The General Data Protection Regulation known as GDPR is a new regulation which replaces the Data Protection Regulation (Directive 95/46/EC) The Regulation aims to harmonize data protection legislation across EU member states, enhancing privacy rights for individuals and providing a framework within which commercial organizations can legally operate.
2. Who we are and what we do
Human Asset is a Human Resources Consulting firm offering Recruitment Services, Human Resource Management Services and Training Solutions.
We collect the personal data of the following types of individuals to allow us to undertake our business:
- Prospective and placed candidates for job roles we undertake on behalf of our clients;
- Prospective and current client contacts;
- Supplier contacts with whom we cooperate
- Client Details and their employees whether permanent or temporary
- Website visitors
- Individuals for whom we received their contacts to ask for references for one of our candidates
3. When is data processing allowed?
Under GDPR there are different circumstances were an organization is allowed to collect or reuse your personal information:
- Consent:when you have given clear consent to them to process your personal data for a specific purpose.
- Contract:the processing is necessary for a contract that you have with them
- Legal obligation:the processing is necessary for them to comply with the
- Vital interests:the processing is necessary to protect someone’s life.
- Public task:the processing is necessary in order to perform a task in the public interest or for their official functions, and the task or function has a clear basis in law.
- Legitimate interests:the processing is necessary for their legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests
4. Your Rights under GDPR
- The right to be informed: This is your right to be provided with clear and concise information about what we do with your personal data.
- Right to access: This is your right to request and obtain a copy of your personal data free of charge.
- Right to rectification/correction: If you believe that we have stored personal data about you that aren’t correct or are incomplete, you have the right to request correction or update of your personal data.
- Right to erasure/to be forgotten: If your personal data is no longer needed or is being used unlawfully then you can ask for your data to be deleted.
- Right to restrict processing: This is your right to limit the way that an organization use your data and is an alternative to requesting the erasure of your personal data.
- Right to data portability: This is your right to receive your personal data in a structured, commonly used and machine readable format and to ask that they are transmitted to another controller, if this is technically possible.
- Right to object: This is your right to object to the processing of your personal data i.e. for an organization to stop processing your personal data (subject to specific circumstances).
- Rights related to automated decision making including profiling: To the extend provided by the relevant law, you have the right not to be subject to a decision that is based solely on automated processing and which significantly affect you.
5. Our basis for processing your personal information
The main grounds that we rely upon in order to process your personal information are the following:
- Necessary for entering into, or performing, a contract – in order to perform obligations that we undertake in providing a service to you, or in order to take steps at your request to enter into a contract with us, it will be necessary for us to process your personal data;
- Required for purposes of compliance with a legal obligation – as an organization we are subject to legal requirements that may require us to process your personal information. We may also be required by law to disclose your personal information to regulatory authorities;
- Required for the purposes of legitimate interests – either we, or a third party, may need to process your personal information for the purposes of legitimate interests. Examples of legitimate interests include responding to your questions or inquires, improving our website and visitor experience or informing you about our services.
- Consent – Asking for your consent to process your personal information.
6. How we use your personal information
We believe that is reasonable to expect that if you have submitted your CV to us either directly (Human Asset Website) or indirectly (via external job portals or an acquaintance) you are happy for us to:
- Collect and use your personal data to provide you with our recruitment services and help you find the job you are looking for
- Assess your background and experience and much your profile against current and future available vacancies
- Share your information with prospective employers
- Perform any other checks where circumstances call for this (reference check, criminal record, financial background check)
- Process your data and share with you via email, phone or direct marketing, other vacancies or information (e.g. articles and trainings) that will help you with your job hunt
- Process your data and share with you via email, phone or direct marketing, information relevant to our recruitment services
- Process your personal data to comply with our contractual obligations (e.g. billing)
- Keep records of our meetings and discussion comments relevant to your job application/search
To ensure a smooth relationship and that we provide you with the best possible service we expect that you are happy for us to:
- Collect and store your personal data or personal data of individuals working within your organization
- Keep records of our meetings and services provided
- Collect and store your personal data for administrative purposes (e.g. billing)
- Process your data and share with you via email, phone or direct marketing, information relevant to the service provided
To ensure a smooth relationship and facilitate the service that we receive from you, we expect that you are happy for us to:
- Collect and store your personal data and individuals working for your organization
- Collect and store financial details to ensure that we meet our contractual obligations
Details of individuals whose data we collect from candidates
If a candidate has shared with us your personal data we expect that this candidate has already informed you of the fact and that you are happy for us to contact you via email or telephone for references. This practice is an integral part of our business as recruiters.
