Introduction
This privacy notice applies to the processing of personal data we collect when you visit our website, use our mobile app, when we provide you our Services namely in the field of recruitment and selection, mediation, temporary staffing, secondment, payroll, personal development, career guidance, coaching, planning, and personnel and salary administration as further described in the Terms and Conditions (collectively “Services”) and the processing of personal data of persons who work for companies with which we conduct (or intend to conduct) business.
Your privacy and the security of your personal data is important to Jobetto and the rest of the Jobetto group companies. We are responsible for ensuring that all personal data entrusted to us is processed in accordance with applicable data protection legislation.
This notice explains who we are, for what purposes we may use your personal data, how we handle it, to whom we may disclose it to such as clients, service providers and/or other Jobetto group companies, where it may be transferred to or accessible from and what your rights are.
About Jobetto
Jobetto (referred to in this notice as: “we” or “us” or “Jobetto”), will process your personal data in accordance with this privacy notice (such personal data sometimes also referred to as “information”).
Except as otherwise set out below, Jobetto is the controller of the personal data (‘controller’ within the meaning of applicable data protection legislation).
For the efficient operation and management of our business, Jobetto group companies may in certain instances jointly define the purposes and means of Processing Personal Data (joint controllers). Examples of processing activities where Jobetto group companies jointly process personal data are those related to managing our Misconduct Reporting Procedure and Sanctions checks, Jobetto may also be joint and independent controllers with some of our clients. Please contact us (see the section “Contact us” below) if you want to know more about these jointly-controlled processing activities or would like to receive a summary of the joint controllers’ roles and responsibilities and/or exercise your data protection rights regarding any jointly-controlled processing of your personal data.
Website Visitor
When you visit our website or a Jobetto app, we collect some information related to your device, your browser and to the way you navigate our content. We may use cookies to collect this personal data.
Cookies are small text files that are saved on your device when you visit our website. Cookies enable the website to remember your actions and preferences (for example, your choice of language) and recognize you when you return, so that we may analyze trends, determine your areas of interest and administer our website in order to speed up the navigation process and to make your site experience more efficient.
What personal data do we collect?
When you visit our website, we gather information that relates to your device, your browser and to the way you navigate our website content, such as:
- the Internet Protocol (IP) address of your device
- the IP address of your Internet Service Provider
- device screen resolution
- device type (unique device identifiers)
- browser and operating system versions
- geographic location (country only)
- preferred language used to display
- the date and time of access to the website
- the internet address from which you were directly linked through to our website
- the control system that you use
- the parts of the website that you visit
- the pages of the website that you have visited and the information that you viewed
- the hyperlinks you have clicked
- the material that you send to or download from our website
If you choose to download our reports or white papers; or to subscribe to our newsletter news, events and alerts; or submit an inquiry we may ask you to fill out a form with information such as your name, e-mail address, job title and company. From the moment you engage in one of the aforementioned actions, we will be able to relate the information listed above about your device, your browser and to the way you navigate our website content directly to you.
The type of information we ask from you to use is your name, e-mail address, job title and employment status and, if you wish to obtain a detailed report, information about your job responsibilities and compensation.
Why do you need your personal data?
Jobetto processes your personal data only for the purposes specified below:
- To manage the website and for system administration purposes (e.g. also for diagnosing technical problems, analyse the traffic to our website): based on the legal ground of (a) legitimate interest of managing our website, marketing and communications strategy; or (b) where (a) is not possible because local mandatory law requires so, only in those limited cases may this be based on a consent;
- For web analytics, in order to optimize the user experience (analyzing the way our pages are visited, analyzing trends, observe and measure how our visitors engage with our website) and the quality of the content provided to you (e.g. job posting): based on the legal ground of (a) legitimate interest of improving our website, marketing and communications strategy; or (b) where (a) is not possible because local mandatory law requires so, only in those limited cases may this be based on a consent;
- If you choose to download our reports or white papers or to subscribe to news, events and alerts, fill in webforms, we will use the information you provide us to send you the content requested, to communicate with you (including, where you agree, to send you related information that might be of interest to you) and to improve our marketing and communication strategy: Jobetto can send whitepapers, newsletters, events and alerts where you have given consent to receive this. If you are no longer interested in these Jobetto messages you are always able to opt-out from receiving such communications by emailing info@Jobetto.com or hr@Jobetto.com
- For managing specific inquiries: based on the legal ground of (a) legitimate interest of improving our website, marketing and communications strategy; or (b) where (a) is not possible because local mandatory law requires so, only in those limited cases may this be based on a consent;
- Cooperating with law enforcement agencies/courts, management of legal disputes/claims: processing is necessary for the purpose of the legitimate interests pursued by Jobetto, which include the protection of company assets, protecting its legal interests and managing legal claims/disputes;
Your personal data may be shared with:
- other members of Jobetto, and third party service providers and suppliers located in Jobetto's worldwide locations.
