Since we consider ensuring the right to the protection of personal data as a fundamental commitment for HUNT RECRUITMENT, we dedicate all the necessary resources and efforts to process your data in full compliance with Regulation 679/2016 (“General Data Protection Regulation” or “GDPR”) , as well as with any other legislation applicable on the territory of Romania. The processing of personal data is carried out by mixed means (manual and automatic), in compliance with legal requirements and under conditions that ensure security, confidentiality, principles and respect for the rights of the persons concerned.
Definitions – “Personal Data” means any information about a natural person or from any person that can be directly or indirectly identified.
“Process”, “Processing” or “Processing” means any activity involving personal data, including but not limited to: collection, recording, organization, structuring, storage, retrieval and use, disclosure by transmission, deletion or destruction of personal data.
The term “User” of the Site means any visitor who accesses a Site and completes an online registration form.
What categories of personal data we are processing – we generally collect your personal data directly from you, so you have control over the type of information you give us. During the course of our business processes we may have access to the following categories of data:
• personal data provided during the recruitment process: name, surname, phone number, email address, experience, studies and place of residence at the time of application
• personal business data of the contact persons from our partners and suppliers: name, surname, company, function, department, email address and service phone number
• commercial information related to the type of solutions and services requested, bank accounts
• information about your interactions with our online content or social media
• records of any consent you have given, the type of activity that requires consent, the date and time the consent was sent and any related information (ex.: email opt-in option)
• any comments and opinions you send or publish in relation to HUNT RECRUITMENT on social platforms, websites, forums and online communities
Please do not send us personal data of a special or intimate nature. Any other information provided that is not required in the recruitment process will be deleted. We may ask for references from former employers for some positions, but only with your consent. It is also possible that third parties, as providers of applications, tools and plug-ins on our site, may use automated means of collecting data regarding your interaction with those platforms. In this situation, the data is collected directly by those providers, who play the role of personal data controllers. We advise you to consult the data protection policies of those providers.
What are the purposes of processing – The purposes for which we may process personal information, in accordance with applicable law, include:
• Recruitment and placement within specific HR services – the data provided is necessary to identify whether your professional experience and training are suitable for the position you have applied for. Contact data is only used to inform you about the jobs you have applied for, schedule the interview, communicate the results of the interview, signal new possible positions of interest, as well as request consent to participate in a new recruitment process. The use of data for the stated purpose may involve the transfer to third parties – potential employers;
• The resolution of any requests/complaints and the provision of any information requested by completing the contact form (name, surname, e-mail address, phone number) will only be used to resolve the received request and subsequent processing activities
• Analysing and improving our services and communications
If you have given us your consent, we can also process your personal data for the following purposes
• Communication for direct marketing purposes through the channels you have approved to keep you up to date with our activity, announcements and other information regarding our services, events and projects in which we are involved or any other information on related topics. Your data will not be used for other purposes
• You have the right to withdraw your consent at any time by simply clicking on the ‘unsubscribe’ link at the footer of direct marketing messages or by sending a request containing full details of the service you wish to opt out of to the address: email@example.com
What are the legal bases of our processing activities – In accordance with the provisions of Art. 6 (1) GDPR, the processing of personal data at HUNT RECRUITMENT is carried out on the basis of the following legal bases:
• the existence of a contract (services, purchases, invoice or other documents with contractual value)
• the existence of a legal obligation of a commercial or legal nature, associated with certain types of activities (labour code, accounting and commercial laws)
• processing is necessary for the purpose of ensuring our legitimate interests in providing you with the best quality services, except where your interests or fundamental rights and freedoms prevail over our interests
• the existence of an informed and free consent associated with the processing of personal data for direct communication activities or for any other processing activity for which there is no other legal basis
How we collect your information – We may collect or obtain information about you in the following ways:
• directly from you (e.g. if you contact us by phone, email or social media channels)
• when you fill in online forms on our website
• when you provide us with information to participate in the selection process for a certain position
• in the course of other types of interactions (marketing and consulting services, visit on the occasion of an event
• when you make personal information public (ex. social media posts)
Please note that we are not responsible for the personal information you voluntarily provide on public pages or social networks, through phone, email or website requests for offers. This policy also does not cover the practices of third parties who may provide us with information about you. Also, in certain circumstances, we may collect your data from a third party source, who becomes responsible for the accuracy of that data, having all the obligations and responsibilities of a controller regarding compliance with the legislation in force.
