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Privacy Policy and Personal Data Protection

Last updated March 2024

Introduction

This Privacy Policy outlines how we collect, use, or process your personal data while adhering to legal requirements. We highly value the privacy of all parties we engage with and are dedicated to protecting your data privacy rights.

This policy applies to the following categories of individuals: Candidates, Temporary Workers, Clients, Suppliers and Third Parties, Individuals Whose Data We Receive, and Website Users. We comply with applicable data protection legislation, including but not l imited to the General Data Protection Regulation (GDPR) and the Bulgarian Personal Data Protection Act.

Please be aware that this Privacy Policy may be updated over time. If you have any concerns about any aspect of our Privacy Policy, you may have specific legal rights, as outlined in this document.

Our Privacy Policy details how we use your personal data and outlines your rights. For example, you can request data deletion, verify the information we hold about you, revoke consents, or lodge a complaint with our Data Protection Officer or a supervisory authority if necessary.

The Privacy Policy contains the following:

Privacy information that applies to the specific categories of people covered:

General privacy information that applies to all categories of people covered:

Toro Groups Staff can find information about processing of their personal data in the internal policy, available in the office and the internal network.

Candidates applying for roles with Toro Groups will be treated as Candidates in general, as described below.

CATEGORY-SPECIFIC PRIVACY INFORMATION

1. Candidates

This section of the Privacy Policy applies to Candidates.

Candidates are natural persons with whom we may or may not have had previous interaction, but whom we believe would be interested in, or stand to gain from, our services. This includes those being considered for any positions we are recruiting for, whether advertised or not, comprising permanent, temporary, or part time positions.

Candidates also include active applicants for these positions who have submitted applications in response to a job posting, individuals who have forwarded their CV to us without reference to any particular job, or those who have interacted with us regarding our services and/or advertised positions. Additionally, it includes individuals who are part of our candidate database from past interactions. Individual contractors, freelancers, and personnel of suppliers or other third parties proposed for roles with our Clients as part of a contingent workforce offering will be regarded as Candidates for the purposes outlined in this Privacy Policy.

In varying circumstances, we may gather some or all the information detailed below. This enables us to determine how we can offer optimal support if we reasonably ascertain your potential interest in or benefit from our services. Primarily, we utilize this data to provide employment opportunities aligned with your preferences. It’s crucial to acknowledge that the collected information supplements any personal data we are legally required to process under specific circumstances.

Key identification and contact information

  • Name;
  • Age/date of birth;
  • Photograph;
  • Marital status;
  • Nationality/citizenship/place of birth;
  • Contact details;

 

Education and employment information

  • Education details;
  • Employment history;
  • Current job title/specialism/industry sector;
  • Skills and languages spoken;
  • Referee contact details;
  • Immigration status (whether you need a work permit);
  • Start date or availability date;
  • Information regarding your past, present, or anticipated compensation and benefits
  • Details regarding your preferences and requirements concerning future employment, gathered either directly or inferred

 

Financial Information

  • Bank details;
  • Other financial information;

 

Special category information

  • Information about your physical or mental well being, including details about disabilities,
    to facilitate the provision of reasonable accommodations. Additionally, health related
    data may be utilized or offered for occupational health purposes in specific role contexts;

 

Criminal conviction data

  • Information regarding any criminal convictions, if required for a role you are considering
    applying for;

 

Automatically collected information

  • IP address;
  • Usage information including the dates, times and frequency with which you access our
    services;
  • User choices (e.g. marketing preferences);
  • User reports;
  • Log and troubleshooting information;
  • Device information when you access or use our services;
  • Website browsing data e.g. pages viewed on our website;
  • Email engagement history with us
  • Location information (inferred from jobs, IP address, application history or system stored data);

Information that others provide about you

  • Extra information that people who refer you to us choose to tell us about you;
  • Additional details provided by our Clients or obtained from third party sources such as job sites or web platforms (where you have uploaded information, or is otherwise made available to us);
  • Data concerning your interests and preferences regarding future employment, acquired both directly and inferred. This may include insights derived from jobs viewed or articles read on our website, as well as from links clicked on in emails from us; and

 

Additional information that you choose to tell us

  • Any other information that you may provide to us when corresponding with us via email
    or otherwise.

Please be advised that the aforementioned list of personal data categories we collect may not be exhaustive and is subject to change over time.

Additionally, accessing our website or clicking through any links in an email from us will result in the collection of certain data from you. For further details on this matter, please refer to the section of this Privacy Policy that pertains specifically to Website Users.

HOW DO WE COLLECT YOUR PERSONAL DATA?

We collect Candidate personal data in the following ways:

  • Personal data that you give to us;
  • Personal data that we receive from other sources; and
  • Personal data that we collect automatically.
  •  

Personal data you give to us

We need to know certain information about you in order to provide you with our services. This will enable us, amongst other things, to provide you with the best opportunities, and should save you time in not having to go through information about jobs and services that are not relevant to you.

There are numerous ways you can share your information with us. These may include:

  • Entering your details on our website or via an application form;
  • Leaving a hard copy CV at a recruitment event, job fair or our office;
  • Emailing your CV or other information, or otherwise sending a CV through a messaging platform, to a consultant, or being interviewed by them;
  • Applying for jobs through a job platform, a job aggregator, which then redirects you to the our website, or applying directly on our website;
  • Applying to a job post, sending your CV or other information through a social media channel such as Facebook, LinkedIn or similar.

 

The types of information that we may receive from you in this way include:

  • Key identification and contact information;
  • Education and employment information;
  • Special category information;
  • Additional information that you choose to tell us

Personal data we receive from other sources

We also receive personal data about Candidates from other sources. Depending on the relevant circumstances and applicable local laws and requirements, this entails receiving personal data in the following scenarios:

  • When conducting a search for Candidates through third-party sources like LinkedIn and other job sites, through which we obtain your personal information, and/or when conducting other pre-recruitment activities (please see the section titled “Pre-recruitment activities” below);
  • If you were referred to us by another recruitment agency, they may have shared personal information about you with us;
  • Your referees would disclose personal information about you;
  • Our Clients, Suppliers, other Candidates and our colleagues within TGS and our sister-company Friisberg & Partners Bulgaria (e.g. in the context of them making a referral) may share personal information about you with us;
  • If we receive your personal information from Facebook, if you ‘like’ our Facebook page (or perform a similar interaction with us on any social media platform on which we have a presence); and

Personal data we collect automatically

  • If you access our website or interact with our emails, we may collect your data automatically (e.g., through website tracking scripts like cookies or pixels) or by your direct provision. This collection is conducted in accordance with any legal requirements. For further details, please refer to the section of this Privacy Policy that specifically addresses Website Users.

HOW DO WE USE YOUR PERSONAL DATA?

We generally use Candidate data in the following ways:

  • Pre-recruitment Activities;
  • Recruitment Activities;
  • Marketing Activities;
  • Equal Opportunities Monitoring;
  • To help us to establish, exercise or defend legal claims.
  • In appropriate circumstances, we also use Candidate data for Profiling.

Pre-recruitment Activities

  • During pre-recruitment activities, we utilize your data to determine your potential interest in or benefit from our services, and to evaluate how we could potentially assist you. If we believe we can provide assistance, we will use your contact details to reach out and ascertain your interest in our services (typically through a LinkedIn message).
  • For us to do this, we may:
    • Collect your personal data;
    • Store your details (and update them when necessary) on our database so that we can contact you about our services;
    • Send you an email to inform you about our processing of your personal data and to direct you towards this Privacy Policy;
    • Review your information to work out whether and how our services might help you; and
    • Contact you about our services.
  • Below, we’ve provided further details on the various methods we employ to use and process your personal data in order to assess whether our services would be advantageous to you. Please be aware that this list is not exhaustive.
  • Typically, we utilize your personal data for the following purposes if we consider it necessary to do so for our legitimate interests. Article 6(1)(f) of the GDPR permits us to process your data when it “is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of you which require protection of personal data.”
  • We believe that none of the activities for which we rely on the legitimate interests condition would prejudice Candidates in any manner. Nevertheless, you retain the right to object to us processing your personal data on this basis. For further information on how to do so, please consult the section titled “How can you access, amend, or retract the personal data that you have provided to us” in the General Privacy Information section of this Privacy Policy.
Why and how we process your information Types of personal data used Legal basis relied upon
Collecting and processing data in the course of and to the extent necessary to work out whether you might be interested in or benefit from recruitment services, including by: • collecting data from Candidates and other sources, such as LinkedIn • storing Candidates’ details on databases • assessing data against vacancies • Key identification and contact information • Education and employment information • Additional information that you choose to tell us • Information that others provide about you • Automatically collected information Legitimate interests, namely it is in our interests and your interests for us to assess whether you may be interested in or benefit from our recruitment services
Collecting and processing your data in the course of reviewing your information to ascertain how TGS recruitment services may assist • Key identification and contact information • Additional information that you choose to tell us Legitimate interests, namely it is in our interests and your interests for us to identify how we can help you with your job search
Collecting and processing your data in the course of communicating with you in relation to TGS recruitment services • Key identification and contact information • Additional information that you choose to tell us Legitimate interests, namely it is in our interests and your interests to contact and correspond with you as part of providing you with our recruitment services