- any person or authority (including a government department/body) with a lawful entitlement to obtain the information.
Talent
We use your personal data when providing our HR-services, which include services in the field of recruitment and selection, mediation, temporary staffing, transfer of employer/ redeployment, payroll, personal development, career guidance, coaching, planning, and personnel and salary administration as further described in the Terms and Conditions (collectively “Services”).
By innovating at scale, Jobetto will fulfill our compelling vision: to empower lifelong employability and deliver on our brand promise of proactivity, transparency and guidance to offer a truly enriching talent experience for finding a job around the world.
What personal data do we collect about you?
As a candidate, we collect and process personal data about you such as:
- Identification information – we may process your name, contact information (including email, home address, home phone number and mobile phone number), citizenship & country of residence, date of birth, gender, digital signature, languages spoken and nationality & immigration status (and information from related documents).
- CV/resumes and other recruitment information – we may process your CV/resume, work history, information about your skills, your experience and educational background and other relevant information (such as your photograph, interview notes and personal data included in the cover letter or as part of the application process). We may also process details in references about you that we receive from third parties.
- Compensation and benefits information – we may process personal data relating to your current compensation and benefits including (without limitation) your current bonus, recurring payments and benefits.
- Government issued identifiers – we may process government issued identifiers including (without limitation) PAN, Aadhar card, address proof, employment ID and driving license number, as legally required.
- Information about you available from third parties - including the results of any state criminal record checks, credit checks and/or financial sanctions checks.
- Photographs and video footage – when participating in recruitment-related events, meetings, conferences etc., we may process photographs or videos of you.
- Visitor information – when accessing our buildings, we may collect your name, contact details, car plate number, and other identification for security reasons. Where we are legally required to do so we may also ask you to disclose information about your health (including information related to viral infections, flu, etc.) for health and safety reasons (client specific drug test also applies)
- Information you choose to share with us – we may process additional personal data if you choose to share that with us.
This data may be obtained directly from you, from the public domain or from third parties. In the last case, we will inform you of the purpose and data sources we use, the exception is where the provision of this information to you would cause disproportionate efforts. In that case, we may take alternative measures to protect your rights and freedoms.
Why do we need your personal data?
Jobetto processes your personal data only for the purposes specified below:
- To provide our Services to you (including matching and proposing you to clients, interviews, assessments): For example, we may process your personal data to recommend jobs to you based on your profile and enable our consultants to provide you with tailored job opportunities, career advice, reskilling options, inclusiveness, suggest additional training where necessary and introduce you to hiring managers. The processing of your data and the use of automated systems is necessary to provide you with the matching services, and is therefore based on (pre-) contractual necessity;
- Training and updating of systems/statistical purposes. Some of the systems that we use to provide our Services are based on machine learning technology. In order for that technology to function reliably, it needs to be trained and updated on the basis of existing data. We may also process personal data in an aggregated manner for statistical purposes: Based on our legitimate interest in training and updating our systems. We have implemented mitigating measures to limit the privacy impact, such as de-identification and an easy opt-out in your choices;
- Dispute management and litigation: Processing is necessary for the purpose of the legitimate interests pursued by Jobetto, which include the protection of company assets, protecting its legal interests and managing legal claims, disputes and/or grievances;
- To conduct checks to verify your suitability for placements: we may carry out criminal record checks, credit checks and verify whether you are a politically exposed person, a specially designated national or otherwise subject to sanctions under applicable laws or regulations.
