Privacy Policy

Cpl Jobs Sp. z o.o. , located in Warsaw (02-001) at Al. Jerozolimskie 81, entered into the National Register of Entrepreneurs kept by the District Court for Warsaw, 12th Commercial Division of the National Court Register under KRS No. 0000364333, NIP (VAT identification number) 7010256845, REGON (National Official Business Register) 142578192, National Employment Agencies Register KRAZ No. 10504 is committed to protecting all personal and categories of data held on you.

As such, Cpl Jobs Sp. z o.o. wants you, the ‘data subject’, to understand how Cpl Jobs Sp. z o.o. collects, uses, store, and share your personal data. Cpl Jobs Sp. z o.o. also wants 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 Sp. z o.o. uses your personal data. Please note that Cpl Jobs Sp. z o.o. reserves the right to update this Privacy Notice as required.

Cpl Jobs Sp. z o.o. provides recruitment services and matches people with the right jobs every day.

Cpl Jobs Sp. z o.o. is committed to protecting the rights and privacy of individuals in accordance with both European Union and Polish data protection legislation. Cpl Jobs Sp. z o.o. 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 Sp. z o.o. is done so in accordance with the Personal Data Protection Act (PDPA).

If you are unhappy with the way Cpl Jobs Sp. z o.o.  handles your personal data or if you simply want further information about the way your personal data will be used, please contact Cpl Jobs Sp. z o.o.  at the below:

Data Protection Officer
Cpl Jobs Sp. z o.o.
Jerozolimskie 81, 02-001 Warszawa
Telephone: +48 22 488 65 00
Email: warsaw@cpljobs.pl

Cpl Jobs Sp. z o.o. will always use best efforts to address and settle any requests or complaints you may bring to Cpl Jobs Sp. z o.o.’s attention. Besides contacting the Cpl Jobs Sp. z o.o.  Data Privacy Officer, you also have the right to approach the competent data protection authority with your request or complaint here:

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 Sp. z o.o. will take all appropriate technical and organisational steps to safeguard your personal data. In the unlikely event of a data breach, Cpl Jobs Sp. z o.o. will contact you in line with Cpl Jobs Sp. z o.o.’s legal obligations.

Cpl Jobs Sp. z o.o.  collects personal data to enable the provision of services to support Cpl Jobs Sp. z o.o.’s purpose. The following non-exhaustive methods of data collection are an indication of ways in which Cpl Jobs Sp. z o.o. may obtain your information:

  • Obtain personal data directly from you;
  • Personal data that Cpl Jobs Sp. z o.o. receives from other sources; and
  • When entering Cpl Jobs Sp. z o.o.’s premises, you may be recorded on CCTV surveillance and the Visitor book for security purposes.

It is important that the personal data you provide Cpl Jobs Sp. z o.o.  is up to date and accurate. As outlined in Section 7.4 of this notice, if personal data Cpl Jobs Sp. z o.o.  holds on you is inaccurate or incomplete, please contact Cpl Jobs Sp. z o.o.  to update the information.

1 Process, Purpose, and Lawful Basis

Cpl Jobs Sp. z o.o. uses personal data collected to fulfil Cpl Jobs Sp. z o.o.’s obligations to provide recruitment services and to enable the provision of services to support Cpl Jobs Sp. z o.o.’s purpose.

Cpl Jobs Sp. z o.o. 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.

 

Recruitment

and Selection

To complete the recruitment process and assess data subject suitability. Processing is necessary in order to take steps at the request of the data subject prior to entering into a contract.

Processing relates to Cpl Jobs Sp. z o.o.’s obligations in employment and for assessing data subject’s work capacity.

 

Payroll To enable Cpl Jobs Sp. z o.o. 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 Sp. z o.o. to achieve compliance with its obligations pursuant to any local legislation governing the entitlement to work. Processing is necessary for compliance with a legal obligation to which Cpl Jobs Sp. z o.o. is subject.
Time and Attendance Records To enable the data subject to avail of their rights and entitlement pursuant to The Polish Labour Code.