Recruitment Activities

  • Being a licensed recruitment agency and provider of temporary staffing, one of our main areas of work is recruitment – linking suitable Candidates with suitable positions. Below, we’ve provided further details on the various methods we employ to process your personal data for this purpose. Please be aware that this list is not exhaustive.
  • Typically, we utilize your personal data for the following purposes if we consider it necessary to do so for our legitimate interests. Article 6(1)(f) of the GDPR permits us to process your data when it “is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of you which require protection of personal data.”
  • We believe that none of the activities for which we rely on the legitimate interests condition would prejudice Candidates in any manner – in fact, they help us to offer you a more tailored, efficient service. Nevertheless, you retain the right to object to us processing your personal data on this basis. For further information on how to do so, please consult the section titled “How can you access, amend, or retract the personal data that you have provided to us” in the General Privacy Information section of this Privacy Policy.
  • We may in certain circumstances process your personal data for the purposes below if it is necessary for us to deliver a contractual service to you (or to fulfil a pre-contract request from you). Article 6(1)(b) of the GDPR says that we can process your data where it “is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.”
  • When we process your information for recruitment activities based on your consent, you reserve the right to withdraw your consent at any time without impacting the legality of processing based on such consent prior to its withdrawal. You can do so by referring to the section titled “How can you access, amend, or retract the personal data that you have provided to us” in the General Privacy Information section of this Privacy Policy.
  • If you are dissatisfied with our data processing approach for recruitment purposes, you retain the right to be forgotten and the right to limit processing at any time. You can learn more about how to exercise these rights by referring to the section titled “How can you access, amend, or retract the personal data that you have provided to us” in the General Privacy Information section of this Privacy Policy. We want to let you know that even if you have exercised your right to be forgotten, it is possible that your details may be recaptured through public sources in another recruitment assignment or unconnected marketing campaign. We will try to make sure this doesn’t happen, but if it does, we’re sorry. We’d just ask that in those circumstances you opt out again.
Why and how we process your information Types of personal data used Legal basis relied upon
Collecting and processing data in the course of and to the extent necessary to provide recruitment services to Candidates and facilitating the recruitment process including by: • Collecting data from Candidates and other sources, such as LinkedIn • Storing Candidates' details on database • Assessing data against vacancies • Proactively and directly informing Candidates about vacancies they might be interested in, based on stored data • Sending Candidates' information to Clients in anonymised form, in order to apply for jobs or to assess eligibility for jobs • Enabling Candidates to submit CVs, apply online for jobs or to subscribe to alerts about jobs • Key identification and contact information • Education and employment information • Additional information that you choose to tell us • Information that others provide about you We will rely on legitimate interests, namely it is in our interests and your interests for us to provide you with our recruitment services and for you to receive them in order for us to function as a profit-making business, and to help you and other Candidates to find employment If you have entered or are about to enter into a contract with us or if you are making a request in the course of doing so, we may rely on the performance of a contract legal basis to the extent that the processing activity that we are seeking to conduct is necessary for the purposes of the contract or your request
Collecting and processing Candidates' data in the course of carrying out: • customer satisfaction surveys • TGS market research which we will use to inform our marketing materials and other informational materials such as whitepapers, reports and articles (e.g. our salary guides) To the extent that any data is published, this will be in aggregated/anonymised form only • Key identification and contact information • Additional information that you choose to tell us Legitimate interests, namely it is in our interests to: • improve and develop the recruitment services that we provide to you by considering your feedback and feeding this into our processes where we deem necessary • gain an insight into the careers, goals and aspirations of the Candidates to whom we provide services in order to market our service offering to help differentiate us in a competitive marketplace
Collecting and processing Candidates' data in the course of communicating with Candidates in relation to services-related issues and providing customer support by processing requests for support • Key identification and contact information • Additional information that you choose to tell us We will rely on legitimate interests, namely it is in our interests and your interests to: • address any issues that you have been experiencing • improve and develop the recruitment services that we provide to you by considering your feedback and feeding this into our processes where we deem necessary If you have entered or are about to enter into a contract with us or if you are making a request in the course of doing so, we may rely on the performance of a contract legal basis in relation to using your data in the course conducting communications relating to our services with you
Processing Candidates' data in the course of carrying out TGS obligations arising from any contracts entered into between TGS and third parties in relation to Candidates' recruitment, such as potential employers to whom we are committed to identifying the most suitable Candidates for roles in their organisations • Key identification and contact information • Education and employment information • Information that others provide about you • Additional information that you choose to tell us We will rely on legitimate interests, namely it is in our interests and your interests to fulfil our obligations under agreements with third parties such as potential employers so that we can help you find employment If you have entered or are about to enter into a contract with us or if you are making a request in the course of doing so, we may rely on the performance of a contract legal basis to the extent that the processing activity that we are seeking to conduct is also necessary for the purposes of our contract with you (as well of the third party) ли, за да можем да Ви помогнем да намерите работа. Ако сте сключили или сте на път да сключите договор с нас или ако правите заявка в хода на това, ние можем да разчитаме на изпълнението на договорно правно основание до степента, в която дейността по обработване, е необходима за целите на нашия договор с Вас (както и на третата страна).
Verifying details that a Candidate has provided or to request information (such as references, qualifications and potentially any criminal convictions, to the extent that this is appropriate and in accordance with the law) • Key identification and contact information • Education and employment information • Criminal conviction data • Information that others provide about you • Additional information that you choose to tell us For criminal conviction data, we will obtain your explicit consent. For all other types of data: • we will rely on the legitimate interests legal basis, namely it is in our interests and your interests to verify that all of the information that you have provided to us is true and accurate and to obtain references about your prior conduct as part of the process of finding you employment • if you have entered or are about to enter into a contract with us or if you are making a request in the course of doing so, we may rely on the performance of a contract legal basis to the extent that verifying details that you have provided or the requests that we need to make are necessary for the purposes of our contract with you.
Collecting and processing Candidate data in the course of carrying out assessment and development activities such as psychometric evaluations or skills tests • Key identification and contact information • Additional information that you provide or choose to tell us during the evaluation/skills test (including in relation to your performance) • Key identification and contact information Additional information that you provide or choose to tell us during the evaluation/skills test (including in relation to your performance)

Marketing Activities

  • We may occasionally send you information that we believe you might find interesting, or to request your assistance in connecting other Candidates with jobs. Specifically, we will utilize your data for the purposes listed below, as applicable and in compliance with local laws and regulations. Please be aware that this list is not exhaustive.
  • For other forms of e-marketing, we are obligated to secure your explicit consent. If you are dissatisfied with our marketing approach, you have the right to opt out or withdraw your consent at any time. You can learn more about how to do so by referring to the section titled “How can you access, amend, or retract the personal data that you have provided to us” in the General Privacy Information section of this Privacy Policy.
  • We want to inform you that even if you have opted out from our marketing communications, there is a possibility that your details may be recaptured through public sources in an unrelated marketing campaign. While we endeavour to prevent this, if it occurs, we kindly request that you opt out again.
Why and how we process your information Types of personal data used Legal basis relied upon
Using Candidates' data to carry out marketing activities to promote our services through digital channels including in relation to: • marketing our full range of services to you • sending Candidates details of reports, promotions, offers, networking and client events, and general information about the industry sectors which we think might be of interest to them • Key identification and contact information • Automatically collected information If we have obtained your contact details from an occasion when you previously engaged with us and we are e-marketing other recruitment-related services of our own, we will rely on legitimate interests legal basis, namely if we wish to reach out to you to tell you about our services and we consider that it would be in your interests to hear about similar services to those that you have already expressed an interest in In all other circumstances, we will obtain your consent
Collection of data via cookies or tracking pixels and use of data to show users TGS adverts and other content on other websites, for example, Facebook • Key identification and contact information • Automatically collected information • Key identification and contact information • Automatically collected information We will obtain your consent via the Cookie Preferences link on our website If you do not want us to use your data in this way, please turn off the “Advertising Cookies” option (please refer to our Cookies Policy) Even where you have turned off advertising cookies, it is still possible that you may see a TGS advert, but in this case it won’t have been targeted at you personally, but rather at an anonymous audience Please note that if you access TGS’ services across multiple devices, you may need to adjust your settings (e.g. if you want to turn off advertising cookies) via the Cookie Preferences link on each of your devices
Lookalike targeting and other data driven marketing: providing lists of certain Candidates' data to Facebook and Google to enable them to find an audience of people with similar characteristics or demographics to these Candidates (which will not include these Candidates) for TGS’ marketing purposes. Facebook's policy is to irreversibly hash such lists prior to use, match the hashed data against their own customers, generate the lookalike audience, then delete the original list and use it for no other purpose. We will not have access to the identity of anyone in the lookalike audience, unless they choose to click on the advertisements. • Key identification and contact information • Automatically collected information (advertising identifiers) We will obtain your opt-in consent for the collection of advertising identifiers via the Cookie Preferences link on our website We will share these advertising identifiers with Facebook and Google in reliance on the legitimate interests legal basis, namely it is in our interests to identify and target advertisements to potential customers who share characteristics or demographics with our existing customers, unless we are required by local law to obtain your consent in which case we will obtain such consent via our consent management tool
Special category data
  • We are dedicated to ensuring that our recruitment procedures adhere to our equal opportunities approach. Therefore, we will handle certain special category data about you to facilitate this alignment. As appropriate and in compliance with local laws and regulations, we will utilize this information on an anonymized basis to monitor our adherence to our equal opportunities obligations.
  • We may gather additional special category personal data about you, such as health-related information, if deemed appropriate in accordance with local laws. Article 9(2)(b) of the GDPR permits us to do so when the processing is “necessary for the purposes of carrying out the obligations and exercising our or your specific rights… in the field of employment and social security and social protection law,” provided it is permitted by law.
Why and how we process your information Types of personal data used Legal basis relied upon
Collecting and analysing Candidates' data in order to assess and ensure our compliance with equal opportunities obligations Details of physical or mental health, including disability-related information We will process your personal data in this way if our processing is necessary for the purposes of (and we have a legitimate interest in) keeping under review the existence or absence of equality of opportunity or treatment between groups of people and local laws allow us to process your data in this way without obtaining your consent If local law requires us to obtain your consent, we will do so
Sharing Candidates' data (that has been collected to assess and ensure our compliance with equal opportunities obligations) with Clients (including to their internal or external auditors) where this is contractually required or the Client specifically requests such information to enable them to comply with their own employment processes Details of physical or mental health, including disability-related information We will obtain your explicit consent before we share your data in this way
Processing medical history/health-related data to make reasonable adjustments during the recruitment process Medical history/physical or mental health-related data We will process your personal data in this way if we have a legitimate interest in and it is necessary for us to process your data for health and social care purposes (e.g. to assess the working capacity of an employee or potential employee for an employer) and local laws allow us to process your data in this way without obtaining your consent If local law requires us to obtain your consent, we will do so
Processing health-related data to when we need to use or offer occupational health to Candidates in the context of certain types of roles (e.g. teaching, nursing or night work) Medical history/physical or mental health-related data We will process your personal data in this way if we have a legitimate interest in and it is necessary for us to process your data for health and social care purposes (e.g. the provision of health care or treatment) and local laws allow us to process your data in this way without obtaining your consent If local law requires us to obtain your consent, we will do so
Processing criminal record data when carrying out background checks Details of any criminal convictions disclosed by Candidate Details of any criminal records obtained via background checks that we are required to carry out where this is necessary for us to comply with our legal obligations in connection with a Candidate's search for work (e.g. if we put a Candidate forward for certain roles which require a certain type of background check to be carried out) We will usually obtain your explicit consent during the application process, though we may need to request Electronic Conviction Status Certificate a without your consent where this is necessary for us to comply with our legal obligations in connection with your search for workронен сертификат за съдебен статус без Вашето съгласие, когато това е необходимо, за да изпълним нашите законови задължения във връзка с Вашето търсене на работа.
Processing certain types of Candidate data in order to calculate entitlement to annual leave Medical history/health-related data We will process your personal data in this way if our processing is necessary for the purposes of (and we have a legitimate interest in) carrying out the obligations and exercising TGS' specific rights in the field of employment and social security and social protection law and local laws allow us to process your data in this way without obtaining your consent If local law requires us to obtain your consent, we will do so
Processing the sensitive/special category personal data of individuals connected with Candidates, for example: • to allow the relevant Candidate to access certain benefits Details about physical or mental health, including disability-related information We will process your personal data in this way if our processing is necessary for the purposes of (and we have a legitimate interest in) carrying out the obligations and exercising TGS' specific rights in the field of employment and social security and social protection law and local laws allow us to process your data in this way without obtaining your consent If local law requires us to obtain your consent, we will do so

