Privacy notice for applicants

When receiving a spontaneous application at CUSTOMER CENTRIC CONSULTANCY  we process information about you (“personal data”). It is done in order to evaluate the adequacy of your profile and skills with our human resources needs.

In this context, we protect your personal data and privacy by taking all relevant measures in accordance with applicable legislation, including the EU Regulation 2016/679 – known as General Data Protection Regulation (GDPR).

This privacy notice describes how CUSTOMER CENTRIC CONSULTANCY uses your personal data, how we ensure its protection and which privacy rights are granted to you by law.

For the purpose of this notice, “we” and “our” will refer to CUSTOMER CENTRIC CONSULTANCY and “you” and “your” will refer to applicants.

1. Why we process your personal data?

We process your personal data in order to ensure the effective management of our recruitment process. This data is provided by you when sending a request in this regard. CUSTOMER CENTRIC CONSULTANCY may request additional personal data further along the hiring process, mainly in relation to the steps in the evaluation process (e.g. written tests, interviews).

We grouped below the main purposes for which we will process your personal data:

• to assess the adequacy of your profile and skills with our present human resources needs;
• to evaluate your capacities to perform the required tasks;
• to inform you about the status of your job application;
• to ensure the fairness of assessments;
• to respond to potential future human resources needs;

2. On what legal grounds we process your data?

When one of the above-mentioned purposes is pursued, we have a clearly defined legal basis in order to process your data. Therefore, for every processing operation, CUSTOMER CENTRIC CONSULTANCY ensures that at least one of the following legal bases apply:

• we have to comply with a legal obligation under the laws applicable in our jurisdictions;
• you gave us your consent to use your personal data for a specific purpose;
• we have a legitimate interest to use your data for the stated purpose, and this interest does not override yours;

Moreover, we will also have a valid legal basis when we:

• require processing your data to protect your or another person’s vital interests;
• need to carry out a task in the public interest or in the exercise of official authority vested in us.

We will only use your data for the above-listed interests as long as they are not overridden by your interests and fundamental rights. In this regard, each time any of these legal bases will be used, we will make a balancing test between this interest and your rights and liberties, in order not to limit disproportionately the latest.

3. What categories of your personal data we use?

As mentioned above, when carrying out our recruitment procedures, we process several categories of personal data. This data is extracted from the documents provided to us by you, mainly your curriculum vitae and cover letter. Due to the freedom of format for these two documents, the categories of personal data process may include but are not limited to:

• General information: Name, surname, home address, phone number, email, signature, marital status, nationality;
• Education: attended education institutions, examinations and evaluation information;
• Professional experience: past employers, contact and personal data of past job references;
• Specific skills: IT skills, languages are spoken and proficiency;

During written and oral evaluation phases, we will also process personal data concerning:

• Video surveillance and access to our premises: video image/biometric data;
• Publically available information: information from social networks, newspapers, online published information

4. Storage, retention and erasure of personal data

CUSTOMER CENTRIC CONSULTANCY ensures that your data is stored in a centralized and organized manner, namely in the relevant human resources internal information systems and in our administrative cloud accounts. Your information may also be stored on secure corporate email accounts, as a result of intra-group data transfers. Moreover, we also store relevant documents (e.g. CVs, cover letter) in a paper-based form in adequate physical storage spaces.

We ensure its security by implementing a thorough access rights system, which ensures that only the authorized and relevant personnel can access it uniquely for lawful and clearly defined purposes.

Our retention periods are based on several well-defined criteria. Therefore, the data will be stored for as long as we are actively pursuing one of the purposes enumerated above and while we have a valid legal basis to do so.

After the expiration of the purposes, your data will be stored solely for the purpose to respond to pending or potential litigations.

5. Transfers of personal data

In the course of our activities, your personal data may be transferred within our group of companies (intra-group transfers).

