Personal data means any information about an individual from which that person can be identified.
Your personal data and privacy is important to us.
We are committed to safeguarding your personal data and protecting your privacy.
This privacy policy explains how we achieve that by describing:
We have set out this privacy policy in a layered format, so that you can click through to the specific areas listed above individually rather than having to scroll through them.
When you click on the hyperlinked sections listed above, you will first be shown an “at-a-glance” short notice, which sets out the key information relating to that section. You will be able to expand that section further to reveal more detailed information.
This privacy policy applies to:
We refer to the above groups of individuals collectively as “you” unless the context dictates otherwise.
This privacy policy replaces any privacy policy that we have previously issued from Ekkiden.
Any notices or statements relating to data, data protection, fair processing and/or privacy that we may issue at the time of collecting personal data about you will supplement this privacy policy. They are not intended to override it.
We may change this privacy policy from time to time to reflect changes in the law and/or our personal data handling activities and data protection practices.
We encourage you to check this privacy policy for changes whenever you visit our website, as we may not always notify you of the changes.
It is important that the personal data we hold about you is accurate and current.
Please keep us informed if your personal data changes during your relationship with us.
We are the Ekkiden group of companies which is ultimately owned by Ekkiden Group (company no. XXX) of Avenue Louis-Casaï 18, 1209 Geneva, Switzerland.
We provide technological consultancy services, hiring candidates on a permanent contract in technical or organizational projects providing services in IT/Digital or Engineering/Sciences across the world.
We will typically be the primary data controller of your personal data. However, as we are part of a group of companies involved in providing the services described above, other companies wholly controlled by us may be the data controller of your personal data, instead of us.
We will let you know which member of our group of companies is the controller of your personal data at any given time. Where we do not let you know, you can assume that the data controller is Ekkiden Group.
This privacy policy is issued by Ekkiden Group and on behalf of all other members of our group of companies from Ekkiden Group or Elca Informatique SA and only applies where any such members act as the data controller of your personal data.
The applicable data controller will be referred to as “we”, “us”, “our” from now on within this privacy policy.
There are instances where Ekkiden Group or other members of the group act on behalf of a client to process personal data rather as the data controller. For example, where processing interview feedback or timesheets.
The privacy policy or privacy notice of the client will apply in those instances and NOT this privacy policy.
Where we are a data processor, we will refer you to the applicable data controller and their privacy policy if you have any data protection-related queries.
We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy policy.
If you have any questions about this privacy notice, including any requests to exercise your legal rights relating to your personal data, please contact the DPO using the details set out below.
You can contact us and our DPO for any data related query or make a complaint about how your personal data is being handled using the details below:
If you wish to make a request to access your personal data or to have your personal data removed please use the details below
The applicable data controller will largely be the entity involved in the collection and handling of your personal data. The following other parties may be involved, however:
A list of the current third party service provides that we use when we use them and what we use them for is set out in Appendix 1. We will update this list from time to time; and
Clicking on those links, or enabling those connections, may allow third parties to collect or share data about you. We do not control these third parties and are not responsible for their data protection compliance. When you leave our website, or connect to a third party from us, it is your responsibility to familiarise yourself with their privacy policy or notice, as we accept no responsibility for, and have no control over, them or any information or data collected by or for them.
Personal data means “any information relating to an identified or identifiable individual”.
It does not, therefore, include data where the identity has been removed (anonymous data).
---------------------------------------------------------------------------------------------------------------------------------
We will collect and handle, process, use, store, share and transfer (generically referred to as handling) the different kinds of personal data about you that is listed under the name of the category of individual that applies to you. Please note, that even though a type of data may be collected, it does not mean that it is collected or retained.
In some countries, we are restricted from processing some of the personal data set out below.