To help us to establish, exercise or defend legal claims

  • At times, it may be necessary for us to process personal data based on the legitimate interests legal basis, and, where applicable and in accordance with local laws and requirements, special category data in relation to exercising or defending legal claims. Article 9(2)(f) of the GDPR permits this when the processing “is necessary for the establishment, exercise, or defence of legal claims or whenever courts are acting in their judicial capacity.”
  • This may occur, for instance, when we require legal advice regarding legal proceedings or are obligated by law to preserve or disclose specific information as part of the legal process.
Why and how we process your information Types of personal data used Legal basis relied upon
Preserving, sharing and otherwise processing Candidate data to establish, exercise or defend legal claims The actual information used depends on the factual circumstances, but could include any of the following: • Key identification and contact information • Education and employment information • Special category information • Criminal conviction data • Automatically collected information • Information that others provide about you • Additional information that you choose to tell us Legitimate interests, namely it is in our interests to seek and receive legal advice should we need it and to protect ourselves in the context of litigation and other disputes In the unlikely event that we need to process any special category information or criminal conviction data for this purpose, we will only do so where the law allows us to process such data to establish, exercise or defend legal claims

Profiling, Algorithms and Automated Decision Making

  • We will employ profiling methods concerning your personal data if we deem it necessary for our legitimate interests, as outlined in the table below. If you are dissatisfied with this approach, under certain circumstances, you have the right to object. You can learn more about how and when to exercise this right by referring to the section titled “How can you access, amend, or retract the personal data that you have provided to us” in the General Privacy Information section of this Privacy Policy.
  • We may also use automated systems, including filtering tools and occasionally more advanced tools incorporating artificial intelligence elements such as algorithms or machine learning (including those provided by third parties). These systems aid us in analysing data concerning you and other Candidates, as well as data pertaining to our Clients’ requirements, thereby facilitating more efficient and accurate decision-making based on this information. This can involve employing algorithms (such as filtering tools or machine learning) to Candidate personal data to generate the most suitable shortlist for a specific role. Such technology is intended to significantly reduce the time required for evaluating when Candidates may be the best fit for relevant positions. Consequently, this should enhance the efficiency and effectiveness of the recruitment process, thereby enhancing your overall experience with us.
  • As advancements in technology continue, certain profiling and processing activities utilizing automated systems, as described above, may constitute Automated Decision Making as defined in Article 22 of the GDPR. This entails making decisions through automated means with minimal or no human involvement in reaching the decision. We will solely employ automated decision making concerning your personal data when we deem it necessary for completing pre-contractual steps initiated at your request.
Why and how we process your information Types of personal data used Legal basis relied upon
Collection of data via personalisation cookies/pixels and use of this data for profiling purposes so that we can show Candidates both targeted and personalised content. This will include: • personalising Candidates' website experience, including in relation to the roles that are brought to their attention when visiting the website • making recommendations for editorial content that we think may be of interest to Candidates (e.g. reports about developments in their industry) • personalising the marketing content that Candidates receive via the website, email and other marketing channels (where they have consented to that marketing) These personalisation cookies/pixels are used to understand how Candidates engage with the website by recording their visit to the website, the pages they have visited, the interactions they have made and the links they have followed We will use this information to understand what they may be interested in and tailor what we show and send to them accordingly • Key identification and contact information • Education and employment information • Automatically collected information • Additional information that you choose to tell us More specifically, this will include: • Personal information and information about the Candidate's job search (i.e. as submitted via form or pulled through from our Systems) • Details of Candidates' interactions with the website (e.g. applications, web page visits), and other information pulled through from the Systems (e.g. job title, past applications) • Location data - either inferred from jobs, IP, or application history, or system stored data • Digital identifiers - IP address, personalisation cookies • Website browsing data, form submission data and email engagement data • Marketing preferences We will obtain your consent via the Cookie Preferences link on our website before we place personalisation cookies/pixels on your device and enable this functionality If you do not wish to provide your consent to us placing a personalisation cookie on your device, please turn off the “Functionality Cookies” and “Advertising Cookies” options (please refer to our Cookies Policy) Please note that if you access TGS' services across multiple devices, you may need to adjust your settings via the Cookie Preferences link on each of your devices. Notwithstanding our collection of consent prior to placing personalisation cookies/pixels onto your device, we will rely on the legitimate interests condition in relation to the personalisation activities that we subsequently carry out We consider that it is in our interests (and sometimes your interests) to: • increase engagement with and improve the experience of using our services by increasing the relevance of the content that you see across the TGS websites and email campaigns • increase application numbers, conversion rates and application usefulness through providing tailored job recommendations to you • encourage you to come back to our website by making this most helpful experience possible • reduce website bounce rate • increase email engagement rate (i.e. the frequency with which users click through)
We may use profiling methods in relation to Candidates' data so that we can: • place them and other suitable Candidates on shortlists for particular roles based on prescribed criteria, which will allow our consultants to identify the most appropriate Candidates for roles in the most efficient manner efficiently; and • recommend roles based on how a Candidate's interests, habits, attributes and/or preferences, rank in comparison to other Candidates Our intention is for any such activities (which might involve using automated processes to profile, select, screen, rank, grade, shortlist and/or put forward Candidates for roles) to complement rather than completely replace the activity of our consultants • Key identification and contact information • Education and employment information • Automatically collected information • Additional information that you choose to tell us More specifically, this will include: • Personal information and information about the Candidate's job search (i.e. as submitted via form or pulled through from our Systems) • Details of Candidates' interactions with the website (e.g. applications, web page visits), and other information pulled through from the Systems (e.g. job title, past applications) • Location data - either inferred from jobs, IP, or application history, or system stored data • Digital identifiers - IP address, personalisation cookies • Website browsing data, form submission data and email engagement data • Marketing preferences • Key identification and contact information • Education and employment information • Automatically collected information • Information that others provide about you • Additional information that you choose to tell us Legitimate interests, namely it is in our interests to use profiling methods to place you and your Candidate profile into groups or segments with other Candidates, based on your interests, habits, attributes and/or preferences in order to: • help us to optimise the matching of Candidate profiles to roles and improve the effectiveness and efficiency of the recruitment cycle • help our consultants to make decisions in relation to suggesting relevant roles to you If these shortlisting and ranking activities amount to Automated Decision Making for the purposes of Article 22 of the GDPR, we will only conduct these activities where we deem this to be necessary for the completion of pre-contractual steps taken at your request. We think it is reasonable to assume that, as a Candidate, you are hoping to enter into an employment contract, and that by using our services you are asking us to take the necessary steps for this purpose. Such steps might include, for example, checking you meet certain requirements for a particular role. If the role is very popular, we may have to check the eligibility of a large number of potential Candidates – we may therefore use automated decision making to filter this pool of Candidates down to a more manageable number.

Compliance with a legal obligation

  • In some circumstances, we will use your personal data to comply with our legal obligations. Article 6(1)(c) of the GDPR says that we can process your data where it “is necessary for compliance with a legal obligation to which (we) are subject”.
Why and how we process your information Types of personal data used Legal basis relied upon
Accessing, preserving and disclosing Candidates' data if there is a valid legal request from a regulator, law enforcement, authority or if we otherwise have a legal duty to do so The actual information used depends on the factual circumstances, but could include any of the following: • Key identification and contact information • Financial information • Automatically collected information • Education and employment information • Information that others provide about you Compliance with a legal obligation including where: • we are in receipt of a court order to disclose information for the purposes of court proceedings in the context of civil and commercial matters • we are compelled by law enforcement agencies to provide data in relation to a criminal investigation • we need to comply with our obligations under consumer law, for example competition legislation • we need to comply with our obligations under companies legislation and tax law, for example, to provide details of your remuneration and tax paid • we need to comply with our obligations under data protection laws • we need to comply with our obligations under employment laws (e.g. those which require us to track the number of hours you have worked)
Processing Candidates' data when verifying documents and information requested from and provided by Candidates to prove that they have the right to work in a particular location • Key identification and contact information (e.g. a copy of your passport and proof of address) • Education and employment information (e.g. immigration status and work permit if applicable) • Financial information (e.g. social security number or equivalent in your country) We will process your data where this is necessary for us to comply with our legal obligations in relation to ensuring that you have the right to work in the country

Sharing of data

  • We may disclose your personal data to various parties, utilizing various methods and for various purposes. Our primary objective is to share your information with potential employers to enhance your prospects of securing the desired job.
  • For a comprehensive list of entities with whom we may share your personal data, please consult the section titled “Who do we share your personal data with” in the General Privacy Information section of this Privacy Policy.
Why and how we process your information Types of personal data used Legal basis relied upon
Disclosing Candidates' data to the recipients listed in the section entitled “Who do we share your personal data with”. Where possible and as often as possible Candidates’ data is shared in anonymized form The actual information used depends on the factual circumstances, but could include any of the following: • Key identification and contact information • Financial information • Education and employment information • Special category data • Criminal conviction data • Automatically collected information • Information that others provide about you • Additional information that you choose to tell us • The disclosure is necessary (e.g. to potential employers) to conclude and perform any contracts that we have entered into with you (see section entitled Recruitment Activities above) • The disclosure (e.g. to tax, audit, or other authorities) is necessary for the compliance with a legal obligation to which we are subject (see section entitled Compliance with a legal obligation above) • The disclosure (e.g. to our professional advisers) is necessary to help us to establish, exercise or defend legal claims • The disclosure is necessary for health and social care purposes (e.g. to an occupational health specialist to enable the provision of support during the recruitment process if an Candidate suffers from a health condition or disability) • The disclosure is necessary for the purposes of ‘legitimate interests’ pursued by us (as detailed in the tables above)

2. Temporary Workers

Temporary Workers include individuals who are employed or engaged by TGS to perform temporary work for a Client or another TGS group company. If you fall under this category, we will continue to process your personal data as a Candidate throughout the duration of your temporary work assignment and beyond, in accordance with the terms outlined in this Privacy Policy. The term “Temp Relationship” refers to our contractual association with Temporary Workers during their employment or engagement directly by us.

