Privacy Notice
(updated 21 August 2019)
This Privacy Notice (“Notice”) describes how Moving People (we, us, our or Moving People) may use, process, store and disclose Personal Information that we may collect about individuals through this website and from other sources, such as when you apply for a job through job sites. The types of data we collect are described in the section below “Your Personal Information and how we collect it”.
We act as a controller and we are responsible for the Personal Information we process. This Notice informs you how we protect your Personal Information and informs you about your privacy rights.
It is important that you read this Notice so that you are fully aware of how and why we are using your Personal Information.
This website is not intended for children and we do not knowingly collect data relating to children.
Contact Details
If you have any questions about how we use your Personal Information, contact us at: info@movingpeople.com.
Your Personal Information and how we collect it
Registering with this Website
When you use this website, we may ask for certain Personal Information including your name and contact information (email, home address, phone number, age, nationality, profession and other background information). We will collect your Personal Information directly from you and from other sources including when you apply for a job via a Job Board, directly through our website, from Social Media sites such as LinkedIn, Facebook and Twitter or when you provide us with your details during a job fair, promotional, networking or training event.
During our Candidate Registration process we will collect your Personal Information directly from you and your CV. Our Clients may request additional Personal Information about you in relation to their job vacancies and requirements. The categories of Personal Information we may collect include:
• your Identity (your full name, previous names, evidence of change of name); gender, date of birth and marital status;
• evidence of your right to work which may include a photograph, nationality, place of birth, driving licence, etc (in accordance with legal requirements);
• contact details including your email, home address and phone numbers;
• your job search criteria, preferences and expectations;
• your qualifications, skills, experience and training;
• current remuneration and other benefits;
• educational history;
• employment history;
• details of employment;
• other information contained in your CV or that you choose to provide to us;
• usage data including information about how you use our website and services;
Information about your health and/or judicial/criminal records will only be processed if this is relevant to your job application and in compliance with legally imposed restrictions.
To provide you with work finding services our recruitment consultants will contact you with proposal matching your job search criteria and preferences.
If you provide us with information about 3rd parties, we will assume that the 3rd party in question has given you permission to do so and to Moving People collecting, processing and transferring their Personal Information to the same extent as yours.
Our Clients and Suppliers
If you are a Client or supplier of services, we will collect and process information about individuals in your organisation to enable us to communicate with them and to provide our services or receive services. Usually we process the individual’s name and business contact data only.
Website visitors
We collect a limited amount of information about our website users, which we use to help us improve your experience with our website and manage our services.
The following information will be collected:
• technical data including internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. Please see our Cookie Policy for further details;
• usage data including information about how you use our website and services;
How we use your Personal Information
We use, process, store and disclose your Personal Information and other data we collect including during our Candidate Registration process. Moving People will process your Personal Information in accordance with our Candidate contract (provided during our candidate registration process) applicable to the type of work you are seeking and we will disclose your Personal Information to our Clients in relation to their job vacancies.
We will also process your Personal Information for other legitimate business purposes such as producing statistics, analysing how successful our marketing campaigns are, the number of visitors to our website and complying with other contractual, legal and regulatory obligations and duties.
Currently we do not use automated decision-making technologies to make final or conclusive decisions about you and a member of our staff will always be involved in the provision of working finding services.
Change of Purpose
We will only use your Personal Information for the purposes for which we collected it (e.g. the provision for employment), unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your Personal Information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
We may process your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosing your Personal Information to 3rd Parties
To the extent necessary or appropriate and without notifying you, Moving People may disclose your Personal Information to external 3rd Parties (who are not members of the Moving People group of companies) in the following circumstances:
• to government agencies including: Police and other law enforcement agencies; regulatory and supervisory authorities and 3rd parties performing sanctions and terrorism checks.
• to comply with applicable laws or if we reasonably believe that such action is necessary to: (a) comply with the law requiring such disclosure; (b) protect the rights or property of Moving People or its group companies; (c) prevent a crime, protect national security or for fraud detection or prevention; or (d) protect the personal safety of individuals using our website or members of the public.
• to IT consultants carrying out testing and development work on our IT systems, service providers who we may appoint as data processors and to other service providers who may be based outside the EEA.
