Privacy Policy

CPL Jobs Kft is committed to protecting all personal and categories of data held on you.

As such, CPL Jobs Kft want you, the ‘data subject’, to understand how CPL Jobs Kft collects, uses, stores, and shares your personal data. CPL Jobs Kft also want you understand what rights you can invoke to help you to protect your privacy. In this regard, it is important that you read this Privacy Notice and understand how CPL Jobs Kft use your personal data. Please note that CPL Jobs Kft reserve the right to update this Privacy Notice as required.

CPL Jobs Kft provides recruitment services and matches people with the right jobs every day.

CPL Jobs Kft is committed to protecting the rights and privacy of individuals in accordance with both European Union and Hungarian data protection legislation. CPL Jobs Kft shall lawfully and fairly process personal data about candidates, employees, clients, and other stakeholders to achieve its mission and functions.

CPL Jobs Kft is committed to protecting all personal and categories of data held on you.

As such, CPL Jobs Kft want you, the ‘data subject’, to understand how CPL Jobs Kft collects, uses, stores, and shares your personal data. CPL Jobs Kft also want you understand what rights you can invoke to help you to protect your privacy. In this regard, it is important that you read this Privacy Notice and understand how CPL Jobs Kft use your personal data. Please note that CPL Jobs Kft reserve the right to update this Privacy Notice as required.

CPL Jobs Kft provides recruitment services and matches people with the right jobs every day.

CPL Jobs Kft is committed to protecting the rights and privacy of individuals in accordance with both European Union and Hungarian data protection legislation. CPL Jobs Kft shall lawfully and fairly process personal data about candidates, employees, clients, and other stakeholders to achieve its mission and functions.

All personal data processed by CPL Jobs Kft is done so in accordance with the Act CXII of 2011 on the Right of Informational Self-Determination and on Freedom of Information

If you are unhappy with the way CPL Jobs Kft handle your personal data or if you simply want further information about the way your personal data will be used, please contact CPL Jobs Kft at the below:

Data Protection Officer
Cpl Jobs  Kft
1062 Budapest,
Teréz krt. 55,
Building, 2nd floor
Hungary
Telephone: +36 1 501 5460
Email: budapest@cpljobs.hu

You have the right to lodge a complaint with the Data Protection Commission. To contact the Data Protection Commission, please use the following details:

Data Protection Commission
21 Fitzwilliam Square South
Dublin 2
D02 RD28
Ireland
Telephone: +353 (0)761 104 800
Telephone: +353 (0)57 868 4800
Email: info@dataprotection.ie

CPL Jobs Kft will take all appropriate technical and organisational steps to safeguard your personal data. In the unlikely event of a data breach, CPL Jobs Kft will contact you in line with CPL Jobs Kft legal obligations.

CPL Jobs Kft collect personal data to enable the provision of services to support the CPL Jobs Kft purpose. The following non-exhaustive methods of data collection are an indication of ways in which CPL Jobs Kft may obtain your information:

  • Obtain personal data directly from you;
  • Personal data that CPL Jobs Kft receive from other sources; and
  • When entering CPL Jobs Kft premises, you will be recorded on CCTV surveillance and the Visitor Sign In tablet/book for security purposes.

It is important that the personal data you provide CPL Jobs Kft is up to date and accurate. As outlined in Section 7.4 of this notice, if personal data CPL Jobs Kft hold on you is inaccurate or incomplete, please contact CPL Jobs Kft and CPL Jobs Kft will update the information.

Process, Purpose, and Lawful Basis

CPL Jobs Kft use personal data collected to fulfil CPL Jobs Kft obligations to provide recruitment services and to enable the provision of services to support the CPL Jobs Kft purpose.

CPL Jobs Kft uses personal data gathered for any of the following purposes:

Process Purpose Lawful Basis
Pre-Recruitment To register a prospective data subject’s interest in recruitment for employment. Processing is necessary in order to take steps at the request of the data subject prior to entering into a contract.

 

Background Checks To verify if the data subject is qualified and eligible for certain positions within CPL Jobs Kft. Processing of personal data is necessary for compliance with a legal obligation pertaining to the data controller[Section 6.1(a)]
Recruitment
and Selection
To complete the recruitment process and assess data subject suitability. Processing of personal data is necessary for compliance with a legal obligation pertaining to the data controller[Section 6.1(a)]
Payroll To enable CPL Jobs Kft to effect payment to the data subject. Processing is necessary for the performance of a contract to which the data subject is party.
Personnel File To comply with employment and revenue laws and to ensure that terms and conditions of employment are adhered to. Processing is necessary for the performance of a contract to which the data subject is party.

