This is the Privacy Statement of Tulleken Executive Search (KvK:51158825). The Privacy Statement is hereinafter also referred to as "Privacy Statement" or as "Statement." Tulleken Executive Search receives personal data in connection with its services,
- in which Tulleken Executive Search seeks the right candidate for its clients for permanent or temporary positions;
- Tulleken Executive Search seeks an appropriate position for candidates looking to take a new step in their career;
- evaluate this with all parties after a placement;-and/or Tulleken Executive Search conducts interviews with candidates in connection with choices to be made about their future careers. According to the General Data Protection Regulation ("AVG"), applicable as of May 25, 2018, Tulleken Executive Search is responsible for the processing of personal data in the performance of its services. Personal data is processed with the utmost care and is kept confidential. Tulleken Executive Search is aware of the regulations imposed on it by the AVG in connection with the processing of personal data received by it and complies with them and the laws and regulations based thereon in the manner described in this Statement. Tulleken Executive Search guarantees the protection of the privacy of the users of its website. In addition, Tulleken Executive Search tries to make contact with its candidates, clients and other relations as personal as possible. This Privacy Statement informs you about, among other things, what personal data is collected, for what purpose and how it is processed. It also describes your rights in this regard.
2. Use of personal data
This Statement applies to personal data that Tulleken Executive Search processes from:
- contacts of clients;
- contacts of organizations from which Tulleken Executive Search purchases services (hereinafter also referred to as "suppliers");
- contacts of organizations to which Tulleken Executive Search offers services;
- Persons whom Tulleken Executive Search should contact to learn more about candidates, including referees provided by candidates;
- persons to be contacted in an emergency;
- other relations of Tulleken Executive Search. In order to be able to use the services of Tulleken Executive Search, the persons named above provide personal data to Tulleken Executive Search, or personal data is provided to Tulleken Executive Search by third parties about these named persons. These personal data are used by Tulleken Executive Search solely for the purpose of performing its services. If these personal data are not provided to Tulleken Executive Search, Tulleken Executive Search cannot perform its services or respond to contact requests expressed to Tulleken Executive Search.
3. Types of personal data
Contact persons of clients provide in particular the necessary contact details of their organization to Tulleken Executive Search or the details of the individual contact persons within their organization. Contact persons of suppliers will supply the necessary contact details of their organization to Tulleken Executive Search or the details of the individual contact persons within their organization. (Potential) candidates are requested to supply the personal data relevant to them as listed under 3 via email@example.com. Much of this information is supplied by (potential) candidates in the form of a Curriculum Vitae ("CV") and a letter of motivation. Data that may be processed include:
- Name, contact information such as address, phone number(s) and e-mail address;
- Nationality, marital status, date and place of birth;
- Photo;-BSN number and ID (if required by law);
- Details of salary, claims, pension plan and other applicable terms and conditions of employment;
- Details of (current) position and employment;
- Data regarding employment history and thereby acquired knowledge and experience;
- Details of education and training courses taken and completed;
- Performance data, feedback and related information;
- Data on physical and mental disabilities (if relevant to the position being considered or applied for out of interest);
- Data on possible criminal convictions (if relevant to the position being responded to or applied for out of interest);
- Information on interests and needs regarding future work;
- Additional information provided to Tulleken Executive Search; Reference details;
- Information provided to Tulleken Executive Search by referees consulted at the request of a candidate;
- Information which clients provide to Tulleken Executive Search about candidates or which Tulleken Executive Search receives from third parties, for example through job sites etc. Tulleken Executive Search wishes to emphasize that this list of personal data collected by Tulleken Executive Search may not be exhaustive. In particular, references provide Tulleken Executive Search with the necessary individual contact information and their position within their organization. In particular, the other contacts listed above, including persons specified to contact in case of emergency, provide the necessary individual contact information.
