Pendl & Piswanger Romania is fully committed to protecting the privacy of our clients, candidates, partners and suppliers personal data. This statement summarizes our policy regarding the collection, use and transfer of your personal data, the security measures P&P takes to protect such data and your rights in relation to it.
This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page. Any significant changes to this policy will be notified.
Collection of Personal Data
In general, the personal data we collect is provided by you by e-mail, through our website ppromania.ro, social media networks, or during your visits to our headquarters. Examples of sources from which we may collect Personal Data include the following:
- When you provide us your personal data (for example, when you send us your CV, when you contact us by email, phone, social media)
- When you interact with us or send us your CV using the contact forms on our website (for example, when you apply for a career opportunity, when you send us a spontaneous application, when you request a career check session, when you subscribe to our newsletter, or by any other means).
- We may collect your Personal Data during an active recruitment process, when you have been identified as a potential candidate for a particular role, on LinkedIn or other professional platforms (eJobs, bestjobs) and you agreed to participate in the recruitment process.
- We may receive your Personal Data from our candidates (when you are recommended for a role) or other members of the Dr. Pendl & Dr. Piswanger network of firms.
- When you interact with us on social networks (message, like, share, comment, review, etc.), we will have access to information about you, in particular data that you manifestly choose to make public on your social media profile.
- We may receive your Personal Data from third parties who provide it to us (e.g., past employers; referees)
- We may, with your prior consent, conduct background checks, when you are selected as a potential candidate for one of our projects.
- We may collect or obtain Personal Data when you visit our website or use any features or resources available on or through our website. When you visit our website, your device and browser will automatically disclose certain information (such as device type, operating system, browser type, browser settings, IP address, language settings, and other technical communications information), some of which may constitute Personal Data.
Creation of Personal Data: We may also create Personal Data about you, such as notes taken by the consultant during the interview you are attending.
Personal Data we collect
The categories of Personal Data about you that we may Process include:
- Personal details: given name(s); preferred name; gender; date of birth / age; nationality; photograph; marital status; job title; employer entity; department; salary and compensation details; passport number (where applicable);
- Contact details: address; e-mail address; telephone number and other contact information
- Employment records: CV or cover letter, previous work experience and / or other experience, education, transcripts or other information you provide us in support of an application and / or application and recruitment process
- Details of the type of job you are looking for, the current and / or desired salary and other terms relating to compensation and benefit packages, relocation desire or other job preferences, and the type of organization you prefer.
- Information from interviews and telephone conversations you may have, if any;
- Specific cognitive abilities, personality traits and vocational interests. When you are selected as a potential candidate for one of our projects you may be asked to complete a professional assessment test or a personality questionnaire
- Reference information and / or information received from background checks (if appropriate), including information provided by third parties; and / or letters of recommendation
- Information you have made public on your social media profile and any other data you voluntarily submit to us.
- Information about any antecedents of previous employment relationships.
- Other information provided voluntarily, including Any sensitive and / or demographic information, such as gender, citizenship information, medical or health information, and / or racial ethnic or religious origin.
Lawful Basis for Processing Personal Data
In Processing your Personal Data in connection with the purposes set out in this Policy, we may rely on one or more of the following legal bases:
- we have a legitimate interest in carrying out the Processing, which is not overridden by your interests, fundamental rights, or freedoms. Where we rely on this legal basis, our legitimate interests are: our legitimate interest in the management and operation of our business; our legitimate interest in the promotion of our business; our legitimate interest in the provision of services to our Clients; and our legitimate interest in supporting our candidates’ career aspirations.
- we process the data based on your consent for marketing communications (newsletter)
- the processing is necessary in connection with any contract that you may enter into with us.
Processing your Sensitive Personal Data
We do not seek to collect or otherwise Process your Sensitive Personal Data, except where: Processing is required or permitted by applicable law (e.g., to comply with diversity reporting obligations); is necessary for the detection or prevention of crime; necessary for the establishment, exercise or defence of legal rights; or we have, in accordance with applicable law, obtained your prior explicit consent before Processing your Sensitive Personal Data.
Purposes for which we may Process your Personal Data
The purposes for which we may Process Personal Data, subject to applicable law, include:
- Recruitment activities on behalf of clients: recruitment operations; providing services to our Clients; identifying and attracting the most suitable candidates; record-keeping; and performing background checks.
- Coaching and career advisory services: career advisory services designed for our candidates who are considering a move or are already actively looking for a new assignment.
- Management consultancy: providing leadership consulting services to clients.
- Executive onboarding & transition: providing customized executive onboarding and team alignment support in addition to our executive search services.
- Interim Management: identifying and attracting Interim Managers that can replace, supplement or coach managers on a short-term or long-term basis.