To comply with various employment and revenue laws.

To protect the vital interests of the data subject in the event of an accident or emergency.

 

Entitlement to Work To enable CPL Jobs Kft to achieve compliance with its obligations pursuant to any local legislation governing the entitlement to work. Processing of personal data is necessary for compliance with a legal obligation pertaining to the data controller[Section 6.1(a)]
Time and Attendance Records To enable the data subject to avail of their rights and entitlement pursuant to the Hungarian Labour Code (Act I of 2012).

 

The processing is necessary for the performance of contract to which the data subject is party.
Statutory Entitlement To enable CPL Jobs Kft to achieve compliance with:

· Its obligation to the data subject;

· Record keeping obligations pursuant to a variety of employment law statutes.

 

Processing of personal data is necessary for compliance with a legal obligation pertaining to the data controller[Section 6.1(a)]
Training Records To ensure that CPL Jobs Kft is in a position to assess the data subject’s training needs and to capture proof of training.

 

The processing is necessary for the performance of contract to which the data subject is party.
Performance Details To manage the data subject’s performance in accordance with relevant CPL Jobs Kft policies.

 

The processing is necessary for the performance of contract to which the data subject is party.
Grievance

and Disciplinary

To ensure the data subject’s complaints are fairly investigated in accordance with CPL Jobs Kft policies. To comply with CPL Jobs Kft legal obligation to apply fair procedures to any data subject’s investigation.

The processing is necessary for the performance of contract to which the data subject is party.

Medical Information To manage the data subject’s absences, to manage sick pay in accordance with the contract of employment, and to manage the fitness to work of data subjects. Processing is necessary to assess, subject to data subject safeguards, the working capacity of the data subject.

Personal data may be processed also if obtaining the data subject’s consent is impossible or it would give rise to disproportionate costs, and the processing of personal data is necessary for compliance with a legal obligation pertaining to the data controller[Section 6.1(a)]

Making or Receiving Payments To make or receive any payments in the discharge of normal business functions, dispute settlement, or to carry out any other payment requirements. Processing is necessary for compliance with various employment and revenue laws.

 

The processing is necessary for the performance of contract to which the data subject is party.

Attracting Talent To provide support and assistance on recruitment services to data subjects via third party sources, such as LinkedIn and other job sites, from which CPL Jobs Kft obtain personal data.

 

Processing is based on legitimate interest [Section 6.1(b)]
Supporting Talent To support data subjects in their career guidance and communicate with them directly with useful information, advice, and support materials through email, messaging, or mobile/web notification.

 

Processing is based on legitimate interests and contractual obligations [Section 6.1(b)]
Regulatory Compliance To comply with financial regulations and any other relevant laws and regulations. Processing of personal data is necessary for compliance with a legal obligation pertaining to the data controller[Section 6.1(a)]
Third Party

Data Sharing

To allow CPL Jobs Kft to conduct and carry out functions with third party service providers that enable CPL Jobs Kft to deliver CPL Jobs Kft services. 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.

 

Back-ups To store personal data and make back-ups of that data in case of emergencies and for disaster recovery purposes.

 

Processing of personal data is necessary for compliance with a legal obligation pertaining to the data controller[Section 6.1(a)]
Evidence Submissions To gather information for dispute resolution services and legal proceedings. Processing of personal data is necessary for compliance with a legal obligation pertaining to the data controller[Section 6.1(a)]

 

Transfer of

Information for

Parties Legal

Proceedings

To allow parties to commence legal proceedings. Processing of personal data is necessary for compliance with a legal obligation pertaining to the data controller[Section 6.1(a)]

 

CCTV systems For the security, health, and safety of individuals on CPL Jobs Kft premises Processing is based on legitimate interest and is necessary for compliance with a legal obligation to which the Cpl Group is subject.

 

Accidents and

Incidents

To enable CPL Jobs Kft to comply with record keeping obligation pursuant to Hungarian Labour Code (Act I of 2012).