- Compliance with labor, tax and social security laws and other legal or regulatory requirements (e.g. equal opportunity and workplace diversity requirements): Processing is necessary for compliance with employment and social security legal obligations;
- Events: Based on our legitimate interest in maintaining a good relationship with our community of candidates and promoting our services by inviting you to our events;
- Facilities, security and contingency planning purposes: Processing is necessary for the purpose of the legitimate interests pursued by Jobetto, which include safeguarding and securing our assets, our facilities, our information systems and our people;
- To conduct corporate transactions (including mergers, acquisitions and divestments): Processing is necessary for the purpose of the legitimate interests pursued by Jobetto, which include Jobetto’s interest in developing its business through mergers, acquisitions and divestments;
How long do we keep your personal data?
If we have placed you in a permanent role or temporary assignment successfully, we will retain your personal data for 5 years from the date your permanent role begins or the last day you worked on temporary assignment, as relevant. Otherwise we will retain your personal data for 3 years from the date we created your record in our database. If applicable, we will retain certain pay-related and other financial information for 7 years in order to comply with our legal obligations.
In any event, we may keep your personal data for longer if necessary in connection with any actual or potential dispute (e.g. we need this personal data to establish or defend legal claims), in which case we will keep your personal data until the end of such dispute or if we are required to do so by any applicable law or regulation.
EW OR contract worker
Once you have been successfully matched to a temporary assignment, we will collect additional personal data from you to provide you with our Services and to support you as a temporary worker.
What personal data do we collect about you?
When you are a contract worker on a temporary assignment at one of our clients, we may process personal data about you such as:
- Identification information – we may process your name, contact information (including email, home address, home phone number and mobile phone number), citizenship & country of residence, date of birth, gender, digital signature, languages spoken and nationality & immigration status (and information from related documents).
- CV/resumes and other recruitment information – we may process your CV/resume, work history, information about your skills, your experience and educational background and other relevant information (such as your photograph, interview notes and personal data included in the cover letter or as part of the application process). We may also process details in references about you that we receive from third parties.
- Compensation and benefits information – we may process personal data relating to your current compensation and benefits including (without limitation) your current bonus, recurring payments and benefits.
- Government issued identifiers – we may process government issued identifiers including (without limitation) your national identification number, social insurance number, social security number and driving license number, as legally required.
- Information about you available from third parties - including the results of any state criminal record checks, credit checks and/or financial sanctions checks.
- Photographs and video footage – when participating in recruitment-related events, meetings, conferences etc., we may process photographs or videos of you.
- Visitor information – when accessing our buildings, we may collect your name, contact details, car plate number, and other identification for security reasons. Where we are legally required to do so we may also ask you to disclose information about your health (including information related to viral infections, flu, etc.) for health and safety reasons.
- Time and attendance records - information we gather from you, from swipe card systems, time management system, time clock records.
- Professional information – we may process personal data related to your work including (without limitation) your job title, description and location, your department, professional email address, reporting levels, and employment status (full-time/part-time/etc.).
- Financial information – financial information including (without limitation) your bank account number, bank details, VAT number.
- Salary information – we may process salary information including (without limitation) recurring payments and benefits, your bonus.
- Performance-related information – performance-related information including (without limitation) information on your performance reviews.
- Disciplinary information - information relating to disciplinary measures taken against you, if any.
- Grievance information – In order to assist in the reporting of grievances and (suspected) misconduct within the Jobetto of companies, we have established dedicated channels through which stakeholders may voice concerns, either through local reporting mechanisms in place at the level of the local Jobetto companies or, for serious misconduct (including whistleblowing), through our Integrity Line, the Jobetto reporting facility. Whenever we receive a grievance report or a report about (suspected) misconduct we may process personal data related to the complainant, the other individuals mentioned in the complaint and the person(s) that is/are subject of the complaint and/or of the investigation into the complaint.
- Travel and expense data – travel and accommodation information and expenses including (without limitation) travel itineraries, hotel and travel reward cards.
- Vehicle information – information about your personal or company car including (without limitation) your license plate, parking tickets and driving fines.