Where applicable, we will impose appropriate contractual, security, confidentiality and other obligations on to 3rd party service providers and processors we have appointed, based on the nature of the services they provide to us. We will only permit them to process your Personal Information in accordance with the law and our instructions. We do not allow them to use your Personal information for their own purposes and when our relationship ends
we will ensure your Personal Information is securely returned or destroyed.
Some of these 3rd parties are also controllers responsible for processing your Personal Information for their purposes, for example, the local tax authority is a controller for tax purposes. We may not be able to impose obligations or restrictions on these controllers in connection with how they process your Personal Information.
Keeping your Personal Information Secure
We have put in place appropriate security measures to prevent your Personal Information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Information to those employees who have a business need to do so.
We have put in place procedures to deal with any suspected Personal Information breaches and we will notify you and the applicable supervisory authority of a breach where we are legally required to do so.
How long we Retain your Personal Information
Moving People will retain your Personal Information for as long as necessary to fulfil the purposes that we collected it for. This means we will keep your Personal Information throughout the period of your relationship with us and whilst we are providing you with work finding services.
If you have not been placed in a job by us, your data will be stored up to 2 years after the final contact. At the end of this period, you will be contacted again to decide whether you want to continue to be registered at our offices.
If you have been placed in a job by us, your data will be stored up to 5 years after signing the last contract. At the end of this period, you will be contacted again to decide whether you want to continue to be registered at our offices.
Your personal data will in any case be stored in compliance with the law and the limitation periods that oblige us to store your personal data for a longer period, e.g. to defend ourselves against any legal actions.
Where there is no retention period stated in law, we determine the appropriate retention period for Personal Information by considering the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of the data, the purposes for which we process it and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your Personal Information (so that it can no longer be associated with you and we cannot identify you). We do this for research or statistical purposes in which case we may use this anonymised data indefinitely without further notice to you.
Details of the retention periods for different aspects of your Personal Information are set out in our Record Retention and Destruction Policy which you can request from us by contacting us at: info@movingpeople.com
Your Legal Rights
You have the right to:
Make a Data Subject Access Request to access your Personal Information at any time. This enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it.
Request correction of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate Personal Information we hold about you corrected, although we may need to verify the accuracy of the new data you provide to us.
Request erasure / deletion / removal of your Personal Information. This enables you to ask us to delete or remove your Personal Information where we do not have a valid reason to continue to process it. You also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your Personal Information to comply with local law. Please Note: we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your Personal Information where we are relying on a legitimate interest (or those of a 3rd party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. We are not processing direct marketing. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which
override your rights and freedoms.
Request restriction of processing of your Personal Information.
This enables you to ask us to suspend the processing of your Personal Information in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have
overriding legitimate grounds to process it.
Data Portability / Request the transfer of your Personal Information to you or to a 3rd party. We will assist you with this transfer to a 3rd party either by transferring your Personal Information for you or by providing you with a copy in a machine readable format. Please Note: this right only applies to automated information which you initially provided consent for us to use or where we used the Personal Information to perform a contract with
you.
Withdraw consent at any time where we are relying on your consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
We want to ensure we keep your Personal Information accurate and up to date. In addition to your legal rights, you may ask us to make changes or request a copy of your Personal Information informally, by contacting your local Moving People branch.
Additional information, Response Times and Fees
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights or when you make an informal request). This is a security measure to ensure that Personal Information is not disclosed to any person other than the individual who has the right to receive it. We may also contact you to ask you for further information in relation to your request to help us locate your data and to speed up our response.
We try to respond to all legitimate requests within one month. It may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You will not have to pay a fee to exercise any of these rights. However, we may charge a reasonable fee if your request is unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
The Legal Basis for processing your Personal Information
We have set out a short description of main ways we will collect, store, process, share and disclose your Personal Information and the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.
We will only use your Personal information when the law allows us to. Most commonly, we will use your Personal information in the following circumstances:
• To fulfil a contract, we are about to enter into or have entered into with you;
• Where it is in our legitimate interests;
• When it is our legal or regulatory duty;
• When you consent.
