Privacy Police

Thomas Stark Management Unipessoal LDA (“We” and/or “Our”) and its affiliates respects your privacy. You have certain rights related to any personal information we collect from you. Likewise, we have certain obligations in respect of same.

The following information outlines our privacy principles and our practices for gathering, storing and using your personal information. Please review this information so that you understand and are able to consent to how we may collect, use and share your personal information. Unless you provide sufficient personal information we may be unable to properly assist you with your request for employment, placement, job-matching or workforce solutions to be performed by Thomas Stark Management Unipessoal LDA.

Your personal data is in safe hands with us. As a potential job candidate, you must be secure in the knowledge that we do everything we can to protect your data. We comply with the relevant laws and regulations, specifically the General Data Protection Regulation (GDPR). This Privacy Statement for the Recruitment and Selection process (referred to below as the ‘R&S process’) explains how your data is processed.

1.1 Thomas Stark Management Unipessoal LDA is bound by the applicable rules regarding personal data processing.

What rules apply to the R&S process?

• General Data Protection Regulation (GDPR);
• Thomas Stark Management Unipessoal LDA Privacy Regulations
• Local laws and/or regulations with regard to the implementation of the GDPR.

1.2 What do we mean exactly by ‘personal data’ and the processing of this data?

Personal data refers to data which relates to you personally, either directly or indirectly as mentioned in the GDPR. This might include:

• Your name, address, telephone number and email address;
• Your CV and cover letter;
• Links to your public profiles on websites such as LinkedIn;
• Optional: a photograph and/or audiovisual job application video.

Processing refers to any activity involving personal data. When you apply for a job with us, we collect, use and retain your personal data. We do this, among other things, to verify that you hold the qualifications required for the position.

1.3 Whose personal data do we process, and how do we process it, during the job application process?

This Privacy Statement applies to all processing of personal data of candidates and potential candidates as part of the R&S process at Thomas Stark Management Unipessoal LDA. The data is processed in the HR system by or on behalf of Thomas Stark Management Unipessoal LDA. If you are hired by Thomas Stark Management Unipessoal LDA, you will be subject to the Thomas Stark Management Unipessoal LDA Privacy Regulations.

1.4 Who is responsible for processing my personal data?

Thomas Stark Management Unipessoal LDA and/or its affiliates is responsible for processing all personal data.

1.5 How do we obtain your personal data?

We have two ways of acquiring your personal data:

• You provide this yourself or through a third party/third parties (either through referees or an external recruitment agency).
• We also collect data (including contact details) ourselves through resources such as CV databases (e.g. Stack Overflow and LinkedIn; this process is known as ’sourcing’). We do this if we think you might be interested in working for Thomas Stark Management Unipessoal LDA. If the recruiter contacts you, he or she will tell you where we found your contact details. In addition, he or she will ask you for permission to use your personal data to contact you regarding an Thomas Stark Management Unipessoal LDA job opening or event. It goes without saying that you can change or revoke your consent at any time.

We process your data:

• based on your express consent – which, of course, can be revoked at any time;
• if we have a statutory obligation to do so, e.g. making a photocopy of your ID for payroll tax purposes;
• in order to enter into an employment contract with you and subsequently perform this contract;
• based on a legitimate interest on Thomas Stark Management Unipessoal LDAs part, e.g. in the case of ‘sourcing’.

2.1 For what purposes do we process personal data?

We process personal data for the following purposes:

• Human resources and personnel policy
  We require your personal data in order to be able to properly conduct our R&S process. This includes assessing whether you are suitable for the position and whether we would like to invite you for an interview. Another reason might be to produce an access card, which you require in order to enter the building and also to support you and to facilitate your workplace at Thomas Stark Management Unipessoal LDA
• Business reports and analysis and organizational development
  We may process your data to create business reports, surveys and analyses. We may also merge the various data we possess, for example to improve the R&S reports (e.g. the number of job openings, number of applicants and the time it takes to fill these vacancies). The results of the analyses and the resulting recommendations can never be traced back to you.
• Protection of job applicants’ vital interests
  We may process data in order to protect your vital interests, e.g. your medical details. Suppose you are in acute danger (and have lost consciousness) and are no longer able to give consent for your medical details to be shared. In this case, these details are vital in order to be able to provide you with immediate assistance.