- Family and dependent information – information related to your family and dependents including (without limitation) details regarding family composition (names, genders, ages), any "special needs" or education requirements for children or dependents, special needs of elderly parents, emergency contact information.
- Information related to identification/access control cards – employee identification and access control cards may contain your name, photograph, employee number and may be linked to other details on record (department, phone number, license plate).
- CCTV footage – we may process footage of you obtained through our use of CCTV surveillance systems.
- Survey results – we may process your responses to questions in employee surveys.
- Information related to your usage of Jobetto devices, software and access to Jobetto’s network – we may process information related to your use of our devices, software and access to our networks, including (without limitation) your browsing history, your use of email, internet and social media, whether at the workplace, on our equipment or otherwise through our networks.
- Special categories of data, such as:
- Health-related information – health-related information including (without limitation) injuries and exposure, incident reports, disability, sickness and absences and maternity leave information, as legally required.
- Ethnic origin – information revealing your ethnic origin, as legally required.
To the extent we process these special categories of data, we will protect, secure and use that information in a manner consistent with this notice and applicable laws.
- Trade union membership – data revealing your trade union membership.
This data may be obtained directly from you, from the public domain or from third parties. In the last case, we will inform you of the purpose and data sources we use, the exception is where the provision of this information to you would cause disproportionate efforts. In that case, we may take alternative measures to protect your rights and freedoms.
Why do we need your personal data?
Jobetto processes your personal data only for the purposes specified below:
- General HR management and administration purposes (including workforce management): The processing is necessary for the performance of the temporary worker’s employment contract; and/or Processing is necessary for compliance with employment and social security legal obligations;
- Compensation, payroll and expense reimbursement (including reporting and billing to clients): The processing is necessary for the performance of the temporary worker’s employment contract; and/or Processing is necessary for compliance with employment and social security/tax legal obligations;
- Insurance, pension and other benefits: Processing is necessary for the performance of the temporary worker’s employment contract; and/or Processing is necessary for compliance with employment and social security legal obligations;
- Performance management, career development and training: Processing is necessary for the performance of the temporary worker’s employment contract; and/or Processing is necessary for the purpose of the legitimate interests pursued by Jobetto, which include the development and training of employees;
- Fleet management: Processing is necessary for the performance of the temporary worker’s employment contract; and/or Processing is necessary for the purpose of the legitimate interests pursued by Jobetto, which include safeguarding our assets;
- Disciplinary and grievance management, investigations, appeals (including managing complaints) and handling reports through Jobetto’s misconduct reporting procedure: Processing is necessary for the purpose of the legitimate interests pursued by Jobetto, which include the protection of company assets, protecting its legal interests and managing legal claims/disputes;
- Dispute management and litigation: Processing is necessary for the purpose of the legitimate interests pursued by Jobetto, which include the protection of company assets, protecting its legal interests and managing legal claims/disputes;
- Health and safety management: The processing is necessary for the performance of the temporary worker’s employment contract; and/or Processing is necessary for compliance with employment and social security legal obligations. If not based on the above grounds: Processing is necessary for the purpose of the legitimate interests pursued by Jobetto, which include the protection of its employees, company assets, protecting its legal interests and managing legal claims/disputes; or protection of the vital interests of the Data Subjects;
- Managing holidays, leaves and other absences: Processing is necessary for the performance of the temporary worker’s employment contract; and Processing is necessary for the purpose of the legitimate interests pursued by Jobetto, which include improving efficiency in the workplace and the proper conduct of its business;
- Compliance with labor, tax and social security laws and other legal or regulatory requirements (e.g. equal opportunity and workplace diversity requirements): Processing is necessary for compliance with employment and compliance with our legal obligations under labor, tax, social security and other laws and regulations;
- IT support: Processing is necessary for the performance of the temporary worker’s employment contract; and/or
- Processing is necessary for the purpose of the legitimate interests pursued by Jobetto, which include safeguarding our assets and ensuring security of our information systems;
- Facilities, security and contingency planning purposes: Processing is necessary for the performance of the temporary worker’s employment contract; and/or Processing is necessary for the purpose of the legitimate interests pursued by Jobetto, which include safeguarding and securing our assets, our facilities, our information systems and our people;