--------------------------------------------------------------------------------------------------
CANDIDATES:
Verification Data, which includes a copy of your driving licence, passport, identity card or another form of identification and referee details;
--------------------------------------------------------------------------------------------------
WEBSITE USERS:
--------------------------------------------------------------------------------------------------
REFEREES and CORPORATE STAFF:
--------------------------------------------------------------------------------------------------
In respect of Candidates and Website Users only, we also handle the following types of data:
We do not intentionally collect personal data relating to children.
----------------------------------------------------------------------------------------------------
-------------------------------------------------------------------------------------------------
CANDIDATES:
We generally collect your personal data directly from you. For example, we collect all of your personal data when you:
We also use the following channels to collect your personal data:
- pre-employment screening and background checking organisations;
- your referees;
- your past educators and employers and relevant education authorities;
We will obtain your consent to contact such third parties in order to collect this type of your personal data. You should have been provided with a Consent Form to allow us to do so. Please contact us if you have not been provided with the Consent Form.
- governmental and regulatory bodies such as tax and social security authorities;
- the third party suppliers, including recruitment and employment agencies, job board providers and job aggregators and our managed service providers who are within our supply chain;
WEBSITE USERS: we will collect all of your personal data via our third-party service providers, such as Google Analytics, Hubspot, Recruiterflow and various job boards.
As you use our websites, we may automatically collect your Technical Data. We collect this personal data by using cookies, server logs and other similar technologies.
You may also receive Technical Data about you if you visit other websites employing our cookies.
Please see our Cookies Policy for further details.
REFEREES: we will collect all of your personal data from a Candidate.
CORPORATE STAFF: we will collect your personal data directly from you except where you have previously been a Candidate where we will have also collected personal data in such capacity.
If you don’t provide certain information to us, we may not be able to carry out the services for you.
We’ll make it clear to you which personal data is optional to provide and which personal data without which we cannot work with you.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
We have set out in Section 13 a description of what we will specifically do with your personal data and our legal justification for doing so.
We set out below some general examples of what we do with your personal data.
--------------------------------------------------------------------------------------------------
CANDIDATES: your personal data will be collected and handled by us in order to:
--------------------------------------------------------------------------------------------------
WEBSITE USERS: your personal data will be collected and handled by us in order to:
Marketing preferences – where you tell us you are happy to receive information from us or have purchased products or services from us, we will send you communications which may include the following:
o e-newsletters and hard copy newsletters;
o emails about the services we offer and new product launches;
o reminders when your products or services may be due for renewal; and
o opportunities to participate in market research.
Depending on the contact preferences you select, we will communicate with you by post, telephone, SMS, email or other electronic means such as via social and digital media. We may use your Usage Data to help ensure that this messaging is personalised and relevant to you;
You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly;
--------------------------------------------------------------------------------------------------
REFEREES: we will use your personal data purely to verify a Candidate.
--------------------------------------------------------------------------------------------------
CORPORATE STAFF: we will use your personal data only to pursue our contractual relationship with your employer or engager.
If we need to use your personal data for an unrelated purpose, we will notify you, and we will explain the legal basis which allows us to do so.
We may share your personal data with the following entities for the purposes set out in Section 13:
We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions, which includes this privacy policy.
1.Purpose/Activity: Background Checks, Job Search and placement.
Type of Personal Data: Personal data described in Section 8 above.
Legal Basis for collection, handling and usage:
Legitimate Interest. We believe it is reasonable to expect that if you are looking for employment or have posted your professional CV information on a job board or professional networking site, you are happy for us to collect and otherwise use your personal data to offer or provide our consultancy services to you, share that information with prospective customers and assess your skills against our bank of vacancies. Once it's looking like you may get the job, your prospective customer may also want to double check any information you've given us (such as the results from psychometric evaluations or skills tests) or to confirm your references, qualifications and criminal record, to the extent that this is appropriate and in accordance with local laws. We also believe that you will expect us to have an ongoing relationship over a number of years and will continue to hold your data providing that we retain reasonable periodic contact with you or until you inform us otherwise. We need to do these things so that we can function as a profit-making business, and to help you and other Candidates get the jobs you deserve.
