1. GENERAL TERMS
1.1. SIA “IT Camp”, registration no. 40103908693, legal address: Kaivas street 50, k-2, dz. 24C, Riga, LV-1021 (hereinafter referred to as the Company) the purpose of the personal data processing policy for candidates (hereinafter referred to as the Policy) is to provide the data subject (identified or identifiable natural person) as a candidate (hereinafter referred to as the Candidate) with information on the processing of personal data by the personnel in the selection process, processing purpose, scope, term, as well as personal data protection and information about the Candidate’s rights, etc. related information.
1.2. The Candidate’s personal data is processed in accordance with Regulation No. 2016/679 from April 27, 2016 of the European Parliament and the Council on the protection of natural persons with regard to the processing of personal data and the free movement of such data, which repeals Directive 95/46/EC (General Data Protection Regulation) (hereinafter – the Regulation), the Law on the Processing of Personal Data, this Policy and others to the applicable laws of the Republic of Latvia in the field of privacy and personal data processing and protection.
1.3. Processing – any activity performed with personal data or a set of personal data, which the Company performs with or without automated means, such as data collection, registration, recording, organization, structuring, storage, adaptation or transformation, change, transfer, etc.
1.4. The Candidate’s personal data is processed for the purpose of evaluating the Candidate’s suitability for the vacant positions of the Company’s clients, as the Company performs the functions of a legal recruitment agency and performs commercial activities in the field of recruitment. The Company processes the Candidate’s personal data with the intention of ensuring the personnel selection process and the realization of the rights and obligations arising from it, as well as promoting the establishment of employment legal relations or legal commercial cooperation between the Candidate selected in the selection process and the Company’s client.
1.5. The Candidate’s personal data is processed based on Article 6, Part 1, subparagraph f) of the Regulation – the processing is necessary to respect the legitimate interests of the Controller (Company). The company’s legitimate interest is a legal interest in processing the application received by the Candidate, evaluating the information provided in it, organizing the negotiation procedure, conducting negotiations and providing evidence that supports the legal course of the relevant process. In case of disputes, the information obtained during the selection process may be used to reflect the legal progress of the relevant process. In the event that the Candidate agrees to the processing of his/her personal data for possible selection processes for future vacancies, then in such a case the personal data is processed based on Article 6, Part 1, subparagraph a) of the Regulation – consent of the data subject.
1.6. The Company undertakes to ensure the confidentiality of the Candidate’s personal data and to protect his/her data using secure modern technology options, including security measures such as data encryption with data transmission (SSL encryption) and other protective measures to prevent unauthorized access to the Candidate’s personal data, its disclosure or other unlawful person the use of data, and security measures are constantly improved in accordance with the requirements set forth in regulatory acts.
1.7. The company undertakes not to disclose or transfer information about the Candidate to third parties without his/her consent, except in cases where the laws and regulations of the Republic of Latvia are violated.
1.8. Candidates’ personal data are not sent outside the European Union and the European Economic Area. The Candidate’s personal data is processed in the territory of the European Union and the European Economic Area. If the Company transfers the Candidate’s data outside the European Union and the European Economic Area, it will be done in accordance with the applicable laws and regulations of the European Union in the field of data protection and with the written consent of the Candidate.
1.9. The Policy applies to data processing regardless of the form and/or medium in which the Candidate provides personal data (in person, electronically via e-mail, on the Company’s website, in paper format, by telephone, etc.).
2. CONTROLLER AND CONTROLLER CONTACT INFORMATION
2.1. The controller of personal data processing is SIA “IT Camp”, registration number: 40103908693, legal address: Kaivas street 50, k-2, dz. 24C, Riga, LV-1021.
2.2. Contact information for issues related to personal data processing and for information on possible data protection violations: tel. +371 26884088, e-mail address: info@itcamp.lv. Using this contact information, you can ask a question about the processing of personal data in the Company.
3. WHAT DATA DOES THE COMPANY PROCESS AND FOR WHAT PURPOSE
3.1. Purpose: Ensuring the Company’s client personnel selection process, based on legal contractual obligations with the client and the Candidate’s directly expressed desire to participate in the said process through the Company, as well as evaluating the Candidate’s suitability for the specific client vacancy. The provision of the following personal data by the Candidate is objectively necessary for the evaluation of his/her candidacy and the possibility of participating in the selection for the vacant position.
3.1.1. Legal basis: Consent of the Candidate. The Candidate, through his/her active activity, sends the application and CV or electronically through e-mail agrees to the processing of personal data for the above-mentioned purpose.