If we directly employ or engage you as a Temporary Worker, we will, based on the relevant circumstances and applicable laws and requirements, gather some or all of the information detailed below (in addition to the data collected about Candidates). This is done to ensure the smooth operation of our Temp Relationship and to fulfill our contractual obligations to each other, as well as to our Clients, and to comply with obligations to third parties such as tax authorities and government agencies.

WHAT KIND OF PERSONAL INFORMATION DO WE COLLECT?

Temporary worker information

  • National ID Number
  • Location of your workplace at the Client;
  • Details of hours worked once you have been placed in a role;
  • Bank details;
  • Details of any complaints, whether brought by or against you or in which you are or have been otherwise involved;
  • Details of any leave you take or request during our Temp Relationship;
  • Details of travel undertaken;
  • Details of residence/work permit;
  • Where applicable:
    • Information regarding any grievances or disciplinary issues, whether initiated by or against you, or in which you are or have been otherwise involved; and
    • information about any bonuses or promotions received, performance evaluations, and other relevant data related to your employment, interactions with colleagues, and employment-related matters that arise; and

 

Special category information

  • Details of any sickness absence including health-related information.
  • Details of any criminal convictions if this is required for the role that you are hired for;

Please be aware that the above list of personal data categories we collect is not exhaustive.

Certain elements of the items listed above are necessary to fulfill our contractual obligations to you or to others. For instance, your national ID number may be required by statute or other laws. Other items may be essential to ensure the smooth operation of our Temp Relationship or our business operations.

Depending on the type of personal data involved and the legal grounds for processing it, if you choose not to provide us with such data, we may be unable to fulfill our contractual obligations or, in extreme cases, may not be able to proceed with our Temp Relationship.

HOW DO WE COLLECT YOUR PERSONAL DATA?

If we employ or engage you as a Temporary Worker directly, we collect your data (in addition to the data already collected about Candidates) in the following ways:

  • Personal data that you give to us; and
  • Personal data that we receive from other sources.

Below are some more details about each of these methods.

Personal data you give to us

TGS requires specific information about you to fulfil our obligations to you, ensure your compliance with our requirements, and uphold our commitments to others. This information is essential for maintaining a standard Temp Relationship and all associated responsibilities.

There are various ways you can provide us with information beyond what is shared as a Candidate. Where applicable and in accordance with local laws and regulations, these may include:

  • when you complete registration forms at the beginning of our Temp Relationship; or
  • in meetings or communications with your consultant, our HR team or other colleagues.

 

The types of information that we receive from you in this way include:

  • Temporary worker information; and
  • Special category information,

as described in the section entitled “What Kind of Personal Information Do We Collect?” above.

Personal data we receive from other sources

We also receive personal data about you from other sources. Depending on the relevant circumstances and applicable local laws and requirements, these may include personal data received in the following situations:

  • if you were referred to us through a recruitment agency or a client, they may have shared personal information about you with us;
  • your colleagues may share personal information about you with us;
  • Medical professionals may, in suitable and restricted circumstances, disclose personal information about you to us;
  • your pension and benefits providers may share relevant personal information about you with us; and
  • other third parties like your local tax authority may share your personal data with us.

 

The types of information that we receive about you in this way include:

  • Temporary worker information; and
  • Special category information,

as described in the section entitled “What Kind of Personal Information Do We Collect?” above.

HOW DO WE USE YOUR PERSONAL DATA?

If we employ or engage you as a Temporary Worker directly, we use your data for the following purposes:

  • To ensure the smooth running of our Temp Relationship, including all of the activities that need to be undertaken in a usual relationship of that type, such as:
    • facilitating payroll and invoicing processes;
    • determining the terms on which you work during your Temp Relationship;
    • keeping a record of any promotions, salary rises or bonuses you are awarded; and
  • Assessing your performance. 

Temp Relationship Activities

  • Below, we’ve detailed various ways in which we will utilize and process your personal data in relation to our Temp Relationship, as deemed appropriate and in accordance with local laws and regulations. Please be aware that this list is not exhaustive.
  • In most instances, we will employ your personal data for the following purposes if it is necessary to fulfil our obligations under a contract we have with you or if we consider it necessary for our legitimate interests.
  • Article 6(1)(b) of the GDPR says that we can process your data where it “is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.”
  • Article 6(1)(f) of the GDPR says that we can process your data where it “is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of you which require protection of personal data.”
  • We believe that none of the activities for which we rely on the legitimate interests condition prejudice Temporary Workers in any manner – indeed, they assist us in providing you with a more customized and efficient service. However, you retain the right to object to us processing your personal data on this basis. For more information on how to do so, please consult the section titled “How can you access, amend, or retract the personal data that you have provided to us” in the General Privacy Information section of this Privacy Policy
  • When we process your information for recruitment activities based on your consent, you reserve the right to withdraw your consent at any time without impacting the legality of processing based on such consent prior to its withdrawal. You can do so by referring to the section titled “How can you access, amend, or retract the personal data that you have provided to us” in the General Privacy Information section of this Privacy Policy.
Why and how we process your information Types of personal data used Legal basis relied upon
Collecting and processing data in the course of and to the extent necessary to facilitate the Temp Relationship, including by: • Facilitating payroll and invoicing processes • Determining the terms on which Temporary Workers work during the Temp Relationship • Storing Temporary Worker details on database (including start dates and duration of the length of assignment, hours worked during assignments, and records of any promotions, salary rises or bonuses awarded) • Assessing Temporary Workers' performance • Giving Temporary Workers feedback in relation to assignments • Managing absences • Temporary worker information • Special category information If you have entered into a Temp Relationship with us, we will rely on the performance of a contract legal basis to the extent that the processing activity that we are seeking to conduct is necessary for the purposes of the contract that we have entered into with you We will otherwise rely on legitimate interests, namely it is in our interests and your interests for us to facilitate the Temp Relationship If we need to process your special category data (e.g. details of any sickness absence including health-related information), we will process your personal data in this way if we have a legitimate interest in and it is necessary for us to process your data for health and social care purposes and local laws allow us to process your data in this way without obtaining your consent. If local law requires us to obtain your consent, we will do so.

Sharing of data

  • If we directly employ or engage you as a Temporary Worker, we may share your personal data with several additional parties to facilitate the smooth operation of our Temp Relationship. For instance, we may share your personal data with relevant colleagues within TGS, with a Client, and, if necessary, with medical professionals such as your GP or an occupational health specialist (for instance, for the purpose of any work adjustment assessments if applicable).
  • Generally, we will depend on the same legal bases outlined in the section concerning Temp Relationship Activities above, depending on the context.

3. Clients

This section of the Privacy Policy is applicable to Clients.

Clients encompass our customers, clients, and other entities to whom TGS delivers services as part of its business operations or whom TGS reasonably believes would be interested in our services. In specific situations, TGS provides services to individual employees working for Client organizations, such as training and development activities, coaching, and consulting services. Please note that in this context, TGS requires Clients to disseminate the relevant sections of this Privacy Policy (specifically those directed at Clients and Website Users) to their employees.

WHAT KIND OF PERSONAL INFORMATION DO WE COLLECT?

Here’s a more detailed overview of the types of information we may gather about you as a client. This information is in addition to any personal data we are legally obligated to process in specific situations.

The data we collect about Clients is typically quite limited. Generally, we only require your contact details or the details of individual contacts within your organization. This enables us to communicate with you about our services, ensure a smooth relationship, and, in certain cases, provide services to your employees. Additionally, we retain information regarding your online interactions with Candidate profiles and other content published by TGS. This helps us ensure that our marketing communications to you are pertinent and timely. We may also possess additional information that someone within your organization has chosen to disclose to us. If we require any additional personal data for any reason, we will notify you accordingly.

Key identification and contact information

  • About yourself or individual contacts at your organisation, including:

    • Names;
    • Job titles;
    • Telephone numbers;
    • Email addresses;

 

Automatically collected information

  • Information relating to your online engagement with other material published by TGS;
  • IP address;
  • Extra Usage information that you choose to tell us; including the dates, times and frequency with which you access our services;
  • Website browsing data e.g. pages viewed (limited to TGS websites);
  • Email engagement with TGS;
  • Location information (inferred from IP address or system stored data);

 

Information that others provide about you

  • Extra information that our Candidates may tell us about you, or that we find from other third party sources; and

 

Additional information that you choose to tell us

  • Extra information that you or someone in your organisation has chosen to tell us, including when corresponding with us via email or otherwise.

Please be aware that the list of personal data categories we collect is not exhaustive.  Furthermore, if you access our website or click through any links in an email or text message from us, we will also gather certain data from you. For further details on this matter, please consult the Context-Specific section of this Privacy Policy that pertains to Website Users.

HOW DO WE COLLECT YOUR PERSONAL DATA?

We collect Client personal data in the following ways:

  • Personal data that we receive from you;
  • Personal data that we collect or receive from other sources; and
  • Personal data that we collect automatically.

Personal data that we receive directly from you

We both share the same goal – to make sure that you have the best staff for and at your organisation.

We will receive data directly from you in two ways:

  • Where you contact us proactively, usually by phone or email; and/or
  • Where we contact you, either by phone or email, or through our consultants’ business development activities more generally.

 

The types of information that we receive from you in this way include:

  • Key identification and contact information; and
  • Additional information that you choose to tell us,

as described in the section entitled “What Kind of Personal Information Do We Collect?” above.