- Network and device usage optimization and related security controls (including company network access and authentication): Processing is necessary for the performance of the temporary worker’s employment contract; and/or processing is necessary for the purpose of the legitimate interests pursued by Jobetto, which include safeguarding our assets and ensuring security of our information systems;
- Preventing, detecting and investigating fraud and other crimes, and compliance with sanctions regimes (including identification of politically exposed persons, specially designated nationals and screening against sanctions lists): Processing is necessary for the purpose of the legitimate interests pursued by Jobetto, which include the protection of company assets, protecting its legal interests and managing legal claims/disputes; and/or Processing is necessary to comply with our legal obligations (including when authorities or administrations ask information about a temporary worker);
- Emergency and disaster management: Based on a legitimate interest pursued by Jobetto, which includes ensuring the safety of talent; and Where the above ground is not possible because local mandatory law requires so, only in those limited cases may this be based on a consent;
- Relocation, mobility and travel management: Processing is necessary for the performance of the temporary worker’s employment contract; and/or Processing is necessary for the purpose of the legitimate interests pursued by Jobetto, which include improving efficiency in the workplace and the proper conduct of its business;
- To conduct checks to verify your suitability for placements: we may carry out criminal record checks, credit checks and verify whether you are a politically exposed person, a specially designated national or otherwise subject to sanctions under applicable laws or regulations.
- To monitor and enforce compliance with Jobetto policies and procedures: For the purpose of the legitimate interests pursued by Jobetto, which include safeguarding our assets and ensuring security of our information systems;
- To monitor and enforce compliance with legal obligations applicable to us (including the requirements set out in your contract with us): Processing is necessary for the purpose of the legitimate interests pursued by Jobetto, which include the protection of company assets, protecting its legal interests and managing legal claims/disputes;
- Recruitment and staffing: based on the legal grounds of (a) (pre-)contractual necessity for our services when matching (e.g. via Terms & Conditions on the website) or when we enter into an employment contract with you we require some data to be able to draw up this contract and to then be able to execute it correctly; (b) If and only if the local process would not amount to a legally binding contractual relationship under (a) or if applicable law prescribes otherwise, the exception could be based on our legitimate interest to build and maintain a relationship; (c) Where (a) and (b) are not possible or local mandatory law requires so, only in those limited cases may this be based on a consent
- To provide references about you to third parties: Processing is necessary to perform the Services, to comply with our legal obligations for the purposes of legitimate interests particularly to maintain records and to comply with legal, regulatory and corporate governance obligations and good practice;
- Employee surveys, statistical purposes: Based on our legitimate interest to survey our temporary workers so as to better understand their needs, to improve our services and to build and maintain a good relationship with our temporary workers and with the clients our temporary workers work at;
- Events: Based on our legitimate interest to organise events so as to better build and maintain a good relationship with the community of temporary workers and with the clients our temporary workers work at;
- To manage memberships of employees to professional associations: Processing is necessary for the purpose of the legitimate interests pursued by Jobetto, which include improving efficiency in the workplace and the proper conduct of its business;
- To perform internal and external audits: Processing is necessary for the purpose of the legitimate interests pursued by Jobetto, which include improving efficiency in the workplace and the proper conduct of its business, including compliance with laws and regulations;
- To conduct corporate transactions (including mergers, acquisitions and divestments): Processing is necessary for the purpose of the legitimate interests pursued by Jobetto, which include Jobetto’s interest in developing its business through mergers, acquisitions and divestments;
How long do we keep your personal data?
We will retain your personal data for 5 years from the last day you worked on a temporary assignment. We will retain certain pay-related and other financial information for 7 years in order to comply with our legal obligations.
In any event, we may keep your personal data for longer if necessary in connection with any actual or potential dispute (e.g. we need this personal data to establish or defend legal claims), in which case we will keep your personal data until the end of such dispute or if we are required to do so by any applicable law or regulation.
client
In the context of our Services, we process your personal data if you are working for companies with which we are conducting (or intending to conduct) business (e.g. to make offers for the Services and to maintain a business relationship with the company you work for).
what personal data do we collect about you?
