Personal Data Protection Policy
ICAP PEOPLE SOLUTIONS Α.Ε.
Ave. 2 Eleftheriou Venizelou Avenue, Kallithea, Athens, Greece
VAT 800991837 (GEMI serial number 146482401000)
Last modified on
15.07.2018
- Scope of application
This Privacy Statement sets out the framework within which ICAP People Solutions S.A. (hereinafter “ICAP People Solutions“) collects, uses, processes, stores, manages and protects the data provided through CVs, data related to the skills, competences and psychometric properties of the subjects, as well as the behavioural data and development needs of the subjects (hereinafter “Personal Data“), so that all the above actions are carried out in accordance with the standards of the European Union and the European Union.
The Privacy Policy applies to all information (i) related to the Human Resources products and services (hereinafter “Services“) provided by ICAP People Solutions (including, but not limited to, the provision of training programs, executive search and selection services and HR development consulting services) (ii) relating to subject characteristics collected through third party assessments, by executive search firms, as well as through the use of third party recruitment and selection services, and through the use of the services. ICAP People Solutions is committed to the protection of the private data of clients, individuals and other subjects and complies with the currently applicable legal framework for the protection of personal data.This policy does not apply to information collected through any other website, platform, services, products, or the practices of companies we do not control. We are not responsible for any privacy practices exposed on other companies’ websites or involving other companies’ services, products and/or platforms.
- Categories and types of data we collect
Data we collect:
A. Data from CVs: Name/First name, postal address, contact details (including email address and mobile phone number), academic qualifications, work experience, hobbies, interests, references.
B.Data, relating to personal data: Name/First name , VAT, date of birth, skills, abilities and psychometric qualities (profiling).
C. Data relating to behavioural elements: Name/First name linked to outcomes resulting from training programmes attended by the subject, to individual development needs and to behavioural skills and attributes of the subject (profiling).
Declaration on the Processing of Personal Data by ICAPPeopleSolutions (in its capacity as Data Controller and Data Processor; in accordance with the EU General Data Protection Regulation 679/2016)Why do we process Personal Data?
ICAP People Solutions offers services relating to education and training programmes, executive search and selection and human resources development, for the provision of which it uses CV, personality and behavioural data of the subjects based on the intended purpose as described in paragraph 6 herein. Their content varies depending on the type and purpose of the service provided by ICAP People Solutions. The lawful basis for data processing is the legitimate interest of ICAP People Solutions in providing these services and in some cases the consent of the data subjects.In addition, ICAP People Solutions may collect personal data from prospective employees with their consent for the purpose of providing employment opportunities and related vocational training programs.
In addition, ICAP People Solutions collects data from CVs, results of psychometric tools and employee personality and competency assessments through third party sources (skills assessment platforms, psychometric tools and executive search and selection services or other sources), based on its legitimate interest. More specifically:
(i) ICAP PEOPLES OLUTIONS collaborates with CareerBuilder and uses www.icapcareer.com, an online candidate networking platform, from which it receives and manages data of a professional nature as well as data provided in the subjects’ CVs. For
more information regarding CareerBuilder, please read the Privacy Policy at: https:
//hiring.careerbuilder.com/company/privacy-policy(ii) ICAP PEOPLE SOLUTIONS works with INAC, an international network of executive search and selection companies, from which we receive and manage professional data and data provided in the CVs of the subjects.
(iii) ICAP PEOPLE SOLUTIONS uses the on-line individual/company assessment platform Cut-e (https://www.cut-e.com/assessment-solutions/) from which we receive and administer individual or company employee skills tests.
For more information about the Cut-e
platform please read our Privacy Policy at: https:
//www.cut-e.com/privacy/(iv) When acting as a data processor on behalf of its corporate clients in accordance with their written instructions, ICAP People Solutions uses the online Hogan personality assessment platform (https://www.hoganassessments.com/about/) from which it receives data ,relating to individual skills, competencies and psychometric attributes
For more information about the Hogan platform please read the Privacy Policy at: https:
//www.hoganassessments.com/privacy-policy/(v) HICAPPEOPLESOLUTIONS uses the online education and training platform “MyHuthwaite” (https://myhuthwaite.com) to provide e-learning services.
