Policy on the processing of applicants' data via the Talent finder recruitment platform
1. Who is responsible for processing your personal data?
The companies Q-Park Belgium, Q-Park Holding, City Parking and Q-Park Real Estate (or "the companies Q-Park Belgium" "we" or "the controller"), having their registered offices at 3 Belgicastraat B-1930 Zaventem, box 6, represented by Mr Philippe De Brabanter, are to be understood, within the meaning of the General Data Protection Regulation, as data controllers insofar as they process the personal data of candidates for employment ("you" or "your").
The purpose of this Policy is to inform you, as transparently as possible, about the way in which the companies Q-Park Belgium process, collect and store your personal data when you register on the platform https://jobs.q-park.be.
This online platform is published and managed by THE PROFILE GROUP, whose registered office is at 54, Boulevard Louis Schmidt, 1040 Etterbeek, Brussels, Belgium.
This document applies in compliance with the Act of 30 July 2018 on the protection of individuals with regard to the processing of personal data (hereinafter referred to as the "Belgian Privacy Act") and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data repealing Directive 95/46/EC (hereinafter referred to as the "GDPR").
This Policy is for information purposes only.
2. Essential concepts
For the purposes of this Policy, "personal data" means any information that makes it possible to identify you, as a natural person, directly or indirectly.
“Processing of personal data" means any operation or set of operations which is performed upon personal data or sets of personal data, whether or not by automatic means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
“Data controller" means the natural or legal person, public authority, department or other body which, alone or jointly with others, determines the purposes and means of the processing operation. In this case, the companies Q-Park Belgium.
“Third party" means any natural or legal person, public authority, department or body other than the data subject, the controller, the processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data
Finally, "recipient" refers to any organisation that receives the data.
3. What personal data do we process? And how do we access it?
3.1. Categories of data processed
To identify the applicant
- Personal identification data, such as name and address;
- Electronic identification data, such as email address, mobile phone number and cookies;
- Personal details, such as age, gender, date of birth, place of birth, marital status, nationality and language;
- Immigration status, such as the existence of a valid work permit in Belgium.
To analyse the candidate's profile in relation to the vacancy
- Academic curriculum (and any information the applicant inserts in it, such as a photograph, for example) and, if applicable, your covering letter;
- Professional qualifications, such as vocational training and possession of a driving licence;
- Desired place of work;
- Professional experience ;
- Publications ;
- Information about current employment;
- Recruitment information ;
- Information concerning the end of employment ;
- Career data ;
- Data relating to work organisation ;
- Salary details (desired salary) ;
- Candidate availability ;
- Assessment ;
- Training for the position ;
- Membership/participation in professional organisations.
For platform management
- Security details, such as password.
3.2. Specific data
As a matter of principle, we do not process any particular category of personal data revealing your racial or ethnic origin, your political opinions, your religious or philosophical beliefs, your trade union membership, your genetic data, your biometric data, your health data or data concerning your sex life or sexual orientation, without your consent.
Exceptionally, we may need to process this type of data if you expressly ask us to do so because of your specific needs, or if you provide us with this information voluntarily (in your CV or verbally during discussions, for example).
3.3. Non-personal data
We may also collect non-personal data. This data is considered to be of a non-personal nature because it does not directly or indirectly identify a specific individual. It may therefore be used for any purpose whatsoever.
On the other hand, if non-personal data is combined with personal data in such a way that it is possible to identify the persons concerned, this data will be treated as personal data until such time as it is impossible to link it with a specific person.
3.4. Method(s) of collection
Your personal data is collected in various ways:
- When you send an application to Q-Park Belgium via the Talentfinder platform either by filling in the registration form, in response to a job offer or by submitting an unsolicited application;
- When you voluntarily complete or modify your individual profile on the Talentfinder platform;
- When you speak with a Q-Park Belgium Human Resources manager by telephone, email or video.
When a candidate chooses to provide the aforementioned data via a registration form and/or by means of an unsolicited application, he or she explicitly agrees that Q-Park Belgium may use his or her data to contact him or her by telephone and/or e-mail in order to receive further information from Q-Park Belgium regarding the vacancy(s) and, if he or she so wishes, to provide further information about his or her professional expectations.