- Newsletters and other marketing communications: communicating with you via any means (including via email, telephone, text message, social media, post or in person) news items and possible opportunities in which you may be interested.
Where do we store your data
After applying for a recruitment process, P&P will collect, process, and store the information in your applicant / candidate file in P&P company’s database, on a secure server located in United Kingdom. We will store data on our secure, local servers and in cloud (in Microsoft data centers in European Union). Our Psychometric Testing Provider – Profiles International, LLC will store data on servers located in Illinois, United States. The data transmitted through social media networks will be stored by them according to their own policies.
Disclosure of Personal Data to third parties
We will only disclose your personal data for the purposes and those third parties as described below. P&P Romania will take the necessary steps to ensure that your personal data is processed, secured and transferred under the applicable law.
Clients of Pendl & Piswanger Romania
Considering the specifics of our activity, we will forward to our clients the personal data of candidates from the recruitment process. We will share or provide customers with only the necessary information to fulfill the subject matter of the recruitment contract. This information may only be used by them for the purpose of recruitment, any other use not permitted under this agreement.
External service providers
If necessary, we will charge other companies and individuals to perform certain tasks that contribute to our services. We can, for example, provide personal data to agents, contractors or authorized partners for hosting our databases, data processing services or send you information that you have requested. We will share or make available to external service providers that information to the extent necessary to process your requests. This information cannot be used by them for any other purpose, especially not for their purposes or for third parties. P&P External service providers are contractually bound to respect the confidentiality of personal data.
We will disclose your personal data to public bodies only if this is required by law. For example, P&P Romania will respond to requests from the courts, law enforcement bodies, regulatory agencies and other public and governmental authorities, which may include such authorities from the outside of residence country.
Our sites uses third party plugins or content (e.g., Facebook, Twitter, Google+ and LinkedIn). If you choose to interact with any such plugins or content, your Personal Data may be shared with the relevant third party.
International transfer of Personal Data
Because of the international nature of our business, we may need to transfer your Personal Data to other entities within the Dr. Pendl & Dr. Piswanger Partnership network, InterSearch Organization, and to third parties as noted in the section above (Disclosure of Personal Data to third parties), in connection with the purposes set out in this Policy. For this reason, we may transfer your Personal Data to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located. In particular, your Personal Data may be disclosed to other members of the P&P InterSearch Partnership network, to the extent appropriate, in connection with any client opportunities in respect of which you are a candidate, or any Leadership Assessment in which you are a participant.
If you are selected as a potential candidate for one of our projects you may be asked to complete a professional assessment test or a personality questionnaire evaluating specific cognitive abilities, personality traits and vocational interests. The personal data you provide through the test platform will be transferred to the United States and stored on the secured Profiles International server in Chicago, Illinois.
P&P Romania shares personal data with partners operating in and outside the European Economic Area (“EEA”).
List of international partners with whom we share data:
- Cookie third parties: YouTube, Google
- Online platforms: Facebook, LinkedIn
- Microsoft: cloud data storage services
- Profiles International, LLC: psychometric testing services
Certain categories of personal data may be stored and processed in any country where we employ service providers. We may transfer the personal data we keep about you to recipients in countries other than the country in which the personal data was originally collected. These countries have data protection rules that are different from those in your country. However, we will take steps to ensure that any such transfers comply with applicable data protection laws and that your personal data remain protected according to European standards. In certain circumstances, the courts, law enforcement agencies, regulatory agencies, or security authorities of those other countries may have the right to access your personal data.
Where applicable law requires us to ensure that an international data transfer is governed by a data transfer mechanism, we use one or more of the following mechanisms: EU standard contractual terms with a data recipient outside the EEA or the United Kingdom; Verifying that the recipient has implemented binding corporate rules. We will also ensure that all our international partners have taken further steps to provide adequate safeguards, enforceable rights and effective legal remedies. The role of these measures is to provide assurance to data subjects that the transfer of data under standard contractual clauses or binding corporate rules provides a level of protection equivalent to that guaranteed within the European Union.
An Important Note about your Resume
When you send us a CV, we store it in our resume database located in United Kingdom. We cannot control the retention, use or confidentiality of CVs that have been viewed already by potential employers in the recruitment process. Once your resume has been revealed, P&P cannot recover it from third parties who have accessed it. The resume you submit does not have to contain sensitive data about racial or ethnic, political conviction, philosophical or religious beliefs, membership of a trade union or a political party, the history of criminal offenses or criminal proceedings and sanctions or fines associated, committing any illegal or inappropriate behavior and associated sanctions; or any national identification number. If your resume or profile contains this information, you agree that it is at your own risk.
P&P Romania pays special attention to the protection of your data and applies the appropriate technical and organizational measures to ensure the protection of personal data processed against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of Processing, in accordance with applicable law. Please remember that unfortunately no data transmission or storage is 100% risk free.
