Competence – Excellence – Individuality

Integrity – Passion – Result-orientation

We commit

We provide execution, outcome and success – not only consulting

The wrong organisation cannot implement the right strategy

Measure – target – deliver

You bring the «what» – we bring the «how»

Your business requirements – our business solution

New day – new challenge

New challenge – new solution

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.

Con­text-Spe­cif­ic Pri­va­cy Infor­ma­tion

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;

  • 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.

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.

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;

  • 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.

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;

  • 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 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.

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;

  • 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.

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.

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

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.

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.

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.

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.

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.

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.

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

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.

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

 

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:

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.

  • 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).