Website users: We only use your data to improve your experience of using our website.
7. What kind of personal data do we collect?
Candidate Data: Subject to circumstances and to the extend permissible by relevant legislation(s), we may collect some or all of the information listed below to enable us to offer you employment opportunities which are tailored to your circumstances and career aspirations:
- Personal information that are usually included on your CV when you apply for a job or register with us that may include: Name; – Age/date of birth;- Gender; Photograph; – Marital status;- Contact details (telephone number, email, residential address); Education details; Employment history; – Referee details; Nationality/citizenship/place of birth; military service status; Information about your current salary and benefits; details about your career aspirations and future roles
- Information that may be relevant to a specific role such as immigration status/work permit, copy of driving license, passport or identity card, criminal record or financial information (in the case of financial background check)
- Other information: information that you choose to disclose to us and you want to be kept in record; information disclosed to us by your referees; date(s)/time(s) and frequency you access our web services (e.g. when you submit an application; IP address
Client data: In order to be able to provide you with our services and subject to what type of service we are providing to you, we may collect some or all of the information listed below to enable us to offer you the best possible service that fit with your organization’s needs:
- Individual Contact Details: Your name; contact details (telephone number and email) and Job Title and/or of the individuals with whom we will work with for providing you with a specific service.
- Other information: In the case where we provide you with Training services we may need additional information such as ID Card Number (in the case where such trainings are subsidized by local authorities)
Supplier Data: In the case of suppliers we only collect the details (name, telephone number and email address) of employees within your organization with whom we will work with in the course of providing us with a specific service. We also hold your organization’s bank details for the purpose of paying relevant fees.
Details of individuals whose data we collect from candidates: This information are collected directly from candidates to enable us to receive candidate references. Such details are limited to name, email address, job title and telephone number.
What about Sensitive Personal Data?
We do not usually ask our candidates, clients or suppliers to share with us any sensitive personal data unless we consider it necessary under our legitimate interest such as in cases where we need to confirm eligibility of candidates against specific roles (e.g. eligibility to work in the country, reference checks, background checks) in order to fulfil our contractual obligations with clients/associates. In such circumstances we will ask for your explicit consent.
8. Sharing your personal information
We will share your personal information for any of the reasons described below:
- To provide you with our services;
- For business development;
- For systems administration/development and testing;
- To improve our customer service and to make our services more valuable to you;
- To improve our website and visitors experience
- With our clients in order to enable you to find employment. Nevertheless, , we will never share your details with clients prior getting your explicit consent on your interest on a specific vacancy or client.
9. How long do we keep your personal data?
Candidates Data: Once you have submitted your CV through our website, either for a specific vacancy or as General (for future vacancies that may arise), and unless otherwise notified by you, your data will be kept in our systems for recruitment purposes, up until the point we have placed you with a client.
Clients and Suppliers: We will preserve your personal data in our systems for as long as we are in a commercial agreement or for such longer period as we believe the law requires us to preserve your data. After this period your data will be deleted from our systems.
Data of individuals whose data we collect from candidates: we delete this data from our system as soon as we fulfill the purpose for which they have been collected.
10. Do we transfer your data internationally?
We store your personal data on servers that are located in the European Union. We may however, transfer your personal data in non EU countries to fulfil an agreement or contract such as in the case of recruitment activities where the job vacancy is in a non EU country.
11. How do we secure your data?
We take all reasonable and appropriate steps to protect the personal information that we hold. We do this by having in place a range of appropriate technical and organizational measures.
12. Do we use links to other websites?
Our websites may contain links to other websites that may not be governed by this Policy. Human Asset . is not responsible for the security content or privacy practices of such website destinations.
13. How to contact us
If you have any concerns or you want to raise any request in relation to this policy or our privacy practices please contact us at email@example.com or 24 Stasikratous 1st floor, office 104, 1065 Nicosia, Cyprus, tel. +357 22517701 (for Cyprus), Karakasi 14, Thessaloniki, 54248, Greece, tel +302310330150 (For Greece).
14. Changes to this Policy
We update this policy when required. Please check this site regularly to update yourself with any changes.
B. Human Asset Cookies policy
Last updated on May 2019
1. Automatic collection of personal information
The collection of this information allows us to customize your online experience, improve the performance, usability and effectiveness of HUMAN ASSET’s online presence, and to measure the effectiveness of our marketing activities.