Intra-group transfers of personal data

CUSTOMER CENTRIC CONSULTANCY is a part of CIVITTA, which  is composed of several legal entities, forming what is called a group of undertakings. With your consent, we can share your personal data with other companies, part of this group of undertakings, in case your profile might respond to human resources needs from those entities.

CIVITTA develops a holistic approach in protecting the personal data of applicants, therefore ensuring that you will benefit from the same guarantees and rights for the whole group.

Trans-border transfers outside the EEA

Due to the international structure and reach of our actives, part of our operations and clients can be situated outside the European Economic Area (EU member states + Iceland, Norway and Liechtenstein). Therefore, we may transfer your personal data outside the EEA to countries without an adequacy decision from the European Commission.

To mitigate and ensure an EU-level of data protection, CIVITTA uses Standard contractual clauses approved by the European Commission for all our trans-border transfers, which constitute a GDPR-compliant adequate safeguard for such operations.

6. Your rights

6.1. Right to access your personal data

You can request and you are entitled to obtain from us insight into the personal data we process, where it comes from and what we use it for. You can obtain information about how long we store your data and who receives data about you. Your right of access may, however, be restricted by legislation, protection of other persons’ privacy and considerations for our business and practices. Our know-how, business confidential data, as well as internal assessments and material may also as such be exempt from the right of insight.

6.2. Right to rectification and erasure of data

If you have discovered that the personal information we have about you is incorrect, incomplete or irrelevant, you are entitled to have the data corrected or erased with the restrictions that follow from existing legislation and rights to process data.

6.3. Right to the restriction of use

If you believe that the data we have processed about you is incorrect or incomplete, or if you have objected to the use of the data, you may demand that we restrict the use of these data to storage. Use will only be restricted to storage until the correctness of the data can be established, or it can be checked whether our legitimate interests outweigh your interests.

If you are entitled to have the data we have registered about you erased, you may instead request us to restrict the use of these data to storage.

6.4. Right to data portability

If we use data based on your consent or as a result of an agreement, and the data processing is automated, you have a right to receive the copy of the data you have provided in an electronic machine-readable format.

6.5. Right to object

You have the right to object against CUSTOMER CENTRIC CONSULTANCY processing your personal data when we invoke our legitimate interest for such an operation, when we carry a task in the public interest or for direct marketing purposes.

6.6. Automated individual decision-making

You also shall have the right to object to a decision based solely on automated processing, including profiling. In these situations, CUSTOMER CENTRIC CONSULTANCY will guarantee suitable measures to safeguard your rights, mainly the right to human intervention when reviewing such cases.

You will be notified if any automated decision-making is performed in relation to your personal data.

6.7. Withdrawal of consent

If we process personal data based on your consent, you can withdraw your consent to disclose data at any given time. Please also note that we will continue to use your personal data if we have to fulfill a legal or contractual obligation.

7. Accuracy and updating your personal data

We will update your personal data continuously during the period it is stored in our database. This is done for internal organization purposes and in order to permit better adequacy between our client’s needs and requests and your skills. In this regard, it is possible for you to update your data by notifying the Human Resources representative at Gedimino str. 27, Vilnius through info@ccconsultancy.lt.

8. Updates to this privacy notice

We may revise this Policy from time to time by posting an updated version on our website. If substantial changes are made, that may significantly influence your rights or increase your responsibilities, we will notify you. We may provide notice of changes in other circumstances as well. We encourage you to periodically review this page for the latest information on our privacy practices.

9. Contact details and complaint lodging

You are always welcome to contact us as a data controller if you have questions about your privacy rights and how we register and use personal data. Our offices in Lithuania are located at Gedimino str. 27, Vilnius and you can contact the responsible person by email at info@ccconsultancy.lt.

If you are dissatisfied with how we process your personal data and you were not satisfied with your interaction with the responsible person, you can lodge a complaint with the Valstybinė duomenų apsaugos inspekcija at the contact details provided below.

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