3.1.2. The Candidate confirms that he is familiar with and agrees that the data provided by him is used in accordance with the requirements of regulatory acts, so that the Company can perform the necessary actions, which are determined in clause 3.1.. Also, the Candidate agrees that notifications related to the processing of his/her personal data, necessary for coordination and confirmation of consent, are sent to the e-mail indicated by him.
3.1.3. The Candidate has the right to withdraw his/her consent at any time by contacting the Company via e-mail: info@itcamp.lv.
3.1.4. Processing of personal data:
Identification data: name, surname, birth data;
Contact information: e-mail, telephone;
Qualification data: education (educational institution, study period, acquired education and/or qualification), work experience (workplace, work period, position, duties and/or achievements), CV and information contained in the application, information on language skills, information technologies, other competencies;
Other information contained in the application documents (application documents include: motivation letter, CV, references, educational certificates and other documents that come to the Company’s disposal during the personnel selection process);
Information about further education (training, obtained certificates, etc.);
Recommendations: identity and contact information of the representative of the current or former employer, content of the reference. The Candidate has the right to submit the personal data of other persons to the Company only in exceptional cases, for example, when submitting the data of the person who provides or could provide the Company with a review of the Candidate’s previous work experience. In such cases, the Candidate, as the controller of this third party’s data, is responsible for fulfilling the legal basis of this data processing and the requirements of other relevant regulatory acts;
Data created during the personnel selection process: tests, tasks, interviews and information obtained during them;
Other data: desired salary, a link to the LinkedIn profile and the information specified in it, as well as other information provided by the Candidate in the CV, motivation letter or other documents; any other data submitted by the Candidate at its discretion for consideration as part of the recruitment process.
3.1.5. Period of storage of personal data: until the end of the competition for the relevant vacancy, as well as at least 6 (six) months after that, in order to protect against possible claims and legal proceedings against the Company, or until the Candidate’s consent is withdrawn.
3.2. Purpose: Administration of the database of potential candidates. The Candidate may consent to his/her personal data being included in the Company’s database of potential candidates and for the Company to contact the Candidate in connection with possible vacancies among the Company’s clients (even if the Candidate’s application and consent does not apply to a specific vacancy), which corresponds to the Candidate’s professional competence.
3.2.1. Legal basis: Consent of the Candidate. The Candidate by his/her active activity sends the application and CV or electronically agrees to the processing of personal data for the aforementioned purpose via e-mail.
3.2.2. The Candidate confirms that he is familiar with and agrees that the data provided by him is used in accordance with the requirements of the regulatory acts, so that the Company can perform the necessary actions, which are determined in clause 3.2.. Also, the Candidate agrees that notifications related to the processing of his/her personal data, necessary for coordination and confirmation of consent, are sent to the e-mail indicated by him.
3.2.3. The Candidate has the right to withdraw his/her consent at any time by contacting the Company via e-mail: info@itcamp.lv.
3.2.4. Processing of personal data: all personal data specified in clause 3.1.4 can be processed for this purpose.
3.2.5. Period of storage of personal data: 2 (two) years from the moment of consent or until the withdrawal of the Candidate’s consent, depending on which event occurs first.
3.3. The Candidate is informed (by e-mail or in person) about the possibility of agreeing or not agreeing to the processing and saving of his/her CV and additional information, personal data in the Company’s database or sending his/her personal data to the Company’s clients. In the event that the Candidate does not agree to the processing of personal data, the Company does not consider or forward his/her candidacy to the relevant recruitment process.
3.4. The Company undertakes to do everything possible to minimize data processing as much as possible and not to process personal data of the Candidate that are not necessary for evaluating his/her suitability for the relevant job vacancy. In the submitted CV and application, the Candidate is invited not to provide information that is not necessary for the evaluation of the Candidate’s eligibility, in particular data that should be considered as a category of specially protected data or sensitive personal data (for example, photo; information about age; information about pregnancy and health status, except , if such information is required by law; information about family or marital status; information about previous convictions, except when it may be relevant to the work to be done; information about religious beliefs or affiliation to a religious group denomination, membership of a political party, trade union or other public organization; national or ethnic origin), as well as other data that are not objectively necessary for the personnel selection process in order to evaluate the Candidate’s suitability for the offered position.
4. PERSONAL DATA STORAGE PERIOD
4.1. Taking into account the requirements of the current regulatory acts, personal data are stored as long as their storage is necessary according to the relevant personal data processing purposes.