A legitimate interest is when we have a business or commercial reason to use your information in conducting and managing our business. We will consider and balance any potential impact on you and your legal rights when we process your Personal Information for our legitimate interests. We do not use your Personal Information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise
required for compliance with a legal or regulatory obligation or permitted to by law).
| Purpose/Activity | Type of Personal Information | Lawful basis for processing Personal Information |
|---|---|---|
| To register you as a candidate for work finding services | Identity Contact details Evidence of your right to work CV Qualifications | Fulfil a contract Legal or regulatory duty (complying with the recruitment industry and immigration regulations) |
| To provide you with work finding services including: sending you details of available job opportunities and job alert emails in accordance with your job search preferences and criteria, providing your CV to clients in relation to their job vacancies / roles) and charging clients for placements we make. | Identity Contact details Financial data Transaction data information Qualifications | Fulfil a contract (RH Candidate Agreement and Client Contracts); Legitimate interests Legal or regulatory duty |
| Disclosing your Personal Information to government and law enforcement agencies and our appointed 3rd party vendors providing services. | Identity Contact details Evidence of your right to work CV Qualifications Financial data | Legitimate interests Legal or regulatory duty |
| To manage our relationship with you including: Notifying you about changes to our Candidate Agreement or Privacy Notices Asking you to leave a review or feedback or complete a survey administration and IT services connected with representing you for roles, etc | Identity Contact Profile/Survey | Fulfil a contract Legal or regulatory duty Legitimate interests (keeping our records updated and to study how candidates and potential candidates and visitors to our website use our services and website, to develop and improve them and to grow our business |
| Keeping your Personal Information secure to prevent it from being lost, used, accessed, disclosed or altered in an unauthorised way | Identity Contact details Evidence of your right to work CV Qualifications Remuneration | Legal or regulatory duty Legitimate interests Fulfil a contract |
| To investigate issues, disputes and complaints between us, and between us, you and our clients and to seek to resolve them | Identity Contact details Profile Usage data Evidence of your right to work CV Qualifications Remuneration | Legitimate interests Defense against legal claims Fulfil a contract |
| To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | Identity Contact Technical data | Legitimate interests (keeping our business and website safe) Legal or regulatory duty |
| To deliver relevant website content and measure or understand the effectiveness of our advertising | Identity Contact Profile data Usage data Technical data | Legitimate interests (to study how customers use our services/website, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our website, services, marketing, customer relationships and experiences | Technical data Usage data Profile data | Legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| Retaining your Personal Information for as long as necessary for the purposes of providing you with work finding services. | Identity Contact details Profile Usage data Marketing and Communications Evidence of your right to work CV Qualifications | Legitimate interests Legal or regulatory duty |
| To help us respond to queries, complaints or for other reasons such as responding to requests from regulators, government and law enforcement agencies such as the Police | Contact | Legitimate interests Legal or regulatory duty |
Cookies
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. For more information about the cookies we use, please see our Cookies Policy.
A cookie is a small piece of data that a website asks your browser to store on your computer or mobile device. The cookie allows the website to “remember” your actions or preferences over time.
When you visit the website for the first time, you are shown a message about the use of cookies. Accepting and closing this message means that you agree to the use of cookies in accordance with the provisions of this privacy policy.
Analysis and statistics
We track website statistics and for this purpose we use Google Analytics. In this regard, collected information is completely anonymous and does not allow your identification.
The use of Google Analytics services involves the implementation of the tracking code provided by Google into our website’s code.
Details related to the use of information collected by Google as part of our use of Google Analytics as part of our site can be found here:
https://policies.google.com/technologies/partner-sites?hl=en
Links to other websitesPage
Our website may include links to 3rd party. Clicking on those links may allow third parties to collect or share data about you. We do not control these 3rd party websites and are not responsible for their privacy statements.
Feedback and Complaints
You have the right to make a complaint at any time to the Belgian supervisory authority for data protection issues, the Commission for the protection of Personal Data (CBPL), (https://www.privacycommission.be/en) We would ask you to provide us with the opportunity to discuss your concerns with you
before you contact the supervisory authority so please contact Moving People, Avenue Lavoisier 18C, 1300 Wavre, Belgium or email info@movingpeople.com.
Changes to this Privacy Notice
If we change this Privacy Notice we will post any updates here for your review. If we change material terms we will provide notice of the revised Privacy Notice for 30 days on our home page at www.movingpeople.com with a link back to this page.
This Privacy Notice was last updated: 21 August 2019.