Registration agreement

Registration agreement

Personal Data Protection Policy

Bulwork Company OOD is a legal entity registered as a personnel recruitment agency within the meaning of Article 5, Item 1 of the Ordinance on the Terms and Conditions of rendering intermediary services in the process of hiring personnel holding Certificate of Registration No. 2107 / 01. 09. 2016 issued by the Employment Agency.

Our mission is to connect companies from the information and telecommunication technology sector and job applicants providing both sides with the best possible opportunities whilst adhering to the principles of professional ethics.

To achieve the objective of our core business, which is recruitment, career consultancy, and personnel assessment, and to fulfil our legal duty to the Employment Agency relating to the management and oversight of employment intermediary activities, we collect, store, and process the personal data of job applicants by making sure:

Your personal data is used exclusively for recruitment purposes;
Your personal data will be kept confidential, up-to-date, and available through a combination of technical solutions, organizational measures, and internal oversight;
Your personal data will be managed using transparent procedures to allow you to easily and effectively exercise your rights under the GDPR;
A personal career consultant will present to you the most suitable job offers and will provide advice on your presentation before your potential employers as well as full cooperation in managing your personal data.

Our commitment to you does not stop at providing professional services and assistance on your way to realizing your full professional potential, we also make sure your personal data is protected in full compliance with the provisions of Regulation (EU) 2016/ 679 and the General Data Protection Regulation (GDPR).

For more details, please take the time to read and understand the full text of our Personal Data Management and Confidentiality Policy and feel free to contact us at any time with any additional questions and inquiries.

 

25.05.2018

PERSONAL DATA MANAGEMENT AND CONFIDENTIALITY POLICY

We at Bulwork Company OOD collect and process personal data in accordance with the law, in good faith and in a transparent manner following the principles of personal privacy and non-intrusion into the private life of citizens. Our Personal Data Confidentiality Policy imposes on us the commitment to process your personal data only when:

a) You have given us your consent to process your personal data for one or more specific purposes;

b) Processing your personal data is necessary for the performance of the Intermediary Employment Services Agreement to which we are a party or for undertaking certain pre-contract steps at your request;

c) Processing your personal data is required to comply with a legal obligation applicable to administrators and our legitimate interest as related to our core business namely recruitment, consultancy, and expert assessment.

This Personal Data Management and Confidentiality Policy is in full compliance with the requirements of the General Data Protection Regulation (EU 2016/679 (GDPR), Directive 2002/58/EC concerning the processing of personal data and the protection of privacy in the electronic communications sector, the Personal Data Protection Act, the Electronic Communications Actand the Ordinance on the Terms and Conditions on performing employment intermediary services and is applicable to the following:

(1) Individuals applying for jobs with us;

(2) Applicants to whom we provide employment or appointment with one of our customers;

(3) Applicants who have been referred to us by our customers following personnel lay-offs to be considered for vacancies with other customers of ours;

(4) Users of the https://bulwork.com website as well as individuals who have applied for work through the platforms of our partners such as jobs.bg, zaplata.bg, and rabota.bg among others;

The Policy hereunder describes the types of personal data we collect, the purposes and manners in which we use such data and the parties with whom we share this data, as well as the rights and options available to individuals with regard to the use of their data. We have also described the measures we take to protect the confidentiality of this data and the ways in which you can get in touch with us regarding our confidentiality practices and the exercise of your rights.

Data we collect

We collect your personal data in various different ways such as through our website, through public platforms for job seekers (such as jobs.bg, zaplata.bg, rabota.bg, etc.), social media (such as Facebook, LinkedIn etc.),through various events, by phone or e-mail, from job applications and personal recruitment and in the course of our relationships with customers and providers. We can collect the following types of personal data:

Contact information (name, e-mail address, and telephone number);
Date of birth;
Sex;
Nationality and work permit status;
Other data included in your resumes, information you have volunteered with regard to your career development preferences, as well as any other information regarding your employment-related qualifications:

Information regarding previous employment and educational background;
Language and other job-related skills;

Information contained in your letters of reference,
Other data you may provide for example through the use of the Contact Us function of our website.

