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Recruitment Privacy Notice

Information notice: Processing of personal data for recruitment purposes.

1. About Us

We are RINF OUTSOURCING SOLUTIONS S.R.L., a limited liability company with headquarters located in Bucharest, Green Court, 4C Gara Herastrau Street, Building B, 3rd Floor, District 2, Romania („RINF TECH”). When you respond to our talent acquisition proposals, contact us, or apply for an open position in our company, we collect and process several categories of your personal data. This makes us a data controller and you a data subject, according to the data protection legislation.

Please read this document carefully, to find out how we process your data and what are your rights.

2. How and why we collect and process your personal data

2.1. Talent search and contact

When we contact potential candidates on professional platforms (such as LinkedIn), we store the publicly accessible professional resume (profile including name, contact details and professional experience) or the resume which you send to us when you reply to our messages. We use a LinkedIn Recruiter account for such purposes and we comply with the LinkedIn community rules on contacting passive candidates and respecting users’ choices.

We perform talent searches based on our legitimate interest to find the most suitable candidates and we only store your information in our recruitment database when you show interest in a specific position.

We also receive job applications through our Careers portal, where you can contact us directly and send us your name, contact details, CV and other professional information. We process this data in order to take steps at your request prior to entering into a labour contract, or (in the case of contractor) based on our legitimate interest to identify the most appropriate collaborators.

2.2. Interview and next steps

If you are a good match for our open positions, we can invite you to undergo an interview with our talent acquisition and/or technical teams. In this phase, we collect additional information about your qualifications, and we may ask you to undergo a technical skills test.

We may also ask you to provide documentation in support of your statements regarding educational and professional background (e.g., diplomas, licenses, certificates etc.). If you refuse to provide us such information, we may decide to discontinue the recruitment process.

In certain exceptional circumstances, the position you apply for might require background checks which involve the verification of prior criminal convictions. If so, then we will inform you and require you to obtain and show a clean criminal record certificate. We do not collect or store such certificates and we ask you to abstain from showing/sending us any criminal record certificates which do not meet the job description requirements.

Some of our open positions involve working on projects where our clients require a direct verification of the team’s skills. For this purpose, your name and professional experience details will be made available to those specific clients and, in some cases, you might be invited to an interview with them.

We use the above data in our legitimate interest to confirm the information in the resumes, bios and letters of intent. We also have an interest to maintain the good reputation of the company and, in specific situations, comply with our client’s project demands, and therefore, we deem it important to verify whether the applicant does not have criminal convictions incompatible with the job description.

2.3. Storing your information for future opportunities

The IT business sector is very dynamic, and our company always posts new job openings. If the recruitment phase is complete and you do not receive an offer from us, you can stay in contact with us and find out about other opportunities. You can opt in for this purpose, using the choices which are presented to you when you send your application, and this will enable us to use your personal data to contact you until you withdraw your consent by contacting us using the details provided in section 6.

2.4. Storing your information for evidentiary purposes

Please note that we will keep any communications with you concerning the recruitment process for a period of 3 years, for evidentiary purposes. This means that we have a legitimate interest to prove that our recruitment processes are performed equitable and in observance with the legal requirements. This is different from the processing describe under pt. 2.3 above and does not imply using the information to contact you or in any way related to professional opportunities.

3. Retention of your personal data

Your personal data is kept only for as long as needed for the fulfilment of the purposes for which such information is processed.

Storage of data for further contacting: is done in accordance with section 2.3 above.

Storage of data for evidentiary purposes: is done according to section 2.4 above.

If you communicate with us via e-mail, all messages are kept for evidentiary purposes according to our e-mail archiving and erasure policy.

The personal data of applicants who receive job offers is subject to a distinct policy which will be provided at the time of employment.

4. Who has access to your personal data

Your personal data may be distributed to any other company that is an affiliate of RINF TECH, for internal group administrative purposes or where we consider that it is in our legitimate interest to do so for improving our recruitment process within the group and identifying the most appropriate candidates for job openings within the group.

Access to your personal data is limited to those persons who need to know this information for professional purposes. They may include the department/team and their designees for the fulfilment of certain tasks, as well as employees in the human resources, legal, IT, client engagement, sales and financial departments.