- When you have a face-to-face interview with a member of Q-Park Belgium's Human Resources department
When a candidate agrees to an interview with Q-Park Belgium, he or she explicitly accepts that Q-Park Belgium uses his/her personal data to invite him/her to this interview and to evaluate him/her during this interview, as well as to check the references and information provided. The foregoing implies in particular that the Human Resources department of Q-Park Belgium will, if necessary, contact the companies and/or organisations provided with information by the candidate.
4. Why do we process your personal data? And on what legal basis(s) do we process your personal data?
Processing based on the legitimate interests of Q-Park Belgium
Your personal data is processed, in particular, for the following purposes:
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- to compile statistics, market research with the aim of improving the experience of candidates.
With regard to processing on this legal basis in particular, we always ensure that there is a balance between your interests and those of the Q-Park Belgium companies.
Processing on the basis of compliance by Q-Park Belgium with a legal obligation
The processing of personal data may result from a legal obligation which requires Q-Park Belgium companies, in particular, to respond to a request from an authorised third party, to apply fiscal and social obligations, to comply with applicable legislation in terms of labour law, social security and social protection.
Processing based on your consent
If you consent in writing to the processing of your personal data, including the processing of your personal data, by Q-Park Belgium, this processing is authorised provided that it is carried out solely for the purposes for which you have expressly consented.
In this case, these purposes are as follows:
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- Registration of the applicant on the platform (name of the platform) with a view to submitting an application and/or responding to a job offer;
- Transfer of the applicant's data to Q-Park's Human Resources department with a view to conducting one or more interviews;
- Management of applications by Q-Park Belgium;
- Any verification by Q-Park Belgium of the information provided by the applicant.
This being the case, applicants may withdraw their consent at any time, without this withdrawal affecting the lawfulness of the processing carried out prior to the withdrawal.
Processings not yet considered
Q-Park Belgium may carry out processing operations that are not yet provided for in this Policy.
In this case, you will be contacted by Q-Park Belgium before any re-use of your personal data in order to inform you of the processing not yet envisaged and to give you the opportunity, where appropriate, to refuse it.
5. Who has access to your personal data?
5.1. Internal communications
Access to your personal data is strictly limited within Q-Park Belgium to the following persons only:
- members of the hierarchical staff in charge of personnel administration, only if this is strictly necessary for operational or organisational purposes or in the performance of their duties (assessment data, remuneration, etc.), and always under the supervision of Q-Park Belgium;
- authorised persons in the Human Resources Department.
5.2. Communications to third parties
It is also possible that Q-Park Belgium may be required to disclose some of your personal data to third parties authorised to have access to it, in particular when legal provisions, a court decision or an order from a public authority make such disclosure necessary.
In particular, this may involve disclosure to the following third parties: banking institution, labour inspectorate, tax services, police services, bailiffs, insurance company, social secretariat, National Office for Annual Holidays, ONSS, ONEM, Existence Security Fund, etc.
None of your personal data is transferred to third countries outside the European Union or to international organisations. Should this be the case, we undertake to take the appropriate security measures in order to guarantee a sufficient level of protection for your personal data.
The Profile Group may also have access to some of your personal data, as a subcontractor of Q-Park, publisher of the Talentfinder platform. However, The Profile Group will only have access to the following data:
- Personal identification data, such as name and address;
- Electronic identification data, such as email address, mobile phone number and cookies;
- Personal details, such as age, gender, date of birth, place of birth, marital status, nationality and language;
- Immigration status, such as the existence of a valid work permit in Belgium;
- Psychological descriptions, such as personality by means of a psycho-technical test;
- Academic curriculum;
- Professional qualifications, such as vocational training and possession of a driving licence;
- Professional experience;
- Membership/participation in professional organisations;
- Publications ;
- Current employment information ;
- Recruitment information;
- Information concerning termination of employment ;
- Career data ;
- Data relating to work organisation ;
- Salary data ;
- Evaluation ;
- Job training ;
- Images ;
- Data relating to security, such as passwords
- Data relating to leisure activities and interests.
Talent finder is an online applicant tacking system (ATS) tool that manages the recruitment and selection process from A-Z. The tool is web based and works in a SAAS (Software As A Service) mode to allow HR professionals permanent and online access to all of their recruitment missions.
