise will be treated as Candidates for the purposes of this Privacy Policy.
Depending on the relevant circumstances and applicable local laws and requirements, we may collect some or all of the information listed below to enable us to assess how we can assist you if we reasonably believe you might be interested in, or might benefit from our services, and to offer you employment opportunities which are tailored to your circumstances and your interests.
In some jurisdictions, we are restricted from processing some of the data outlined below. In such cases, we will only process the data in those jurisdictions to the extent and under the circumstances permitted by law.
- Key identification and contact information
- Name;
- Age/date of birth;
- Birth number;
- Sex/gender;
- Photograph;
- Marital status;
- Nationality/citizenship/place of birth;
- Contact details;
- Emergency contacts/next of kin information and details of any dependants;
- A copy of your driving licence and/or passport/identity card;
- Education and employment information
- Education details;
- Employment history;
- Current job title/specialism/industry sector;
- Skills and languages spoken;
- Referee details;
- Immigration status (whether you need a work permit);
- Start date or availability date;
- Details about your previous and current remuneration, pensions and benefits arrangements;
- Details of hours worked (once you have been placed in a role);
- 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 or from links clicked on in emails from us;
- Financial information
- Bank details;
- Financial information (where we need to carry out financial background checks);
- Social security number (or equivalent in your country) and any other tax-related information;
- Special category information
- Details of racial or ethnic origin, sexual orientation, religious or other similar beliefs, and physical or mental health, including disability-related information, in ease case for diversity monitoring purposes;
- Sexual orientation (for example where you disclose this through providing next-of-kin details);
- Physical or mental health, including disability-related information in order to enable us to make reasonable adjustments and health-related information when we need to use or offer occupational health to you in the context of certain types of roles;
- Details of health-related information arising from or in connection with the COVID-19 or other pandemics, if this is required for a role that you are interested in applying for or where volunteered by you, e.g. a test result (whether positive or negative) or vaccination history (including medical conditions relating to or affecting vaccination) where appropriate;
- In certain circumstances, video recordings of Candidates attending or participating in training or meetings where individuals have consented to the recording;
- Religious Beliefs in order to calculate entitlement to annual leave;
- Criminal conviction data
- Details of any criminal convictions if this is required for a role that you are interested in applying for;
- Details of any criminal convictions if this is required for a role that you are interested in applying for;
- Automatically collected information
- IP address;
- Usage information including the dates, times and frequency with which you access our services;
- User choices (e.g. marketing preferences);
- User reports;
- Log and troubleshooting information;
- Device information when you install, access or use our services;
- Website browsing data e.g. pages viewed e.g. Contauro or Clients’ websites;
- CCTV footage if you attend our premises.
- Email engagement history with Contauro;
- Location information (inferred from jobs, IP address, application history or system stored data);
- Account access information (e.g. PIN numbers for account verification purposes);
- Information that others provide about you
- Extra information that your referees chooses 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 (which you have uploaded information onto, or is otherwise made available to us);
- Information about your interests and needs regarding future employment, both collected directly and inferred, for example from jobs viewed or articles read on our website or from links clicked on in emails from us;
- Additional information that you choose to tell us
- Any other information that you may provide to us including, for instance, details of your childcare or carer arrangements (for example, when you authorise a deduction from pay for childcare vouchers or when you volunteer this information) and when corresponding with us via email or otherwise.
Please note that the above list of categories of personal data we collect is not exhaustive.
To the extent that you access our website or click through any links in an email from us, we will also collect certain data from you. If you would like more information about this, please refer to the context-specific section of this Privacy Policy that applies to Website Users.
We collect Candidate personal data in the following ways:
- Personal data that you, the Candidate, give to us;
- Personal data that we receive from other sources; and
- Personal data that we collect automatically.
Personal Data You Give To Us
Contauro needs to know certain information about you in order to provide you with its services. This will enable us, amongst other things, 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. These may include:
- Entering your details on the Contauro website or via an application form, as part of the registration process;
- Leaving a hard copy CV at a Contauro recruitment event, job fair or office;
- Emailing your CV or other information to a Contauro consultant or being interviewed by them;
- Applying for jobs through a job aggregator, which then redirects you to the Contauro website;
- Entering your personal details into a Contauro microsite; or
- Entering a competition through a social media channel such as Facebook or Twitter (or similar).
The types of information that we receive from you in this way include:
- Key identification and contact information;
- Education and employment information;
- Financial information;
- Special category information;
- Criminal conviction data, and
- Additional information that you choose to tell us,
as described in the section entitled “What Kind of Personal Information Do We Collect?” above.
Personal Data We Receive From Other Sources
We also receive personal data about Candidates from other sources. Depending on the relevant circumstances and applicable local laws and requirements, this will involve personal data received in the following situations:
- When we search for Candidates via third party sources, such as LinkedIn and other job sites, from which we obtain your personal information and/or when we carry out other pre-recruitment activities (please refer to the section entitled “Pre-recruitment activities” below);
- Your referees may disclose personal information about you;
- Our Clients, Suppliers, other Candidates and our colleagues within Contauro (e.g. in the context of them making a referral) may share personal information about you with us;
- If we receive your personal information from Facebook or Twitter, if you ‘like’ our Facebook page or ‘follow’ us on Twitter (or perform a similar interaction with us on any social media platform on which we have a presence); and
- If you were referred to us through an RPO or an MSP supplier, they may share personal information about you with us.
Personal Data We Collect Automatically
To the extent that you access our website or read or click on an email from us, where appropriate and in accordance with any local laws and requirements, we will also collect your data automatically (e.g. via website tracking scripts such as cookies or pixels) or through you providing it to us. For more information, please refer to the context-specific section of this Privacy Policy that applies to Website Users.
The types of information that we collect about you in this way includes the “Automatically collected information” described in the section entitled “What Kind of Personal Information Do We Collect?” above.
We generally use Candidate data in five ways:
- Pre-recruitment Activities;
- Recruitment Activities;
- Marketing Activities;
- Equal Opportunities Monitoring; and
- To help us to establish, exercise or defend legal claims.
In appropriate circumstances, we also use Candidate data for Profiling.
Pre-recruitment Activities
When conducting pre-recruitment activities, we use your data to work out whether you might be interested in, or might benefit from, our services, and to assess whether and how we might be able to assist you. If we think we can help, we will use your contact details to get in touch with you and find out if you are interested in our services (usually via email), subject to any applicable laws and requirements.
In order for us to do this, we may:
- Collect your personal data;
- Store your details (and update them when necessary) on our database so that we can contact you about our services;
- Send you an email to inform you about our processing of your personal data and to direct you towards this Privacy Policy;
- Review your information to work out whether and how our services might help you; and
- Contact you about our services.
Please note that this list is not exhaustive.
We will use your personal data for these purposes if we deem this to be necessary for our legitimate interests or in accordance with applicable employment law.
If you are not happy about this, you have the right to object and can find out more about how to do so by referring to the section entitled “How can you access, amend or take back the personal data that you have given to us” in the General Privacy Information section of this Privacy Policy.
Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements. For more information in relation to your jurisdiction, please read here.
Recruitment Activities;
One of our major area of work is recruitment – connecting the right Candidates with the right jobs. We have listed below various ways in which we will 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 subscribe to alerts about jobs;
- Recording your question and answer sessions and/or video interviews to support our recruitment services (with the recordings being analysed for training/monitoring purposes and/or shared with Clients and viewed via a secure third party platform)
- Making video recordings of your participation in training sessions or meetings for internal training/monitoring purposes and/or monitoring internal compliance standards
- Allowing you to participate in specialist online training;
- Allowing you to participate in the interactive features of our services, when you choose to do so;
- Carrying out our obligations arising from any contracts entered into between us;
- Carrying out our obligations arising from any contracts entered into between Contauro 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 local laws);
- Complying with our legal obligations in connection with the detection of crime or the collection of taxes or duties; and
- 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 will use your personal data for these purposes if we deem this to be necessary for our legitimate interests or in accordance with applicable employment law.