4. Processing purposes and legal basis.
By sending your personal data to Tulleken Executive Search via firstname.lastname@example.org you, as (potential) candidate, give your consent for the processing of your personal data. The purpose of this information is to ensure that we can alert you to and offer client job openings that are tailored to your individual circumstances and interests. If you have been approached for a specific job opening, transmission of this information is necessary for preparing a performance of you as a candidate to the client. Also, this data is used for the following purposes, among others:
- transmission of a (vacancy) survey;
- contacting you at a possible position suitable for you;
- preparing candidate file;
- Preparation of report of the qualified candidate;
- To best tailor content and resources to your preferences;
- To send other information that may be of interest to you. Contact persons of clients provide, in particular, the necessary contact details to ensure that Tulleken Executive Search can provide its services in connection with the contracts of assignment to be concluded and the cooperation runs smoothly. If the contact person of the client provides information to Tulleken Executive Search about their organization in the interest of an assignment provided, Tulleken Executive Search may also process this information. Contact persons of suppliers, in particular, provide the necessary contact details to ensure that supplier can provide Tulleken Executive Search with the services in connection with the agreements to be concluded and the cooperation runs smoothly. If Tulleken Executive Search intends to further process your personal data for (a) purpose(s) other than the aforementioned, Tulleken Executive Search will first provide you with all relevant information about such other purpose(s) prior to such processing. Specifically, references provide Tulleken Executive Search with the necessary individual contact information and their position within their organization to ensure that you can confirm what you already know about a candidate with the goal of enabling that candidate to get the job he/she wants. Without contact information, it is not possible to get in touch. Our use of your data as described above is permitted by the AVG because:
- it is necessary for the legitimate interests of Tulleken Executive Search in the pursuit of the purposes as indicated above, whereby these interests may in each individual case not outweigh your privacy interests;
- Tulleken Executive Search in some cases must comply with its obligations under laws and regulations, such as disclosure to government, regulators or regulatory and government agencies;
- it is necessary in some cases for the performance of a task carried out in the public interest and, where Tulleken Executive Search processes special categories of personal data, such processing is necessary for the establishment, exercise or support of legal claims or where the processing is related to personal data which have been made public;
- these data are processed with your consent that Tulleken Executive Search obtains from you from time to time. Tulleken Executive Search does not use automated decision making based solely on automated processing including profiling that produces legal consequences for you, or affects you in a similar way.
5. Sharing personal data of (potential) candidates within Tulleken Executive Search and with third parties.
When you submit your personal data to Tulleken Executive Search, the consultants working at Tulleken Executive Search and the administrative and other support staff have access to your data. In order to facilitate the efficient use of your personal data and to provide you with the best services and/or opportunities, it may sometimes be necessary for Tulleken Executive Search to provide your personal data to third parties. However, this disclosure of personal data will only occur in the following circumstances: To potential employers and/or clients: Tulleken Executive Search will be able to send your personal data to these parties in connection with the agreed service provision. This will always be done only after prior consultation with you.
- To suppliers, (sub)contractors and agents: Tulleken Executive Search may contract or hire other companies and/or individuals from time to time to perform functions on behalf of Tulleken Executive Search. Examples include hosting and/or maintaining Website, providing content and/or certain options offered by the Website, storing your personal data and providing secure storage of our data (the network operator), managing the network, providing marketing services or providing financial updates at your request, managing the tool for an assessment to be performed. Such recipients will only have access to the personal data they need to perform their duties and may not use such personal data for any other purpose. These recipients are subject to contractual confidentiality obligations.
- To government or law enforcement authorities: Tulleken Executive Search will share personal data in the event Tulleken Executive Search believes it is required to do so. Tulleken Executive Search has entered into the necessary processor agreements with the above parties. If necessary, references provided by you as a candidate will be contacted to verify information provided by you. This will be both written and oral. Otherwise, your personal data will not be provided to third parties.
6. Retention period
Personal data will not be kept or processed any longer than necessary for the purposes for which it was collected. The retention period may vary by (category of) personal data. By submitting your personal data as a (potential) candidate, you expressly consent that your personal data will be used by Tulleken Executive Search for the duration of 1 (one) year from the date of submission. If no such consent is given, personal data will be deleted by Tulleken Executive Search within 4 weeks after the end of the application process. Before the expiration of the one-year period, Tulleken Executive Search will contact you to request whether it may keep your personal data on file for one more year. Tulleken Executive Search does not retain personal data any longer than is strictly necessary for the purposes for which it has collected such personal data. The personal data of candidates with whom Tulleken Executive Search has had contact at any time will in principle be kept for fifteen years after the last contact. The personal data of candidates with whom Tulleken Executive Search has not (yet) had contact will in principle be kept for up to fifteen years. Website visitors' personal data is kept for six months after the last visit to the Website. Candidates and Website visitors may request Tulleken Executive Search to remove personal data sooner. If the personal data are no longer needed for the purposes for which Tulleken Executive Search has collected or otherwise processed the personal data, Tulleken Executive Search will delete the personal data.
7. Rights to information, access, correction and deletion of personal data
Under the AVG, you have the following rights:
- Information and inspection: The right to access (view) and obtain a copy of your personal data: You have the right to request confirmation as to whether Tulleken Executive Search processes your personal data. If so, you are entitled to access your personal data and to certain information about how it is processed. In some cases, you may ask Tulleken Executive Search to send you an electronic copy of your information. Upon receipt of your request, Tulleken Executive Search will provide you with a copy of the personal data. If you request additional copies, Tulleken Executive Search may charge a reasonable fee, based on administrative costs.
- Rectification Right to change your personal data: You have the right to obtain from Tulleken Executive Search rectification of incorrect personal data. By means of, among other things, a supplementary statement, you can indicate which data are (by now) incorrect, specifying the correct personal data and possibly making the incomplete personal data complete, whereby the purposes as included in this Statement will always be observed by Tulleken Executive Search.