 

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

· Its obligation to the data subject;

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

 

The processing is necessary for compliance with legal obligation to which Cpl Jobs Sp. z o.o. is subject.
Training Records To ensure that Cpl Jobs Sp. z o.o. 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 Sp. z o.o. 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 Sp. z o.o. policies. To comply with Cpl Jobs Sp. z o.o. 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.

To carry out obligations and exercise rights under employment law.

 

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.

 

Voice of the Customer To obtain the data subject’s feedback by survey on the Cpl Jobs Sp. z o.o. recruitment processes, client services and for research purposes.

 

Processing is based on request of consent which will be taken from the data subject.
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 Sp. z o.o. obtain personal data.

 

Processing is based on legitimate interest.
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.
Regulatory Compliance To comply with financial regulations and any other relevant laws and regulations. Processing is necessary for compliance with a legal obligation to which Cpl Jobs Sp. z o.o. is subject.

 

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.

 

Third Party

Data Sharing

To allow Cpl Jobs Sp. z o.o. to conduct and carry out functions with third party service providers that enable Cpl Jobs Sp. z o.o. to deliver Cpl Jobs Sp. z o.o.’s 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 is necessary for compliance with a legal obligation to which the Cpl Jobs Sp. z o.o. is subject.
Evidence Submissions To gather information for dispute resolution services and legal proceedings. Processing is necessary for compliance with a legal obligation to which the Cpl Jobs Sp. z o.o. is subject.

 

Transfer of

Information for

Parties Legal

Proceedings

To allow parties to commence legal proceedings. Processing is necessary for compliance with a legal obligation to which the Cpl Jobs Sp. z o.o. is subject.

 

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

 

Accidents and

Incidents

To enable Cpl Jobs Sp. z o.o. to comply with record keeping obligation pursuant to The Labour Code and Regulation of the Minister of Labor and Social Policy of 26 September 1997 on general provisions on occupational health and safety of Laws.

 

Processing is necessary for compliance with a legal obligation to which the Cpl Jobs Sp. z o.o. is subject.

Cpl Jobs Sp. z o.o. may share personal data with other parties in the course of Cpl Jobs Sp. z o.o.’s duties. When this is done, Cpl Jobs Sp. z o.o. adheres 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 Sp. z o.o. ensures appropriate technical and organisational safeguards are used to protect your personal data.
  • Where Cpl Jobs Sp. z o.o. engages a third party to provide a service to Cpl Jobs Sp. z o.o., Cpl Jobs Sp. z o.o. ensures the provider has taken appropriate technical and organisational measures to process, store, and safeguard your personal data.
  • Cpl Jobs Sp. z o.o., 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 Sp. z o.o. engages may change occasionally, Cpl Jobs Sp. z o.o. believe it is important you are aware of the types of parties Cpl Jobs Sp. z o.o. shares 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 Sp. z o.o. shares data with.

If you are registered as a candidate in Cpl Jobs Sp. z o.o.’s database, Cpl Jobs Sp. z o.o. will pass on your personal data to other companies within the Cpl Group in the EEA.

4.1 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 Sp. z o.o.’s processes and services (such as consultants).

4.2 Government Departments, Bodies or Agencies

Cpl Jobs Sp. z o.o. is legally obligated to share personal data with state actors which is outlined in the Personal Data Protection Act.
Recipients of this data include Government departments such as Social Insurance Office, National Health Fund and voivodeship labour office, agencies, bodies, investigatory bodies and local authorities.

4.3 International Transfers

Where personal data is transferred outside the European Economic Area, Cpl Jobs Sp. z o.o. use safeguards known as Standard Contractual Clauses (SCCs).

Third parties for the purposes of internal and external audits, carrying out research, general practitioners, and or third parties who may improve Cpl Jobs Sp. z o.o.’s processes and services (such as consultants).