If you are not happy about this, you have the right to object and can find out more about how to do so by referring to the section entitled “How can you access, amend or take back the personal data that you have given to us” in the General Privacy Information section of this Privacy Policy.
Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements. For more information in relation to your jurisdiction, please read here.
Marketing Activities
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 use your data for the purposes listed below, where appropriate and in accordance with any local laws and requirements. Please note that this list is not exhaustive. To:
- enable us to develop and market other products and services;
- market our full range of recruitment services (permanent, temporary, contract, outplacement and RPO 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 Contauro’s website(s) as a success story (only where we have obtained your express consent to do so); and
- provide you with information about certain discounts and offers that you are eligible for by virtue of your relationship with Contauro.
We need your consent for some aspects of these activities which are not covered by our legitimate interests (in particular, the collection of data via cookies, and the delivery of direct marketing to you through digital channels) and, depending on the situation, we’ll ask for this via an explicit opt-in consent or soft-opt-in (which we explain further below). Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements. For more information in relation to your jurisdiction, please read 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 read below. 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 below. 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 through our preference centre, 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.
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 and in accordance with local law and requirements) 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 local laws and requirements, we will use this information on an anonymised basis to monitor our compliance with our equal opportunities policy. We may also disclose this (suitably anonymised 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 will 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.
We may collect other sensitive personal information particularly sensitive personal data about you, such as data about religious, ideological, political or trade union views or activities; health, privacy or racial or ethnic affiliation; social assistance measures; administrative and criminal prosecutions or sanctions; genetic and biometric data that uniquely identifies a natural person when permitted by local law and required for the job for which you wish to apply. We will never do this without your explicit consent.
If you would like to find out more about consent, please read below. Please note that in certain of the jurisdictions in which we operate, different rules apply to this sensitive data. For more information in relation to your jurisdiction, please read below.
To Help Us To Establish, Exercise Or Defend Legal Claims
In more unusual circumstances, we may use your personal data to help us to establish, exercise or defend legal claims.
Profiling, Algorithms and Automated Decision Making
Profiling is a type of processing activity which enables us better to understand the information that we collect about you, to help us to develop a personalised “profile” for you. This helps us to gain a better idea of how you like to interact with us and our services, the sorts of requests you like to make of us and, of course, the sorts of things you don’t like. The purpose of our building this personalised profile is to enable us to provide the best possible service to you and maximise the chances that we will be able quickly and efficiently to provide you with access to content that is most likely to be relevant and helpful to you.
We may use profiling methods in relation to your personal data for the purposes listed below, if we consider this is necessary for our legitimate interests and in accordance with any local laws and requirements. Please note that this list is not exhaustive.
- Personalising Candidates’ website experience, including in relation to the roles that are brought to their attention when visiting the website;
- Making recommendations for editorial content that we think may be of interest to Candidates (e.g. reports about developments in their industry);
- Personalising the marketing content that Candidates receive via the website, email and other marketing channels (where they have consented to that marketing);
- Place suitable Candidates on shortlists for particular roles based on prescribed criteria, which will allow our consultants to identify the most appropriate Candidates for roles in the most efficient manner efficiently;
- Recommend roles based on how a Candidate’s interests, habits, attributes and/or preferences, rank in comparison to other Candidates;
- Capture and analyse Candidates’ web-based behaviours using various items of data e.g. number of job ads read/applied for online, number and type of articles read, number of web visits made, membership of “talent pools”/segments – see below) in order to award a Candidate a weighted “approachability score” with a view to providing insights into Candidates’ needs and to allow us to follow up where needed;
- Shortlisting and ranking activities described in more detail below and as a factor in determining whether to approach/show roles to a Candidate, which will serve to supplement other data that Contauro holds about the Candidate;
- Analysing Candidates’ data by continuously tracking and monitoring their experience and account activity in order to profile them and allocate them to “talent pools” based on their attributes and behaviours (e.g. previous roles, skills, industry experience, location, when a Candidate is willing to work). Talent pools are used as a means of managing the Candidate database, placing Candidates in roles and marketing to Candidates. The assignment of Candidates to talent pools is a fully automated process and can involve the use of bots.
If you are not happy about this, in certain circumstances you have the right to object and can find out more about how and when to do this by referring to the section entitled “How can you access, amend or take back the personal data that you have given to us” in the General Privacy Information section of this Privacy Policy.
We also sometimes use automated systems such as filtering tools, or occasionally more complex tools which use an element of artificial intelligence, such as algorithms or machine learning (including those provided by third parties), to help us quickly, efficiently and more accurately to analyse data we have about you and other Candidates, as well as data we hold on our Clients’ needs, and this ultimately helps us to make decisions based on this data. This can include applying tools which use algorithms (such as filtering tools or machine learning) to Candidate personal data in order to help us come up with the best possible shortlist for a particular role. Such technology should reduce significantly the amount of time needed to consider when Candidates might be the best fit for relevant jobs. This should in turn make the recruitment process much more efficient and effective, which, we hope, will improve your overall experience with us.
As new and better technology becomes more prevalent, some of our profiling activities and our processing activities which use automated systems such as those described above, may amount to Automated Decision Making within the meaning of Article 22 of the GDPR. This means a process of making a decision by automated means with limited, or even no, human intervention in reaching the decision. We will only use automated decision making in relation to your personal data where we consider this is necessary for the completion of pre-contractual steps taken at your request.
Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements. For more information in relation to your jurisdiction, please read here.
2. Temporary Workers
This section of the Privacy Policy applies to Temporary Workers.
Temporary Workers include someone who becomes employed or engaged by Contauro for the purposes of undertaking temporary work for a Client or other Contauro group company. If you are a Temporary Worker, we will also continue to process your personal data as a Candidate throughout the duration of your temporary work assignment and thereafter, in accordance with the terms of this Privacy Policy. The question of whether and the extent to which the Staff Privacy Policy apply to you as a Temporary Worker depends on local law requirements. For more information in relation to your jurisdiction, please read below. Temp Relationship means our contractual relationship with Temporary Workers while they are employed or engaged directly by us.
If we employ or engage you as a Temporary Worker directly, we will, depending on the relevant circumstances and applicable local laws and requirements, collect some or all of the information listed below (in addition to the data collected about Candidates) in order to ensure that our Temp Relationship runs smoothly and that we are able to comply with our contractual and other duties to each other, and to our Clients, as part of our Temp Relationship and our duties to third parties such as tax authorities and government agencies. In some jurisdictions, we are restricted from processing some of the data outlined below. In such cases, we will only process the data in those jurisdictions to the extent and under the circumstances permitted by law:
- Temporary worker information
- Staff number/social security number/other identifier;
- Location of your workplace at the Client;
- Details of any complaints, whether brought by or against you or in which you are or have been otherwise involved;
- Details of any leave you take or request during our Temp Relationship;
- Details of travel undertaken;
- Details of resident/work permit;
- Where applicable:
- Details of any grievance or disciplinary matters, whether brought by or against you or in which you are or have been otherwise involved; and
- Information about your performance in your role during our Temp Relationship, including details of any bonuses or promotions you receive performance assessments and other information that relates to your employment, your interaction with colleagues and employment-related issues that arise;
- Special category information
- Details of any sickness absence including health-related information.
Please note that the above list of categories of personal data we collect is not exhaustive.
A number of elements of the items listed above are required to enable us to fulfil our contractual duties to you or to others. Some, for example your social security number (or equivalent) are required by statute or other laws. Other items may simply be needed to ensure that our Temp Relationship can run smoothly, or to run our business.
Depending on the type of personal data in question and the grounds on which we may be processing it, should you decline to provide us with such data, we may not be able to fulfil our contractual requirements or, in extreme cases, may not be able to continue with our Temp Relationship.
If we employ or engage you as a Temporary Worker directly, we collect your data (in addition to the data already collected about Candidates) in the following ways:
- Personal data that you give to us; and
- Personal data that we receive from other sources.
