Introduction
Why and how does Ebbinge collect personal data
Types of personal data used by Ebbinge
Use of personal data
Assessment and coaching
E-mailservice and communication
Storage period
Rights: access, correction, data portability, objection, erasure and complaints
Data storage and security
Third parties
General/website
Changes

 

Introduction

Ebbinge offers search, advice and interim services (“the services”) as further explained on our websites. Ebbinge has extremely high standards when it comes to the quality of their services. An important aspect of high-quality services is ensuring the protection of privacy and the handling of (personal) data with care.

This Privacy Statement applies to candidates, clients, referees, visitors to the Ebbinge websites (ebbinge.nl, ebbinge.be, ebbingecampus.nl, investmentprogram.nl) and persons who have signed up to receive information that Ebbinge sends periodically, such as our e-mail service.
In this Privacy Statement, the following definitions apply:

• client: an organisation that calls upon Ebbinge for the provision of services;
• candidate: a person who registers for our services, a (potential) candidate for a current or future vacancy or an employee of a client;
• referee: a person who gives a personal opinion about a candidate.

Why and how does Ebbinge collect personal data

In order to provide the services to clients and candidates, it is necessary for Ebbinge to collect personal information about individuals, for instance in order to fill a vacancy with a client.

For certain positions, Ebbinge places an announcement to which candidates can reply directly. Ebbinge may also contact candidates and referees personally, by telephone, e-mail or at the office. On that occasion, the candidate or referee will be informed of the fact that his or her personal data may be processed. This Privacy Statement will also be provided.

Ebbinge also processes personal data for the purpose of conducting research into company sectors or market segments, often at the request of a client. Such research provides Ebbinge with insight into target groups and the persons working in these groups. It also helps clients with their search for suitable candidates.

This type of work implies that Ebbinge processes personal data on the basis of confidentiality and sometimes has to work without the data subject(s) being aware of the processing, for instance when conducting a search assignment for a client which cannot yet be disclosed. If it is not possible or reasonably feasible to directly approach the data subject, Ebbinge processes personal data on the basis of a legitimate interest. Where possible, Ebbinge requests consent, as further explained below.

Types of personal data used by Ebbinge

Clients:

Ebbinge uses company and contact information such as the client’s name, e-mail address, position and telephone number. In addition, Ebbinge uses information provided by the client, such as reports on discussions with the client about vacancies and candidates.

Candidates:

If a candidate registers himself or herself in the candidate system, either online or after personal contact, for an open or future position, Ebbinge collects the candidate’s name, address, place of residence, e-mail address, telephone number, position and, if applicable, a resume and motivation letter.
For searches and market research, Ebbinge also processes personal information from public sources (e.g. chambers of commerce and online publications). Personal data from third-party databases are not used.

Referees:

Ebbinge requests the name, e-mail address and telephone number of a referee as well as the referee’s personal opinion on the suitability of a candidate for an open position.

Use of personal data

Ebbinge processes personal data for the following purposes:

– Clients
Client information is used to perform an agreement with Ebbinge and to pursue legitimate interests of Ebbinge, such as relationship management and marketing.

– Candidates

• To fill vacancies, where Ebbinge acts on behalf of a client. If a candidate applies for an open position, Ebbinge can forward the candidate’s personal data to the client.
• To match candidates with future vacancies. Ebbinge keeps personal information in its candidate system (in portfolio) in order to assess the suitability of a candidate for a future position to be filled by Ebbinge.
• To perform a (confidential) search for a client. In this case, Ebbinge makes a preselection and then shares a limited set of personal data relating to the candidate with the client. If the client is interested, Ebbinge contacts the candidate for a discussion. If the discussion results in an invitation to an interview, Ebbinge will share the other relevant personal data with the client.
• To conduct research that a client wishes to have performed. To this end, Ebbinge can use limited personal information, such as position and sector.
• For the analysis or improvement of our services, for example, in the case of online questionnaires.

Ebbinge does not make a fully automated candidate selection based on personal information it receives.

Please note that Ebbinge is not responsible for the use of personal data relating to candidates by clients, provided it has complied with its own statutory obligations.

– Referees

In order to better assess the suitability of a candidate and perform the services, Ebbinge occasionally uses information about and relating to the referee.