We will share your personal data, on a need-to-know basis only with the following categories of third parties:

  1. companies who supply us with apps and services regarding the digitalisations of the recruitment process (e.g., sending automated e-mails, storing and organising candidates’ applications and options etc.);
  2. RINF TECH clients, where such clients require information about candidates for specific projects;
  3. information technology systems suppliers and related support services suppliers, including email archiving, file storage and sharing, back-up and disaster recovery, cyber security services;
  4. regulatory authorities, accountants, auditors, lawyers, labour law specialists or other external experts, where their activity requires such information;

 

We will also disclose your personal data to third parties in the following cases: if you request or authorize us to do so; to persons demonstrating legal authority to act on your behalf; where it is in our legitimate interest to do so in order to run, grow and develop our business: (i) in case of a transfer of undertaking (we sell a part of the business or certain assets) related to the job you apply for, we may disclose your personal information to the prospective buyer of such business or assets, in order to ensure that the activity continues as a going concern, or (ii) if RINF TECH (or a substantially part of its assets) are acquired by a third party, in which case personal information held by us will be one of the transferred assets; if we are under a duty to disclose your personal information in order to comply with any legal obligation or any lawful request from public authorities; to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity; to protect the rights, property or safety of RINF TECH, its employees, customers, suppliers or other persons.

5. Transfers of personal data to third countries

Depending on the means of interaction with us and the recruitment process, there are certain circumstances where we transfer your personal data outside of the European Economic Area (EEA). In such cases, we apply legal safeguards according to the requirements of the General Data Protection Regulation (GDPR).

Some projects we work on might require us to inform our clients who are based outside of the EEA about new proposed team members. This means that we will inform such clients about your identity and some essential professional qualifications. We will let you know about this particular disclosure on a case by case basis and we will apply legal safeguards for the data transfers.

6. Your rights

RNF TECH is a company registered in the European Union and is subject to the requirements of the GDPR and the applicable Romanian national legislation.

RINF TECH does not make recruiting decisions based on solely automated processing which produces legal effects concerning candidates or similarly significantly affects them.

Data subjects have the following rights in relation to RINF TECH, in connection to the recruitments process:

    1. Right of access: You may ask from us information regarding personal data that we hold about you, including information as to the categories of data, what they are being used for, where we collected them, if obtained indirectly, and to whom it has been disclosed, if applicable.
    2. Right to rectification: You may ask us to rectify the incorrect or incomplete information which we process about you. Please note that this right does not extend to incorrect / incomplete information which you provided during the recruitment process and this right cannot be used as a means to influence the recruitment process post-factum.
    3. Right to restriction: You may obtain from us restriction of processing of your personal data, if: you contest the accuracy of your personal data, for the period we need to verify the accuracy; the processing is unlawful, if you request the restriction of the processing instead of the erasure of your personal data; we no longer need your personal data, but you request it for the establishment, exercise or defence of legal claims; or you object to the processing while we verify whether our grounded reasons override yours.
    4. Right to delete data: You may request to delete the personal data we process about you. This right is applicable if:
      1. the personal data is no longer required for the purposes for which it has been collected;
      2. you oppose processing for reasons related to your particular situation;
      3. the personal data has been processed unlawfully;
      4. the personal data must be deleted to comply with a legal obligation that we have, unless data is required: for the exercise of the right to free expression and information; to comply with a legal obligation that we have; for purposes of archiving in the public interest, scientific or for historical studies or for statistical purposes; or for ascertaining, exercising or defending a right in court.
    5. Right to opposition: You may object – at any time – to the processing of your personal data due to your particular situation, provided that the processing is not based on your consent but on our legitimate interests or those of a third party. In this event we shall no longer process your personal data, unless (i) we can demonstrate compelling legitimate grounds which justify the processing and override your interests, rights and freedoms, or (ii) in case the purpose is the establishment, exercise or defence of a right in court.
    6. Right to withdraw your consent for data processing purposes where consent is the legal basis (such as contacting you for future opportunities).
    7. Right to complain to a supervising authority or court of law: You have the right to petition the national data supervisory authority from our country of registration (the Romanian National Data Supervisor – ANSPDCP) as well as other data supervisors depending on the country where you have your habitual residence or work. You also have the right to seek judicial remedies in a court of law.

How to exercise your rights: You can send us a formal request concerning any of your rights as a data subject, using the following contact details:
data-protection@rinftech.com

Time period: We aim to respond to your request within one month. This period may be extended, due to the complexity of your request, with a maximum additional period of 2 months. In all cases, if this period is extended, we will inform you about the term of extension and the reasons that led to it.

No identification: In some cases, we may not be able to identify your personal data due to the incomplete / incorrect identifiers you provide in your request. In such cases, where we cannot identify you as a data subject, we are not able to comply with your request in accordance with this section, unless you provide additional information enabling your identification. We will inform you and give you the opportunity to provide such additional details.

7. Final remarks

This notice is applicable as of January 2024. We reserve the right to modify, where we deem appropriate, the privacy practices and update and make changes to this notice at any time. Any changes to this notice will be displayed through any means we deem appropriate, including by posting it on our website.

Thank you for reading this information notice!

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