Personal data we receive from other sources

Where appropriate and in accordance with any local laws and requirements, we will seek more information about you or your colleagues from other sources generally by way of due diligence or other market intelligence:

  • From third party market research and by analysing online and offline media (which we will do ourselves or may employ other organisations to do for us);
  • From reputable vendors of business-to-business data lists to the extent we are able to use such data from such sources in compliance with the GDPR;
  • From delegate lists at relevant events; and
  • From other limited sources and third parties, for example, from our Candidates to the extent that they provide us with your details to act as a referee for them or where they give feedback on a particular assignment.

 

The types of information that we receive about you in this way may include information that others provide about you as described in the section entitled “What Kind of Personal Information Do We Collect?” above.

Personal data we collect via our website or through links and emails

To the extent that you access our website or read or click on an email or text message from us, where appropriate and in accordance with any local laws and requirements, we will also collect your data automatically or through you providing it to us. For more information, please refer to the Context-Specific section of this Privacy Policy that applies to Website Users.

The types of information that we collect about you in this way include the automatically collected information as described in the section entitled “What Kind of Personal Information Do We Collect?” above.

HOW DO WE USE YOUR PERSONAL DATA?

We use Client information for:

  • Providing our services;
  • Marketing Activities; and
  • To help us to establish, exercise or defend legal claims.

Providing our services

  • Our services broadly consist of: (i) providing you with Candidates as part of recruitment projects; (ii) Staffing, Employer of Record, HR Outsourcing Services; (iii) Assessment, Leadership development and Coaching programmes; and (iv) Consultancy and Organizational Development services. We’ve listed below the various ways in which we use your data in order to facilitate this.
  • In most cases, we will use your personal data for the purposes below if we deem it necessary to do so for our legitimate interests.
  • Article 6(1)(f) of the GDPR says that we can process your data where it “is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of you which require protection of personal data.”
  • We believe that none of the activities for which we rely on the legitimate interests condition prejudice Clients in any manner. However, you retain the right to object to us processing your personal data on this basis. For more information on how to do so, please refer to the section titled “How can you access, amend, or retract the personal data that you have provided to us” in the General Privacy Information section of this Privacy Policy.
Why and how we process your information Types of personal data used Legal basis relied upon
Collecting and processing data in the course of and to the extent necessary to reach out to Clients about our services, including by: • Storing Client details (and updating them when necessary) on TGS' database, so that TGS can contact Clients in relation to our services; • Keeping records of TGS' conversations and meetings with Clients, so that TGS can provide targeted services to Clients • Key identification and contact information • Information that others provide about you • Additional information that you choose to tell us Legitimate interests, namely it is in our interests and your interests: • for us to reach out to you about our services in order to provide you or your organisation with suitable Candidates; Staffing, Employer of Record, HR Outsourcing Services; Assessment, Leadership development and Coaching programmes; and Consultancy and Organizational Development services
Collecting and processing data in the course of and to the extent necessary to: • provide services to colleagues/employees of TGS' Clients • Key identification and contact information • Additional information that you choose to tell us Legitimate interests, namely it is in our interests and your interests: • for us to, in certain circumstances, reach out to your colleagues/employees about our services
Collecting and processing Client data in the course of carrying out: • customer satisfaction surveys • TGS market research which TGS will use to inform its marketing materials and other informational materials, such as whitepapers, reports and articles (e.g. TGS' salary guides) To the extent that any data is published, this will be in aggregated/anonymised form only • Key identification and contact information • Automatically collected information • Additional information that you choose to tell us Legitimate interests, namely it is in our interests and your interests to: • improve and develop the services that we provide to you by considering your feedback and feeding this into our processes where we deem necessary
Processing Client data in the course of carrying out TGS' obligations arising from any contracts entered into between TGS and third parties in relation to recruitment, such as potential Candidates who TGS identifies as suitable for a role in a Client organisation • Key identification and contact information • Information that others provide about you • Additional information that you choose to tell us Legitimate interests, namely it is in our interests and your interests to fulfil our obligations under agreements with third parties such as potential Candidates, so that we can help you find suitable employees
Collecting and processing Client data in the course of obtaining Candidate references from Clients, and sharing this data with third parties who require these references where appropriate • Key identification and contact information • Additional information that you choose to tell us • Reference about a Candidate Legitimate interests, namely it is in our interests to obtain Candidate references in the course of carrying out our services, and to verify details they have provided

Marketing Activities

  • Unless required by applicable local laws and requirements, we typically do not seek your consent when sending marketing materials to a corporate postal or email address.
  • If you are dissatisfied with this approach, you have the right to opt out of receiving marketing materials from us. You can learn more about how to do so by referring to the section titled “How can you access, amend, or retract the personal data that you have provided to us” in the General Privacy Information section of this Privacy Policy.
Why and how we process your information Types of personal data used Legal basis relied upon
Processing Client data for the purpose of targeting appropriate marketing campaigns for TGS’ services • Key identification and contact information • Automatically collected information Legitimate interests, namely if we wish to reach out to you to tell you about our services, and we consider that it would be in your interests to hear about similar services to those that you have already expressed an interest in.

Profiling, Algorithms and Automated Decision Making

  • Profiling is a processing activity that aids us in comprehending the information we collect about you, allowing us to construct a personalized “profile” for you. This assists us in gaining insights into how you prefer to interact with us and our services, the types of requests you typically make, and your preferences. The aim of developing this personalized profile is to enhance our service delivery to you and increase the likelihood of promptly and efficiently providing you with access to content that is most relevant and beneficial to you
  • We will utilize profiling methods concerning your personal data if we deem it necessary for our legitimate interests, as outlined in the table below. If you are dissatisfied with this, you have the right to object under certain circumstances. For more information on how and when to do so, please refer to the section titled “How can you access, amend, or retract the personal data that you have provided to us” in the General Privacy Information section of this Privacy Policy.
  • As new and improved technology becomes increasingly available, some of our profiling activities and processing activities utilizing automated systems, as described above, may qualify as Automated Decision Making under Article 22 of the GDPR. This entails making decisions by automated means with minimal or no human intervention. We will only employ automated decision-making concerning your personal data when we deem it necessary for completing pre-contractual steps initiated at your request.
Why and how we process your information Types of personal data used Legal basis relied upon
Collection of data via personalisation cookies/pixels and use of this data for profiling purposes so that TGS can show Clients both targeted and personalised content This will include: • personalising Clients' website experience, including in relation to the roles that are brought to their attention when visiting the website • making recommendations for editorial content that we think may be of interest to Clients (e.g. reports about developments in the relevant industry) • personalising the marketing content that Clients receive via the website, email and other marketing channels (where they have consented to that marketing) These personalisation cookies/pixels are used to understand how Clients engage with the website by recording their visit to the website, the pages they have visited, the interactions they have made and the links they have followed. TGS will use this information to understand what they may be interested in and tailor what it shows and sends to them accordingly • Key identification and contact information • Automatically collected information More specifically, this will include: • Details of Clients' interactions with the website (e.g. applications, web page visits), and other information pulled through from the Systems (e.g. job title, past applications) • Location data - either inferred from jobs, IP, or application history, or system stored data • Digital identifiers - IP address, personalisation cookies • Website browsing data, form submission data and email engagement data Marketing preferences We will obtain your consent via the Cookie Preferences link on our website before we place personalisation cookies/pixels on your device and enable this functionality. If you do not wish to provide your consent to us placing a personalisation cookie on your device, please turn off the “Functionality Cookies” and “Advertising Cookies” options (please refer to our Cookies Policy) Please note that if you access TGS' services across multiple devices, you may need to adjust your settings via the Cookie Preferences link on each of your devices Notwithstanding our collection of consent prior to placing personalisation cookies/pixels onto your device, we will rely on the legitimate interests condition in relation to the personalisation activities that we subsequently carry out We consider that it is in our interests (and sometimes your interests) to: • increase engagement with and improve the experience of using our services by increasing the relevance of the content that you see across the TGS websites and email campaigns • increase application numbers, conversion rates and application usefulness through providing tailored job recommendations to you • encourage you to come back to our website by making this most helpful experience possible • reduce website bounce rate • increase email engagement rate (i.e. the frequency with which users click through)
TGS may capture and analyse Clients' web-based behaviours using various items of data e.g. number of web visits made, number of candidates searched) in order to award a Client a weighted “approachability score” with a view to providing insights into Clients' needs and to allow TGS to follow up where needed Consultants will use these scores as part of the shortlisting and ranking activities described in more detail below and as a factor in determining whether to approach/show roles to a Client (and what to show them), which will serve to supplement other data that TGS holds about the Client TGS collection of web-based data will rely on the personalisation cookies/pixels that it places on Clients' devices as part of the personalisation activities described above • Key identification and contact information • Automatically collected information • Information that others provide about you • Additional information that you choose to tell us We will obtain your consent via the Cookie Preferences link on our website before we place personalisation cookies/pixels on your device If you do not wish to provide your consent to us placing a personalisation cookie on your device, please turn off the “Functionality Cookies” and “Advertising Cookies” options (please refer to our Cookies Policy) Please note that if you access TGS' services across multiple devices, you may need to adjust your settings via the Cookie Preferences link on each of your devices However, please note that we may still carry out engagement scoring activities even if a personalisation cookie is not placed on your device (e.g. we may consider the data that we already hold on our systems about you with a view to allocating you an engagement score even if you have opted out of the personalisation cookie) Notwithstanding our collection of consent prior to placing personalisation cookies/pixels onto your device, we will rely on the legitimate interests condition in relation to allocating you an engagement score and our subsequent use of this score We consider that it is in our legitimate interests to allocate you with an engagement score in order to help our consultants to make decisions in relation to suggesting relevant services and sending relevant communications to you
TGS may use the data that it collects via personalisation cookies/pixels e.g. web-based behaviours such as details of Clients' interactions with the website (e.g. applications, web page visits), to enrich the Client data and existing profiles about them that TGS already holds on its Systems • Key identification and contact information • Automatically collected information We will obtain your consent via the Cookie Preferences link on our website before we place personalisation cookies/pixels on your device If you do not wish to provide your consent to us placing a personalisation cookie on your device, please turn off the “Functionality Cookies” and “Advertising Cookies” options (please refer to our Cookies Policy) Please note that if you access TGS' services across multiple devices, you may need to adjust your settings via the Cookie Preferences link on each of your devices Notwithstanding our collection of consent prior to placing personalisation cookies/pixels onto your device, we will rely on the legitimate interests condition in relation to using data that we collect about you to enrich your existing profile on our Systems We consider that it is in our legitimate interests to enrich the data that we hold about you to help our consultants to make decisions in relation to suggesting relevant services and sending relevant communications to you