- Deletion Right to oblivion/to have data erased: In certain circumstances, you have the right to have your personal data erased. You may make such a request at any time and Tulleken Executive Search will then consider whether to comply with your request; however, this right is subject to any legal rights or obligations applicable to Tulleken Executive Search regarding data retention. In situations where we decide in accordance with the law that your request to delete your personal data must be complied with, Tulleken Executive Search will do so without unnecessary delay. Tulleken Executive Search is also obliged to delete your personal data without unreasonable delay in the event that you withdraw your consent to the processing of your personal data and there is no other legal basis for processing it or if your personal data are no longer necessary for the purposes for which they were collected. A request for inspection, rectification or deletion can be directed to Philip Tulleken: email@example.com. If your personal data has been rectified, deleted or if its processing has been restricted, Tulleken Executive Search will notify any recipients of your personal data, including potential employers.
8. Withdrawal of consent
Depending on the extent to which the processing of your personal data is based on your consent, you also have the right to withdraw your consent at any time. However, withdrawing your consent will not affect the lawfulness of any processing based on your prior consent before Tulleken Executive Search has received such withdrawal. You may withdraw your consent by emailing your notice to firstname.lastname@example.org.
9. Right to restriction
You have the right to restrict the processing of your personal data. This means that your personal data may not be processed (temporarily). You have this right if you dispute the accuracy of your personal data, if the processing is unlawful and you request restriction of the use of the data instead of their deletion, if you need your personal data in connection with the establishment, exercise or substantiation of a legal claim and Tulleken Executive Search no longer needs these personal data for the processing purposes or if you have objected to the processing. If you have obtained a restriction on processing, Tulleken Executive Search may no longer process your personal data. Your personal data may then only be stored. If you have obtained a restriction on the processing of your personal data, you will be notified by Tulleken Executive Search before the restriction on processing is lifted.
10. Right to object
If your personal data is used to send you a vacancy (overview), you have the right to object to the processing of your personal data for this purpose at any time. If you have objected, your personal data will no longer be used for this purpose.
11. Right to transfer data
You have the right to obtain your personal data, which you have provided to Tulleken Executive Search, in a structured, common and machine-readable form so that you can transfer it to another data controller. If technically possible, you have the right to have your personal data transferred directly from one processing controller (in this case Tulleken Executive Search) to another.
12. Submission of complaint
You have the right to file a complaint with the Personal Data Authority, which is responsible for handling complaints about compliance with legal requirements regarding the protection of personal data.
13. Security of personal data
Tulleken Executive Search has implemented appropriate technical and organizational security measures to secure personal data collected by Tulleken Executive Search against loss or unlawful processing, including but not limited to security by passwords, secure data storage, Tulleken Executive Search endeavors to take all reasonable measures required to ensure that your personal data is treated securely and in accordance with this Statement. As explained under "sharing with third parties" above, Tulleken Executive Search shares your personal data with one or more of the third parties listed there. In cases where we use external suppliers, (sub)contractors or agents, Tulleken Executive Search will continue to monitor your personal data and Tulleken Executive Search has controls in place to ensure that your personal data is adequately protected. Although Tulleken Executive Search makes every effort to protect your personal data, you should be aware that the transmission of information via the Internet is never completely secure and Tulleken Executive Search cannot guarantee the security of your personal data transmitted to the Website or any third party; for this reason, any transmission is at your own risk. Tulleken Executive Searchwill implement strict operational procedures and adequate, technical and business organizational security measures to prevent unauthorized access, alteration, deletion or transfer of personal data. If you share your computer with other users, Tulleken Executive Search recommends that you do not select the "remember my information" option when the Website gives you that choice.
14. Sending personal data to locations outside the European Union
Your personal data may be sent to and processed in one or more countries within or outside the European Union. Tulleken Executive Search will only transfer your personal data to countries outside the EU where the European Commission considers that you have an adequate level of protection or where Tulleken Executive Search has taken appropriate security measures to safeguard the privacy of your data. To exercise your rights, please contact Tulleken Executive Search at the following e-mailadres:email@example.com.
15. Marketing Communications
In principle, Tulleken Executive Search does not send marketing communications by e-mail. Should Tulleken Executive Search nevertheless wish to do so in the future, it will only do so after you have given your prior consent.
16. Amendments to this Statement.
Tulleken Executive Search reserves the right to change the terms of this Statement from time to time. Tulleken Executive Search will post material changes to this Privacy Statement by appropriate notice on its website or by contacting you through other communication channels. Of course, Tulleken Executive Search also advises you to regularly visit the Privacy Statement on its Website to see if any changes have been made.
17. Controller identity and contact information and contact
If you would like to know more about this Statement or have questions and/or comments about your rights, the processing and our further handling regarding the processing of your personal data and/or privacy in general, please contact our Data Protection Officer Philip Tulleken. He can be reached at the following e-mail address: firstname.lastname@example.org or at the phone numbers: +31 (0)6 50831638.
Tulleken Executive Search November 2019