To fulfil Cpl Jobs Sp. z o.o.’s mandate and perform tasks as outlined in this statement, Cpl Jobs Sp. z o.o. needs to collect various types of personal data.
While the type of personal data may change occasionally, Cpl Jobs Sp. z o.o. believes it is important you are aware of the types of data Cpl Jobs Sp. z o.o. gathers and uses. The following table is a non-exhaustive list and provides an indication of the categories and types of data Cpl Jobs Sp. z o.o. uses to perform Cpl Jobs Sp. z o.o. ’s 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, surname, contact details, date of birth, address details, education history, employment history, qualifications, trainings, interests, EU work permit details, interview notes
  • Special categories: Disability details, nationality
Employees
  • Name, surname, address details, date of birth, place of birth, education history, email address, employment history, qualifications, trainings, interests, nationality, EU work permit information, bank details, tax details, emergency contact, Health & Safety Initial training certificate, PESEL, ID details, father’s name, training completed, performance records, NHF details, sick leave details, annual leave details, initial occupational medicine certificate, periodical occupational medicine certificate, Health & Safety periodical training certificate, occupation, family member details for insurance, meeting notes for grievance and disciplinary investigations.
  • Special Categories of data: Sickness/Injury description/ report, EU work permit details, disability details
Other Stakeholders
  • Contact details of service providers
  • Contact details, ID details, bank details, company registration details, ID details of service providers with sole proprietorship

Cpl Jobs Sp. z o.o.  has developed a record retention schedule for all the personal data Cpl Jobs Sp. z o.o.  holds. Each retention period varies dependent on the nature and the purpose of the processing. Employment records are retained for a period of 10 years (though it may differ in specific cases, i.e. for documents created before 1st of Jan 2019 it may be 50 years) in accordance with The Polish Labour Code.

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.

1.1 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 Sp. z o.o.  to deal with your request efficiently. To answer your request, Cpl Jobs Sp. z o.o.  may ask you to provide identification for verification purposes.

1.2 How long will a request take?

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

Cpl Jobs Sp. z o.o.  will not charge a fee for any requests, provided Cpl Jobs Sp. z o.o.  does not consider them to be unjustified or excessive. If Cpl Jobs Sp. z o.o.  considers these to be unjustified or excessive, Cpl Jobs Sp. z o.o.  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 Sp. z o.o. refuses your request.

1.3 Right of Access

You have a right to know what personal data Cpl Jobs Sp. z o.o.  holds on you, why Cpl Jobs Sp. z o.o.  holds the data, and how Cpl Jobs Sp. z o.o.  is processing your personal data.

When submitting your request, please provide Cpl Jobs Sp. z o.o.  with information to help verify your identity and as much detail as possible to help Cpl Jobs Sp. z o.o.  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 Sp. z o.o.  determines a request to be unjustified or excessive, Cpl Jobs Sp. z o.o.  may charge you a reasonable fee.

1.4 Right to Rectification

You have a right to request that Cpl Jobs Sp. z o.o.  information held on you is up to date and accurate.

Where information is inaccurate or incomplete, Cpl Jobs Sp. z o.o.  encourages you to contact Cpl Jobs Sp. z o.o.  to have this information rectified. Upon receipt of request, Cpl Jobs Sp. z o.o.  will ensure that the personal data is rectified and as up to date as is reasonably possible.

1.5 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 Sp. z o.o.  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 Sp. z o.o. ’s 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 Sp. z o.o.  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 Sp. z o.o.  is unable to fulfil your request.

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

1.6 Right to Restriction

You have the right to restrict the extent of personal data processed by the Cpl Jobs Sp. z o.o.  in circumstances where:

  • You believe the personal data is not accurate (restriction period will exist until Cpl Jobs Sp. z o.o. updates 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 Sp. z o.o. , 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.

Cpl Jobs Sp. z o.o.  will contact you confirm where the request for restriction is fulfilled and will only lift the restriction after Cpl Jobs Sp. z o.o.  has informed you that Cpl Jobs Sp. z o.o.  is doing so.

1.7 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 Sp. z o.o.  sends this personal data to another data controller where technically feasible.

1.8 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 Sp. z o.o.

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