2.Purpose/Activity: Background Checks.
Type of Personal Data: Verification Data
Legal Basis for collection, handling and usage: Legitimate Interest.
We believe it is reasonable to check the credentials and qualifications of candidates within applicable local laws provided that personal data is kept secure and only shared with the client who is making a decision whether or not to engage or employ an individual.
However, you do have the right to object to us processing your personal data on this basis. If you would like to know more about how to do so, please see Section 29 below.
3.Purpose/Activity: Background Checks.
Type of Personal Data: Verification Data
Legal Basis for collection, handling and usage: Legitimate Interest.
1.Entity with whom personal data is shared: Entities within the Elca Informatique Group and Ekkiden Group.
What personal data is shared: Personal data described in Section 8 above.
Purpose of sharing: In connection with our recruitment service provision.
Legal Basis for sharing: Legitimate Interest.
2.Entity with whom personal data is shared: Tax, audit and other authorities.
What personal data is shared: Personal data described in Section 8 above.
Purpose of sharing: To comply with our legal and regulatory requirements in relation to taxation and financial compliance.
Legal Basis for sharing: Legal Compliance.
3.Third Entity with whom personal data is shared: Third Party Service Providers to us including without limitation:
What personal data is shared: Personal data described in Section 8 above.
Purpose of sharing: In connection with our consultancy service provision.
Legal Basis for sharing: Legitimate Interest.
4.Entity with whom personal data is shared: Referees and other individuals and organisations who hold information related to reference or application to work and to project research.
What personal data is shared: Verification Data.
Purpose of sharing: Verification of information provided to ensure you are successful in any roles that our candidates are successful in obtaining.
Legal Basis for sharing: Legitimate Interest.
What personal data is shared: Personal data described in Section 8 above.
Purpose of sharing: To ensure continued provision of consultancy and associated services to you.
Legal Basis for sharing: Legitimate Interest.
6.Entity with whom personal data is shared: Marketing technology platforms and suppliers.
What personal data is shared: Personal data described in Section 8 above.
Purpose of sharing: In connection with our recruitment service provision.
Legal Basis for sharing: Legitimate Interest.
What personal data is shared: Personal data described in Section 8 above.
Purpose of sharing: To assist you in gaining a new role.
Legal Basis for sharing: Legitimate Interest.
What personal data is shared: Personal data described in Section 8 above.
Purpose of sharing: In connection to our consultancy service provision
Legal Basis for sharing: Legitimate Interest.
9.Entity with whom personal data is shared: Third-Parties that assist us in the provision of our pre-employment screening process
What personal data is shared: Personal data described in Section 8 above.
Purpose of sharing: We believe it is reasonable to check the credentials and qualifications of candidates within applicable local laws provided that personal data is kept secure and only shared with the client who is making a decision whether or not to engage or employ an individual. However, you do have the right to object to us processing your personal data on this basis. If you would like to know more about how to do so, please see Section 29 below.
Legal Basis for sharing: Legitimate Interest.
We will not typically transfer your personal data outside the EEA.
The personal data we collect from you may be transferred outside the EEA either by us and/or by any of the third parties to whom your personal data may be disclosed to as listed in Section 13. Such transfers will occur only where they are necessary as part of the recruitment and/or related intermediary services we provide, e.g. where you apply for a vacancy or position outside the EEA, or where the transfer is authorised by law.
We, our third party data storage providers and/or the third parties to whom we may disclose your personal data may store your personal data on a server overseas.
If we do transfer your personal data outside the EEA, we’ll make sure that suitable safeguards are in place, for example by using approved contractual agreements, unless certain exceptions apply, or we are authorised to do so.
We will provide you with details of the safeguards that we have implemented if you would like to know what they are.
We hold your personal data in a combination of secure computer storage facilities and paper-based files.