Below are some more details about each of these methods.
Personal Data You Give To Us
Contauro needs to know certain information about you in order to fulfil our obligations to you, to ensure that you are properly fulfilling your obligations to us, and to ensure that we are both fulfilling our obligations to others. This information will enable us to operate a usual Temp Relationship, along with all that entails.
There are numerous ways that you can share your information with us in addition to the information you share as a Candidate. Where appropriate and in accordance with any local laws and requirements, these may include:
- when you complete registration forms at the beginning of our Temp Relationship; or
- in meetings or communications with your consultant, our HR team or other colleagues.
The types of information that we receive from you in this way include:
- Temporary worker information; and
- Special category information,
as described in the section entitled “What Kind of Personal Information Do We Collect?” above
Personal Data We Receive From Other Sources
We also receive personal data about you from other sources. Depending on the relevant circumstances and applicable local laws and requirements, these may include personal data received in the following situations:
- if you were referred to us through a recruitment agency or other work agencies, they may have shared personal information about you with us;
- information obtained about you from third party service providers who undertook background checks about you on our behalf at the start of our Temp Relationship;
- your colleagues may share personal information about you with us;
- medical professionals may (in appropriate and limited circumstances) share personal information about you with us;
- your pension and benefits providers may share relevant personal information about you with us; and
- other third parties like your local tax authority may share your personal data with us.
The types of information that we receive about you in this way include:
- Temporary worker information; and
- Special category information,
as described in the section entitled “What Kind of Personal Information Do We Collect?” above.
If we employ or engage you as a Temporary Worker directly, we use your data for the following purposes:
- To ensure the smooth running of our Temp Relationship, including all of the activities that need to be undertaken in a usual relationship of that type, such as:
- facilitating payroll and invoicing processes, if relevant to your jurisdiction;
- determining the terms on which you work during your Temp Relationship;
- keeping a record of any promotions, salary rises or bonuses you are awarded;
- Assessing your performance;
- Managing absences
We will use your personal data for these purposes if we deem this to be necessary for our legitimate interests or in accordance with applicable employment law.
If you are not happy about this, you have the right to object and can find out more about how to do so by referring to the section entitled “How can you access, amend or take back the personal data that you have given to us” in the General Privacy Information section of this Privacy Policy.
The question of whether and the extent to which the Staff Privacy Policy apply to you as a Temporary Worker depends on local law requirements. For more information in relation to your jurisdiction, please read here.
3. Clients
This section of the Privacy Policy applies to Clients.
Clients include our customers, clients, and others to whom Contauro provides services in the course of its business or whom Contauro reasonably considers would be interested in our services. In certain circumstances, Contauro provides services to individual employees who work for Client organisations, such as training courses to teaching staff who work for Clients in the education sector. Please note that in this context, Contauro requires Clients to communicate the relevant parts of this Privacy Policy (namely the sections directed at Clients and Website Users) to their employees.
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 to enable us to ensure that we can reach out to you about our services, ensure our relationship runs smoothly and in certain circumstances, provide services to your employees. We also hold information relating to your online engagement with Candidate profiles and other material published by Contauro, 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 Debt Recovery teams, our calls with you may be recorded, depending on the applicable local laws and requirements. If we need any additional personal data for any reason, we will let you know:
- Key identification and contact information
About yourself or individual contacts at your organisation, including:- Names;
- Job titles;
- Telephone numbers;
- Email addresses;
- Automatically collected information
- Information relating to your online engagement with Candidate profiles;
- Information relating to your online engagement with other material published by Contauro;
- IP address;
- Usage information including the dates, times and frequency with which you access our services;
- User choices (e.g. marketing preferences);
- User reports;
- Log and troubleshooting information;
- Device information when you install, access or use our services;
- Website browsing data e.g. pages viewed (limited to Contauro websites);
- CCTV footage if you attend our premises.
- Email engagement history with Contauro;
- Location information (inferred from jobs, IP address, application history or system stored data);
- Account access information (e.g. PIN numbers for account verification purposes);
- Information that others provide about you
- Extra information that our Candidates may tell us about you, or that we find from other third party sources;
- Extra information that our Candidates may tell us about you, or that we find from other third party sources;
- Additional information that you choose to tell us
- Extra information that you or someone in your organisation has chosen to tell us, including when corresponding with us via email or otherwise.
Please note that the above list of categories of personal data we collect is not exhaustive.
To the extent that you access our website or click through any links in an email or text message from us, we will also collect certain data from you. If you would like more information about this, please refer to the context-specific section of this Privacy Policy that applies to Website Users.
We collect Client personal data in the following ways:
- Personal data that we receive from you;
- Personal data that we collect or receive from other sources; and
- Personal data that we collect automatically.
Personal Data We Receive Directly From You
- We both share the same goal – to make sure that you receive the best service for and at your organisation. We will receive data directly from you in two ways:
- Where you contact us proactively, usually by phone or email; and/or
- Where we contact you, either by phone or email, or through our consultants’ business development activities more generally.
- The types of information that we receive from you in this way include:
- Key identification and contact information; and
- Additional information that you choose to tell us,
as described in the section entitled “What Kind of Personal Information Do We Collect?” above.
Personal Data We Receive From Other Sources
- Where appropriate and in accordance with any local laws and requirements, we will seek more information about you or your colleagues from other sources generally by way of due diligence or other market intelligence:
- From third party market research and by analysing online and offline media (which we will do ourselves or employ other organisations to do for us);
- From reputable vendors of business-to-business data lists to the extent we are able to use such data from such sources in compliance with the GDPR;
- From delegate lists at relevant events; and
- 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 or where they give feedback on a particular assignment.
- The types of information that we receive about you in this way may include information that others provide about you as described in the section entitled “What Kind of Personal Information Do We Collect?” above.
Personal Data We Collect Automatically
To the extent that you access our website or read or click on an email or text message from us, where appropriate and in accordance with any local laws and requirements, we will also collect your data automatically (e.g. via website tracking scripts such as cookies or pixels) or through you providing it to us. For more information, please refer to the context-specific section of this Privacy Policy that applies to Website Users.
The types of information that we collect about you in this way include the automatically collected information as described in the section entitled “What Kind of Personal Information Do We Collect?” above.
We generally use Client information for:
- Providing our services;
- Marketing Activities;
- To help us to establish, exercise or defend legal claims.
Providing Our Services
Our services broadly consist of: (i) providing you with Candidates; (ii) RPO services; and (iii) Consultancy and advisory services. We have listed below the various ways in which we use your data in order to facilitate this. Please note that this list is not exhaustive.
- Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to our services;
- Keeping records of our conversations and meetings, so that we can provide targeted services to you;
- Undertaking customer satisfaction surveys; and
- Processing your data for the purpose of targeting appropriate marketing campaigns.
We also provide services to your employees such as training courses to teaching staff who work for our Clients in the education sector, which will require us to use their personal data in order to grant them access to these services.
In most cases, we will use your personal data for the purposes below if we deem it necessary to do so for our legitimate interests.
Article 6(1)(f) of the GDPR 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 activities in relation to which we rely on the legitimate interests condition prejudice Clients in any way. 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 refer to the section entitled “How can you access, amend or take back the personal data that you have given to us” in the General Privacy Information section of this Privacy Policy.
Please note that in certain jurisdictions in which we operate, we comply with additional local law requirements. For more information in relation to your jurisdiction, please read here.
Marketing Activities
Subject to any applicable local laws and requirements, we will not, as a matter of course, seek your consent when sending marketing materials 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 by referring to the section entitled “How can you access, amend or take back the personal data that you have given to us” in the General Privacy Information section of this Privacy Policy.
Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements regarding marketing activities. For more information in relation to your jurisdiction, please read here.
To Help Us To Establish, Exercise Or Defend Legal Claims
In more unusual circumstances, we may use your personal data to help us to establish, exercise or defend legal claims.
4. Suppliers And Other Third Parties
This section of the Privacy Policy applies to Suppliers.