We process the following personal data about you:
- Identification information – we may process your name and other contact information (including email address, landline phone number and mobile phone number), gender, digital signature and languages spoken.
- Professional information – we may process information related to your work including (without limitation) your job title, your location and your department.
- Photographs and video footage – when participating in our events, meetings, conferences etc., we may process photographs or videos of you.
- Survey results – we may process your responses to questions in surveys.
- Visitor information – when accessing our buildings, we may collect your name, contact details, car plate number, identification, etc. for security reasons. Where we are legally permitted to do so we may also ask you to disclose information about your health (including information related to viral infections, flu, etc.) for health and safety reasons.
- Information you choose to share with us – we may process additional information if you choose to share that with us.
- Trade sanctions information relating to you - we may verify whether you are a politically exposed person, a specially designated national or otherwise subject to sanctions under applicable laws or regulations.
This data may be obtained directly from you, from the public domain or from third parties. In the last case, we will inform you of the purpose and data sources we use, the exception is where the provision of this information to you would cause disproportionate efforts. In that case, we may take alternative measures to protect your rights and freedoms.
why do we need your personal data?
Jobetto processes your personal data only for the purposes specified below:
- To administer and manage the contractual relationship between Jobetto and our clients and suppliers: Necessary for the performance of the contract between Jobetto and the client or supplier;
- Business development (including sending direct marketing and offers to those who have opted in): Depending on the circumstances this may be based either on your consent or on our legitimate interest to maintain good relations with our current or prospective clients and suppliers. You can always choose not to receive direct marketing and offers from us; see the section “Your data protection rights” below;
- Facilities, security and contingency planning purposes: For the purpose of the legitimate interests pursued by Jobetto, which include safeguarding and securing our assets, our facilities, our information systems and our people;
- Health and safety management: Processing is necessary for the purpose of the legitimate interests pursued by Jobetto, which include the protection of its employees, company assets, protecting its legal interests and managing legal claims/disputes; and/or protection of the vital interests of the Data Subjects;
- To conduct corporate transactions (including mergers, acquisitions and divestments): Processing is necessary for the purpose of the legitimate interests pursued by Jobetto, which include Jobetto’s interest in developing its business through mergers, acquisitions and divestments;
- Events: Based on our legitimate interest to organise events so as to better build and maintain a good relationship with our clients and our suppliers;
- Preventing, detecting and investigating fraud: To comply with our legal obligations when some authorities or administrations ask information about our contact as a client; and/or Processing is necessary for the purpose of the legitimate interests pursued by Jobetto, which include the protection of company assets, protecting its legal interests and managing legal claims/disputes;
- IT support: Processing is necessary for the purpose of the legitimate interests pursued by Jobetto, which include safeguarding our assets and ensuring security of our information systems;
- Surveys (including satisfaction surveys): Based on our legitimate interest to survey our clients so as to better understand their needs, to improve our services and to build and maintain a good relationship with our clients;
- Dispute management and litigation: Processing is necessary for the purpose of the legitimate interests pursued by Jobetto, which include the protection of company assets, protecting its legal interests and managing legal claims/disputes with our clients and suppliers;
- Compliance with legal or regulatory requirements: Processing is necessary for compliance with our legal or regulatory obligations (e.g. obligations under tax laws to keep certain information including personal data);
- Preventing, detecting and investigating fraud: To comply with our legal obligations when some authorities or administrations ask information including personal data; and;or Processing is necessary for the purpose of the legitimate interests pursued by Jobetto, which include the protection of company assets, protecting its legal interests and managing legal claims/disputes;
- To monitor and enforce compliance with Jobetto policies and procedures: For the purpose of the legitimate interests pursued by Jobetto, which include safeguarding our assets and ensuring security of our information systems;
- To perform internal and external audits: For the purpose of the legitimate interests pursued by Jobetto, which include the proper conduct of its business and accuracy of financial reporting;
How long do we keep your personal data?
We will retain your personal data until you inform us in writing that you withdraw your consent for us to do so.
In any event, we may keep your personal data for longer if necessary in connection with any actual or potential dispute (e.g. we need this personal data to establish or defend legal claims), in which case we will keep your personal data until the end of such dispute or if we are required to do so by any applicable law or regulation.