4.2. When evaluating the duration of personal data storage, the applicable requirements of regulatory acts, the Candidate’s instructions in case of consent, as well as aspects of the Company’s operation and legitimate interests are taken into account. If personal data are no longer needed for the specified purposes, they are deleted or destroyed.
4.3. The CV submitted by the Candidate for a specific job vacancy and the documents attached to it are stored until the end of the competition, as well as at least 6 (six) months after that, in order to protect against possible claims and legal proceedings against the Company.
4.4. If the Candidate has submitted the CV and accompanying documents without addressing a specific job vacancy, or has given consent to use the CV and accompanying documents also for later selections, the CV and accompanying documents will be stored for 2 (two) years. The Candidate always has the right to withdraw his/her consent to the storage of such data.
4.5. In the event that the Candidate’s personal data is needed to resolve the dispute, the relevant personal data will be stored until the dispute is resolved and/or the legal proceedings are over.
5. HOW ARE THE CANDIDATE’S PERSONAL DATA OBTAINED?
The Company receives personal data:
5.1. directly from the Candidate – when the Candidate refers to the Company’s job advertisement and/or submits his/her CV and/or other documents (motivation letter, etc.) to the Company;
5.2. personal data is obtained when the Candidate contacts the Company and talks with the recruitment specialist by phone or using distance communication means or social networks (Messenger, WhatsApp, Viber, Telegram, LinkedIn, etc.) or meets and talks with the Company’s recruitment specialist in person, incl. in notes made by the Company’s personnel selection specialist during a meeting or during a job discussion/interview;
5.3. The Company can also receive information about the Candidate’s candidacy, his/her CV and/or other documents from public job search portals (CV.lv, etc.), the career social network LinkedIn, where the Candidate published his/her personal data publicly;
5.4. The Company may also receive certain information about the Candidate from third parties, such as persons who recommend him/her (for example, current or former employers, colleagues). Such information is processed by the Company only if the Candidate gives his/her consent in writing (or in electronic form via e-mail) to contact the current or former employer and/or other person specified by the Candidate and receive a recommendation or feedback about his/her candidacy.
6. WHO COULD ACCESS THE CANDIDATE’S PERSONAL DATA?
6.1. Appropriate measures are taken to process personal data in accordance with applicable laws and to ensure that personal data is not accessed by third parties who do not have a relevant legal basis for processing personal data.
6.2. Personal data could be accessed if necessary:
6.2.1. Employees of the Company who participate in the evaluation of Candidates and who need the Candidate’s personal data for the performance of work duties, namely for personnel selection and to the extent that it is legally necessary to achieve this goal;
6.2.2. to the IT service provider that ensures the operation of the Company’s candidate database and its information system;
6.2.3. The Company may transfer the Candidate’s data for processing to third parties, namely the Company’s clients, to whom the Company provides services in the field of personnel selection based on legal contractual obligations. In this case, personal data is transferred only to persons authorized by the client, who process the Candidate’s personal data only to the extent necessary, namely for the evaluation of the Candidate’s candidacy, when he participates in the recruitment for the desired vacancy with the aim of being employed in the event of a successful result of the recruitment;
6.2.4. in cases specified in the legal acts of state and local government institutions, for example, state institutions, institutions, administrative institutions, courts, prosecutor’s office, state and local government police, tax administration institution, etc., but only at their request and only if it is provided for by the applicable laws or in the cases specified by law, to ensure the rights of the Company, to raise, secure and defend legal claims.
7. CANDIDATE’S RIGHTS
7.1. In accordance with the applicable legal acts, including Articles 12-22 of the Regulation, the Candidate has the right to:
withdraw the given consent to the processing of personal data at any time, however, the fact that the Candidate withdraws his/her consent will not affect the lawfulness of the data processing, which was based on this consent before its withdrawal;
to receive confirmation as to whether the Company processes personal data regarding the Candidate and, if so, to receive information about the personal data being processed (including the time of receipt, type and reasons for storage);
to access his/her data and receive personal data submitted by the Candidate to the Company, which relate specifically to the Candidate and whose processing is based on his/her consent (the Candidate has the right to receive free of charge one copy of his/her personal data processed by the Company, including in electronic form);
to request the restriction of the processing of your personal data (marking of the Candidate’s personal data in the Company’s possession with the aim of limiting their processing in the future);
request to fulfill the right to data portability;
object to the processing of your personal data;
withdraw the given consent to the processing of your personal data;
request to correct your personal data if it is incomplete or inaccurate or to update your personal data;
request to delete your personal data (the right to be forgotten), if this does not contradict the applicable laws and regulations. The Company ensures the deletion of the Candidate’s personal data if it is no longer necessary in connection with the purposes for which it was collected, for example, if data processing is based on the Candidate’s consent, which the Candidate withdraws in his/her request. On the other hand, if the Company processes personal data in accordance with another legal basis, for example, on the basis of the law, to ensure compliance with the requirements of regulatory acts, the data will not be deleted as long as the relevant legal basis is in force. In the event that the Candidate has withdrawn his/her consent to the processing of his/her personal data, the deletion of his/her personal data will be ensured immediately, but no later than within 5 (five) working days;
not exclusively the subject of automated processing (including profiling);
the right to submit a complaint to the supervisory authority Data State Inspectorate, e-mail: pasts@dvi.gov.lv, address: Elijas street 17, Riga, LV-1050, regarding the processing of personal data by the Company.