Suppliers include partnerships and companies (including sole traders), and atypical workers such as independent contractors and freelance workers, who provide services to Contauro. In certain circumstances Contauro will sub-contract the services it provides to Clients to third party suppliers who perform services on Contauro’s behalf. In this context, suppliers that are individual contractors, freelance workers, or employees of suppliers will be treated as Candidates for data protection purposes. Please note that in this context, Contauro requires Suppliers to communicate the relevant parts of this Privacy Policy (namely the sections directed at Candidates) to their employees.
This section of the Privacy Policy also applies to other parties with which we have a business or other type of relationship (ranging from investors to charitable organisations).
We don’t collect much data about Suppliers and other third parties with which we conduct a business relationship (e.g. investors) – we simply need to make sure that our relationship runs smoothly. We’ll collect the details of contacts within your organisation, such as names, telephone numbers and email addresses. In the case of Suppliers, 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 a Supplier engages with our Finance and Debt Recovery teams, our calls with you may be recorded, depending on the applicable local laws and requirements:
- Key identification and contact information
About yourself or individual contacts at your organisation, including:- Names;
- Job titles;
- Telephone numbers;
- Email addresses;
- Business account bank details;
- Identification number;
- Information that others provide about you
- Extra information that our Candidates or Clients may tell us about you, or that we find from other third party sources;
- Extra information that our Candidates or Clients may tell us about you, or that we find from other third party sources;
- Additional information that you choose to tell us
- Extra information that you or someone in your organisation has chosen to tell us, including when corresponding with us via email or otherwise.
- Extra information that you or someone in your organisation has chosen to tell us, including when corresponding with us via email or otherwise.
Please note that the above list of categories of personal data we collect is not exhaustive.
To the extent that you access our website or click through any links in an email or text message from us, we will also collect certain data from you. If you would like more information about this, please refer to the context-specific section of this Privacy Policy that applies to Website Users.
We collect Supplier and other third party data in the following ways:
- Personal data that we receive from you;
- Personal data that we collect or receive from other sources.
Personal Data We Receive Directly From You
- We will receive data directly from you in two ways:
- Where you contact us proactively, usually by phone or email; and/or
- Where we contact you, either by phone or email.
- The types of information that we receive from you in this way include:
- Key identification and contact information; and
- Additional information that you choose to tell us,
as described in the section entitled “What Kind of Personal Information Do We Collect?” above.
Personal Data We Receive From Other Sources
- Where appropriate and in accordance with any local laws and requirements, we will seek more information about you or your colleagues from other sources generally by way of due diligence or other market intelligence:
- From third party market research and by analysing online and offline media (which we will do ourselves or employ other organisations to do for us);
- From reputable vendors of business-to-business data lists to the extent we are able to use such data from such sources in compliance with the GDPR;
- From delegate lists at relevant events; and
- From other limited sources and third parties.
- The types of information that we receive about you in this way may include information that others provide about you as described in the section entitled “What Kind of Personal Information Do We Collect?” above.
We have listed below the various ways in which we use your data in general. Please note that this list is not exhaustive.
- Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to our agreements;
- Keeping records of our conversations and meetings;
- To perform certain legal obligations;
- To help us to target appropriate marketing campaigns; and
- In more unusual circumstances, to help us to establish, exercise or defend legal claims.
We will use your personal data for these purposes if we deem this to be necessary for our legitimate interests or in accordance with applicable employment law.
We will not, as a matter of course, seek your consent when sending marketing messages to a corporate postal or email address.
If you are not happy about this, you have the right to object and can find out more about how to do so by referring to the section entitled “How can you access, amend or take back the personal data that you have given to us” in the General Privacy Information section of this Privacy Policy.
Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements. For more information in relation to your jurisdiction, please read here.
5. People Whose Data We Receive From Candidates And Staff, Such As Referees And Emergency Contacts
This section of the Privacy Policy applies to People Whose Data we receive from Candidates and Contauro’s Staff. These may include emergency contacts and referees. We will only contact them in appropriate circumstances.
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.
We will collect your date of birth, contact details and potentially some health information if a member of our Staff has put you down as a dependant or any other kind of beneficiary for a benefit connected with their employment or if a member of our Staff exercises certain employment rights. We may also be provided (by inference) with some limited information about your sexual orientation if a member of our Staff identifies you as a spouse or partner when putting you down as a dependant, next of kin or emergency contact:
- Key identification and contact information
- Name;
- Age/Date of birth
- Marital status;
- Contact details;
- Use of Staff member’s company vehicle;
- Special category of information
- Details of sexual orientation (inferred) and physical or mental health, for example if this is necessary in connection with a beneficiary’s entitlement to a benefit connected with their employment or where you disclose this through providing next-of-kin details;
- Details of sexual orientation (inferred) and physical or mental health, for example if this is necessary in connection with a beneficiary’s entitlement to a benefit connected with their employment or where you disclose this through providing next-of-kin details;
- Information that others provide about you
- Extra information that your referrer chooses to tell us about you;
- Extra information that a member of Staff may tell us about you;
- Additional information that you choose to tell us
- Any other information that you may provide to us including when corresponding with us via email or otherwise.
- Any other information that you may provide to us including when corresponding with us via email or otherwise.
Please note that the above list of categories of personal data we collect is not exhaustive.
To the extent that you access our website or click through any links in an email or text message from us, we will also collect certain data from you. If you would like more information about this, please refer to the context-specific section of this Privacy Policy that applies to Website Users.
We will only use the information that our Candidates or Staff give us about you for the following purposes:
- If our Candidates or Staff members put you down on our form as an emergency contact, we’ll contact you in the case of an accident or emergency affecting them;
- If you were put down by a Staff member or Temporary Worker as a next of kin or dependant or any other kind of beneficiary, we will store your personal data to ensure the personnel records of that Staff member or Temporary Worker are correct, and use your personal data where necessary to provide employee benefits and pay remuneration and disclose your data to the relevant benefits provider; or
- If you were put down by a Candidate or prospective Staff member as a referee, we will contact you to get a reference or give your details to a third party to do this on our behalf. Where you are being asked to give a reference based on their professional experience of a Candidate, and where we think that you may be interested in becoming a Client of ours, we may also use your details to reach out to get in touch in that alternative capacity (subject to any local laws and requirements).
We will use your personal data for these purposes if we deem this to be necessary for our legitimate interests or in accordance with applicable employment law.
If you are not happy about this, you have the right to object and can find out more about how to do so by referring to the section entitled “How can you access, amend or take back the personal data that you have given to us” in the General Privacy Information section of this Privacy Policy.
Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements. For more information in relation to your jurisdiction, please read here.
6. Website Users
This section of the Privacy Policy applies to Website Users.
Website Users include any individual who accesses any of the Contauro websites or any of the Contauro mobile applications (apps).
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 or mobile apps and to help us manage the services we provide. This comprises information such as how you use our website or our mobile apps, the frequency with which you access our website or mobile apps, your browser type, your type of device, the location you view our website from, the language you choose to view it in and the times that our website is most popular. If you contact us via the website or the mobile apps, for example by using the chat function, or when you register for one of our newsletters, webinars or participate in any further offer of our website or mobile apps, we will collect any information that you provide to us, for example your name and contact details:
- Key identification and contact information
- Names;
- Telephone numbers;
- Email addresses;
- Automatically collected information
- Information relating to your online engagement with material published by Contauro;
- IP address;
- Extra Usage information that you choose to tell us; including the dates, times and frequency with and location from which you access our services;
- User choices;
- User reports;
- Log and troubleshooting information;
- Device information when you install, access or use our services;
- Account access information (e.g. PIN numbers for account verification purposes);
- Additional information that you choose to tell us
- Any other information that you may provide to us including when corresponding with us via email or otherwise.
Please note that the above list of categories of personal data we collect is not exhaustive.
