Privacy Notice for Recruitment

• Keystone Solutions ("we", "us", "our") are committed to protecting and respecting your privacy. This policy acts as the basis on which we will process any personal data we collect from candidates for employment, or data that is provided to us by individuals or third-party sources for the purposes of recruitment.
  
• Wherever you apply for a job opening posted by us, these Privacy Notice provisions will apply to how we process your personal information. This is in addition to our other Privacy Notice, which has been provided to you separately or is available on our website.
  
• Personal data means all information that relates to an identified individual or to an identifiable individual.
  
• For the purpose of the General Data Protection Regulation ("GDPR"), the Data Controller is Keystone Solutions.
  
• We use Manatal, a cloud-based application to assist with our recruitment process. Hence, Manatal acts as a data processor on our behalf and is only entitled to process your personal data in accordance with our instructions.
  
• This policy made by us does not apply to Manatal.
  
• This policy also provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR) and the local data protection law.
  
• This policy does not form part of any contractual agreement and may be amended at any time.
  

How is your personal data collected?

We collect personal data about you from the following sources:

• You, the candidate, via an online job site, career site, email, in person at video interviews, and/or by any other method.
  
• Those who referred you, from whom we collect your personal data.
  
• Trusted third-party vendors who recommend you as a candidate for a specific job opening or for our business more generally.
  
• From publicly accessible sources, such as LinkedIn or Source Boosters (Indeed, Monster, Career Builder, Dice, and so on), where we collect your full name, email, work history, and other data included on your profile. Please find detailed information about this in the section below.
  

Personal information we collect from you

• In particular, we collect the following personal details:
  
  • Name
    
  • Contact information
    
  • Educational background
    
  • Employment background
    
  • Job qualifications/skills
    
  • CV/resume or transcripts, and any supporting documentation attached to your resume, such as copies of certificates, passport, cover letters, etc.
    
• Details of your visits to our career site, including but not limited to traffic data, location data, weblogs and other communication data, the site that referred you to our website, and the resources that you access.
  

Lawful basis for processing

We rely on legitimate interest as the lawful basis by which we collect and use your personal data.

Wherever you apply for a job opening through our Quick Apply and job board integration vendors, we rely on consent during the application process to disclose your personal data to the service provider on the basis described below.

Purposes of processing

We process personal data related to you for the purposes of enabling us to consider your suitability for employment. Without such processing, it would not be possible for us to consider your application for employment. We use information held about you for any or all of the following purposes:

• Identifying and evaluating candidates for potential employment, as well as for future roles that may become available
  
• Maintaining records in relation to recruiting and hiring
  
• To communicate with you and respond to your requests or application
  

Disclosure of your information

We take care to only share your personal information with those who really need it in order to perform their tasks and duties.
Primarily, we pass your information to our service providers, including Manatal, their sub-processors, and the third-party integrations enabled by us in Zoho Recruit, who use your information only in accordance with our instructions and as otherwise required by law.

For example:

1. Manatal may engage a sub-processor to assist us in parsing your CV and obtaining the information required for the application/interview process.
   
2. We may disclose your personal information to third-party integrations provided by Manatal for purposes like background verification, assessment, and so on.
   
3. Wherever you have applied for a job opening through our Smart Apply feature, and wherever you have consented to this disclosure, we will disclose to the service provider certain personal data that we hold, including but not limited to a unique identifier used by the service provider to identify you, and information about your progress through our hiring process for the applicable job opening; as well as tangible, intangible, visual, electronic, present, or future information that we hold about you, such as your name, contact information and other details involved in the data analysis process related to you as an applicant for employment (collectively, “Disposition Data”). The service provider's Privacy Notice regarding their use of this shared data will be available on their website. For more details, learn more about Smart Apply.
   

Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need-to-know. They will only process your personal data on our specific instructions, and they are subject to a duty of confidentiality.

In case of any security breach, we will notify you and any applicable regulator where we are legally required to do so.

Where we store and who has access to your personal data

We store your personal data in United States.
If you are a candidate from the European Economic Area:

The data that we collect from you and process may be transferred to a destination outside the European Economic Area ("EEA"). It may also be accessed and processed by staff operating outside the EEA who work for us or for one of our suppliers.

If you would like further information, please contact us (see 'Contact' below).

How long we store your personal data

We shall determine appropriate retention periods considering the purposes stated in this policy and relevant legal requirements. Your personal information will be deleted on one of the following occurrences:

• Receipt of a written request by you to us.
  
• Deletion of your personal information based on criteria defined by us.
  • For example, if we failed to receive your consent within the defined timeline, your data will be automatically deleted.
    

Your rights

Under the General Data Protection Regulation, you have a number of important rights free of charge. In summary, those include:

• Right to know and access
  
• Right to seek correction
  
• Right to request erasure
  
• Right to receive a copy of your data
  
• Right to object to processing and to direct marketing
  
• Right to object to automated decision making
  
• Right to restrict processing
  

If you would like to exercise any of those rights, please:

• Contact us using our contact details below
  
• Give us enough information to verify your identity
  
• Let us know the information to which your request relates
  

How to complain

We hope that we can resolve any question or concern you raise about our use of your information.
The General Data Protection Regulation gives you the right to lodge a complaint with an appropriate supervisory authority, particularly if you are from the European Economic Area.

Contact

All questions, comments, and requests regarding this Privacy Notice should be addressed to privacy@keystone-solutions.be.