Version 2.1 - Updated 1st January 2021
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If at any time you are concerned or have questions about how we might be handling your data, please reach out to our Data Protection Officer at firstname.lastname@example.org
TABLE OF CONTENTS
When you apply for a job at GAT, the company will collect and use personal data about you during the recruiting and any hiring process. The purpose of collecting your personal data will be limited to the recruitment process only.
We will collect, store, use and disclose Personal Data in accordance with all applicable laws relating to the protection of Personal Data, including the EU Data Protection Directive 95/46/EC, the EU General Data Protection Regulation 2016/679, the EU ePrivacy Directive 2002/58/EC as amended by Directive 2009/136/EC, UK Data Protection Act 2018as amended or superseded from time to time, and any national implementing legislation ("Data Protection Laws").
We adhere to the principles relating to the processing of Privacy & Personal Data.
We collect, process, and share Personal Data fairly and lawfully and for specified purposes. The law restricts our actions regarding Personal Data to specified lawful purposes. These restrictions are not intended to prevent processing, but ensure that we process Personal Data fairly and without adversely affecting the Data Subject.
We provide detailed, specific information to Data Subjects depending on whether the information was collected directly from Data Subjects or from elsewhere.
We provide the Data Subject with all the information required by the law, including the identity of the Data Controller and Data Protection Officer, how and why we will use, process, disclose, protect and retain that Personal Data.
We check that the Personal Data was collected by the third party in accordance with the law and on the basis that contemplates our proposed processing of that Personal Data.
We collect Personal Data only for specified, explicit and legitimate purposes.
We do not use Personal Data for new, different, or incompatible purposes from that disclosed when it was first obtained unless you have informed the Data Subject of the new purposes, and they have consented where necessary.
We collect Personal Data only for specified, explicit, and legitimate purposes. We do not further process in any manner incompatible with those purposes.
We do not use Personal Data for new, different, or incompatible purposes from that disclosed when it was first obtained unless you have informed the Data Subject of the new purposes, and they have Consented where necessary.
We ensure that Personal Data is accurate and, where necessary, kept up to date. We correct or delete it without delay when inaccurate.
We store Personal Data only for specified, explicit, and legitimate purposes. They're not further processed in any manner incompatible with those purposes.
We secure Personal Data by appropriate technical and organizational methods or measures against unauthorized or unlawful processing and accidental loss, alteration, destruction, or damage.
We implement appropriate technical and organizational methods or measures in an effective manner to ensure compliance with data protection principles, according to commonly accepted standards, laws, or internal regulations.
We are able to demonstrate compliance with the data protection principles. We recognize new laws and regulations and adapt our activities to changes in the context or broad -range framework or business environment.
We have adequate resources and controls in place to ensure and to document the law compliance including:
We keep and maintain accurate records reflecting our processing, including records of Data Subjects' Consent and procedures for obtaining Consent. These records include, at a minimum, contact details of the Data Controller and the Data Protection Officer, descriptions of the Personal Data types, Data Subject types, Processing activities, Processing purposes, third-party recipients of the Personal Data, Personal Data storage locations, Personal Data transfers, the Personal Data's retention period and a description of the security measures in place.
We ensure that all personnel have undergone adequate training to enable them to comply with data privacy laws. We regularly test our systems and processes to assess compliance with all of the regulations.
We do not share Personal Data with third parties unless certain safeguards and contractual arrangements have been put in place. We share the Personal Data internally if the recipient has a job-related need to know the information.
"Personal Data" means any information relating to an identified or identifiable natural person; an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Personal data may also be a combination of data as described above.
We may obtain and use the following Personal Data and Sensitive Data about you:
We do not intentionally collect data which is, by its nature, particularly sensitive (e.g., genetic data, biometric data, data revealing racial or ethnic origin, political opinions, sex life, sexual orientation, religion or other beliefs, data concerning health, criminal background or trade union membership). All responsibility for providing data as above does not belong to GAT.
Providing data (except for the implementation of the legal obligation) is voluntary. We will never request unnecessary or redundant data from you. If you do not want to provide your data just do not do it, justify or inform us about it. Work with us to protect your privacy, identity and Personal Data - our DPO will also work with you on behalf of GAT.
Workable provides Us with the facility to link the data you provide to Us, with other publicly available information about you that you have published on the Internet – this may include sources such as LinkedIn and other social media profiles.
Workable’s technology allows Us to search various databases – some publicly available and others not, which may include your personal data (including your CV or Resumé), to find possible candidates to fill our job openings. Where We find you in this way we will obtain your personal data from these sources.
We may receive your personal data from a third party who recommends you as a candidate for a specific job opening or for our business more generally.
Cookies and IP Addresses
We may obtain information about your device, which includes your public IP address, browser type, and operating system where available. This accumulation of data is used to assist system administration.