Sharing of data

  • We will share your data: (i) primarily to ensure that we provide you with a suitable pool of Candidates; (ii) to provide Employer of Record, HR Outsourcing Services; (iii) to provide Assessment, Leadership development and Coaching programmes; and/or (iv) to provide Consultancy and Organizational Development service. Unless you specify otherwise, we will share your information with any of our affiliated third parties, such as our service providers, to assist us in achieving these objectives.
Why and how we process your information Types of personal data used Legal basis relied upon
Disclosing Clients' data to the recipients listed in the section entitled “Who do we share your personal data with”, including the transfer, storage and processing of such data outside of the UK/European Economic Area for the purposes listed in the preceding tables The actual information used depends on the factual circumstances, but could include any of the following: • Key identification and contact information • Automatically collected information • Information that others provide about you • Additional information that you choose to tell us • The disclosure (e.g. to our professional advisers) is necessary to help us to establish, exercise or defend legal claims • The disclosure is necessary for the purposes of ‘legitimate interests’ pursued by us (as detailed in the tables above)

To help us to establish, exercise or defend legal claims

  • In more unusual circumstances, we will rely on the legitimate interests legal basis to utilize your personal data, aiding us in establishing, exercising, or defending legal claims.
Why and how we process your information Types of personal data used Legal basis relied upon
Preserving, sharing and otherwise processing Client data to establish, exercise or defend legal claims The actual information used depends on the factual circumstances, but could include any of the following: • Key identification and contact information • Automatically collected information • Information that others provide about you • Additional information that you choose to tell us Legitimate interests, namely it is in our interests to seek and receive legal advice should we need it and to protect ourselves in the context of litigation and other disputes

4. Suppliers and other Third Parties

This section of the Privacy Policy pertains to Suppliers.

Suppliers encompass partnerships, companies (including sole traders), and non-traditional workers such as independent contractors and freelancers who render services to TGS. In certain scenarios, TGS may subcontract services provided to Clients to third-party suppliers who perform tasks on behalf of TGS. In this regard, suppliers who are individual contractors, freelancers, or employees of suppliers will be regarded as Candidates for data protection purposes. Please note that within this context, TGS mandates Suppliers to relay the relevant sections of this Privacy Policy (specifically those directed at Candidates) to their employees.

Furthermore, this section of the Privacy Policy is applicable to other entities with whom we maintain a business or similar relationship.

WHAT KIND OF PERSONAL INFORMATION DO WE COLLECT?

We don’t gather extensive data about Suppliers and other third parties with whom we maintain a business relationship – our aim is to ensure the smooth functioning of our relationship. We’ll compile the contact details of individuals within your organization, including names, telephone numbers, and email addresses. Additionally, for Suppliers, we’ll collect bank details to facilitate payments. Furthermore, we may retain additional information disclosed to us by someone within your organization.

Key identification and contact information

  • About yourself or individual contacts at your organisation, including:
    • Names;
    • Job titles;
    • Telephone numbers;
    • Email addresses;
    • Business account bank details;
    • Identification number;

Information that others provide about you

  • Extra information that our Candidates or Clients may tell us about you, or that we find from other third party sources; and

Additional information that you choose to tell us

  • Extra information that you or someone in your organisation has chosen to tell us, including when corresponding with us via email or otherwise.  

Please be aware that the list of personal data categories we collect is not exhaustive.  Furthermore, if you access our website or click through any links in an email or text message from us, we will also gather certain data from you. For further details on this matter, please consult the Context-Specific section of this Privacy Policy that pertains to Website Users.

HOW DO WE COLLECT YOUR PERSONAL DATA?

We collect Supplier and other third party personal data in the following ways:

  • Personal data that we receive from you; and
  • Personal data that we collect or receive from other sources.

Personal data that we receive directly from you

We will receive data directly from you in two ways:

  • Where you contact us proactively, usually by phone or email; and/or
  • Where we contact you, either by phone or email.

The types of information that we receive from you in this way include:

  • Key identification and contact information; and
  • Additional information that you choose to tell us,

as described in the section entitled “What Kind of Personal Information Do We Collect?” above.

Personal data we receive from other sources

Where appropriate and in accordance with any local laws and requirements, we will seek more information about you or your colleagues from other sources generally by way of due diligence or other market intelligence:

  • From third party market research and by analysing online and offline media (which we will do ourselves or employ other organisations to do for us);
  • From delegate lists at relevant events; and
  • From other limited sources and third parties. 

The types of information that we receive about you in this way may include information that others provide about you as described in the section entitled “What Kind of Personal Information Do We Collect?” above

HOW DO WE USE YOUR PERSONAL DATA?

  • In most cases, we will use your personal data for the purposes below if we deem this to be necessary for our legitimate interests. Article 6(1)(f) of the GDPR says that we can process your data where it “is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of you which require protection of personal data.”
  • We will not, as a matter of course, seek your consent when sending marketing messages to a corporate postal or email address.
  • We believe that none of the activities listed below prejudice Suppliers or other third parties in any manner. However, you retain the right to object to us processing your personal data on this basis. For more details on how to do so, please consult the section titled “How can you access, amend, or retract the personal data that you have provided to us” in the General Privacy Information section of this Privacy Policy.
Why and how we process your information Types of personal data used Legal basis relied upon
Storing Supplier and other third party details (and updating them where necessary) on TGS' database, so that TGS can contact Suppliers and third parties in relation to TGS' agreements and business relationships with these parties • Key identification and contact information • Information that others provide about you • Additional information that you choose to tell us Legitimate interests, namely it is in our interests and your interests: • for us to reach out to you about the arrangements that we have in place
Collecting and processing data in the course of and to the extent necessary to receive support and services from Suppliers and maintain business relationships with other third parties • Key identification and contact information • Additional information that you choose to tell us Legitimate interests, namely it is in our interests and your interests to: • for us to, in certain circumstances, receive information from you about your services • conduct our business relationship with you If you are an individual (e.g. a Supplier that operates as a sole trader) or you have entered or are about to enter into a contract with us or if you are making a request in the course of doing so, we may rely on the performance of a contract legal basis In limited circumstances, we may need to rely on the compliance with a legal obligation legal basis to the extent that we are compelled by applicable law to conduct various checks in relation to our Suppliers and other third parties e.g. in relation to verifying that social contributions are being paid and obtaining lists of overseas employees)
Preserving, sharing and otherwise processing Supplier and third party data to establish, exercise or defend legal claims The actual information used depends on the factual circumstances, but could include: • Key identification and contact information • Information that others provide about you • Additional information that you choose to tell us Legitimate interests, namely it is in our interests to seek and receive legal advice should we need it and to protect ourselves in the context of litigation and other disputes

Sharing of data

  • Where we have recognized you as a Supplier or another third party, and unless you state otherwise, we may distribute your information to any of our group companies and affiliated third parties, such as our service providers, to communicate with you regarding our services. We will generally rely on the same legal bases that we have referred to in the section above.
  • If you wish to view a comprehensive list of the entities with whom we will share your personal data, please refer to the section titled “Who do we share your personal data with” in the General Privacy Information segment of this Privacy Policy.

5. People whose data we receive from candidates, clients and staff, like referees

This section of the Privacy Policy pertains to Individuals Whose Data We Receive from Candidates and TGS’ Staff. These individuals may include emergency contacts and referees. We will only reach out to them in suitable circumstances.

WHAT KIND OF PERSONAL INFORMATION DO WE COLLECT?

Referees provide confirmation of the info we already possess about our Candidate or prospective Staff member, aiding them in securing their desired position. Emergency contact details allow us to reach out in case of an emergency. To request a reference, we will require the referee’s contact details, including their name, email address, and telephone number.

Key identification and contact information

  • Name;
  • Contact details;

Information that others provide about you

  • Extra information that your referrer chooses to tell us about you;
  • Extra information that a member of Staff may tell us about you; and

Additional information that you choose to tell us

  • Any other information that you may provide to us including when corresponding with us via email or otherwise.

Please note that the above list of categories of personal data we collect is not exhaustive. To the extent that you access our website or click through any links in an email from us, we will also collect certain data from you. If you would like more information about this, please refer to the Context-Specific section of this Privacy Policy that applies to Website Users.

HOW DO WE USE YOUR PERSONAL DATA?

We will only use the information that our Candidates or Staff give us about you for the following purposes: 

  • If a Candidate or prospective Staff member has designated you as a referee, we will reach out to you directly to obtain a reference or may share your details with a third party to do so on our behalf. Additionally, if you are being requested to provide a reference based on your professional experience with a Candidate and we believe you may be interested in becoming a Client or a Candidate of ours, we may also use your details to contact you in that alternative capacity.

 

We will use your personal data for these purposes if we deem this to be necessary for our legitimate interests or in accordance with applicable employment law. If you are dissatisfied with this, you have the right to object, and you can learn more about how to do so by referring to the section titled “How can you access, amend, or retract the personal data that you have provided to us” in the General Privacy Information segment of this Privacy Policy.

Why and how we process your information Types of personal data used Legal basis relied upon
Collecting and processing data of people whose data TGS receives from Candidates and Staff, such as referees, in the course of communicating with referees in order to obtain Candidate or Staff references, and sharing this data with third parties who require references where appropriate  Key identification and contact information;  Additional information that you choose to tell us  Reference about a Candidate Legitimate interests, namely it is in our interests to obtain Staff and Candidate references in the course of carrying out our services, and to verify details they have provided
Using the data of people whose data TGS receives from Candidates and Staff, such as referees, to carry out marketing activities to promote TGS' services where TGS thinks the individual may be interested in becoming a Client (subject to any local laws and requirements) • Key identification and contact information We will obtain your opt-in consent

Sharing of data

  • Unless specified otherwise, we will share your information with any of our affiliated companies and associated third parties, including our service providers and organizations to whom we provide services.
  • If you wish to view a comprehensive list of entities with whom we will share your personal data, please refer to the section titled “Who do we share your personal data with” in the General Privacy Information segment of this Privacy Policy.