When you visit our website or mobile apps there is certain information that we will automatically collect, whether or not you decide to use our services namely your IP address, the date and the times and frequency with which you access the website or the mobile apps, the way you browse its content and other technical information. We will also collect data from you when you contact us via the website or the mobile apps, for example by using the chat function or when you register for one of our newsletters, webinars or participate in any further offer of our website or mobile apps.
We collect your data automatically via cookies or similar technology such as tracking pixels and HTML5 Local Storage in line with the cookie settings that you specify via the “Cookie Preferences” link at either the top or bottom of the website, or the settings in your browser. If you are also a Candidate or a Client of Contauro, we will use data from your use of our websites to enhance other aspects of our communications with or service to you. If you would like to find out more about cookies or similar technology, including how we use them and what choices are available to you, please refer to the section entitled “Cookies” in the General Privacy Information section of this Privacy Policy.
The types of information that we collect about you in this way include:
- Key identification and contact information;
- Automatically collected information.
as described in the section entitled “What Kind of Personal Information Do We Collect?” above.
We use your data to:
- provide you with the service you registered for or the services you participated in, for example sending you a newsletter or taking part in an online survey;
- protect our Systems from attacks and other illegal activities; and
- to help us to improve your experience of using our website or our mobile apps, for example by analysing your recent job search criteria to help us to present jobs or Candidates to you that we think you’ll be interested in.
We will use your personal data for these purposes if we deem this to be necessary for our legitimate interests.
If you are not happy about this, you have the right to object and can find out more about how to do so by referring to the section entitled “How can you access, amend or take back the personal data that you have given to us” in the General Privacy Information section of this Privacy Policy.
If you would like to find out more about cookies or similar technology, including how we use them and what choices are available to you, please refer to the section entitled “Cookies” in the General Privacy Information section of this Privacy Policy.
Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements. For more information in relation to your jurisdiction, please read here.
General Privacy Information
1. Who Do We Share Your Personal Data With?
Where appropriate and in accordance with local laws and requirements, we generally share your personal data with the following categories of people:
- Any of our group companies;
- Appropriate colleagues within Contauro (this may include colleagues in overseas offices);
- Individuals and organisations 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);
- Service providers (whether third parties or our group companies) who perform functions on our behalf (including external consultants, business associates and professional advisers such as lawyers, auditors and accountants, administration functions, 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; and
- If Contauro 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.
There are also certain categories of people that we share your personal data with if you are a Candidate, Temporary Worker or Person whose data we receive (e.g. a referee).
If you are a Candidate, we may also share your personal data with the following categories of people:
- potential employers and other recruitment agencies/organisations to increase your chances of finding employment;
- third party partners, job boards, job platforms, job aggregators, software providers and cloud based databases where we consider this will improve the chances of finding you the right job or improving recruitment processes more generally;
- 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;
- internal and external auditors of our Clients when we are required to share this data with them upon request in order to comply with our contractual or regulatory obligations; and
- third parties helping us by developing services and processes to optimise the Candidate selection process in order to improve the quality and efficiency of recruitment services.
If you are a Temporary Worker, we may also share your personal data with the following categories of people:
- in limited circumstances as appropriate, medical professionals such as your GP or an occupational health specialist;
- the Client where you as a Temporary Worker are or will be working; and
- prospective employers (for example, when providing a reference, where permissible in accordance with local laws and requirements).
If you are a referee of one of our Candidates, we may also share your personal data with the following categories of people:
- 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; and
- internal and external auditors of our Clients when we are required to share this data with them upon request in order to comply with our contractual or regulatory obligations.
2. 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 unauthorised access. We do this by having in place a range of appropriate technical and organisational measures. These include measures to deal with any suspected data breach.
If you suspect any misuse or loss of or unauthorised access to your personal information please let us know immediately. Details of how to contact us can be found below.
3. How Long Do We Keep Your Personal Data For?
In determining the appropriate retention period for different types of personal data, we always consider the amount, nature, and sensitivity of the personal data in question, the potential risk of harm from unauthorised use or disclosure of that personal data, the purposes for which we need to process it and whether we can achieve those purposes by other means (in addition of course to ensuring that we comply with our legal, regulatory and risk-management obligations).
We set out below the retention practices that we apply to certain categories of people.
If you are a Candidate, we will keep your personal data on our Systems for a period of up to two years from the point that we collect such personal data or subsequently have meaningful contact with you (or, where appropriate, the company you are working for or with).After this period, it is likely your data will no longer be relevant for the purposes for which it was collected. We may keep your personal data on our Systems for a longer period than this if we believe in good faith that we need to do so, for example, because of our obligations to tax authorities or in connection with any anticipated litigation.
We will consider there to be meaningful contact with you in this context if you, for example, submit a CV to us via our website, take part in any of our online training, communicate with us about potential roles (either by verbal or written communication) or click through from any of our marketing communications. Your receipt, opening or reading of an email or other digital message from us will not count as meaningful contact for these purposes, only where you click-through or reply directly – we will only deem that we have had meaningful contact with you if there is positive action on your part.
For those Candidates whose services are provided via a third party company or other entity, meaningful contact with you means meaningful contact with the company or entity which supplies your services. Where we are notified by such company or entity that it no longer has that relationship with you, we will retain your data for no longer than two years from that point or, if later, for the period of two years from the point we subsequently have meaningful contact directly with you.
If you have expressly indicated as a Candidate that you would rather we didn’t retain your personal data, then we will Delete it from our Systems unless we believe in good faith that we need to preserve it, for example, because of our obligations to tax authorities or in connection with any anticipated litigation.
If we employ or engage you as a Temporary Worker directly, we will ordinarily process your data throughout the course of your Temp Relationship and will then retain it for a period after we have parted ways. The precise length of time will depend on the type of data, our legitimate business needs and other legal or regulatory rules that may require us to retain it for certain minimum periods. For example, we may be required to retain certain data for the purposes of tax reporting or responding to tax queries. We may also retain it if it might be relevant to any potential litigation. In jurisdictions that allow it, we will generally retain personal data relating to you where necessary to enable us to provide you or a future employer with a reference.
If you are a Temporary Worker, we will also continue to process your personal data as a Candidate through the duration of your Temp Relationship and thereafter. The question of whether and the extent to which we will continue to process your personal data as Staff data through the duration of your Temp Relationship and thereafter depends on local law requirements. For more information in relation to your jurisdiction, please read below.
If you are a Client or a Supplier we will retain your personal data in order to provide you with services or to receive services from you, or to provide you with information about our services that we believe you may be interested in.
If you have expressly indicated that you’re not interested in our services, then we will Delete your personal data from our Systems unless we believe in good faith that we need to preserve it, for example, because of our obligations to tax authorities or in connection with any anticipated litigation.
If you are a Website User we will retain your IP address and any other information that is required to operate the website or our mobile apps for 365 days.
We will otherwise retain your data for as long as it is necessary to achieve the purpose it was collected or processed for. If this time has come or you have expressly indicated that you’re not interested in one of our website or mobile app services anymore, we will Delete it from our Systems unless we believe in good faith that we need to preserve it, for example, because of our obligations to tax authorities or in connection with any anticipated litigation.
4. How Can You Access, Amend Or Take Back The Personal Data That You Have Given To Us?
One of the GDPR’s main objectives is to protect and clarify the rights of EU citizens and individuals in the EU with regards to data privacy. This means that you retain various rights in respect of your data, even once you have given it to us. These are described in more detail below.
- To get in touch about these rights, please contact us. We will seek to deal with your request without undue delay, and in any event within one month (subject to any extensions to which we are lawfully entitled). Please note that we will, where necessary, keep a record of your communications to help us resolve any issues which you raise.
- Right to object: this right enables you to object to us processing your personal data where we do so for one of the following four reasons: (i) our legitimate interests; (ii) to enable us to perform a task in the public interest or exercise official authority; (iii) to send you direct marketing materials; and (iv) for scientific, historical, research, or statistical purposes.