We may also collect information regarding your browsing activity and interests through the use of a cookie file. This cookie file is stored on the hard drive of your device and contains information that is transferred to your computer's hard drive. We use the collection of this data to help us improve the experience of users on our Website. The collection of this data allows us to:
We use the following cookies:
You can find more information about some of the individual cookies we use and the purposes for which we use them below. Example of cookies used by Website:
We use the services of many providers of data analysis solutions, below we indicate the most important ones.
Google Analytics / AdWords / Security
We use Google Analytics' / Adwords' 3rd-party audience data such as age, gender, and interests to better understand the behavior of our customers and work with companies that collect information about your online activities to provide advertising targeted to suit your interests and preferences. For example, you may see certain ads on this Website or other websites because we contract with Google and other similar companies to target our ads based on information they or we have collected, including information that was collected through automated means (such as cookies and web beacons). These companies also use automated technologies to collect information when you click on our ads, which helps track and manage the effectiveness of our marketing efforts.
You may opt-out of the automated collection of information by third-party ad networks for the purpose of delivering advertisements tailored to your interests, by visiting the consumer opt-out page for the Self-Regulatory Principles for Online Behavioral Advertising at http://www.aboutads.info/choices/
We care about the safety and privacy of children online. Our Website is not designed or directed at children. We do not intentionally collect any personal information from persons under the age of 16 years of age. If we become aware that we have inadvertently received personal information from a user under the age of 16, we will delete the information from our records according to the law. If any of the laws is more severe, we will comply with it.
The rules for the processing of Personal Data, protection of privacy and freedom for private persons are clear to us, known and communicated to all our employees. We use information for ethical and legitimate purposes, legal and responsible business conduct.
The Personal Data we hold about you may be used in any of the following ways:
We may also use your Personal Data to protect against and prevent fraud, claims, and other liabilities and to comply with or enforce applicable legal requirements, industry standards, and our policies and terms. We use Personal Data for these purposes when it is necessary to protect, exercise, or defend our legal rights, or when we are required to do so by applicable law.
Staff members operating in the UK and within the EEA who work for or on behalf of us may process this information.
Without limiting the foregoing, you agree that Personal Data we obtain from you may be processed by our service providers based in countries outside of the EEA. Such countries may not have laws offering the same level of protection for Personal Data as those inside the EEA.
We store the Personal Data you provide us with on our secure servers.
Your Personal Data will not be kept in a form that allows you to be identified for any longer than is reasonably considered necessary by GAT for achieving the purposes for which it was collected or processed or as it is established in the applicable laws related to data retention periods or as permitted by applicable laws.
After an employment offer is made and accepted by a candidate, all other data for non-selected applicants will be deleted from GAT IT environments within a maximum of a 12 month period.
Disclosure of your Personal Data to third parties will only occur in any of the following events:
We are required to disclose your Personal Data in order to fulfill any legal obligation, to enforce our terms and conditions, or to protect the property, rights, or safety of GAT, users of our services, or others. In such a case, information may be exchanged with third-party companies or organizations in order to prevent fraud or reduce credit risk.
You acknowledge and agree that we may also disclose Personal Data with:
Our service providers have to follow our express instructions when processing the Personal Data and must have in place appropriate technical and organizational security measures to safeguard such Personal Data, and we do not allow them to use this information for their own commercial purposes.
If we do not process your Personal Data in accordance with our legitimate interest or based on a contractual obligation we have with you, we may share or disclose your Personal Data if you provide us with your affirmative consent.
We share the Personal Data we hold with third parties, according our internal Supplier Security Policy and supplier security and privacy risk assessment, such as our service providers if:
You may email us at email@example.com to request a copy of the Personal Data we currently contain.
You can correct what Personal Data we currently hold by emailing us at firstname.lastname@example.org to request that we correct or rectify any Personal Data that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause information to be incorrect. Where applicable, we will ensure such changes are shared with trusted third parties.
If you should wish to have your Personal Data deleted, then you may submit a request by emailing us at email@example.com. Upon receipt of such a request for erasure, we will confirm receipt and will confirm once your Personal Data has been deleted. Where applicable, we will ensure such changes are shared with trusted third parties.
At any time, you may withdraw your consent to our processing of your Personal Data through our Websites by notifying us via email at firstname.lastname@example.org Upon receipt of such a withdrawal of consent, we will confirm receipt and proceed to stop processing your Personal Data. Where applicable, we will ensure such changes are shared with trusted third parties.
You can exercise any of your rights by contacting via email to email@example.com.
We may need to request specific information from you to reasonably confirm your identity and verify you are the Person Data belongs to. This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request and to exercise your rights.
You will not have to pay a fee to access your Personal Data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
Whenever we use a processor, there must be a written contract in place. If a processor uses another organization (i.e., a sub-processor) to assist in its processing of Personal Data for a controller, it needs to have a written contract in place with that sub-processor.
What we set up in the contract:
What is our documentation of processing activities:
If we process special category we document:
When preparing to document our processing activities we:
As part of our record of processing activities we document, or link to documentation, on:
We document our processing activities in a granular way with important links between the different pieces of information.
We conduct regular reviews of the Personal Data we process and update our documentation accordingly.