Your personal data is used exclusively by employees who require access to this data on account of their position. The employees who are involved in your application process are bound by confidentiality.

Sometimes we engage the services of third parties, which process personal data on our behalf. This includes external recruitment agencies and research companies. We can only engage third parties if this suits the purpose for which we processed your personal data and this is sufficiently reliable.

If your application process includes an assessment, we will notify you in advance and will only save the report to your job application file once you have approved the accompanying report.

If your application has not yet led to an appointment, we will delete your personal data after the termination of the application procedure. This includes all application details, e.g. your job application letter, CV, email exchange, and the results of background checks and/or assessments, if applicable.

If we do need to retain your personal data for a longer period of time, e.g. for future job vacancies, we will ask for your consent. You can revoke this consent at any time. We will delete your data within six months after the end of the job application process, if you have given your consent we will delete your personal data after one year at the end of the job application process.

6.1 Right of access
You may ask us to view the data Thomas Stark Management Unipessoal LDA has stored in relation to you, including your public online details and your uploaded CV and cover letter.

6.2 Right of rectification
If your data is incorrect, incomplete or in violation of the law, you can request us to have it rectified.

6.3 Right to be forgotten
You can ask that data recorded in relation to you be deleted if you object to this data being processed. This might be the case, for example, if the processing is unlawful or no longer necessary for the purposes for which it was collected.

6.4 Right to restrict processing
In some cases, you may request that the processing of your personal data be restricted. This means that a smaller amount of data is processed. This is, for example, the case when your CV is updated.

6.5 Right not to be subject to automated decision-making
Automated decision-making’ refers to decisions made by computers rather than people. Thomas Stark Management Unipessoal LDA is permitted under the law to make automated decisions, including profiling. We currently do not use automated decision-making in the job application process.

6.6 Right to data portability
Data which has been provided to us based on an agreement and/or with your consent may be transferred to a third party. This can be facilitated only if it is technically feasible. Thomas Stark Management Unipessoal LDA will transfer the data you have provided yourself in a structured and readable format.

6.7 Right to object
You have the option to object to the processing of your personal data. In this case, we will make a reassessment in order to verify that it is accurate that your data can no longer be used for this purpose. We will also always inform you of our decision.

6.8 Procedure
If you submitted one of the requests described above, we will respond to your request.

We will, of course, keep you updated on the progress of your request. If the data you provided also contains third-party data, such third party may be requested in advance whether they object to their data being processed.

You may be asked to further specify your request. We may also ask you to provide ID because we want to make certain that we are providing data to the right person.
In some cases we may not be able to honour your request. For example, we will not delete the data if it is of significant importance to us or if there is a statutory obligation to retain it. We will notify you if this is the case.

You can direct your questions or complaints regarding personal data processing to the division to which you applied or to the Privacy Workgroup. The latter can be contacted at privacy@stark-partners.com.

Yes, our Privacy Statement may be modified from time to time. If there is new data to be processed, we will amend the Privacy Statement accordingly. You will be able to find the most up-to-date version of our Recruitment & Selection Privacy Statement on our website, along with previous versions of this Statement.

Updates to this Privacy Statement
We may update this Privacy Statement from time to time, so please review it frequently. If we change our Privacy Statement, we will post the revised version here.

How to Contact Thomas Stark Management Unipessoal LDA.

Physical Address:

• Rua Elias Garcia 172, 3F,
  2635-046 Rio de Mouro
  Portugal

E-Mail: privacy@stark-partners.com