- The “legitimate interests” and “direct marketing” categories above are the ones most likely to apply to our Website Users, Candidates, Temporary Workers, Clients and Suppliers. If your objection relates to us processing your personal data because we deem it necessary for your legitimate interests, we must act on your objection by ceasing the activity in question unless:
- we can show that we have compelling legitimate grounds for processing which overrides your interests; or
- we are processing your data for the establishment, exercise or defence of a legal claim.
- If your objection relates to direct marketing, we must act on your objection by ceasing this activity.
- Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example, in order to use cookies or pixels in certain jurisdictions), you may withdraw this consent at any time and we will cease to carry out the particular activity that you previously consented to unless we consider that there is an alternative reason to justify our continued processing of your data for this purpose in which case we will inform you of this condition.
- Data Subject Access Requests (DSAR): You may ask us to confirm what information we hold about you at any time, and request us to modify, update or Delete such information. We may ask you to verify your identity and for more information about your request. If we provide you with access to the information we hold about you, we will not charge you for this unless your request is “manifestly unfounded or excessive”. If you request further copies of this information from us, we may charge you a reasonable administrative cost where legally permissible. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons for doing so.
- Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements regarding data subject access requests and may refuse your request in accordance with such laws. For more information in relation to your jurisdiction, please read below.
- Right to erasure: You have the right to request that we erase your personal data in certain circumstances. Normally, the information must meet one of the following criteria:
- the data are no longer necessary for the purpose for which we originally collected and/or processed them;
- where previously given, you have withdrawn your consent to us processing your data, and there is no other valid reason for us to continue processing;
- the data has been processed unlawfully (i.e. in a manner which does not comply with the GDPR);
- it is necessary for the data to be erased in order for us to comply with our legal obligations as a data controller; or
- if we process the data because we believe it necessary to do so for our legitimate interests, you object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.
- Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements regarding data subject right to erasure and may refuse your request in accordance with local laws. For more information in relation to your jurisdiction, please read below.
- We would only be entitled to refuse to comply with your request for one of the following reasons:
- to exercise the right of freedom of expression and information;
- to comply with legal obligations or for the performance of a public interest task or exercise of official authority;
- for public health reasons in the public interest;
- for archival, research or statistical purposes; or
- to exercise or defend a legal claim.
- When complying with a valid request for the erasure of data we will Delete the relevant data.
- Right to restrict processing: You have the right to request that we restrict our processing of your personal data in certain circumstances. This means that we can only continue to store your data and will not be able to carry out any further processing activities with it until either: (i) one of the circumstances listed below is resolved; (ii) you consent; or (iii) further processing is necessary for either the establishment, exercise or defence of legal claims, the protection of the rights of another individual, or reasons of important EU or Member State public interest.
- The circumstances in which you are entitled to request that we restrict the processing of your personal data are:
- where you dispute the accuracy of the personal data that we are processing about you. In this case, our processing of your personal data will be restricted for the period during which the accuracy of the data is verified;
- where you object to our processing of your personal data for our legitimate interests. Here, you can request that the data be restricted while we verify our grounds for processing your personal data;
- where our processing of your data is unlawful, but you would prefer us to restrict our processing of it rather than erasing it; and
- where we have no further need to process your personal data but you require the data to establish, exercise, or defend legal claims.
- If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data.
- Right to rectification: You also have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. Where appropriate, we will also tell you which third parties we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.
- Right of data portability: If you wish, you have the right to transfer your personal data between data controllers. In effect, this means that you are able to transfer your Contauro account details to another online platform. To allow you to do so, we will provide you with your data in a commonly used machine-readable format that is password-protected so that you can transfer the data to another online platform. Alternatively, we will directly transfer the data for you. This right of data portability applies to: (i) personal data that we process automatically (i.e. without any human intervention); (ii) personal data provided by you; and (iii) personal data that we process based on your consent or in order to fulfil a contract.
- Right to lodge a complaint with a supervisory authority: You also have the right to lodge a complaint with your local supervisory authority. Details of how to contact them can be found below.
- If you would like to exercise any of these rights, or withdraw your consent to the processing of your personal data (where consent is our legal basis for processing your personal data), details of how to contact us can be found below. Please note that we will, where necessary, keep a record of your communications to help us resolve any issues which you raise.
- You may ask to unsubscribe from job alerts and other marketing communications from us at any time. Details of how to do so can be found below.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the period for which we hold your data.
5. Who Is Responsible For Processing Your Personal Data?
You can find out which Contauro entity is responsible for processing your personal data and where it is located below in Annex 1.
If you have any comments or suggestions concerning this Privacy Policy please use the contact details specified below in Annex 1. We take privacy seriously so we’ll get back to you as soon as possible.
6. How Do We Store And Transfer Data Internationally?
So you want to know more about how we store and transfer your data internationally? In order to provide you with the best service and to carry out the purposes described in this Privacy Policy, your data will be transferred:
- between and within Contauro entities;
- to third parties (such as advisers or other Suppliers to the Contauro business);
- to overseas Clients where applicable;
- to Clients within your country, where applicable, who may, in turn, transfer your data internationally;
- to a cloud-based storage provider; and
- to other third parties as set out in the section entitled “Who do we share your personal data with” above.
We want to make sure that your data are stored and transferred in a way which is secure. We will therefore only transfer data outside of the European Economic Area or EEA (i.e. the Member States of the European Union, together with Norway, Iceland and Liechtenstein) where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, for example:
- by way of data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission for the transfer of personal data by data controllers in the EEA to data controllers and processors in jurisdictions without adequate data protection laws; or
- transferring your data to a country where there has been a finding of adequacy by the European Commission in respect of that country’s levels of data protection via its legislation; or
- by way of scheme approved by the European Commission (whether as a successor to the Privacy Shield or otherwise) which regulates exchanges of person data between jurisdictions; or
- where it is necessary for the conclusion or performance of a contract between ourselves and a third party and the transfer is in your interests for the purposes of that contract (for example, if we need to transfer data outside the EEA in order to meet our obligations under that contract if you are a Client of ours); or
- where you have consented to the data transfer.
To ensure that your personal information receives an adequate level of protection, we have put in place appropriate procedures with the third parties we share your personal data with to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the law on data protection.
7. Cookie Policy
A “cookie” (or similar technology such as a tracking pixel) (“Cookie”) is a very small text file or graphic that is placed on your device when you visit a webpage or open an email and which records your behaviour (such as navigation of a website). Cookies are used to enhance your use of the various Contauro digital channels, for example by enabling us to present tailored content and 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 digital channels and do not harm your system. We use them irrespective of whether you interact with Contauro via our website, an app or other digital channel, and regardless of whether you are a Candidate, Temporary Worker, Client, Supplier, Website User or someone else.
If you want to check or change what types of Cookies you accept, this can usually be altered using the privacy settings within your browser, or you can do so very easily using the “Cookie Preferences” link at either the top or bottom of the website. Please note that if you access Contauro’s services across multiple devices, you may need to adjust your settings via the Cookie Preferences link on each of your devices.
