This is KWAN’s new Privacy Policy, GDPR compliant

We need your A-OK: for us to find your next career opportunities we need to process your CV and your personal and professional data.

Privacy Policy and Consent for the Processing of Personal Data Candidates to Job Offers

Under the terms of the applicable legislation on data protection matters, namely the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR) we hereby inform you:

1. Data Controller KWAN, LDA., limited liability company with head office located at Av. Duque D’ Ávila, 46 | 3A, 1050-083 Lisboa, registered in the Commercial Registry Office under the sole identification and registration number 510336973, with the share capital of ten thousand euros, hereinafter referred to as KWAN, provides consultancy services for the recruitment of human resources, programming and computer solutions. Therefore, it is responsible for the Recruitment of employees to be allocated to its own projects or to recruit employees for third parties and, consequently, it is responsible for the processing of the personal data collected under such recruitment processes.

2. Purpose of the processing The personal data of the candidates may be collected and processed by KWAN for the following purposes, which are licit and limited to the strictly necessary:

• • Analysis and selection of candidates for job offers currently available;

• • Analysis and selection of candidates for potential and future job offers;

• • Storage of the data in the database for future opportunities;

• • Internal statistical analysis and internal report.

3. Category of personal data collected For the purposes above referred, KWAN may collect and process the following categories of personal data, including the documents in which such data are collected: Personal and professional data contained in the Curriculum Vitae and other documents made available by the candidate; Personal and professional interests; Dossier and/or portfolios of skills.

4. Retention period The retention period of the data collected corresponds to the period in which the recruiting process, for current or future job offers, takes place.

5. Recipients of data The following are recipients of the personal data collected: a) KWAN, or other company belonging to the RUPEAL Group, employees which work in the human resources department; b) The employees of the recruitment department, nearshore and outsourcing of KWAN and other companies belonging to RUPEAL Group.

6. Rights of the candidates The candidates are entitled to, in accordance with the law, the rights of information, access, rectification if the data are outdated, incorrect or incomplete, restriction, objection and erasure on the data collected. Notwithstanding, the right of erasure may be limited, namely, for public interest, judicial, national security, invoicing, commercial, fiscal, or other reasons provided by law.

• • 6.1 Right of access The data subject has the right to obtain a confirmation issued by KWAN if his/her data are being processed and, if so, the data subject has the right to have access to such data.

• • 6.2 Right of rectification The data subject has the right to obtain, without undue delay, the rectification of the inaccurate or incomplete data which KWAN has stored in its database.

• • 6.3 Right to erasure (“right to be forgotten”) The data subject is entitled to ask KWAN to erase his/her data, without undue delay, and KWAN has the obligation to erase such data when, amongst others, one the following reasons are verified: a) The personal data are no longer necessary for the purposes which justified the collection and processing of the data; b) The data subject has withdrawn its consent to the processing of data (in cases where the processing is based on consent) and there isn’t any other lawful reason for the processing; c) The data subject has objected to the processing and there are no legitimate interests which justify the processing;

• • 6.4 Right to restriction The data subject also has the right to request to KWAN the limitation of the processing, where one of the following is applicable:
    • • a) The accuracy of the data is contested, for a period enabling KWAN to verify the accuracy of the data;
    • • b) The data is requested by the data subject for the issuance of a statement or the exercise of a right or to defend a right in a judicial procedure, and KWAN no longer needs to process the personal data;
    • • c) If it has exercised the right to objection to the processing, until it is verified if the legitimate interests of the data controller prevail over the legitimate interests of the data subject.

• • 6.5 Right to data portability The data subject has the right to receive from KWAN, whenever the processing is carried out by automated means, his/her personal data in a structured, commonly used and machine-readable format and has the right to transmit those data to another controller.

• • 6.6 Right to object If the processing of personal data is based in the legitimate interests of KWAN the data subject is entitled to, at any time, object to such processing of personal data. For the exercise of any of those rights, the candidates have to submit a request, in written, to the e-mail: privacidade@kwan.pt. KWAN shall reply to your request within the period legally established.

7. Consent The consent of the candidates is legally necessary for the storage of their personal data included in the Curriculum Vitae and other documents in a database for the period of 12 (twelve) months, so that they may be contacted if a new job offer appears. The candidates are also entitled to the withdrawal of their consent. Such withdrawal does not affect the lawfulness of the processing based on consent before its withdrawal nor to further processing of the data, when necessary to comply with legal/contractual obligations.

8. KWAN performance in compliance with the General Data Protection Regulation

• • 8.1 KWAN hereby declares that the personal data collected are licit and limited to the necessary.

• • 8.2 KWAN also declares that the data are updated and that the necessary technical and organizational measures are implemented to ensure the safety, update and accuracy of the data collected.

• • 8.3 KWAN has implemented the adequate technical and organizational measures to ensure the confidentiality and safety of the personal data collected, to avoid its destruction, accidental or illicit, modification, accidental loss, diffusion or non-authorized access, namely when such data are transferred by electronic means, and against any illicit processing, in conformity with the categories of the data processed.

• • 8.4 It is hereby informed that the processing of personal data is lawful, loyal and transparent.

9. Notification of a data breach If a data breach which is likely to represent a high risk for the rights and freedoms of the data subjects is detected, KWAN will inform the data subjects about such data breach, as well as the supervisory authority, under the legally foreseen terms.

10. Right to claim before a supervisory authority The candidate has the right to submit a claim before the supervisory authority competent in Portugal, which is the Data Protection Commission (“Comissão Nacional de Proteção de Dados”), if he/she understands that KWAN is breaching its legal obligations.

11. Third Parties providers KWAN has service providers which are located within the European Union and in the United Kingdom and, therefore, your data may be processed outside of UE/EEE. Upon contracting with such providers for the execution of specific data processing, KWAN ensures that such third parties commit themselves to the same data protection obligations as the ones established in this privacy police, in particular, the obligation to provide sufficient guarantees in what respects to the execution of adequate technical and organizational measures so that the processing is compliant with the GDPR.

Learn more regarding our Information security policy here.

If you have any doubts about GDPR, drop us a line at privacidade@kwan.com

Thank You.