6. Website users

This section of the Privacy Policy applies to Website Users.

Website Users include any individual who accesses any of the TGS websites.

WHAT KIND OF PERSONAL INFORMATION DO WE COLLECT?

We gather a limited set of data from our Website Users to enhance your browsing experience on our website or mobile apps and to effectively manage the services we offer. This includes information on your website or app usage, frequency of access, browser type, device type, location, language preference, and peak website usage times. Should you contact us through the website, such as via email, or when signing up for newsletters or requesting a callback, we will collect any information you provide, such as your name and contact details.

Key identification and contact information

  • Names;
  • Email addresses;
  • Phone numbers;

 

Automatically collected information

  • Information relating to your online engagement with material published by TGS;
  • IP address;
  • Extra Usage information that you choose to tell us; including the dates, times and frequency with and location from which you access our services;
  • User choices;
  • User reports;
  • Log and troubleshooting information;
  • Account access information (e.g. PIN numbers for account verification purposes); and

 

Additional information that you choose to tell us

  • Any other information that you may provide to us including when corresponding with us via email or otherwise,

Please note that the above list of categories of personal data we collect is not exhaustive.

HOW DO WE COLLECT YOUR PERSONAL DATA?

When you visit our website or mobile apps, certain information is automatically collected, regardless of whether you use our services. This includes your IP address, the date and times of your visits, the frequency of your access, your browsing behaviour, and other technical details. Additionally, when you contact us through the website or mobile apps, such as via chat function or by registering for newsletters or webinars, we collect data from you.

We gather your data automatically through technologies like cookies, tracking pixels, and HTML5 Local Storage, in accordance with your specified cookie settings. These settings can be adjusted via the “Cookie Preferences” link located at the top or bottom of the website, or through your browser settings. If you are also a Candidate or Client of TGS, we may utilize data from your website usage to enhance our communications and services to you. For more information about cookies or similar technologies, including their usage and available choices, please refer to the “Cookies” section in the General Privacy Information of this Privacy Policy.

The types of information that we collect about you in this way include:

  • Key identification and contact information; and
  • Automatically collected information,

as described in the section entitled “What Kind of Personal Information Do We Collect?” above.

HOW DO WE USE YOUR PERSONAL DATA?

We use your data to:

  • provide you with the service you requested or provide information about a service you have declared interest in, for example sending you a newsletter or taking part in an online survey;
  • protect our Systems from attacks and other illegal activities; and
  • to enhance your experience using our website or mobile apps. This involves analysing your recent job search criteria to tailor job listings or Candidate recommendations that we believe match your interests.

 

We rely on our legitimate interests to utilize your personal data for these purposes. If you have objections, you have the right to object, and you can find detailed instructions on how to do so in the “How can you access, amend or take back the personal data that you have given to us” section of the General Privacy Information in this Privacy Policy.

If you would like to find out more about cookies or similar technology, including how we use them and what choices are available to you, please refer to the section entitled “Cookies” in the General Privacy Information section of this Privacy Policy.

Why and how we process your information Types of personal data used Legal basis relied upon
Collecting and processing data in the course of and to the extent necessary to provide Website Users with services they register for, including newsletters and online surveys • Key identification and contact information • Automatically collected information • Additional information that you choose to tell us We will rely on legitimate interests, namely it is in our interests and your interests for us to provide you with these services and for you to receive them in support of our core business activities relating to recruitment If you have entered or are about to enter into a contract with us or if you are making a request in the course of doing so, we may rely on the performance of a contract legal basis to the extent that the processing activity that we are seeking to conduct is necessary for the purposes of the contract or your request We will obtain opt-in consent before sending you any marketing materials
Collection of data via personalisation cookies/pixels and use of this data for profiling purposes so that TGS can show Website Users both targeted and personalised content. This will include: • personalising Website Users' website experience, including in relation to the roles that are brought to their attention when visiting the website • making recommendations for editorial content that TGS thinks may be of interest to Website Users • personalising the marketing content that Website Users receive via the website, email and other marketing channels (where they have consented to that marketing) These personalisation cookies/pixels are used to understand how Website Users engage with the website by recording their visit to the website, the pages they have visited, the interactions they have made and the links they have followed. TGS will use this information to understand what Website Users may be interested in and tailor what they are shown and sent accordingly. • Key identification and contact information • Automatically collected information More specifically, this will include: • Personal information and information about the Website Users searches (i.e. as submitted via form or pulled through from our Systems) • Details of the Website Users' interactions with the website (e.g. applications, web page visits), and other information pulled through from the Systems (e.g. job title, past applications) • Location data - either inferred from jobs, IP, or application history, or system stored data • Digital identifiers - IP address, personalisation cookies • Website browsing data, form submission data and email engagement data • Marketing preferences We will obtain your consent via the Cookie Preferences link on our website before we place personalisation cookies/pixels on your device and enable this functionality If you do not wish to provide your consent to us placing a personalisation cookie on your device, please turn off the “Functionality Cookies” and “Advertising Cookies” options (please refer to our Cookies Policy) Please note that if you access our services across multiple devices, you may need to adjust your settings via the Cookie Preferences link on each of your devices Notwithstanding our collection of consent prior to placing personalisation cookies/pixels onto your device, we will rely on the legitimate interests condition in relation to the personalisation activities that we subsequently carry out We consider that it is in our interests (and sometimes your interests) to: • increase engagement with and improve the experience of using our services by increasing the relevance of the content that you see across the TGS websites and email campaigns • increase application numbers, conversion rates and application usefulness • encourage you to come back to our website by making the most helpful experience possible • reduce website bounce rate • increase email engagement rate (i.e. the frequency with which users click through)
To prevent and take measures against fraud, illegal activities, infringement of TGS' rights or interests, or other attacks to TGS' Systems • Key identification and contact information • Additional information that you choose to tell us • Automatically collected information Legitimate interests, namely: • it is in our interests and your interests for us to prevent and take measures against fraud, unauthorized use of our System and other illegal or harmful activity • it is in our interests to protect ourselves, you. and others • even if we are not under a legal obligation to share or otherwise process your data, we will, under certain circumstances, have a legitimate interest in cooperating with law enforcement agencies, regulators and other bodies If we are under a legal obligation to share or otherwise process your data, compliance with a legal obligation, for example if we receive a valid legal request from a law enforcement agency, regulator or other body

Sharing of data

  • We may share your information with our group companies and associated third parties, including service providers, unless you specify otherwise.
  • The legal bases for sharing your information are generally the same as those mentioned in the section above.

GENERAL PRIVACY INFORMATION

Who do we share your personal data with?

Where appropriate and in accordance with local laws and requirements, we generally share your personal data with the following categories of people: 

  • Our sister company – Friisberg & Partners Bulgaria;
  • Appropriate colleagues within TGS on a need-to-know basis;
  • Individuals and organisations who hold information related to your reference or application to work with us, such as past or prospective employers, education providers and employment and recruitment agencies;
  • Tax, audit, or other authorities, when the law or other regulation requires us to share this data (for example, because of a request by an authority or in connection with any anticipated litigation);
  • Service providers (whether third parties or our sister companies) who perform functions on our behalf (including external consultants, business associates and professional advisers such as lawyers, auditors and accountants, administration functions, technical support functions and IT consultants carrying out testing and development work on our business technology Systems);
  • Occupational Health and Safety service providers;
  • Third party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place;

There are also certain categories of people that we share your personal data with if you are a Candidate or a Temporary Worker.

Candidates:

If you are a Candidate, we may also share your personal data with the following categories of people:

  • potential employers and other recruitment agencies/organisations to increase your chances of finding employment. Sharing personal data to potential employers is done in anonymised form as often as possible and for as long as possible;
  • third parties who we have retained to provide services such as reference, qualification and background checks, to the extent that these checks are appropriate and in accordance with the law;
  • internal and external auditors of our Clients when we are required to share this data with them upon request in order to comply with our contractual or regulatory obligations; and
  • third parties helping us by developing services and processes to optimise the Candidate selection process in order to improve the quality and efficiency of recruitment services.
Temporary workers:

If you are a Temporary Worker, we may also share your personal data with the following categories of people:

  • in limited circumstances as appropriate, medical professionals such as your GP;
  • our occupational health services provider;
  • the Client where you as a Temporary Worker are or will be working; and
  • prospective employers (for example, when providing a reference, where permissible in accordance with the law).
How do we safeguard your personal data?

We are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures. These include measures to deal with any suspected data breach.

If you suspect any misuse or loss of or unauthorised access to your personal information please let us know immediately. Details of how to contact us can be found here.

How long do we keep your personal data for?

In determining the appropriate retention period for different types of personal data, we always consider the amount, nature, and sensitivity of the personal data in question, the potential risk of harm from unauthorised use or disclosure of that personal data, the purposes for which we need to process it and whether we can achieve those purposes by other means (in addition of course to ensuring that we comply with our legal, regulatory and risk-management obligations).

We set out below the retention practices that we apply to certain categories of people.