 

Processing of personal data is necessary for compliance with a legal obligation pertaining to the data controller[Section 6.1(a)]

CPL Jobs Kft may share personal data with other parties in the course of CPL Jobs Kft’ duties. When this is done, CPL Jobs Kft adhere to the following principles:

  • The transfer is based on a legal obligation, the performance of a contract, or explicit consent.
  • Where data is transferred to another party, CPL Jobs Kft ensure appropriate technical and organisational safeguards are used to protect your personal data.
  • Where CPL Jobs Kft engage a third party to provide a service to CPL Jobs Kft, CPL Jobs Kft ensure the provider has taken appropriate technical and organisational measures to process, store, and safeguard your personal data.
  • CPL Jobs Kft, as a Data Controller, will not sell your data to any third party and will take all appropriate steps to ensure the security of your data in dealings with third parties.

While the parties CPL Jobs Kft engage may change occasionally, CPL Jobs Kft believe it is important you are aware of the types of parties CPL Jobs Kft share data with. The categories and types of third parties outlined below is a non-exhaustive list but provides an indication of the parties CPL Jobs Kft share data with.

1 Other Third Bodies

Third parties for the purposes of internal and external audits, carrying out research, general practitioners, and or third parties who may improve CPL Jobs Kft processes and services (such as consultants).

2 Government Departments, Bodies or Agencies

CPL Jobs Kft is legally obligated to share personal data with state actors which is outlined in the Act CXII of 2011 on the Right of Informational Self-Determination and on Freedom of Information.

Recipients of this data include Government departments, agencies, bodies, investigatory bodies such as the Police, local authorities such as the National Tax Authority, Labor Center, Social Security Authority the National Directorate-General for Aliens Policing and the Department of Employment under the governmental administration of Budapest .

3 International Transfers

Where personal data is transferred outside the European Economic Area, CPL Jobs Kft use safeguards known as Standard Contractual Clauses (SCCs).

To fulfil CPL Jobs Kft mandate and perform tasks as outlined in this statement, CPL Jobs Kft need to collect various types of personal data.

While the type of personal data may change occasionally, CPL Jobs Kft believe it is important you are aware of the types of data CPL Jobs Kft gather and use. The following table is a non-exhaustive list and provides an indication of the categories and types of data CPL Jobs Kft use to perform CPL Jobs Kft tasks.

Please note that information listed under one category may be used for the performance of a task or in relation to activities under another heading or as outlined under Section 3.

Category Type of Data
Candidates
  • Name, residential address, email address, language test score, phone number, language knowledge, results of selection interview and tests, resume, candidate requirements and initial discussion on work details
  • Special data such as residence permit, residence permit expiry date
Employees
  • Personal data – name, work email, department, role, TMS ID, work location, perm address, phone number, date and place of birth, spoken language(s), qualification details, supervisor, previous employer’s docs, tax declarations, additional vacation for child request form, commuting and cafeteria docs, over time and on call docs, official salary deduction and salary advance, hard copy of leaver documents, premium and bonus details, clock card data, pay slips, expense claim forms including travel ticket, hotel booking, bank account details, next of kin, start date, leave date (optional), signed copy of enrollment form, signed contract, signed job description, declaration of other economic interest, declaration of other employment, new starter training agreement form, copy of the certificate of highest education, copy of the certificate of language exam, children’s personal data (name, place and day of birth, SS ID, birth certificate), declaration of tax allowance for first marriages
  • Special data such as sickness documents, paid and unpaid certified absence docs, call recording declaration form, consent for social media appearance, background check for Rothschild, Social Security card ID, work permit,  PID card/Passport number, disability details, ICE person, residence permit, copy of student visa, declaration on social security booklet
Other Stakeholders
  • First name, last name, customer and supplier data

CPL Jobs Kft have developed a record retention schedule for all the personal data CPL Jobs Kft hold. Each retention period varies dependent on the nature and the purpose of the processing.

The main factors which determine retention periods are as follows:

  1. How long it is required to perform the task;
  2. Any legal requirements to hold onto the data;
  3. Any pending legal actions.

If you would like to see a copy of the Retention Policy, please contact the DPO at dataprivacy@cpl.com

As a data subject, you will have the following rights as outlined in this section. However, restrictions may apply in certain situations.

1 Where do I send requests?

Please send all your requests to the contact details provided in Section 1, with as much detail as possible about your requirements to allow CPL Jobs Kft to deal with your request efficiently. To answer your request, CPL Jobs Kft may ask you to provide identification for verification purposes.

