PRIVACY AND PERSONAL DATA PROTECTION POLICY
In its everyday business operations, HRP makes use of a variety of data about identifiable individuals, including data about:
- Current, past and prospective employees
- Users of its website
- Other stakeholders
In collecting and using this data, our company is subject to a variety of legislation controlling how such activities may be carried out and the safeguards that must be put in place to protect it. The purpose of this policy is to set out the relevant legislation and to describe the steps HRP is taking to ensure that it complies with it. This control applies to all systems, people and processes that constitute the company’s information systems, including shareholders, directors, employees, suppliers and other third parties who have access to HRP systems.
2. Privacy and Personal Data Protection Policy
2.1. The General Data Protection Regulation
The General Data Protection Regulation 2016/679 (GDPR) is one of the most significant pieces of legislation affecting the way that HRP carries out its information processing activities. It is HRP’s policy to ensure that our compliance with the GDPR and other relevant legislation (such as, but not limited to, Law 2472/1997) is always clear and demonstrable.
There is a total of 26 definitions listed within the GDPR and it is not appropriate to reproduce them all here. However, the most fundamental definitions with respect to this policy are as follows:
Personal data is defined as:
any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; The Data Controller of your Personal Data is «HUMAN RESOURCES PLANNING E.P.E.» (ΗRP), a company with registered address at 62, Alexandras Ave. Athens, Postal Code 11473, Tel: +30 210 8252095, E-mail: firstname.lastname@example.org , email@example.com .
2.3. Principles Relating to Processing of Personal Data
There are several fundamental principles upon which the GDPR is based. These are as follows:
- Personal data shall be:
(a) processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’);
(b) collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall, in accordance with Article 89(1), not be considered to be incompatible with the initial purposes (‘purpose limitation);
(c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimization);
(d) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy);
(e) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) subject to implementation of the appropriate technical and organizational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject (‘storage limitation);
(f) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures (‘integrity and confidentiality).
- The controller shall be responsible for, and be able to demonstrate compliance with, paragraph 1 (‘accountability’).
HRP will ensure that it complies with all of these principles both in the processing it currently carries out and as part of the introduction of new methods of processing such as new IT systems.
2.4. Rights of the Individual
The data subject also has rights under the GDPR. These consist of:
- Τhe right to be informed
- The right of access
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to data portability
- The right to object
- Rights in relation to automated decision making and profiling.
Each of these rights is supported by appropriate procedures within HPR that allow the required action to be taken within the timescales stated in the GDPR.
You may contact us by E-mail, mail or telephone as listed in paragraph (1) above at any time, in order to exercise your rights under Articles 15 to 22 of GDPR. You can, for example, get an updated list of people who have access to your data, get confirmation of whether or not we process personal data related to you, check their content, source, correctness and location (also in relation to any third country), ask for a copy, ask for their correction and, limitation of processing or even erasure, if applicable. Similarly, you can always report comments and submit complaints to the Greek Data Protection Authority, Kifissias 1-3, GR 115 23, Athens, Call Center: +30-210 6475600 or at http://www.dpa.gr/
You can withdraw your consent at any time, without affecting the legitimacy of the processing that has taken place before the withdrawal of the consent. However, we reserve the right to further processing, if we prove compelling reasons or if the process serves to the exercise or the defense of legal claims.
2.5. Lawfulness of Processing
There are alternative ways in which the lawfulness of a specific case of processing of personal data may be established under the GDPR. It is HRP’s policy to identify the appropriate basis for processing and to document it, in accordance with the Regulation. The main options are described in brief in the following sections.
Unless it is necessary for a reason allowable in the GDPR, HRP will always obtain explicit consent from a data subject to collect and process their data. Transparent information about our usage of their personal data will be provided to data subjects at the time that consent is obtained and their rights with regard to their data explained. This information will be provided in an accessible form, written in clear language and free of charge. If the personal data are not obtained directly from the data subject then this information will be provided to the data subject within a reasonable period after the data are obtained and definitely within one month.
