Impetus Consulting Group Recruitment Privacy Notice

Effective Date: September 8, 2020

Impetus Consulting Group, along with its affiliates understand that your privacy is important to you. We are committed to protecting your personal data in our capacity as data controllers during the recruitment process.

The service for handling recruitments (the "Service") is powered by Teamtailor on behalf of Impetus ("Controller" “we” “us” etc.). It is important that the persons using the Service ("Users”) feel safe with, and are informed about, how we handle User's personal data in the recruitment process. We strive to maintain the highest possible standard regarding the protection of personal data. We process, manage, use, and protect User's Personal Data in accordance with this Privacy Policy ("Privacy Policy").

1. General

We are the controller in accordance with current privacy legislations. The Users’ personal data is processed with the purpose of managing and facilitating recruitment of employees to our business.

2. Collection of Personal Data

We are responsible for the processing of the personal data that the Users contributes to the Service, or for the personal data that we in other ways collects with regards to the Service.

When and how we collect personal data
We collect personal data about Users from Users when Users;

• make an application through the Service or otherwise, adding personal data about themselves either personally or by using a third-party source such as Facebook or LinkedIn; and
• use the Service to connect with our staff, adding personal data about themselves either personally or by using a third-party source such as Facebook or LinkedIn.
• provides identifiable data in the chat (provided through the website that uses the Service) and such data is of relevance to the application procedure;

We collect data from third parties, such as Facebook, Linkedin and through other public sources. This is referred to as “Sourcing” and be manually performed by our employees or automatically in the Service.

In some cases, existing employees can make recommendations about potential applicants. Such employees will add personal data about such potential applicants. In the cases where this is made, the potential applicant is considered a User in the context of this Privacy Policy and will be informed about the processing.

The types of personal data collected and processed
The categories of personal data that can be collected through the Service can be used to identify natural persons from names, e-mails, pictures and videos, information from Facebook and LinkedIn-accounts, answers to questions asked through the recruiting, titles, education and other information that the User or others have provided through the Service. Only data that is relevant for the recruitment process is collected and processed.

Purpose and lawfulness of processing
The purpose of the collecting and processing of personal data is to manage recruiting. The lawfulness of the processing of personal data is our legitimate interest to simplify and facilitate recruitment.

Personal data that is processed with the purpose of aggregated analysis or market research is always made unidentifiable. Such personal data cannot be used to identify a certain User. Thus, such data is not considered personal data.

The consent of the data subject
The User consents to the processing of its personal data with the purpose of Controller’s handling recruiting. The User consents that personal data is collected through the Service, when Users;

• make an application through the Service, adding personal data about themselves either personally or by using a third-party source as Facebook or LinkedIn, and that Controller may use external sourcing-tools to add additional information; and
• when they use the Service to connect to Controller’s recruitment department, adding personal data about themselves either personally or by using a third-party source such as Facebook or LinkedIn.

The User also consents to the Controller collecting publicly available information about the User and compiles them for use in recruitment purposes.

The User consents to the personal data being collected in accordance with the above a) and b) will be processed according to the below sections Storage and transfer and How long the personal data will be processed.

The User has the right to withdraw his or her consent at any time, by contacting Controller using the contact details listed under 9. Using this right may however, mean that the User can not apply for a specific job or otherwise use the Service.

How long the personal data will be processed
If a User does not object, in writing, to the processing of their personal data, the personal data will be stored and processed by us as long as we deem it necessary with regards to the purposes stated above. Note that an applicant (User) may be interesting for future recruitment and for this purpose we may store Users’ Personal Data until they are no longer of value as potential recruitments. If you as a User wish not to have your Personal Data processed for this purpose (future recruitment) please contact us using the contact details in paragraph 10

3. Data Recipients & International Data Transfer

Your personal data may be accessed by recruiters and interviewers working in the country where the position for which you are applying is based, as well as by recruiters and interviewers working in different countries within the global Keyrus organization. Individuals performing administrative functions and IT personnel within Impetus and Keyrus may also have a limited access to your personal data to perform their jobs. In some countries, you may have fewer rights under local law than you do in your country of residence, but we have put in place legal mechanisms designed to ensure adequate data protection of your personal data that is processed by Impetus and its affiliates within the global Keyrus organization, including the transfer of your personal data to countries other than the one in which you reside.