We put in place an appropriate level of security around your personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage to it.
We shall implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of harm that might result from, unauthorised or unlawful processing accidental or unlawful loss, destruction or alteration, unauthorised (or disclosure of) access or damage to your personal data including:
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 instructions and via the access controls listed above. They are also subject to a duty of confidentiality.
We have agreed on security-related measures with the third parties we share your personal data with to ensure that it is treated by those third parties in a way that is consistent with how we safeguard your personal data.
We have also put in place procedures to deal with any suspected personal data breach and will notify you and any applicable supervisory authority where we are legally required to do so.
If you suspect any misuse or loss of or unauthorised access to your personal data, please let us know immediately by contacting us.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
We will appropriately and securely dispose of your personal data when it is no longer required.
To determine the appropriate retention period for personal data, we consider the following factors:
Based on those factors, we have determined that the following retention periods should apply in respect of personal data of the following categories of individuals (unless the law or any data supervisory authority or regulator requires otherwise):
We will continue to process your personal data in the usual manner for up to 2 years from the last meaningful contact we had with you (or such longer period which we believe in good faith circumstances and the law allows for legitimate interest to continue). Meaningful contact may include an employee contacting you directly by phone or you may receive an email from us reminding you that we hold your personal information and asking you to let us know if you are no longer interested in hearing about new opportunities.
After this time your personal data will no longer be immediately accessible from our live systems or will be archived. As a result, you will not receive marketing from us, and your information will not be readily accessible by our employees. If after a further year you or we have not re-established communication your personal data that we hold will be deleted other than basic identification information, information relating to projects which you have been engaged on through us, records of any payments made to you or tax which we have deducted. We hold this information for 7 years from the end of your last contract with our group. We hold this information in case there is a legal claim or tax investigation.
After this time your personal data will no longer be accessible from our live systems. As a result, you will not receive marketing from us, and your information will not be readily accessible by our consultants. If after a further year you or we have not re-established communication your personal data that we hold will be deleted.
In either of the case where we have placed a candidate or not, where we believe that the holding of your personal data no longer constitutes a legitimate interest, we will delete it to the extent necessary.
Personal data relating to criminal convictions and offences (UK ONLY) – we do not believe that we will handle any of this type of personal data. When carrying out the criminal convictions checks, we will only handle binary information as to whether or not a Candidate has a criminal conviction within the category of offences for which we have conducted such a check. The categories that we typically search for are theft, fraud, breach of trust and financial crimes. Where we discover that a Candidate has such a criminal conviction, we will withdraw that individual from any of our recruitment processes and will destroy that binary information immediately.
In some circumstances, you can ask us to delete your personal data. Please see the Right of erasure below for further information.
We will keep and use Anonymised Data indefinitely without further notice to you.
We take reasonable steps to ensure that your personal data is accurate, complete and up to date.
We may contact you from time to time to check that the personal data is still correct.
Please let us know of any changes to your details as soon as you reasonably can so that we can uphold our commitment to accuracy, completeness and currency.
We set out below a list of the legal rights that all individuals have under data protection laws in relation to our handling of your personal data. They don’t apply in all circumstances:
- us in relation to the handling of your personal data; or
- the regulatory body which enforces data protection law in your locality. Click here for a list of contact details.
Procedure to exercise your legal rights
Who can I ask about this policy? To ask us anything in relation to this privacy policy or any personal data that we may hold, please simply please contact us.
Can I request that you stop using my personal data? You have legal rights in respect of your personal. Please refer to Section 19 for more information on what legal rights you have and how you can exercise them.
What should you do if your personal data changes? You should tell us by speaking to your consultant so that we can update our records.
Do you have to provide your personal data to us? We’ll make it clear to you which personal data is optional to provide and which personal data without which we cannot carry out our operations. If we do not tell you, please ask us.
Appendix 1 - Third party service providers
We will make it clear when we collect personal information and will explain what we intend to do with it.