7.2. These rights are not absolute and their enforcement may be limited. For example, the Company has the right to deny the Candidate the termination of personal data processing if the Company indicates compelling legitimate reasons for processing that are more important than the Candidate’s interests, rights and freedoms.
8. REQUEST EXAMINATION PROCEDURE
8.1. The Candidate’s request must be in writing or in a form that can be considered in writing in accordance with regulatory enactments, such as an electronic document signed with a secure electronic signature.
8.2. Upon receiving the Candidate’s request to provide data or exercise other rights, the Company must evaluate the request and fulfill it in accordance with the regulatory enactments, namely the need to identify the Candidate. The Company considers a person who has approached the Company in one of the following ways to be an identified Candidate (identified person):
8.2.1. has appeared in person and presented an identity document;
8.2.2. has delivered the shipment to the Company in the form of registered mail. A response to such a request will be provided to the Candidate by registered post, thereby ensuring that the letter is received by the relevant Candidate identified upon receipt of the mailing. In case of doubt or suspicion, the Company has the right to ask the Candidate for additional information that would allow him to be clearly identified (with the aim of preventing the data from reaching third parties);
8.2.3. sent the request using a secure electronic signature to the Company’s e-mail info@itcamp.lv.
8.3. The information sent in the form of a simple post and e-mail does not provide personal identification, and in such a case the Company will ask the Candidate to provide additional identity confirmation. If the Candidate refuses to identify himself or fails to perform the identification in accordance with the procedure and time specified by the Company, the Company has the right to refuse to fulfill the request.
8.4. Once the Company has confirmed the identity of the Candidate, the Company undertakes to provide the Candidate with information in accordance with the request within one month of receiving the request at the latest. The Company may extend the execution of the request by up to two months, taking into account its complexity or other valid reasons, about which the Candidate will be informed separately.
8.5. In accordance with Article 12 of the Regulation, the Company provides the Candidate with information on data processing: 1) in a concise, transparent and understandable, easily accessible manner (in writing, electronically and, at the Candidate’s request, also orally); 2) using clear and simple language; 3) free of charge, except in cases where the Candidate’s requests are clearly unreasonable or excessive. Requests must be responded to using the same method that was used to submit the request, unless the Candidate has indicated a different method of response. If the Candidate submits a request electronically, the information must be provided electronically whenever possible, unless otherwise requested by the Candidate.
8.6. The Company may refuse to provide the Candidate with information about the data processing performed if:
8.6.1. if the Candidate’s requests are clearly unfounded or excessive (repeated multiple times) and the Candidate has already been issued information of identical content during the last year and the content of the news has not changed since the last issue;
8.6.2. providing such information is not possible or would require a disproportionate amount of effort;
8.6.3. if the Company cannot identify the Candidate and the Candidate has not additionally identified himself at the request of the Company.
8.7. The Candidate has the right to access only his/her personal data, but not to information relating to other natural persons (unless the particular person exercises the right on behalf of another natural person).
8.8. The Company ensures compliance with data processing and protection requirements in accordance with regulatory enactments and, in case of objections from the Candidate, takes appropriate actions to resolve the objections. However, if this fails, the Candidate has the right to apply to the state supervisory authority – the Data State Inspectorate.
9. EFFECTIVENESS AND AMENDMENTS OF THE POLICY
9.1. The current version of this Policy was developed and is valid as of October 1, 2023. If the Policy is amended, the Company will publish its renewed and valid version on its website www.itcamp.lv and, if necessary, inform about the changes in other ways.
10. COMPANY DETAILS
Name: SIA IT Camp
Registration number: 40103908693
VAT registration number: LV40103908693
Legal address: Kaivas street 50, k-2, dz. 24, Riga, LV-1021
Banks: AS Swedbank
Account number LV19HABA0551043005595
Phone: +371 26884088