We use Cookies to do the following:
- to personalise your experience of our digital channels and to enhance their functionality, for example:
- to keep you signed in to your account throughout your visit;
- to tailor and increase the relevance of the content that you see (which may vary depending on whether you are a Candidate, Temporary Worker, Client, Supplier, Website User or someone else, and also according to your preferences) which we hope will in turn increase engagement with and improve the experience of using our services (and encourage you to return);
- if you are a Candidate, to personalise marketing content that we make available to you via our digital channels (where you have consented to that marketing) which we hope will increase application numbers, conversion rates and application usefulness;
- to understand how you engage with our website and other digital channels, for example by tracking the pages you have visited, the interactions you have made, the links you have followed, and the number of job ads and articles read. This enables us to understand how you use our digital channels, tailor what we show and send to you, and track any patterns that emerge individually or from larger groups. This helps us to develop and improve our digital channels and services in response to what our visitors want and need (and we understand that those wants and needs vary depending on whether you are a Candidate, Temporary Worker, Client, Supplier, Website User or someone else) which in turn helps us increase engagement with and improve the experience of using our services by increasing the relevance of the content that we serve. Also, as described above in the sections on “Profiling, Algorithms and Automated Decision Making”, the process of analysing web-based behaviours enables us to award Candidates a weighted “approachability score” with a view to providing insights into Candidates’ needs and allow Contauro to follow up where needed, and Consultants use these scores as part of shortlisting and ranking Candidates and as a factor in determining whether to approach/show roles to a Candidate, which will serve to supplement other data that Contauro holds about the Candidate; and
- if you are a Candidate:
- to help us advertise jobs to you that we think you’ll be interested in, by personalising the roles that are brought to your attention;
- to personalise our recommendations for editorial content (such as reports about developments in your industry) that we think may be of interest;
- to enrich Candidate data and existing profiles about Candidates that we already hold on our Systems;
- analysing data obtained by tracking and monitoring Candidates’ experience and account activity in order to profile Candidates and allocate them to “talent pools” based on their attributes and behaviours (e.g. previous roles, skills, industry experience, location, or when a Candidate is willing to work) – as described above in the sections on “Profiling, Algorithms and Automated Decision Making”, the assignment of Candidates to talent pools is a fully automated process and can involve the use of bots.
Hopefully this means less time for you trawling through endless pages and will get you into the employment you want more quickly.
Cookies are either:
- Session cookies: these are only stored on your device during your browser session and automatically expire when you close your browser – they allow the website to recognise and link your actions during a browsing session and usually store an anonymous session ID allowing you to browse a website without having to log in to each page, but they do not collect any information from your device; or
- Persistent cookies: a persistent cookie is stored on your device in between browsing sessions and so it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again. We use persistent cookies for Google Analytics and for personalisation (see above for more information about what personalisation may involve and also the sections above on “Profiling, Algorithms and Automated Decision Making”).
Cookies can also be categorised as follows:
- Strictly required cookies: These cookies are essential to enable you to use the website effectively, such as when applying for a job, and therefore cannot be turned off. Without these cookies, the services available to you on our website cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
- Functionality cookies: These cookies enable us to monitor and improve the performance of our website. For example, they allow us to count visits, identify traffic sources and see which parts of the site are most popular. Furthermore these cookies allow our website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced features. For instance, we may be able to provide you with news or updates relevant to the services you use. These cookies can also be used to remember changes you have made to text size, font and other parts of web pages that you can customise. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymised.
- Advertisement cookies: These cookies help us to advertise details of potential job opportunities that we think may be of interest. These cookies are persistent (for as long as you are registered with us) and mean that when you log in or return to the website, you may see advertising for jobs that are similar to jobs that you have previously browsed.
The Cookie Preferences link on our website provides a list of the Cookies we use in your jurisdiction, why we use them and what types of Cookies they are.
When you first visit our website(s) you will be asked to choose what kind of Cookies you want to receive. We ask for your prior consent for some Cookies via the Cookie Preferences link, while we may set strictly necessary Cookies without your consent. You may also use the privacy settings within your browser to do this. Please be aware that rejecting all Cookies through your browser’s privacy settings will mean that you may not be able to take full advantage of all our website’s features. Each browser is different, so check the “Help” menu of your browser to learn how to change your Cookie preferences.
You can update your given consent at any time via the Cookie Preferences link. You may also choose to opt-out of Cookies which are not strictly necessary to perform basic features of our website by changing your browser settings. If you use the Cookie Preferences link to update your choice of Cookies, please note that this does not result in deletion of already placed Cookies on your device. If you want to delete these Cookies you should do so using your browser’s privacy settings.
If you choose to delete all Cookies through your browser’s privacy settings, this will also delete any record of having opted-out that may be stored by a Cookie on your device (so that the opt-out can continue to be actioned) and you may need to actively opt-out again.
8. Third Party Services
In the course of using our services, Candidates and Temporary Workers may wish to access independent websites and third party services (e.g. job platforms) which are not operated by us. Such independent sites and third parties are not under our control, and we are not responsible for and have not checked and approved their content or their privacy policies (if any). You will need to make your own independent judgement about whether to use any such independent sites, including whether to use any services offered by the third party.
Occasionally, third party service providers that we have engaged will process personal data that we given to them as a data controller in their own right, for example, for the purposes of: (i) conducting their own internal reporting, (ii) preventing or responding to threats to the security or integrity of their systems; (iii) establishing, exercising or defending their own legal claims; (iv) complying with legal obligations that apply to them; and (v) using personal data in anonymised or aggregated form to improve their own products and services. They will usually have their own privacy policies which set out more detail in relation to these processing activities.
Attachments
Annex 1: How To Contact Us
Country in which you use Contauro’s services or supply Contauro with services
Switzerland
Contauro entity responsible for processing personal data
Contauro AG, 6300 Zug
How you can get in touch with us
For any topic related to your personal data, such as
- to access, amend or take back the personal data that you have given to us;
- if you suspect any misuse or loss of or unauthorised access to your personal information;
- to withdraw your consent to the processing of your personal data (where consent is the legal basis on which we process your personal data);
- with any comments or suggestions concerning this Privacy Policy
you can write to us at the following address:
Contauro AG
Datenschutzbeauftragter/DPO
Industriestrasse 24
6300 Zug
Switzerland
Alternatively, you can send an email to our Data Protection Officer and the data protection team: datenschutz@contauro.com.
How you can get in touch with us to update your marketing preferences
You can do this by updating your profile here.
Alternatively you can email us at: service@contauro.com or by clicking the unsubscribe link in any marketing email we send to you.
Annex 2: How To Contact Your Local Supervisory Authority
Country in which you use Contauro’s services or supply Contauro with services
Switzerland
Contact of your local supervisory authority
Office of the Federal Data Protection and Information Commissioner.
Eidgenössischer Datenschutz- und Öffentlichkeitsbeauftragter
Feldeggweg 1
3003 Bern
Switzerland
Web: https://www.edoeb.admin.ch
Phone: +41 (0)58 462 43 95
Fax: +41 (0)58 465 99 96
Annex 3: Country-specific legal requirements
Jurisdiction: Switzerland
Legal Basis And Applicable Law
When we refer to the GDPR in our Privacy Policy, we also mean the corresponding provision from the Federal Data Protection Act (FADP) in each case.
Disclosure Of Personal Data Abroad
We transfer your data worldwide, should this be necessary for the processing of your data from our point of view. The safeguards we refer to when transferring data outside of Switzerland can be found above in the section “How do we store and transfer data internationally”.
DSARs
If you request information from us about whether personal data about you is being processed (DSAR), you must do so in writing or via the electronic channels we offer. We do not agree to receive your requests verbally (Art. 16 para. 1 DPA).
Consent To Cooperation
The candidate acknowledges and accepts,
- that Contauro provides its services throughout Switzerland and will therefore pass on his details to all Contauro branches in Switzerland;
- that Contauro may verify the references provided by him/her with former employers and other reference providers or have them verified by third parties;
- that Contauro will offer him/her all services in Switzerland, as well as beyond the country’s borders, and will help him to find the right project or job. Therefore, Contauro will also share his/her data with other Contauro group companies in Switzerland and the European Economic Area for the provision of recruitment services
- that the personal data collected from him, including sensitive personal data, may be transferred to (a) other group companies and third parties to be processed under their own responsibility for legitimate purposes (e.g. group-wide personnel statistics, employee programmes, compliance, IT operations, directories) and (b) third party service providers to enable the employee to benefit from services co-financed or supported by Contauro. These recipients may be located in Switzerland or abroad;
- that Contauro may also process his/her data for the purposes described in this privacy statement beyond the end of the agreement or an successful placement (which significantly increases the chances of finding further employment with Contauro).
These consents are independent of each other and are freely given. The candidate may revoke his/her aforementioned consent for data processing at any time for the future by sending Contauro an email with his/her revocation to optout@contauro.com.