The legal grounds for processing the personal data described above is on the one hand our legitimate interest with regard to our main line of business which is personnel recruitment and career consultancy, and on the other – our legal obligation under our license from the Employment Agency to conclude employment intermediary services agreements with our applicants and register them in the Agency’s information platform. Furthermore, pursuant to the same obligations, we are required to retain the data and the resumes of our applicants for a period of 5 years (for more details please read Article 41, Par. 2 of the Ordinance on the Terms and Conditions for Performing Employment Intermediary Services).

By applying for a job opening listed by us, you volunteer your personal data required for you application and become a party to the Employment Intermediary Service Agreement which we will register with the Employment Agency on their Internet site. The Agreement’s reference number is the same as the reference number of your personal account through which you can undertake all legitimate actions provided under the GDPR . Our obligation to you does not end at us not using your personal data for purposes other than recruitment. We are also required to refrain from disclosing your personal data to employers who cannot prove compliance with the requirements of the GDPR. Furthermore, we make sure your personal data is managed using transparent and inclusive procedures designed to ensure your personal data are given the best possible protection (both technically and procedurally)and that their integrity, availability, and confidentiality is guaranteed at all times.

In addition, you will be assigned a personal career development consultant making sure you will get high-quality career consultancy services tailored to your requirements, competent assistance in the application process, and information on suitable vacancies in the future. Your personal consultant will help you update your data as needed and manage them in accordance with the rights afforded to you by the GDPR.

Please note: It is our recommendation that you leave out of you resume any information regarding your racial or ethnic background, political, religious, or philosophical beliefs, membership in any political parties or organizations, religious, philosophical, political, or trade organizations, as well as any information regarding your personal health or sexual life. This is sensitive information which is not relevant to the recruitment process and is not required by employers or the Employment Agency. We would also like to warn you that volunteering meaningful personal ID information such as your Personal Identification Number, passport/ID number or expiration dates, etc. can expose you to unnecessary risks and is not required for us to provide our services.

Data collected automatically

Bulwork Company OOD’s Internet site collects a general data and information when the Data Subject or an automated system visits the site. This general data and information is retained in the server’s logs. Data collected in this manner may include: (1) information regarding the type or version of the browser used; (2) the operating system of the device accessing the site; (3) the website referring you to our Internet site (i.e. referring site), (4) (5) the date and time our site was accessed, (6) the IP address used to access our site, (7) the Internet provider used by the accessing device; (8) any and all other data of similar nature that can be used in case of an attack on our IT systems. Bulwork Company OOD does not use this general data to form any conclusions regarding the Data Subject. This data can be useful to us: (1) to create suitable content for our website; (2) to optimize the content of our website and its advertising; (3) to ensure the long-term viability of our IT and web technologies; and (4) to provide law enforcement agencies actionable information in case of cyber attacks. In pursuance to this, Bulwork Company OOD runs statistical analyses of the data and information collected on anonymous basis so as to improve the protection and security of our data and to ensure an optimal level of protection to the personal data we process. The anonymous data contained in the log files of our server are kept separately from the personal data provided by dada subjects.

Objectives and Ways in which We Use the Information We Collect

We use the information described above to perform the following tasks:

Providing staffing solutions and connecting applicants and employers;
Sending notifications for vacancies;
Management, assessment and improvement of our own operations;
Protecting against, identifying, and preventing fraud and other illegal activities, claims, and liabilities; and
Complying with and fulfilling the applicable legal requirements, industry standards, and contractual obligations and our internal rules.

Apart from the aforementioned, if you are an applicant applying for a particular position, we will use the data subject to these confidentiality rules for the following purposes:

To present to you employment opportunities and offers;
To provide additional services such as training, career consultancy, and career development services;
To assess your aptitude as a job applicant and you qualifications for certain openings; and
To perform analytical tasks such as (i) to analyse our job applicant database, (ii) to evaluate the individual results and capabilities of applicants including their job-specific skills, (iii) to identify the skills applicants do not possess, (iv) to compare individuals based on their potential capabilities, and (v) to analyse data channels (trends regarding the best practices in recruitment).

We shall also be entitled to use this information in any other way subject to express notification at or prior to its collection.

We use Google Analytics, a web analysis service provided by Google Inc., to assess the way in which our site and services are being used, to compile operations reports, and to provide other services relating to Internet use. Google’s privacy statement can be found at http://www.google.com/intl/None/policies/privacy/

By using our sites, you grant your permission to have your data processed by Google in the ways and for the purposes described therein. If you choose so, you can refuse to have your data being used by Google for advertisement display and/or to customize the advertisements you will be exposed to by changing Google’s add settings at: http://www.google.com/settings/ads. For more information on Google Analytics, go to https://www.google.com/analytics/.