For more information about the “MyHuthwaite”
platform please read the Privacy Policy at https://huthwaiteinternational.com/privacy-policy/
Information is automatically collected when you visit or interact with the websites: Regarding the data collected through the website https://www.icap.gr/ you can find out about the respective privacy statement at [https://www.icap.gr/Default.aspx?id=10821&nt=18&lang=1]. - Data collection points●Platforms
used for the provision of recruitment services (INAC, ICAPCareer) – A●Platforms
used for personality assessment (Cut-e, Hogan) – B●
Platforms used for the provision of e-learning services (Huthwaite)
● Information provided by subjects through on-line forms or e-mails) – A, C●
Information provided by corporate clients in the context of cooperation with them – C - Transfer of Data to Third Parties
ICAPPeopleSolutions does not share or disclose your personal information without your consent, except for the purposes set out in this statement or where there is a legal obligation to do so. ICAPPeopleSolutions reserves the right to disclose your personal data to any member of its subsidiary/subsidiaries (parent company and its subsidiaries) or other third parties to the extent reasonably necessary for the purposes set out in this statement and in particular:
●Certain data (from CVs and professional data, competency and/or personality tests) will be transferred to corporate clients with whom we have contractual agreements in order to fulfil obligations
● Profiling data, related to the behaviour and skills development of subjects, may be transferred directly to individuals requesting the provision of the self-training
service or to corporate clients requesting corresponding training programmes for their employees ●
Profiling data, related to the skills, competences and psychometric qualities of subjects, may be disclosed to individuals or corporate clients with whom we have contractual agreements ●
Your data may be
transferred to
individuals or corporate clients with whom we have contractual agreements
● Your data may be transmitted, accessed and processed by our group subsidiaries within the European Union, which implement appropriate technical, physical and administrative security measures to protect the data against loss, misuse, damage, alteration, unauthorized access and disclosure, as provided for by Article 32 of the European Data Protection Regulation 679/2016●
Some data (CVs and professional data) are transferred and processed by For more information about CareerBuilder read their Privacy Policy here: http://www.careerbuilder.com/ie/jobseeker/info/privacy.aspx●
During data transfer, we always take all appropriate measures to ensure that the data transferred is the minimum required for the intended purpose of processing and that the conditions for lawful processing are always met. In addition, all data processors acting on our behalf only process your data in accordance with our instructions and fully comply with this privacy policy.
● ICAPPEOPLESOLUTIONS servers are hosted in the IBM data centre (hosting provider) located in Athens. You can find more information about IBM’s privacy statement at the following link: https://www.ibm.com/privacy/details/us/en/#section_2 - Retention period for Personal Data
ICAPPEOPLESOLUTIONS retains personal data only for as long as necessary by implementing strict review and retention policies in place to meet these obligations. The retention period depends on the lawful basis for the processing, as set out in detail below:
●Where the lawful basis for the processing is the pursuit of legitimate interest, personal data is processed for as long as is necessary to achieve ICAPPeopleSolutions
‘ intended lawful purpose, as described in paragraph 6, and until the limitation period for all relevant claims has expired.
●In case the personal data of individual employees have been provided with their own consent and in the context of our services, we will retain this data until the consent granted by the data subject is revoked. Where consent has been withdrawn for any valid reason, we will retain it for as long as necessary until the limitation period for all relevant claims expires.
● Where the lawful basis for the processing is the performance of the contract, we will retain your data for as long as the contractual relationship with ICAPPeopleSolutions is
in force in paper and electronic form or retain it for as long as necessary until the limitation period for any relevant claim expires. - Legitimate Interest – Purpose – Lawful Basis for Data Processing
The processing of data is necessary for the achievement of the legitimate interest pursued by ICAPPEOPLESOLUTIONS. The legitimate purpose of ICAPPEOPLESOLUTIONS is to provide training, recruitment and staffing services as well as human resources development consultancy services.