If you suspect a breach of the confidentiality of your data, please contact us immediately at: firstname.lastname@example.org
Your Personal Data that we Process will be kept accurate and, where necessary, kept up to date. To ensure that our candidates’ data is up-to-date and accurate, we keep in touch with you so you can let us know of changes to your personal data and we run regular data update campaigns, such as by email or phone call. We will ask you to send us an updated CV or confirm the accuracy of your Personal Data.
Your personal data will be deleted when it is no longer necessary for the purposes for which it was collected or when you request the deletion of data and P&P Romania has no legal obligation to continue to store such data. However, we will retain your personal data when it is necessary for the exercise or defense by P&P of a right of you or another person in court, until the end of the relevant retention period or until the resolution of those actions in court.
We will keep your data for a period of 36 months from the last contact with you, such as an email exchange or a phone call with our consultants, or when you participate in an interview. The data retention period starts from zero every time there is an action from our or your side, such as sending an updated CV, or a phone call or an interview with our consultants.
In the case of subscribing to our newsletter, your personal data will be kept in the system until you unsubscribe. To unsubscribe, click the “Unsubscribe” button available in the email you receive or send us an email stating your wish to unsubscribe to email@example.com
Should you wish us to delete your data, you may send us an email on firstname.lastname@example.org we will delete your data and you will not receive from us information on employment and career development opportunities.
Your legal rights
As a target person, you have specific legal rights with respect to personal data we collect from you. P&P Romania will respect your individual rights and will take care of your concerns accordingly.
- The right to withdraw your consent: If the processing of personal data is carried out on the basis of your consent, you may withdraw your consent to such processing at any time by writing an email to email@example.com Please note that withdrawing your consent will terminate your participation in recruitment actions and you will no longer be eligible for employment opportunities that our company provides to candidates.
- Right to rectification: You can get from us the rectification of personal data that concerns you. We make reasonable efforts to keep personal data accurate, complete, current and relevant, based on the latest information available to us.
- Right to restriction: You may obtain from us the personal data processing restriction if: you challenge the accuracy of personal data for the time we need to verify the accuracy; processing is illegal and you require restriction of processing rather than deletion of personal data; we no longer need your personal data, but you ask for it to be ascertained, exercised or defended; you oppose processing while we check that our legitimate reasons prevail over yours.
- Right of access: You can ask us for information about the personal data we hold about you, including information about which categories of personal data we have in our possession or control, what they are used for, where we have them collected if they are not collected directly from you and to whom it has been disclosed, if appropriate. You may obtain a free copy from us containing the personal data we hold about you. We reserve the right to charge a reasonable fee for each additional specimen you may request.
- Right to data portability: Upon request, we will transfer your personal data to another operator, where technically possible, provided the processing is based on your consent or is required for the performance of a contract. Rather than receiving a copy of your personal information, you may request that we transfer your data directly to another operator specified by you.
- Right to delete: you may obtain from us deletion of your personal data if: your personal data is no longer needed in relation to the purposes for which it was collected or otherwise processed; you have the right to oppose further processing of your personal data (see below) and to execute this objection to processing; personal data has been processed unlawfully; you withdraw your consent on the basis of which the processing takes place. The deletion of your personal data is possible unless processing is required to fulfill a legal obligation that requires our processing; for legal data retention requirements; for the establishment, exercise or defense of a right.
- Right to Object: You may at any time object to the processing of your personal data. If you oppose the processing, please specify whether you wish to delete your personal data or the restriction of data processing by us.
- Right to file a complaint: In the case of an alleged violation of the privacy law in force, you can file a complaint at the data protection supervisory authority in the country where you live or where the alleged violation occurred.
To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Policy, or about our Processing of your Personal Data, please contact our data protection officer directly, by writing an email to firstname.lastname@example.org
• Time period: We will try to meet the request within 30 days. However, the period may be prolonged for specific reasons relating to the specific legal right or complexity of the request.
• Access restriction: In some situations, we may not be able to grant you access to all or part of your personal data because of legal provisions. If we refuse your access request, we will inform you of the reason for the refusal.
• Inability to identify: In some cases, we may not be able to search for your personal data because of the identification elements provided in your application. Two examples of personal data that we cannot look for you when you provide us with your name and email address are: – data collected from social media public sites, if you have posted a comment under a pseudonym that is not known to us. In such cases, where we cannot identify you as the data subject, we are not able to comply with your request to perform the legal rights as described in this section unless you provide additional information that will allow your identification.
If you have any comments, questions, or concerns about any of the information in this Policy, or any other issues relating to the Processing of Personal Data please contact our Data Protection Officer:
Address: No. 17 Nicolae Golescu, 1st floor, Bucharest, 010285, Romania
Phone number: +40 21 323 01 71