2. IP addresses
An IP address is a number assigned to your computer whenever you access the internet. It allows computers and servers to recognise and communicate with one another. IP addresses from which visitors appear to originate may be recorded for IT security and system diagnostic purposes. This information may also be used in aggregate form to conduct web site trend and performance analysis.
Cookies may be placed on your computer or internet-enabled device whenever you visit us online. This allows the site to remember your computer or device and serves a number of purposes. On our web site, a notification banner will appear requiring your consent to collect cookies. If you do not provide consent, your computer or internet-enabled device will not be tracked for marketing-related activities.
A secondary type of cookie referred to as “userinput” cookies may still be required for necessary functionality. Such cookies will not be blocked through the use of this notification banner. Your selection will be saved in a cookie and is valid for a period of 90 days. If you wish to revoke your selection, you may do so by clearing your browser’s cookies.
Although most browsers automatically accept cookies, you can choose whether or not to accept cookies via your browser’s settings (often found in your browser’s Tools or Preferences menu). You may also delete cookies from your device at any time. However, please be aware that if you do not accept cookies, you may not be able to fully experience some of our web sites’ features.
Further information about managing cookies can be found in your browser’s help file or through sites such as www.allaboutcookies.org .
Bellow you may find a list all cookies you use
Performance (i.e. User’s Browser)
Our web site is built using common internet platforms. These have built-in cookies which help compatibility issues (e.g., to identify your browser type) and improve performance (e.g.,quicker loading of content).
Expiry Session – Deleted upon closing the browser type)
Our cookies may also remember your site preferences (e.g. language) or seek to enhance your experience (e.g. by personalising a greeting or content). This will apply to areas where you have registered specifically for access or create an account.
Type and Expiry: Session- Deleted upon closing the browser
We use several third party analytics tools to help us understand how site visitors use our web site. This allows us to improve the quality and content on Human Asset.com for our visitors. The aggregated statistical data cover items such as total visits or page views, and referrers to our web site.
Type and Expiry: Persistent -Deleted automatically after 2 years if you no longer visit Human Asset.com
We use third party social media widgets or buttons to provide you with additional functionality to share content from our web pages to social media websites and email. Use of these widgets or buttons may place a cookie on your device to make their service easier to use, ensure your interaction is displayed on our webpages (e.g. the social share count cache is updated) and log information about your activities across the Internet and on our web sites.
We encourage you to review each provider’s privacy information before using any such service. For further details on our use of social media widgets and applications, see below.
Type and Expiry: Persistent, but will be deleted automatically after two years if you no longer visit Human Asset.com
Other third party tools and widgets may be used on our individual web pages to provide additional functionality. Use of these tools or widgets may place a cookie on your device to make their service easier to use, and ensure your interaction is displayed on our webpages properly.
Cookies by themselves do not tell us your email address or otherwise identify you personally. In our analytical reports, we may obtain other identifiers including IP addresses, but this is for the purpose of identifying the number of unique visitors to our web site and geographic origin of visitor trends, and not to identify individual visitors.
A web beacon is a small image file on a web page that can be used to collect certain information from your computer, such as an IP address, the time the content was viewed, a browser type, and the existence of cookies previously set by the same server. HUMAN ASSET only uses web beacons in accordance with applicable laws. HUMAN ASSET or its service providers may use web beacons to track the effectiveness of third party web sites that provide us with recruiting or marketing services or to gather aggregate visitor statistics and manage cookies.
You have the option to render some web beacons unusable by rejecting their associated cookies. The web beacon may still record an anonymous visit from your IP address but cookie information will not be recorded. In some of our newsletters and other communications, we may monitor recipient actions such as email open rates through embedded links within the messages. We collect this information to gauge user interest and to enhance future user experiences.
HUMAN ASSET may collect and use the geographical location of your computer or mobile device. This location data is collected for the purpose of providing you with information regarding services which we believe may be of interest to you based on your geographic location, and to improve our location-based products and services
6.Social media widgets and applications
HUMAN ASSET web site may include functionality to enable sharing via third party social media applications, such as the Facebook Like button and Twitter widget. These social media applications may collect and use information regarding your use of HUMAN ASSET web site (see details on ‘Social Sharing’ cookies above). Any personal information that you provide via such social media applications may be collected and used by other members of that social media application and such interactions are governed by the privacy policies of the companies that provide the application. We do not have control over, or responsibility for, those companies or their use of your information.