In this context, ICAPPEOPLESOLUTIONS collects, manages and provides data contained in CVs related to the skills, competencies and psychometric qualities of the subjects, as well as data on the behaviour and development needs of the subjects, for the execution of contracts with corporate or individual clients. ICAPPEOPLESOLUTIONS processes and stores these data within the EU. - Rights of Subjects
You may exercise, as the case may be, the rights arising from the applicable Greek legislation and the General Data Protection Regulation (Regulation (EU) 2016/679), which are as follows: a. the right to information (Article 13), b. the right of access (Article 15), c. the right of rectification (Article 16), d. the right of erasure (Article 17), e. the right to restriction of processing (Article 18), f. the right to restriction of processing (Article 18). the right to data portability (to receive your personal data in a structured and commonly used format – Article 20, applicable as appropriate) and g. the right to object (Article 21), which applies to certain data processing activities.These rights can be exercised free of charge for you by sending a letter to the Data Protection Officer (DPO) of ICAPPeopleSolutions: 2, Eleftheriou Venizelou, Kallithea or by e-mail to [email protected]. However, in the event that the aforementioned rights are exercised improperly and without reasonable cause, thereby causing us an administrative burden, you may be charged the costs associated with the exercise of the relevant right.In the event that you exercise any of your rights, we will take all necessary measures available to satisfy your request within thirty (30) days of receipt of the request. We may inform you either of the acceptance of your request or of any objective reasons that may prevent the processing of your request.Notwithstanding the above, you may at any time object to the processing of your Personal Data by withdrawing your consent (Article 7, paragraph 7. 3 of the AEPC 679/2016) by sending a letter to the Data Protection Officer (DPO) of ICAPPeopleSolutions: 2, Eleftheriou Venizelou, Kallithea, or by e-mail to [email protected], this right applies only in cases where the legal basis for the processing of the data is the consent of the data subject. - Data Processing by ICAP PEOPLE SOLUTIONS
In some cases, our corporate clients provide their employees’ data ( data related to the development needs and skills of employees) in order to provide them with training programs that are tailored to the needs of their employees. In such cases, ICAPPeopleSolutions acts as a “Data Processor” of the personal data included in such training program elements. Consequently, in such cases, different requirements of the General Data Protection Regulation 679/2016 apply, under which ICAP PEOPLE SOLUTIONS complies.In addition, throughout the data processing process, ICAP PEOPLE SOLUTIONS applies appropriate technical, physical and administrative security measures to protect and secure personal data against loss, misuse, damage or alteration, unauthorized access and disclosure, in accordance with Article 32 of the General Data Protection Regulation 679/201 These include, inter alia and as appropriate: a) the application of encryption protocols; b) the possibility of ensuring confidentiality (Article 90 GDPR 679/2016), integrity, availability, and resilience of systems and processing services on a continuous basis , c) the possibility of restoring the availability and access to personal data in a timely manner in the event of physical or technical incidents and failures; d) a procedure for regular monitoring and evaluation of the effectiveness of technical and In addition, ICAP People Solutions takes measures to ensure that any natural person, acting under the supervision of the controller or processor, who has access to personal data, will not process such data except on the instructions of the data controller and on the basis of access limits to your personal data, which are set to authorized employees.The additional security measures implemented by ICAPPEOPLESOLUTIONS are as follows:● ICAPPeopleSolutions maintains a
specialized
● The company conducts continuous infrastructure audits to identify vulnerabilities in systems vulnerabilities, etc.
● The company uses the https
protocols for secure and encrypted client communication with ICAPPeopleSolutions.
● The company uses the standard LightweightDirectoryAccessProtocol (LDAP) protocol and in the respective directory services and uses encrypted passwords.
● The company uses the SecureSocketsLayer (SSL)
protocol to establish an encrypted connection between the webserver and the Client/User’s browser.
● ICAPPEOPLESOLUTIONS is ISO 9001 and ISO 27001 certified. - Profiling
We use the information we obtain from third-party sources such as: a) profiling data related to the results of skills assessment and personality tests of the subjects, b) reports and results of employee skills assessment to process, evaluate and categorize data based on our clients’ requirements.We may also perform personalized skills assessment, executive assessment, personality tests, 360 feedback, competency tests if requested by the clients. Our clients can choose to use our assessment reports independently or in combination with other information available to them. We do not maintain blacklists of any kind and do not encourage our clients to reject or approve under any circumstances employees or other persons based on these reports. - Submission of requests:
●For any issue concerning the processing of personal data, you can contact us at [email protected]●Also
, you can always contact the Hellenic Data Protection Authority, which accepts requests and appeals in writing at the protocol office at 1-3, Kifissia
Street, P.C. 115 23, Athens or by e-mail ([email protected]), according to the instructions provided on their website.
● If you no longer wish to receive updates from ICAPPEOPLESOLUTIONS, please send us an e-mail to [email protected] or follow the unsubscribe instructions included in any relevant e-mail or contact with us. - Modifications
This policy may be updated in due course, in case of changes in legislation or in case of modification of the business structure of ICAPPEOPLESOLUTIONS. We therefore encourage our clients to visit our website periodically to be informed of any amendments to our privacy policy. In any case, our clients may be notified by e-mail or a relevant posting on our website regarding recent amendments to this policy.