Data Retention

We will retain your personal data for a period of 5 years in accordance with the provisions of the Bulgarian Law and as long as they are needed for our legitimate business interests, to perform our legal obligations, or establish, enforce or protect our rights. We undertake to update your information by keeping in touch with you so as to be able to present to you the best possible career opportunities.

You are entitled to revoke withdraw your consent to your personal data being used for recruitment purposes and we will make sure they are destroyed in a secure manner.

Data We Share

We shall not disclose the personal data we collect about you except as provided for in this Policy. We will share your personal data with customers who may offer suitable employment opportunities or wish to make job offers to our applicants.

We may share your personal data with companies acting as our subcontractors for the purpose of performing our obligations as a personnel recruitment agency; with IT service providers whose servers are located in Europeand who comply with the European Commission’s standard contractual clauses – for purposes related to the development and technical maintenance of our systems; with auditors and consultants tasked with verifying our compliance with the applicable internal and external standards and requirements. All persons and entities entrusted with the processing of personal data have been carefully selected and audited for compliance with the requirements of the GDPR. The latter are bound by confidentiality and non-disclosure agreements.

Further to the above, we may disclose data related to you (i) if we are required to do so by law or by legal proceedings; (ii) to law enforcement agencies and government employees where such disclosure this is required by law; (iii) when we deem it necessary in order to avoid injury or financial loss, or for the purpose of investigating alleged or actual fraud or illegal activity.

We reserve the right to transfer you personal data following the sale or transfer of our business or assets, or parts thereof (including in case of restructuring, winding-up, and liquidation).

Your rights and options

We are giving you certain options to choose from with regard to the personal data we collect about you and the way in which we will be communicating with you. To update your preferences, request to be removed from the list for periodic communication, to exercise your rights or to submit a request, please contact your personal career consultant or as indicated in the Contact Us section of this policy.

To request access to the personal data we are keeping for you or to request that we correct, change, delete, or block the data, please get in touch with your personal career consultant or as indicated in the Contact Us section of this policy. We can destroy your personal data at your request as long as there is no legal requirement for us to retain them.

You can revoke any consent you have granted to us or object to having your personal data processed at any time as prescribed by law at which point we will adhere to your preference as applicable at the time.

You will be entitled to receive information regarding the actions we have undertaken upon receipt of your request free of charge and within 30 calendar days as of us receiving said request.

You can lodge a complaint regarding Bulwork Cmpany OOD’s processing of your personal data with the Personal Data Protection Commission at the following e-mail address: kzld@cpdp.bg.

Transferring Data

We transfer your personal data only within the European Economic Area (EEA) and Switzerland and will adhere to the applicable legal requirements put in place to ensure suitable degree of protection whilst transferring personal data to recipients in countries other than the members of the European Economic Area and Switzerland.

Personal Data Protection Method

We have appointed a Personal Data Security and Protection Officer who has the required competencies.

We maintain and apply administrative, technical, and physical measures to the security and protection of the personal data provided by you against its inadvertent, illegal, or unauthorized destruction, loss, change, access, disclosure, and use.

Employees with access to personal data are trained in handling sensitive information and are bound to treat such data as confidential.

We have accessed the impact on data protection and have integrated data protection measures in the product design phase and the company’s processes. Furthermore, we conduct periodic risk assessment analyses to ensure the continued improvement of the Information and Personal Data Security Polilcy.

We cooperate with the Personal data Protection Commission in determining the risks and the control mechanisms to be used as well in handling every request made by the supervisory authority as part of its duties.

In case of a breach in the security of the personal data, the Information Security Officer shall inform the Personal Data Protection Commission within 72 hours of becoming aware of such breach in accordance with Article 33 of Regulation (ЕU) 2016/679. Where your rights and liberties have been exposed to a high level of risk, you will also be duly notified of the nature of the breach and the measures undertaken to mitigate its adverse impact by e-mail to the address you have provided

Updating the Confidentiality Policy

This Personal Data Management and Confidentiality Policy may be updated from time to time in order to account for changes in our personal data practices. We will notify you with a discernible notice on our site of any substantial change indicating the effective day of the update to the Policy at the start of the document.

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