Candidates:
  • If you are a Candidate, we will normally keep your personal data on our Systems for a period of up to three years from the point that we collect such personal data or subsequently have meaningful contact with you.
  • In this context, we will deem there to be meaningful contact with you if, for instance, you submit a CV to us through our website or another platform, engage in communication with us regarding potential roles (either verbally or in writing), or click through from any of our marketing communications. Please note that your receipt, opening, or reading of an email or other digital message from us will not be considered meaningful contact for these purposes. We will only consider that meaningful contact has occurred if there is positive action on your part, such as clicking through or replying directly.
  • Even though some of your data may no longer be complete or accurate after this period (for instance, due to job changes or a new phone number), it may still be relevant, along with more recent information we collect from other sources like LinkedIn, for the purposes for which it was initially collected. These purposes include identifying you as a potentially suitable candidate for a vacancy we are recruiting for and informing you about career opportunities. In certain cases, we may opt to retain your personal data for a longer duration than the aforementioned period if we genuinely believe that opportunities will arise in the near future where you may benefit from our services. This is particularly pertinent for Candidates with rare profiles and highly sought-after skills.
  • We will in any case attempt to maintain meaningful contact with as many Candidates from our database as possible.
  • Additionally, we may retain your personal data on our systems for a longer duration than stated if we believe in good faith that it is necessary to do so for fulfilling our obligations to authorities or in anticipation of potential litigation. If you, as a Candidate, have explicitly requested that we do not retain your personal data, we will delete it from our systems unless we believe in good faith that preservation is necessary. This may include obligations to authorities or in anticipation of potential litigation
Temporary Workers:
  • If we directly employ or engage you as a Temporary Worker, we will typically process your data for the duration of your Temp Relationship and retain it for a period after our association has concluded. The specific duration will vary based on the type of data, our legitimate business requirements, and other legal or regulatory mandates necessitating minimum retention periods. For instance, certain data may need to be retained for tax reporting or responding to tax inquiries. We may also retain data if it could be pertinent to any potential litigation.
  • If you are a Temporary Worker, we will also continue to process your personal data as a Candidate throughout the duration of your Temp Relationship and beyond.
Clients and suppliers
  • If you are a Client or a Supplier, we will retain your personal data to facilitate the provision of services to you or to receive services from you. Additionally, we may retain your data to provide you with information about our services that we believe may be of interest to you.
  • If you have explicitly indicated that you are not interested in our services, we will delete your personal data from our systems unless we believe in good faith that preservation is necessary. This may include obligations to authorities or in anticipation of potential litigation.
Website users
  • If you are a Website User we will retain your IP address and any other information that is required to operate the websites for 365 days.
Other categories of people
  • Otherwise, we will retain your data for as long as necessary to fulfill the purpose for which it was collected or processed. If this purpose has been fulfilled or if you have explicitly indicated that you are no longer interested in our services, we will delete it from our systems unless we believe in good faith that preservation is necessary. This may include obligations to authorities or in anticipation of potential litigation.
How can you access, amend or take back the personal data that you have given to us?

One of the main objectives of the GDPR is to safeguard and clarify the rights of EU citizens and individuals in the EU concerning data privacy. This implies that you retain various rights regarding your data, even after providing it to us. These rights are outlined in more detail below.

To inquire about these rights, please contact us. We will strive to address your request promptly, and in any case, within one month (subject to any lawful extensions). Please be aware that we will maintain a record of your communications, as needed, to assist in resolving any issues you raise.

Right to object: this right enables you to object to us processing your personal data where we do so for one of the following four reasons: (i) our legitimate interests; (ii) to enable us to perform a task in the public interest or exercise official authority; (iii) to send you direct marketing materials; and (iv) for scientific, historical, research, or statistical purposes.

  • The “legitimate interests” and “direct marketing” categories above are the ones most likely to apply to our Website Users, Candidates, Temporary Workers, Clients and Suppliers. If your objection relates to us processing your personal data because we deem it necessary for your legitimate interests, we must act on your objection by ceasing the activity in question unless:
    • we can show that we have compelling legitimate grounds for processing which overrides your interests; or
    • we are processing your data for the establishment, exercise or defence of a legal claim.
  • If your objection relates to direct marketing, we must act on your objection by ceasing this activity.

Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities, you may withdraw this consent at any time and we will cease to carry out the particular activity that you previously consented to unless we consider that there is an alternative reason to justify our continued processing of your data for this purpose in which case we will inform you of this condition.

Data Subject Access Requests (DSAR): You may ask us to confirm what information we hold about you at any time, and request us to modify, update or Delete such information. We may ask you to verify your identity and for more information about your request. If we provide you with access to the information we hold about you, we will not charge you for this unless your request is “manifestly unfounded or excessive”. If you request further copies of this information from us, we may charge you a reasonable administrative cost where legally permissible. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons for doing so.

Right to erasure (“right to be forgotten”): You have the right to request that we erase your personal data in certain circumstances. Normally, the information must meet one of the following criteria:

  • the data are no longer necessary for the purpose for which we originally collected and/or processed them;
  • where previously given, you have withdrawn your consent to us processing your data, and there is no other valid reason for us to continue processing;
  • the data has been processed unlawfully (i.e. in a manner which does not comply with the GDPR);
  • it is necessary for the data to be erased in order for us to comply with our legal obligations as a data controller; or
  • if we process the data because we believe it necessary to do so for our legitimate interests, you object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.

We would only be entitled to refuse to comply with your request for one of the following reasons:

  • to exercise the right of freedom of expression and information;
  • to comply with legal obligations or for the performance of a public interest task or exercise of official authority;
  • for public health reasons in the public interest;
  • for archival, research or statistical purposes; or
  • to exercise or defend a legal claim.

When complying with a valid request for the erasure of data we will Delete the relevant data.

Note that exercising your right to be forgotten does not mean and provides no guarantee that you will never again, under no circumstances, become a data subject in any of the capacities discussed above.

Right to restrict processing: You have the right to request that we restrict our processing of your personal data in certain circumstances. This means that we can only continue to store your data and will not be able to carry out any further processing activities with it until either: (i) one of the circumstances listed below is resolved; (ii) you consent; or (iii) further processing is necessary for either the establishment, exercise or defence of legal claims, the protection of the rights of another individual, or reasons of important EU or Member State public interest.

The circumstances in which you are entitled to request that we restrict the processing of your personal data are:

  • where you dispute the accuracy of the personal data that we are processing about you. In this case, our processing of your personal data will be restricted for the period during which the accuracy of the data is verified;
  • where you object to our processing of your personal data for our legitimate interests. Here, you can request that the data be restricted while we verify our grounds for processing your personal data;
  • where our processing of your data is unlawful, but you would prefer us to restrict our processing of it rather than erasing it; and
  • where we have no further need to process your personal data but you require the data to establish, exercise, or defend legal claims.

If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data.

Right to rectification: You also have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. Where appropriate, we will also tell you which third parties we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.

Right of data portability: If you wish, you have the right to transfer your personal data between data controllers. In effect, this means that you are able to transfer your TGS account details to another online platform. To allow you to do so, we will provide you with your data in a commonly used machine-readable format that is password-protected so that you can transfer the data to another online platform. Alternatively, we will directly transfer the data for you. This right of data portability applies to: (i) personal data that we process automatically (i.e. without any human intervention); (ii) personal data provided by you; and (iii) personal data that we process based on your consent or in order to fulfil a contract.

Right to lodge a complaint with a supervisory authority: You also have the right to lodge a complaint with your local supervisory authority. Details of how to contact them can be found here.

  • If you would like to exercise any of these rights, or withdraw your consent to the processing of your personal data (where consent is our legal basis for processing your personal data), details of how to contact us can be found here. Please note that we will, where necessary, keep a record of your communications to help us resolve any issues which you raise.
  • You may ask to unsubscribe from job alerts and other marketing communications from us at any time. Details of how to do so can be found here.
  • It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the period for which we hold your data.
Who is responsible for processing your personal data?
  • You can find out which TGS entity is responsible for processing your personal data and where it is located by following this link.
  • If you have any comments or suggestions concerning this Privacy Policy please follow this link. We take privacy seriously so we’ll get back to you as soon as possible.
How do we store and transfer data internationally?

In order to provide you with the best service and to carry out the purposes described in this Privacy Policy, your data will be transferred:

  • within TGS and its sister companies;
  • to third parties (such as advisers or other Suppliers to the TGS business);
  • to overseas Clients where applicable;                       
  • to Clients within your country, where applicable, who may, in turn, transfer your data internationally;
  • to a cloud-based storage provider; and
  • to other third parties as set out in the section entitled “Who do we share your personal data with” above.

 

We want to make sure that your data are stored and transferred in a way which is secure. We will therefore only transfer data outside of the European Economic Area or EEA (i.e. the Member States of the European Union, together with Norway, Iceland and Liechtenstein) where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, for example:

  • by way of data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission for the transfer of personal data by data controllers in the EEA to data controllers and processors in jurisdictions without adequate data protection laws; or
  • transferring your data to a country where there has been a finding of adequacy by the European Commission in respect of that country’s levels of data protection via its legislation; or
  • by way of scheme approved by the European Commission (whether as a successor to the Privacy Shield or otherwise) which regulates exchanges of person data between jurisdictions; or
  • where it is necessary for the conclusion or performance of a contract between ourselves and a third party and the transfer is in your interests for the purposes of that contract (for example, if we need to transfer data outside the EEA in order to meet our obligations under that contract if you are a Client of ours); or
  • where you have consented to the data transfer.

To ensure that your personal information receives an adequate level of protection, we have put in place appropriate procedures with the third parties we share your personal data with to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the law on data protection.

Cookies Policy

A cookie, a tiny text file, is requested by a website when you visit, prompting your browser to store it on your device. This storage aids in recalling information about you, like language preferences or login details. Cookies set by us are known as first-party cookies. Additionally, we utilize third-party cookies, originating from domains distinct from the website you’re visiting, for advertising and marketing endeavors. 

The following cookies are present on our website:

Strictly necessary cookies. Essential for website functionality, these cookies cannot be disabled in our systems. They typically activate in response to your actions, like setting privacy preferences, logging in, or filling out forms. While you have the option to block or receive alerts about these cookies via your browser settings, certain site features may become unavailable as a result.

Name Domain Duration
elementor .torogroups.com Persistent

Analytical cookies. Analytical cookies are not essential, but they are used to collect valuable information on how a website is being used. This information can help identify issues and figure out what needs to be improved on the site, as well as what content is useful to users. In most cases, the information collected by analytical cookies is anonymous, but some analytics services may collect information that can be used to identify the user.

Name Domain Duration
_gid .torogroups.com a day
_gat_* .torogroups.com a minute
_ga .torogroups.com a year
_ga_* .torogroups.com a year
Use of third-party services

When using our services, you may access external websites and third-party services, like job platforms, that we don’t control. We haven’t checked or approved their content or privacy policies. You’ll need to decide for yourself whether to use these sites or services.

Sometimes, third-party service providers we work with may handle personal data we’ve given them for their own purposes, such as internal reporting, security, legal matters, legal compliance, and improving their products/services. They usually have their own privacy policies explaining these activities.

ADDITIONAL INFORMATION

How to you contact us?
Entity responsible for personal data processing How can you contact us regarding your personal data
Toro Groups OOD You can write to us to: 26 Dragan Tsankov Blvd, fl.1, Sofia, or to email myprivacy@torogroups.com
How to contact the supervisory authority?
Country in which Toro Groups provide the mentioned services Contacts of the supervisory authority
Bulgaria Commission for Personal Data Protection, 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, kzld@cpdp.bg

Get In Touch.

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