We use third party service provider to provide a recruiting software system. We also share your personal data with other third-party service providers that may assist us in recruiting talent, administering, and evaluating pre-employment screening and testing, and improving our recruiting practices.

In addition, we may disclose or transfer your personal data in the event of a re-organization, merger, sale, joint venture, assignment, or other transfer or disposition of all or any portion of our business.

4. Users’ Rights

We take reasonable steps that are designed to keep your personal data accurate, complete, and updated for the purposes for which it is collected and used. We also have implemented measures that are designed to ensure that our processing of your personal data complies with this Privacy Notice and applicable law.

In accordance with applicable law, you may have;

• a right to request a copy of the personal data we hold about you and details of how we use that information
• a right to amend or rectify your personal data if any of the information held about you is incorrect or out of date
• a right of portability of your personal data
• a right to erase your personal data, to demand that we cease the processing of your personal data, to restrict the processing of your personal data, and/or to withdraw your consent to the processing of your personal data. This may not apply if there are other legal justifications to continue processing and we may need to retain certain personal data where required or permitted under applicable law a right to provide us with instructions as to the processing of your personal data in case of death

5. Security

We prioritize the personal integrity and therefore works actively so that the personal data of the Users are processed with utmost care. We take the measures that can be reasonably expected to the make sure that the personal data of Users and others are processed safely and in accordance to this Privacy Policy and the GDPR-regulation.

However, transfers of information over the internet and mobile networks can never occur without any risk, so all transfers are made on the own risk of the person transferring the data. It is important that Users also take responsibility to ensure that their data is protected. It is the responsibility of the User that their login information is kept secret.

6. Transfer of Personal Data to Third Party

We will not sell or otherwise transfer Users’ personal data to third parties.

We may transfer Users’ Personal Data to;

• our contractors and sub-contractors, acting as our Processors and Sub-Processors in accordance with our instructions, for the provision of the Service;
• authorities or legal advisors in case criminal or improper behavior is suspected; and
• authorities, legal advisors or other actors, if required by us according to law or authority’s injunction.

We will only transfer Users’ personal data to third parties that we have confidence in. We carefully choose partners to ensure that the User’s personal data is processed in accordance to current privacy legislations. We cooperate with the following categories of processors of personal data; Teamtailor, who supplies the Service, server and hosting companies, e-mail reference companies, video processing companies, information-sourcing companies, analytical service companies and other companies with regards to supplying the Service.

7. Aggregated Data (non-identifiable personal data)

We may share aggregated data to third parties. The aggregated data has in such instances been compiled from information that has been collected through the Service and can, for example, consist of statistics of internet traffic or the geological location for the use of the Service. The aggregated data does not contain any information that can be used to identify individual persons and is thus not personal data.

8. Cookies

When Users use the Service, information about the usage may be stored as cookies. Cookies are passive text files that are stored in the internet browser on the User’s device, such as computer, mobile phone or tablet, when using the Service. We use cookies to improve the User’s usage of the Service and to gather information about, for example, statistics about the usage of the Service. This is done to secure, maintain and improve the Service. The information that is collected through the cookies can in some instances be personal data and is, in such instances, regulated by our Cookie Policy.

Users can at any time disable the use of cookies by changing the local settings in their devices. Disabling of cookies can affect the experience of the Service, for example disabling some functions in the Service.

9. Changes

We have the right to, at any time, make changes or additions to the Privacy Policy. The latest version of the Privacy Policy will always be available through the Service. A new version is considered communicated to the Users when the User has either received an email informing the User of the new version (using the e-mail stated by the User in connection to the use of the Service) or when the User is otherwise informed of the new Privacy Policy.

10. Contact

For questions, further information about our handling of personal data or for contact with us in other matters, please use the below stated contact details; Impetus Recruiting, recruiting@impetuscg.com