We document our processing activities in writing and electronic form so we can add, remove, and amend information easily.
We share the results of processing your data, but we do not provide the above documents.
We consider data protection issues as part of the design and implementation of systems, services, products, and business practices.
We make data protection an essential component of the core functionality of our processing systems and services.
We anticipate risks and privacy-invasive events before they occur and take steps to prevent harm to individuals.
We only process the Personal Data that we need for our purposes(s) and that we only use the data for those purposes.
We ensure that Personal Data is automatically protected in any our IT system, Service, product, and/or business practice so that individuals should not have to take any specific action to protect their privacy.
We provide contact information of those responsible for data protection both within our organization and to individuals.
We offer strong privacy defaults and controls.
We only use data processors that provide sufficient guarantees of their technical and organizational measures for data protection by design.
When we use other systems, services, or products in our processing activities, we make sure that we only use those whose designers and manufacturers take data protection issues into account.
Our information security & privacy risk assessment and Data Protection Impact Assessments (DPIA) process is based on international standards and best practices.
We have appointed a Data Protection Officer (DPO) based on their professional qualities and expert knowledge of data protection law and practices.
Our DPO reports directly to our highest level of management and is given the required independence to perform their tasks.
We involve our DPO, in a timely manner, in all issues relating to the protection of Personal Data.
We ensure that any other tasks or duties we assign our DPO do not result in a conflict of interest with their role as a DPO.
Our DPO is tasked with monitoring compliance with the GDPR and other data protection laws, our data protection policies, awareness-raising, training, and audits.
We take account of our DPO's advice and the information they provide on our data protection obligations.
When carrying out a DPIA, we seek the advice of our DPO, who also monitors the process.
When performing their tasks, our DPO has due regard to the risk associated with processing operations and takes into account the nature, scope, context, and purposes of the processing.
Our DPO is easily accessible as a single point of contact for our employees, individuals, partners, contractors, third parties and the regulator.
We develop, implement and maintain Information Security & Privacy Management System aligned with ISO 27001 standards and safeguards appropriate to our size, scope, and business, our available resources, the amount of Personal Data that we own or maintain on behalf of others and identified risks (including use of encryption and Anonymization where applicable). We regularly evaluate and test the effectiveness of those safeguards to ensure the security of our processing of Personal Data. We exercise particular care in protecting Sensitive Personal Data from loss and unauthorized access, use, or disclosure.
We maintain data security by protecting the confidentiality, integrity, and availability of the Personal Data, defined as follows:
We comply with and not attempt to circumvent the administrative, physical, and technical safeguards we implement and maintain in accordance with the law and relevant standards to protect Personal Data.
We have put in place procedures to deal with any suspected security incident and Personal Data Breach and will notify Data Subjects or any applicable regulator where we are legally required to do so.
If you know or suspect that a security incident or Personal Data Breach has occurred immediately, contact via email to firstname.lastname@example.org. You should preserve all evidence relating to the potential security incident and Personal Data Breach.
Information we collect from you will be processed mainly in EEA, and UK, but could be processed outside EEA and UK, depending on the purpose of processing. Whenever Personal Data is transferred outside the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
You could check how the EU determines if a non-EU country has an appropriate level of data protection by clicking the link: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en .
If Personal Data is transferred outside the EU for doing business by GAT in other law jurisdictions, then EU law and law of the relevant jurisdiction apply jointly. If they are divergent, that is stringent are used.
We’re using minor IT SaaS services located in the US to support our business. Also in exceptional situations (breakdowns, interruption of continuity), we can use servers located in the US as an alternative and backup solution. Our partners in the US are obliged to ensure the highest standards of security of the processed data.
We may, at times, provide links on our Website to third party websites, including without limitation those owned or managed by our partner networks, affiliates, or advertisers. These websites have separate privacy policies, and we, therefore, cannot accept any responsibility for the content. As such, choosing to follow these links is a choice you make at your own risk, and we advise that you check these websites' individual privacy policies before submitting any Personal Data.
We conduct periodic, not less than every 12 months Policy and Information Security & Privacy System Management and documentation reviews. Review is mandatory after changes in the nature, scope, context, or purposes of the processing of Personal Data.
If at any time we make a change to this Policy, we will update this page to reflect such change. Through a notice on this page, however, we recommend you review this page periodically to ensure you remain happy with the latest version.
The date the Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you.
Our company is subject to the EU's GDPR and the Data Protection Act 2018 (UK) and is compliant with those laws, and rules, standards and guidelines issued by The Information Commissioner's Office (ICO), The EuropeanData Protection Board (EDPB) and local personal data protection supervisory authority.
Our subsidiary in the EU (GAT HUB SRL, company number J12/4395/2016, C.U.I.: RO36846338, address: P-ța. Unirii nr. 4-5, et. 1, ap. 7, Cluj-Napoca, Cluj, Romani) is responsible for contacting personal data protection supervisory authority in any matter regarding the protection of personal data in accordance with the GDPR.