2.5.2 Performance of a Contract
Where the personal data collected and processed are required to fulfill a contract with the data subject, explicit consent is not required. This will often be the case where the contract cannot be completed without the personal data in question eg. a delivery cannot be made without an address to deliver to.
2.5.3 Legal Obligation
If the personal data is required to be collected and processed in order to comply with the law, then explicit consent is not required. This may be the case for some data related to employment and taxation for example, and for many areas addressed by the public sector.
2.5.4 Vital Interests of the Data Subject
In a case where the personal data are required to protect the vital interests of the data subject or of another natural person, then this may be used as the lawful basis of the processing. HRP will retain reasonable, documented evidence that this is the case, whenever this reason is used as the lawful basis of the processing of personal data. As an example, this may be used in aspects of social care, particularly in the public sector.
2.5.5 Task Carried Out in the Public Interest
Where HRP needs to perform a task that it believes is in the public interest or as part of an official duty then the data subject’s consent will not be requested. The assessment of the public interest or official duty will be documented and made available as evidence where required.
2.5.6 Legitimate Interests
If the processing of specific personal data is in the legitimate interests of and is judged not to affect the rights and freedoms of the data subject in a significant way, then this may be defined as the lawful reason for the processing. Again, the reasoning behind this view will be documented.
2.6. Privacy by Design
HRP has adopted the principle of privacy by design and will ensure that the definition and planning of all new or significantly changed systems that collect or process personal data will be subject to due consideration of privacy issues including the completion of one or more data protection impact assessments. Use of techniques such as data minimization and anonymization will be considered where applicable and appropriate.
2.7. Contracts Involving the Processing of Personal Data
HRP will ensure that all relationships it enters into that involve the processing of personal data are subject to a documented contract that includes the specific information and terms required by the GDPR.
2.8. International Transfers of Personal Data
Transfers of personal data outside the European Union will be carefully reviewed prior to the transfer taking place to ensure that they fall within the limits imposed by the GDPR. This depends partly on the European Commission’s judgment as to the adequacy of the safeguards for personal data applicable in the receiving country and this may change over time.
2.9. Breach Notification
It is HRP’s policy to be fair and proportionate when considering the actions to be taken to inform affected parties regarding breaches of personal data. In line with the GDPR, where a breach is known to have occurred which is likely to result in a risk to the rights and freedoms of individuals, the relevant supervisory authority will be informed within 72 hours.
3. Addressing Compliance to the GDPR
The following actions are undertaken to ensure that HRP complies at all times with the accountability principle of the GDPR:
- The legal basis for processing personal data is clear and unambiguous
- All staff involved in handling personal data understand their responsibilities for following good data protection practice
- Training in data protection has been provided to all staff
- Rules regarding consent are followed
- Routes are available to data subjects wishing to exercise their rights regarding personal data and such inquiries are handled effectively
- Regular reviews of procedures involving personal data are carried out
- Privacy by design is adopted for all new or changed systems and processes
- Documentation of processing activities is recorded
These actions are reviewed on a regular basis as part of the management process concerned with data protection.
4. Data we collect through our website
Our company owns and manages the site https://hrp.gr/
As a rule, we only collect and process the data that you provide directly and voluntarily, through the web or otherwise.
However, this rule cannot be fully applied in two cases within the context of the operation of the Site: (i) certain data that is collected automatically upon your visit to our website; and (ii) data collected through cookies and similar technologies.
4.1. Data collected automatically when you visit the site.
When you visit our site our server collects the so-called server log files, namely:
- Date and time of entering the site.
- The volume of data sent in bytes.
- The browser (browser) and the operating system that you used for your entering the Site.
- Internet Protocol address, when you enter the site. The IP address is personal data, along with the date and time of your visit, although we are not able to identify you by this data alone.
The legal basis for which we collect your IP address and keep it in special files ( log files ) is our legitimate interest in processing this data in order to ensure the security of networks, information and services from accidental events or illegal or malicious actions that compromise the availability, authenticity, integrity and confidentiality of the stored or transmitted data (e.g. control ddos attacks “denial of service”), as well as our legal obligation to provide a most secure environment for the processing of your personal data (GDPR art. 6 par. 1 case. f and c). The data will not be transferred or used in any other way. However, we reserve the right to check the server logs (server log files) if specific indications of unauthorized use are found.