Talent finder also manages the job section of the website of the Client, allowing the management and posting of jobs. The database functionality provides the candidates an easy method to access, to upload and to edit their details online, and HR the facility to search and communicate with selected candidates for future job openings.
For HR managers, Talent finder has integrated reporting features that permit a permanent overview of both workflow and key processes.
6. How long do we keep your personal data?
The period of retention of your personal data is strictly controlled by Q-Park Belgium and complies with its Data Retention Procedure, which is available on request. If the retention periods change in the future, we undertake to keep you informed.
More specifically, your surname, first name, e-mail address, telephone number, CV (and possibly your photo if you have included it in your CV), and any covering letter you may have written are kept for 4 weeks from the end of the recruitment procedure if you have been hired for the position concerned, and for a maximum of 1 year after the end of the recruitment procedure if you have not been hired by Q-Park Belgium. In this case, you will of course be asked for your consent. Two months before the end of this one-year retention period, you will receive an e-mail asking you whether or not you wish your personal data to be deleted. If you wish your data to be deleted, it will be deleted automatically and in full on receipt of your return.
7. Your rights
As a data subject to the processing of your personal data, you have a number of rights regarding access to and control of your personal data, including:
- A right of access and copy: you may obtain a copy (including in electronic format) of your personal data free of charge on request. If you request additional copies, we may charge you a reasonable fee based on administrative costs.
- A right of rectification: you may rectify, add to or delete your data if it is inaccurate, incomplete or irrelevant data.
- A right to object: where data processing is carried out on the basis of our legitimate interest you may at any time object to the use of your data for this purpose, unless we can demonstrate that there are compelling legitimate grounds overriding your legitimate interests and rights.
- A right of portability: you may, at any time, request to receive your personal data in a structured, commonly used and machine-readable format free of charge, in particular with a view to transferring it to another data controller.
- A right to limit processing: you have the right to obtain a limitation of the processing of your personal data.
- A right to be forgotten: with certain exceptions, you have the right to ask us to delete your data when the processing is no longer necessary.
- A right to withdraw your consent: you may withdraw your consent at any time, if this consent is the legal basis for processing your personal data.
If you wish to exercise any of these rights:
- Request for exercise: if you wish to exercise any of these rights, you may send a written request (including in electronic format), dated and signed, to the Privacy Officer of Q-Park Belgium or to the Group DPO whose contact details are below.
- Specification of the request: identify the right you wish to exercise.
- Identification of the person concerned: in order to be able to respond to you, we may ask you to provide proof of your identity for security reasons and to prevent unauthorised disclosure or misuse of personal data.
- Response time: within a maximum of one month of receiving your request, we will process your request. If necessary, this period may be extended two months, depending on the complexity or number of requests. If necessary, this period may only be extended if you have been informed and that the reasons for the extension have been communicated to you.
- In the event of refusal: if we have legitimate reasons for not acceding to your request, we will contact you and give reasons for our decision.
8. Security around data
Candidates' personal data is processed in Belgium and stored in a data centre in the Netherlands.
The supplier of the recruitment tool, THE PROFILE GROUP, takes appropriate technical and organisational measures to protect candidates' data, in particular against manipulation and unauthorised access, and uses its best efforts to ensure that these measures are as up-to-date as possible, taking into account the state of knowledge, the costs of implementation and the nature, scope, context and purposes of the processing as well as the risks for candidates.
9. Questions, claims or complaints
If you wish to react to any of the practices described in this Policy, you are advised to contact :
- Belgian Privacy Officer (PO): Lex4u law firm, Mr Frédéric Dechamps, available at the following e-mail address: frederic.dechamps@q-park.be
- Group DPO (DPO): Mr Jeroen Van Hemert, available at the following e-mail address: Jeroen.vanhemert@q-park.com
You may also lodge a complaint with the Belgian Data Protection Authority:
Data Protection Authority
Rue de la Presse, 35
1000 Brussels
Phone + 32 2 274 48 00
Fax: + 32 2 274 48 35
contact@apd-gba.be
Finally, you can lodge a complaint with the competent national courts.
10. Modifications to the Policy
We reserve the right to modify this Policy in order to adapt it to new legal requirements. Such changes will take effect immediately after this document is updated. This update will be communicated to you in the way we deem appropriate.