2 How long will a request take?

Upon receipt of a request, CPL Jobs Kft will have 30 days to provide an answer with an extension of two further months if required. If CPL Jobs Kft require more time to deal with your request, CPL Jobs Kft will notify you of the delay and the reasons behind it within 30 days of the receipt of the request. If CPL Jobs Kft refuse your request, CPL Jobs Kft will also notify you within 30 days of the receipt of the request accompanied by the reasons for the refusal.

CPL Jobs Kft will not charge a fee for any requests, provided CPL Jobs Kft do not consider them to be unjustified or excessive. If CPL Jobs Kft do consider these to be unjustified or excessive, CPL Jobs Kft may charge a reasonable fee (also applicable for multiple copies) or refuse the request.

You are entitled to contact the Data Protection Commission if CPL Jobs Kft refuse your request.

3 Right of Access

You have a right to know what personal data CPL Jobs Kft hold on you, why CPL Jobs Kft hold the data, and how CPL Jobs Kft are processing your personal data.

When submitting your request, please provide CPL Jobs Kft with information to help verify your identity and as much detail as possible to help CPL Jobs Kft understand the information you wish to access (i.e. date range, subject of the request) and email dataprivacy@cpl.com

Please note that an access request is free of charge, however, where CPL Jobs Kft determine a request to be unjustified or excessive, CPL Jobs Kft may charge you a reasonable fee.

4 Right to Rectification

You have a right to request that CPL Jobs Kft information held on you is up to date and accurate.

Where information is inaccurate or incomplete, CPL Jobs Kft encourage you to contact CPL Jobs Kft to have this information rectified. Upon receipt of request, CPL Jobs Kft will ensure that the personal data is rectified and as up to date as is reasonably possible.

5 Right to be Forgotten

You have the right to seek the erasure of your personal data in the following circumstances:

  • The personal data is no longer required for the purposes for which is was obtained;
  • Where data is being processed on the basis of consent, you withdraw consent to the processing and no other lawful basis exists;
  • The personal data is being unlawfully processed;
  • You object to the processing of personal data and there are no overriding legitimate grounds for the processing;
  • Your personal data requires deletion in line with legal requirements.

However, CPL Jobs Kft will be unable to fulfil an erasure request if the processing of personal data is necessary for the following:

  • Exercising the right of freedom of expression and information;
  • Compliance with a legal obligation or for the performance of a task carried out in public interest;
  • Reasons of public interest in the area of public health;
  • Archiving or statistical purposes in the public interest;
  • The establishment, exercise, or defence of legal claims;

Please note that the where the legal basis for CPL Jobs Kft processing of personal data is on the basis of a legal obligation, some processing in relation to your data may not be subject to the right to erasure.

To determine your request for erasure, CPL Jobs Kft will carry out an assessment of the justification for the retaining your personal data where a legal requirement applies and contact you if CPL Jobs Kft are unable to fulfil your request.

Please be aware that in some circumstances CPL Jobs Kft may need to retain some information to ensure all of your preferences are properly respected. For example, CPL Jobs Kft cannot erase all information about you where you have also asked CPL Jobs Kft not to send you marketing material. Otherwise, CPL Jobs Kft would delete your preference not to receive marketing material.

6 Right to Restriction

You have the right to restrict the extent of personal data processed by the CPL Jobs Kft in circumstances where:

  • You believe the personal data is not accurate (restriction period will exist until CPL Jobs Kft update your information);
  • The processing of the personal data is unlawful, but you wish to restrict the processing of data rather than erase it;
  • Where the personal data is no longer required by CPL Jobs Kft, but you require retention of the information for the establishment, exercise, or defence of a legal claim;
  • You have a pending objection to the processing of the personal data;

When processing is restricted, your personal data will only be processed: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of other people; or for reasons important to public interest.

We will contact you confirm where the request for restriction is fulfilled and will only lift the restriction after CPL Jobs Kft have informed you that CPL Jobs Kft are doing so.

7 Right to Data Portability

You have the right to the provision of all personal data held in relation to you in a structured, commonly used and machine-readable format where:

  • Processing is completed on the basis a contract;
  • Processing is completed based on consent by the you;
  • Processing is carried out by automated means.

You may also request that CPL Jobs Kft send this personal data to another data controller where technically feasible.

8 Right to Object

You have the right to object to the processing of your personal data; however, the processing must have been undertaken on the basis of public interest or legitimate interest by CPL Jobs Kft.

If you wish to object to the processing of data, please contact CPL Jobs Kft with your request. CPL Jobs Kft will then stop the processing of personal data unless it is required for legal proceedings.