What do we do?

NTIATIVE Spółka z ograniczoną odpowiedzialnością (“NTIATIVE”) provides permanent, temporary and interim recruitment services to clients seeking to recruit professional staff across a range of specialist areas.

What does this policy cover?

NTIATIVE is committed to respecting your right to privacy. As such, this policy:

  • sets out the types of Personal Data that we collect about you;
  • explains how and why we collect and use your Personal Data;
  • explains how long we keep your Personal Data for;
  • explains when, why and with whom we will share your Personal Data;
  • sets out the legal basis we have for using your Personal Data;
  • explains the effect of refusing to provide the Personal Data requested;
  • explains the different rights and choices you have when it comes to your Personal Data; and
  • explains how we may contact you and how you can contact us.

Who are you?

We collect Personal Data from the following types of people (aka “Data Subjects”) to carry out our business. As such, you are likely to be one of the following:

  • A candidate – either existing or prospective;
  • A client – either existing or prospective;
  • A user of our website;
  • A supplier to our organisation.

Who is the Data Controller?

The Office for the Protection of Personal Data recognises NTIATIVE as a Data Controller i.e. we determine the purposes and means of processing an individual’s Personal Data.

NTIATIVE is a company registered in Poland:

  • Company No (KRS): 0000741505
  • Head Office Address: Ul. Jozefa Sarego 26/17, 31-047 Kraków
  • Contact No: +48694082851
  • Email: info@ntiative.com

What is Personal Data?

Personal Data refers to any data that can identify you as a living individual.

This data can comprise of generic information which relates to a person who can be identified directly or indirectly (e.g. email and contact details, information held about that individual such as job role, comments and references).

It can also include Sensitive Personal Data that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data concerning an individual’s health, sex life or sexual orientation.

Sensitive Personal Data must be protected to a higher standard than generic Personal Data.

What legal basis do we have for using your information?

If you are a candidate, a client, a user of the NTIATIVE website or a supplier to NTIATIVE, the legal basis on which we rely for processing your information will be our legitimate interests.

For candidates

If we consider you to be a good candidate for work at our client’s company or at our company, we process your personal data in order to ensure your participation in the recruitment process.

The recruitment consists of two stages that are important from the perspective of the protection of your personal data. First, we look for you (e.g. at LinkedIn). At this point, you do not know yet that we are processing your data, but we have to do this, otherwise, we would not be able to judge whether you might be interested in a given position and we would not be able to contact you. Our job basically involves making connections between applicants and employers. Therefore, processing is necessary for the purposes of legitimate interests pursued by the controller of personal data, that is us (point (f) of Article 6(1) of GDPR).

We hope that you will not consider this a violation of your rights and freedoms. We make every effort for the first stage of our work to be as short as possible, not to include irrelevant data and not to be a surprise for you. By creating a profile in social media of business or professional nature, by participating in such events and by actively taking part in online discussions on professional topics close to your heart, you may obviously expect that you will be of interest (as a good specialist) to many head-hunters!

Then you fully consciously take part in the next stage of recruitment. We contact you, write you an email and invite you to an interview. Upon such first contact, we provide you with all information included in this Privacy Policy (e.g. by sending you a relevant link via email). At this stage, we will ask you for consent to carry on processing your data – point (a) of Article 6(1) of GDPR.

In the majority of cases, we will then be using your personal data to:

  • match your skills, experience and education with a potential employer
  • source potential opportunities or roles as part of our recruitment services
  • collate market information or trends including providing analysis to potential or actual clients
  • personalise your experience and our offering with appropriate content, whether via our website or otherwise.

Sometimes it is you who contacts us (e.g. via an application form on our website). You should know that, also, in this case, we make the personal data you send us complete by browsing your public profiles in social media of business or professional nature. Hiring a programmer often involves the need to meticulously examine the usefulness of a given person for specific tasks that, more often than not, require very narrow specialisation. Personal data included in standard CVs is usually not sufficient for this purpose.

We will always ask for your consent before we send any of your data to our client.

For potential clients

If we think we can help you find employees, we process your personal data for marketing purposes.

Therefore, processing is necessary for the purposes of legitimate interests pursued by the controller of personal data, that is us (point (f) of Article 6(1) of GDPR).

For clients & suppliers

We retain records of our dealings and transactions with you and where applicable, we use such records for the purposes of:

  • fulfilment of tax obligations,
  • establishing compliance of contractual obligations;
  • addressing any query or dispute that may arise (including establishing, exercising or defending any legal claims).

The legal basis for the processing of your personal data is point (b) of Article 6(1) of GDPR (processing 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), and point (c) of Article 6(1) of GDPR (the processing is necessary for compliance with a legal obligation to which the controller is subject).

From where do we source this Personal Data?

The following include the different sources from which we may collect your Personal Data:

Directly from you. For example:

  • the information you provide to us while searching for a new opportunity
  • the information provided to us during the different stages of the recruitment process.

From an agent/third party acting on your behalf. For example:

  • a Contractor’s Limited Company

Through publicly available sources. For example:

  • LinkedIn
  • your organisation’s website

By reference or word of mouth. For example:

  • you may be recommended by a friend, a former employer, a former colleague or even a present employer.

For how long do we retain your Personal Data?

For candidates

Our goal is to ensure that your data is always up to date. In order to do so, we contact you at least once every 12 months in order to catch up. If for some reasons, we fail to contact you in this period, your personal data will be erased after the lapse of 12 months from its collection.

The only exception to this is where we have had meaningful contact with you if we have placed you in a permanent or interim role.