4.2. Cookies and similar technologies
We may use these technologies to make your browsing comfortable and effective and providing us with some information to evaluate the use of the Site.
We may use Google Analytics, a service analysis provided by Google LLC. The information generated by Google Analytics cookies on the use of this website is generally transmitted to a Google server in the USA and stored there.
On our behalf, Google will use this information to evaluate the use of our website, compile reports on the activity of the site, and provide us with other services related to the use of the site and the Internet. The IP address that is transmitted by your browser within Google Analytics is not merging with other Google data.
You may deny the use of Google Analytics Cookies by selecting the appropriate settings in your browser, as listed below.
You can set up your browser in such a way that you decide, totally or individually, to accept or block cookies. Each browser differs depending on how it manages cookies settings. This is described in the browser’s help menu, which explains how to change the cookie settings. Follow the links below depending on your browser:
Please note that you must adjust the settings separately for each browser and each device you use. Please note that our site’s functionality may be restricted if cookies are not accepted.
5. Data we collect via E-mail
In the context of communication between us through E-mail, we collect your name, E-mail address and any other information you provide us. This data is stored and used exclusively to respond to your request. The legal basis for the processing of your personal data is your consent (GDPR, Article 6 (1) (a) ). Your data will be deleted after the final processing of our communication. This will happen after the purpose and scope of our communication is completed, provided that there are no legal claims for the storage of such data.
6. Submitting a CV
When you submit to our Company via the Web or to our offices a CV , you provide us with your personal information, which is included in your CV resume, such as your first name and surname, training, experience, expertise, professional skills and preferences, etc., as well as any other information that you may wish to disclose to us, such as your photo.
We keep your personal data (CV) for up to three years to consider recruiting you and the legal basis for the processing of your personal data is your consent as well as your request prior to entering into a contract with us (GDPR Article 6 (1), (a) and (b) and Article 9 (2), (a) ). We may also process your CV in the context of our company’s business activities, i.e. to promote it to companies interested in recruiting managers or executives or employees at the basis of a contract between us and the legal basis for the processing of your personal data is the performance of a contract as well as your consent (GDPR Article 6 (1), (b) and (a) and Article 9 (2), (a) ).
7. Who has access to your data. Data Transfers.
Your data is accessible to the personnel of the company as well as any other person authorized to process your data in the course of his / her work tasks. Additionally, we work with third-party service providers, individuals or legal entities, professionals, independent consultants etc. who provide us with commercial, professional or technical services (eg providing IT hosting services, deliveries etc.) for the purposes mentioned above and to support the Company in whole or in part, in connection with its activities. Where applicable, such individuals/legal entities will act as Joint Controllers, Data Processors or persons authorized to process personal data for the same purposes as mentioned above, under the same security measures and in accordance with the applicable legal obligations.
Before the third party receives the Personal Data, we: (1) complete the legal privacy test to evaluate the privacy practices and risks associated with these third parties; (2) we obtain warranties by contract from these third parties that will process Personal Data in accordance with our Company’s guidelines and in accordance with this Policy and the applicable law, that they will promptly notify our Company of any Privacy or Security Incident, including any inability to comply with the standards set forth in this Policy and existing law, that they will cooperate towards the remedy of any such Incident, that they will assist us in responding to the individual’s rights as defined below and that they will allow our company to audit their processing with regard to compliance with these requirements.
We may also transfer your Personal Data to third parties for the performance of a contract between us, such as your CV data.
Finally, the data may be further forwarded to public authorities and institutions as well as legal assistants, for legitimate purposes.
Except as above, Data will not be disclosed to third parties, individuals or legal entities, and will not be disseminated.
Our company does not transfer Personal Data outside E.U., and if we have to (eg in order to use Cloud services) this this will be done under the terms and conditions provided by Articles 44 et seq. of the GDPR, such as by obtaining your consent, applying standard contractual clauses approved by the European Commission or operating in countries that are considered safe by the European Commission.
8. Minors' Data.
Our company does not process minor’s data.
Athens, September 2018