How long we keep your personal data – HUNT RECRUITMENT has implemented appropriate technical and organizational measures to ensure the principle of data retention for as long as necessary. According to our retention policy, personal data is kept for as long as legal conditions allow. In the case of an ideal job search, you can expressly ask us to keep your data for a longer period. Exceptionally, some data may be kept for a period necessary to defend a possible legal right.
Accuracy of personal data processed – HUNT RECRUITMENT takes reasonable steps to ensure that your personal data is correct and, if necessary, updated. If any of the personal data that you have provided to us changes (name or e-mail address changes), please notify us by email: firstname.lastname@example.org
Data minimization and purpose limitation – In accordance with GDPR principles related to minimization, relevance and adequacy, HUNT RECRUITMENT takes reasonable steps to ensure that the personal data we process is limited to what is strictly necessary, relevant and appropriate for the purposes of the processing. To the extent that the procedural conditions for the acquisition of personal data and the legal provisions allow it, HUNT RECRUITMENT tries to limit the processing of certain types of personal data that are not necessarily necessary or that do not represent the purpose of a particular activity. This limitation and minimization can be done without affecting the legal conditions and internal rules established by HUNT RECRUITMENT.
Collection of data about minors – Because we care about children’s online safety and privacy, we do not knowingly contact or collect information from anyone under the age of 16. Our Website is not intended to solicit information of any kind from persons under the age of 16.
Who we share your personal data with – If you have applied to an advertisement posted by HUNT RECRUITMENT to participate in the recruitment process for that position, we will share your personal data with the employer for whom the recruitment is being carried out. We may also share personal data with law enforcement authorities, regulators or lawyers, if there are requirements to establish, exercise or defend a right in court or in a dispute resolution action.
All our relationships with third parties are based on compliance with the principles of the GDPR, the legal bases associated with each type of processing, as well as the fundamental rights and freedoms of our customers, based on contracts that include the necessary clauses of confidentiality and protection of personal data. Your personal data will not be transferred to third parties for marketing purposes.
International data transfer – For customers in Romania, HUNT RECRUITMENT does not transfer personal information to other locations in other countries. Currently, we store and process your personal data only on the territory of Romania. The only personal data that can be transferred through the usual communication channels (telephone, email, online platforms, courier) represent contact data of the representatives of our customers and external partners, for which there are commercial collaboration contracts, and the transfer is made with the consent of all parties and persons involved, by signing the documents.
There may be situations in which the personal data of some customers are processed through platforms that contain specialized applications, offered or hosted by suppliers outside the European Union, from countries that do not appear on the EU suitability list. In such cases, the application provider has the role of processor of personal data processed by HUNT RECRUITMENT as an operator. Responsibility for the safety of data processed through the respective applications rests with the provider. In all these situations, the legal basis for international data transfer by simply hosting within an application/platform is provided by the Standard Contractual Conditions approved by the European Union and concluded by the manufacturer with each user.
How we ensure the security and confidentiality of personal data – HUNT RECRUITMENT takes reasonable steps to ensure the security and confidentiality of personal data by implementing appropriate technical and organizational measures to secure your information and protect it against unauthorized or illegal use and accidental loss or destruction, including:
• sharing and providing access to your data, to the minimum extent necessary, subject to confidentiality restrictions, where appropriate and anonymously, whenever possible
• personal data collected by the HUNT RECRUITMENT operator are stored on secure servers, located in protected rooms and with limited physical access
• the transmission of your personal data is done using the latest-generation encryption algorithms
• verifying the identity of any person requesting access to information
• data transfer is carried out only through secure applications or systems or through encrypted data transfers
• we ensure generally accepted security standards to store and protect the personal data we collect, both during transmission and once received and stored, including the use of encryption where appropriate
• All relationships with third parties are guaranteed by the confidentiality clauses in the collaboration contracts
Despite the measures taken, we draw your attention to the fact that the transmission of information over the Internet, in general, or by attaching documents to communication tools in public or social networks, is not completely secure, there is a risk that the data will be seen and used by unauthorized persons. We cannot be responsible for the vulnerability of data transmitted through systems that are not under our control.