Examples of “meaningful contact” include (but is not necessarily limited to):

  • When we obtain your details via a third-party company (such as a CV database), meaningful contact is defined as any verbal or written communication between us and yourself;
  • If you are a Candidate who has applied for a job through our website or have submitted your CV to us by any other means, we will consider this to be meaningful contact;
  • If there is two-way communication via verbal or written communication or through any of our marketing communications, we will also consider this to be meaningful contact.

You have the right to object at any time, on the reasons relating to your particular situation, to the processing of personal data relating to you based on Article 6(1)(e) or (f) of the GDPR, including profiling on the basis of these provisions. In such a case, we may no longer process such personal data unless we demonstrate the existence of valid legal bases for processing, overriding your interests, rights and freedoms, or bases for establishing, asserting or defending your claims.

For potential clients

We contact you within 30 days after collecting your personal data. If we fail to do so – your personal data will be erased immediately.

You have the right to object at any time, on the reasons relating to your particular situation, to the processing of personal data relating to you based on Article 6(1)(e) or (f) of the GDPR, including profiling on the basis of these provisions. In such a case, we may no longer process such personal data unless we demonstrate the existence of valid legal bases for processing, overriding your interests, rights and freedoms, or bases for establishing, asserting or defending your claims.

As your personal data are processed for the purposes of direct marketing, you have the right at any time to object to the processing of personal data relating to you for the purposes of such marketing, including profiling, to the extent that the processing is related to such direct marketing.

For clients & suppliers

Your personal data will be processed so long as it is necessary for tax purposes, that is, pursuant to the currently applicable provisions of the Polish law, for about 6 years.

If we regularly cooperate with you (e.g. on the basis of a framework agreement), some of your data which are necessary for this purpose will obviously be processed for the entire term of cooperation.

To whom do we disclose your personal data?

For candidates

We use the computing cloud provided by Google, within the framework of the G suite tools.

We use Bullhorn – software dedicated to HR companies.

Our website is powered & hosted by JXT.

In all those situations, your personal data will be transferred to third countries. This transfer takes place on the basis of a legal instrument provided for in GDPR and is absolutely safe.

For potential clients

We use the computing cloud provided by Google, within the framework of the G suite tools. Your personal data processed in this software will be transferred to third countries. This transfer takes place on the basis of a legal instrument provided for in GDPR and is absolutely safe.

We outsource some of the marketing activities to “Adriano Corso Talent Brandly”. In a relevant contract with this entity, we have ensured that your data entrusted to it will not be transferred to third countries.

For clients & suppliers

Your personal data will be disclosed within the required scope to state administration bodies authorised to receive them by law (e.g. tax authorities).

We use the computing cloud provided by Google, within the framework of the G suite tools. Your personal data processed in this software will be transferred to third countries. This transfer takes place on the basis of a legal instrument provided for in GDPR and is absolutely safe.

We also use dedicated software for HR companies provided by an international entity. Your personal data processed in this software will be transferred to third countries. This transfer takes place on the basis of a legal instrument provided for in GDPR and is absolutely safe.

Your personal data will be disclosed to Chandon Waller & Partners sp. z o.o., with its registered office in Kraków, that runs our accounts. In a relevant contract with this entity, we have ensured that your data entrusted to it will not be transferred to third countries.

What are your rights?

By law, you have a number of rights when it comes to your Personal Data. Further information and advice about your rights can be obtained from The Office for the Protection of Personal Data.

What rights do you have in relation to the data we hold on you?

Rights What does this mean?
The right to be informed You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we are providing you with the information in this Policy.
The right of access

You have the right to obtain access to your information (if we are processing it), and certain other information (similar to that provided in this Privacy Policy). If you would like to make a request for information, please contact info@ntiative.com.

This is so you are aware and can check that we are using your information in accordance with the GDPR.

The right to rectification You are entitled to have your information corrected if it is inaccurate or incomplete. We will respond to such a request within 1 month.
The right to erasure This is also known as ‘the right to be forgotten’ and in simple terms, enables you to request the deletion or removal of your information where there is no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
The right to restrict processing You have the right to ‘block’ or suppress the further use of your information. When processing is restricted, we can still store your information, but cannot use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.
The right to data portability You have the right to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT system and theirs safely and securely, without affecting its usability.
The right to object to the processing You have the right to object to certain types of processing, including processing for direct marketing (e.g. if you no longer want to be contacted with potential opportunities).
The right to lodge a complaint You have the right to lodge a complaint about the way we handle or process your personal data with The Office for the Protection of Personal Data
The right to withdraw consent If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes.

Please note that should we receive any requests from you to erase data or stop processing your information, we may retain a record of such requests as well as the actions taken by us. This will serve as both evidence of our compliance to your request as well as enable us to take steps to curtail any future processing of your data should it be received again from a third-party source.

It is our usual practice to provide information free of charge. However, we reserve the right to charge a reasonable fee in order to cover our administrative costs of providing the information for:

  • baseless or excessive/repeated requests, or
  • further copies of the same information.

Please consider your request responsibly before submitting it. We will respond as soon as is practicable. This will be within one month of the date when your request is received; however, in the event that the request is likely to take longer for any reason, we will inform you of the likely timeframe at the time.

For any questions surroundings your rights or should you wish to exercise any of these rights, please contact info@ntiative.com

Cookies and IP Address Policy

IP addresses

  • We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and as a consequence of the communications standards on the internet. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.

Cookies

  • Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy.

Complaints

If you are unhappy about any aspect of the way in which your Personal Data is processed by us, in the first instance please contact us info@ntiative.com

This does not affect your right (pursuant to Article 77 of GDPR) to lodge a complaint to a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the provisions of GDPR.