Marketing, Retargeting And Market Research Purposes
Soft-Opt-In
As described in the main body of our Privacy Policy, we are entitled to rely on “soft-opt-in” consent in respect of certain marketing messages that we wish to send to you. The conditions that apply to our using of soft-opt-in consent are that: (i) we have obtained your email address in connection with the sale of goods or services; (ii) we use that address only for direct advertising of our own (or substantially similar) services; (iii) you have not objected to this use; and (iv) we clearly advise you, in each such communication, of your right to opt-out.
Opt-in
In all other e‑marketing circumstances, we are required to obtain your specific “opt-in” consent and we are required to keep records of such consent having been received. To comply with our obligations under the Act Against Unfair Competition, we undertake what is commonly known as the “double-opt-in” consent procedure, which is where we first ask you to opt-in to receive e‑marketing, and we then send you an email asking you to confirm that you have given your consent. We may only add you to our marketing list once we have received this second email confirmation.
Retargeting
When you consented to the transfer of data to our advertising partners we send your data (e.g. your email address, your name, your phone number) in an encrypted and pseudonymised way (so called “hashed”) to our advertising partners (for a list of our advertising partners, see below). They compare this data with the data they already process about you and if they match, the partners enable us to run targeted advertising on those matches or on similar groups of people like you, which means the partners display on their platforms Contauro advertising which are specially designed for you or for people like you. After the creation of the matches, your encrypted data is automatically deleted again at our partners. The partners do not gain new addresses as a result of this. We think this is a great benefit for you as you get only those advertising which suits your needs.
Contauro group companies & Contauro advertising partners
When we mention Contauro companies in Switzerland in the context of our advertising consent wording, we mean the following legal entities:
- Contauro AG, based in Switzerland
- Sasera AG, based in Switzerland
When we talk about advertising partners in the context of our advertising consent wording, we mean the following partners:
- Facebook Inc, based in the USA, (https://www.facebook.com/about/privacy/update)
- LinkedIn Corporation based in the USA, (https://www.linkedin.com/legal/privacy-policy?trk=homepage-basic_footer-privacy-policy)
- Google Ireland Limited, based in Ireland (https://policies.google.com/privacy)
Transfer outside of Switzerland and the EWR
Where we have asked you for your marketing consent regarding our advertising partners and where those parties are located outside of Switzerland or the European Economic Area, you consent (Art. 6 VI FADP) to a transfer outside of Switzerland and the European Economic Area, and you are aware that there might be a lower level of data protection with these providers/countries than it is the case in Switzerland and the European Economic Area.
There might be in particular a risk that your data may be accessed through authorities for surveillance purposes, even without legal redress procedures. Exercising data protection rights, you know, and you are familiar with under the FADP may be more difficult or even impossible.
Market Research Purposes
When you consented to the use of your personal data for market research purposes, this means that we will run surveys regarding satisfaction, NetPromoterScore, personnel topics, wishes, offers, socio-demographic characteristics, new platform testing, test groups, UX testing and brand panels.
Processing of Video Recordings
We may from time to time record your question and answer sessions and/or video interviews to support our recruitment services for you and our work in finding opportunities for Clients. The video recordings shall be shared with Clients and viewed via a secure third party platform. Video recordings will be removed from the third party platform once they are no longer needed or if a Candidate requests deletion. Video recordings will be retained by Contauro in line with normal Contauro’s retention policy.
Glossary
Candidates — include individuals with whom Contauro has not had prior contact, but whom Contauro reasonably considers would be interested in, or might benefit from, Contauro’s services and being considered for any roles advertised or promoted by Contauro including permanent, part-time and temporary positions and freelance roles with Contauro’s Clients (including those individuals who want to become Temporary Workers). Candidates also include applicants for such roles as well as people who have supplied a speculative CV to Contauro not in relation to a specific job and/or who have engaged with Contauro about Contauro’s services and/or any roles advertised or promoted by Contauro. Individual contractors, freelance workers and employees of suppliers or other third parties put forward for roles with Contauro’s Clients as part of an MSP offering or otherwise will be treated as Candidates for the purposes of this Privacy Policy.
Clients — while it speaks for itself, this category covers our customers, clients, and others to whom Contauro provides services in the course of its business or whom Contauro reasonably considers would be interested in our services.
Delete – In this day and age it is virtually impossible to guarantee the permanent and irretrievable deletion of electronic data. In addition, as we have explained to you in this Privacy Policy, sometimes we will be obliged by law or regulation, or need for risk-management reasons, to retain the ability to access certain elements of personal data. However, our commitment to you is that once your personal data reaches the end of its nominal retention period, or where we receive a valid request from you to erase it, we will put in place specific operational and Systems measures to ensure that your data is “put beyond use”. By this we mean that while the data will still technically exist on an archive system, we will ensure that it cannot be readily accessed by any of our operational Systems, processes or Staff. Only a very (and we mean exceptionally) small number of senior Staff, in very (and, again, we mean exceptionally) limited and carefully prescribed situations, will be able to restore your personal data so that it can be viewed for those legitimate purposes. Once we are clear that all relevant legally mandated retention periods have expired (which, for present purposes, we expect to be the period of seven years), we will go the additional final step of undertaking a “hard delete”, whereby not even that very limited number of senior Staff would be able to restore your personal data.
General Data Protection Regulation (GDPR) – a European Union statutory instrument which aims to harmonise European data protection laws. It has an effective date of 25 May 2018, and any references to it should be construed accordingly to include any related national data protection legislation.
Managed Service Provider (MSP) programmes – Clients’ outsourcing of the management of external staff (including freelance workers, independent contractors and temporary employees) to an external recruitment provider.
Other people whom Contauro may contact – these may include Candidates’ and Contauro’s Staff emergency contacts and referees. We will only contact them in appropriate circumstances.
Recruitment Process Outsourcing (RPO) services – full or partial outsourcing of the recruitment process for permanent employees to a recruitment provider.
Staff – includes current and former employees and interns engaged directly in the business of Contauro (or who have accepted an offer to be engaged) as well as certain other workers who are or were engaged in the business of providing services to Contauro (even though they are not classed as employees). For these purposes we also include employees of Contauro who are engaged to work on Clients’ premises under the terms of RPO or MSP agreements. To be clear, ‘Staff’ does not include individuals hired by Contauro for the purpose of being placed with Clients outside of an RPO/MSP arrangement. These individuals are treated in the same way as Contauro’s Candidates and are covered by this Privacy Policy. Likewise, independent contractors and consultants performing services for Contauro fall within the definition of a ‘Supplier’ for the purposes of this Privacy Policy.
Suppliers – refers to partnerships and companies (including sole traders), and atypical workers such as independent contractors and freelance workers, who provide services to Contauro. In certain circumstances Contauro will sub-contract the services it provides to Clients to third party suppliers who perform services on Contauro’s behalf. In this context, suppliers that are individual contractors, freelance workers, or employees of suppliers will be treated as Candidates for data protection purposes. Please note that in this context, Contauro requires Suppliers to communicate the relevant parts of this Privacy Policy (namely the sections directed at Candidates) to their employees.
Systems – telephone, computer, internet and Wi-Fi systems, software and portals, accounts and/or networks belonging, controlled or used by Contauro that are used to transmit, undertake and/or receive communications or are otherwise used in the course of Contauro’s business, including candidate portal software and CRM systems.
Temp Relationship – means our contractual relationship with Temporary Workers while they are employed or engaged directly by us.
Temporary Workers – includes someone who becomes employed or engaged by Contauro for the purposes of undertaking temporary work for a Client or other Contauro group company. If you are a Temporary Worker, we will also continue to process your personal data as a Candidate throughout the duration of your temporary work assignment and thereafter, in accordance with the terms of this Privacy Policy. The question of whether and the extent to which the Recruits Privacy Policy and the Staff Privacy Policy apply to you as a Temporary Worker depends on local law requirements. For more information in relation to your jurisdiction, please read below.
Website Users – any individual who accesses any of the Contauro websites or any of the Contauro mobile applications (apps).