How we ensure compliance with the rights of access to personal data
Under the conditions provided by the GDPR, as data subjects you have the following rights:
The right to information – refers to the right to receive details regarding the processing activities carried out by HUNT RECRUITMENT, as described in this document;
The right of access to data – the right to obtain from HUNT RECRUITMENT a confirmation of whether or not we are processing personal data, that we have your data on file and that you can request access to that data and the following information: what data we are processing, for what purpose, if they were disclosed to third parties and to whom, as well as the storage period of this data. You have the right to receive free of charge a copy of the personal data that is the subject of processing.
The right to rectification – to obtain the correction of inaccurate/unjustified personal data, as well as the updating of incomplete data.
The right to data erasure (“the right to be forgotten”) – the right to request the erasure of personal data without undue delay, if one of the following reasons applies:
• the data are no longer necessary to fulfil the purposes for which they were collected or processed
• you withdraw your consent and there is no other legal basis for the processing
• you oppose the processing and there are no legitimate reasons to prevail
• personal data were processed illegally
• the data must be deleted to comply with a legal obligation
There may be situations in which, following the request to delete the data, HUNT RECRUITMENT applies procedures to eliminate the elements of identification of the person, through anonymization or pseudonymization techniques, in which case the encrypted data no longer falls under the scope of the GDPR.
The right to restrict processing – to the extent that you dispute the accuracy of the data, requesting the restriction of their processing for a period that allows us to verify their correctness. You can object to processing justified by our legitimate interest (other than direct marketing) where your rights as a data subject prevail over our legitimate rights.
The right to data portability – that is, the right to receive personal data in a structured way, commonly used and in an easy-to-read format. At the same time, you have the right to have this data transmitted by HUNT RECRUITMENT to another data operator, to the extent that the conditions stipulated by law are met.
The right to object – in specific situations, we may stop processing your data, unless we have legitimate, compelling and demonstrable reasons that justify the processing and that override your interests, rights and freedoms.
The right not to be subject to an automated individual decision – ensures the right not to be the subject of a decision taken solely on the basis of automated processing activities, including profiling, which produce legal effects that concern you or affect you to some extent significant.
The right to withdraw consent – is the right to withdraw permission to use personal data for any processing activity carried out by HUNT RECRUITMENT for which you have given your consent. It should be noted that the withdrawal of the consent given in advance refers only to the processing carried out from the moment of the notification of the withdrawal of consent, not affecting the data processing carried out during the existence of the agreement and it will not affect the consent given for other activities or services either. To benefit from this right, it is enough to contact us and your request will be resolved in the shortest possible time.
The right to address the National Supervisory Authority for the Processing of Personal Data (ANSPDCP) in Romania, which can receive notifications at: B-dul G-ral. Gheorghe Magheru no. 28-30, Sector 1, code 010336, Bucharest, email: email@example.com or on the Internet: www.dataprotection.ro
The right to address the Court, for situations in which you consider that the personal data operator or the Competent Authority did not pay the necessary attention to your request to exercise your rights.
Through this policy, HUNT RECRUITMENT assures you that we will always attach the utmost importance to respecting your fundamental rights as a data subject. We are confident that any request you send us will be resolved as soon as possible, in accordance with the provisions of domestic and international legislation and the requirements of the GDPR. In this spirit, HUNT RECRUITMENT has developed and implemented a special procedure for resolving data access requests from data subjects (clients and partners). It is good to remember that we have every legal basis not to comply with a request for access to data if it would negatively affect the fundamental rights and freedoms of other data subjects.
Our contact details – You can contact us at any time by sending your request by post or courier to the address HUNT RECRUITMENT in Str. Avrig 23A-25A, Sector 2, Bucharest or by email to firstname.lastname@example.org with the mention: “To the attention of the Personal Data Protection Officer”.