Assessment and coaching

A client can request coaching or the assessment of a candidate. In that case, Ebbinge processes personal data relating to the candidate for a legitimate interest of the client or further to the instructions and on behalf of the client. If the coaching or assessment includes psychological research and results and Ebbinge does not perform these services on behalf of the client, explicit consent will be requested. Psychological research is conducted in agreement with the code of the Dutch Association of Psychologists (Nederlands Instituut voor Psychologen – NIP).

E-mailservice and communication

When a visitor, client or candidate registers for Ebbinge’s e-mail service or other online communication, Ebbinge processes his or her name and e-mail address.

It is possible to unsubscribe from these messages at any time by clicking on the unsubscribe button in each message.

Storage period

Ebbinge processes personal data only for as long as necessary to provide the services and fulfil the abovementioned purposes. At the end of this period, personal data will be erased or anonymised, unless the data must be kept for a longer period of time in order to (i) comply with a legal obligation to which Ebbinge is subject, (ii) safeguard vital interests of the data subject(s) or a third party or (iii) further a legitimate interest of Ebbinge or a third party, except where this interest is outweighed by the fundamental rights and freedoms of the data subject(s).

Rights: access, correction, data portability, objection, erasure and complaints

A candidate, client or referee is not obliged to provide personal information to Ebbinge. However, in this case, Ebbinge may not be able to provide the services.

Consent can be withdrawn at any time. In addition, Ebbinge can be asked to cease processing of personal data. A candidate, client or referee has the right to know which of their personal data Ebbinge holds. He or she can:

• request access to the data being processed;
• point out any possible inaccuracies and request that changes and improvements be made;
• for reasons specifically related to his/her situation, object to the processing of his/her data if such processing is based on a legitimate interest of Ebbinge or a third party, unless there are legitimate grounds for the processing that outweigh the interests of the data subject; this right also applies if the data are used for direct marketing purposes, in which case the request will always be granted;
• request that data be erased, including in the following cases:
  • when the data are no longer necessary for the purposes for which they were collected;
  • when processing is based on the consent of the data subject and this consent has been withdrawn, unless there is another legal basis for the processing;
  • when the data subject is of the opinion that his or her personal data are being unlawfully processed;
  • when an objection is made to the processing, as described above;
• request that the processing of his/her personal data be restricted in the following cases:
  • when the accuracy of the data is disputed, for the period necessary to verify this;
  • when the processing is unlawful and the data subject requests that restrictions be imposed rather than the erasure of his/her personal data;
  • when an objection has been raised to the processing, as indicated above, pending an answer to the question of whether there are legitimate grounds for the processing that outweigh the interests of the data subject(s);
  • when the data are no longer necessary to achieve the purposes of the processing and can therefore be deleted, but the data subject needs them to establish, exercise or substantiate a claim;
• request that the data be transmitted to the controller in a simple machine-readable form and/or transmitted to another controller, albeit only if the processing is based on the consent of the data subject or the performance of a contract.

Requests can be submitted to privacy@ebbinge.be and will be dealt with within 4 weeks.

Any possible complaints regarding how Ebbinge uses personal data can also be sent to this email address. If a complaint is not dealt with in a satisfactory manner, it is possible to contact the Personal Data Authority, via this link.

Data storage and security

Ebbinge stores personal information, within the EU, using various commercial applications. Ebbinge’s applications are secured by technical and organisational measures in order to protect the personal as well as possible data of candidates, clients and referees against loss, disclosure or unintentional use.

Third parties

In some instances, Ebbinge may for its services rely on external service providers, such as companies that administer psychological and other tests to evaluate candidates and those that provide office automation, storage, email and telephony services. These external service providers may receive personal data relating to candidates and clients which they may use solely for the purpose of performing their contract with Ebbinge. Furthermore, they are contractually obliged to respect the confidentiality of any personal data with which they come into contact and are not permitted to make any other use of such data or to transit them to any other parties. Ebbinge shall conclude appropriate agreements with external suppliers and service providers, in accordance with the applicable legislation, in order to safeguard the rights of data subjects.

General/website

Ebbinge wishes to keep informed of the number of visitors to its website. To this end, the identity of visitors is not important. No specific, personally identifiable information regarding visitors is saved. However, certain information is anonymised and stored. The Ebbinge websites use cookies for this purpose. Click here to read more about cookies and how Ebbinge uses them.

Changes

Ebbinge can modify this Privacy Statement periodically. Ebbinge shall strive to inform clients, candidates and referees of any modifications made hereto.

This Privacy Statement is issued by:

Ebbinge & Company cvba
Brugmannlaan 71
1190 Brussels
V25052018