PRIVACY POLICY
1. Privacy | Candidates
Your privacy is important. All personal data that we obtain in the context of our interactions with you as (potential) candidate for a vacancy with a client will be collected and processed in accordance with applicable data protection legislation, in particular the General Data Protection Regulation 2016/679 of 27 April 2016 (hereinafter “GDPR”). This privacy notice explains why and how we collect your personal data, the measures we take to protect your data and how long we retain your data. The GDPR also grants you certain rights as a data subject.
1.1 Identity and contact details
The data controller for your personal data is the following legal entity:
PROGRESSIO BV
VAT: BE 0820 872 002
Belgium
If you have questions regarding the processing of your personal data, you can always contact us by e-mail or by letter to the postal address mentioned above.
1.2 Purposes
We collect personal data from you as a (potential) candidate to contact you with respect to vacancies with our clients, to assist our clients with the selection of candidates for vacancies and/or to make available legal interim managers to our clients. We may also need your personal data in the context of accounting activities and litigation management.
1.3 Legal basis
We mainly collect your personal data because it is necessary to enter into a contract governing the provision of our services and for the performance of that contract. We may also process your personal data because (i) you have given your consent thereto (for example, in case you have provided us with sensitive data), (ii) we have a legal obligation (for example, tax and accounting regulations) or (iii) we have a legitimate interest that requires us to process your personal data (for example, in case of a dispute).
1.4 Categories of personal data
For the purposes mentioned above, we may collect and process the following personal data:
- Identification data
- Education and training
- Employment data
- Financial data
- Personal characteristics
- Lifestyle habits
- Psychological data
- Composition of family
- Leisure activities and interests
- Memberships
- Health data
- National register number
- Racial or ethnic data
- Political opinions
- Trade union membership
- Religion or beliefs
- Video recordings
- Sound recordings
- Other information provided to us
1.5 Source of personal data
We obtain your personal data in the context of our interactions with you as a (potential) candidate or consultant or interim manager. This includes interactions via our website, via e-mail, by phone and during meetings, events. In certain circumstances we may also receive certain data from third parties such as references and clients, or retrieve such information from publicly available information.
1.6 Recipients of personal data
For the purposes mentioned above, we may have to provide your personal data to the following third parties:
- (potential) Clients
- Consultants
- Accountants
- Social security authorities
- Public authorities
- Judicial and police authorities
- Financial institutions and insurance companies
Our IT, cloud, software and web development providers may also have access to your personal data.
1.7 Transfer of personal data
Your personal data will not be transferred outside the European Economic Area without appropriate safeguards.
1.8 Retention period
We will contact you with respect to vacancies with our clients until you inform us that you no longer wish to be contacted by us about such vacancies. We will in any event store your personal data until 10 years after the end of our cooperation (if any). We may need to store your personal data for a longer period of time because a legal obligation or legitimate interest requires us to retain your personal data longer or because you have consented thereto.
1.9 Rights
You can always contact us if you would like to:
- Request access to or rectification of your personal data.
- Request erasure of your personal data.
- Request a restriction of the processing of your personal data.
- Object to the processing of your personal data.
- Request transmission of your data to another service provider.
- Send us a complaint if you consider that we are not acting in accordance with applicable data protection legislation.
If we process your personal data (for example, sensitive data) because you have given your consent thereto, you can always withdraw your consent (without this affecting the lawfulness of the processing before the withdrawal). The aforementioned rights can be exercised by e-mail or by letter to the postal address mentioned under point 1.1, accompanied by a copy of your ID card. We will grant you all rights to which you are entitled in accordance with the applicable regulations.
Please also inform us when your personal data is not accurate or no longer up-to-date.
1.10 Automated decision-making
We do not engage in automated decision-making.
1.11 Security
We have implemented appropriate technical and organisational measures to ensure the confidentiality of your personal data and protect your data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.
1.12 Amendments
This privacy notice may be amended from time to time within the boundaries of applicable data protection legislation.
2. Privacy | Clients / Suppliers / Public Authorities
Your privacy is important for us. All personal data that we obtain in the context of our interactions with you as a (prospective) client, (prospective) supplier or public authority will be collected and processed in accordance with applicable data protection legislation, in particular the General Data Protection Regulation 2016/679 of 27 April 2016 (hereinafter “GDPR”). This privacy notice explains why and how we collect your personal data, the measures we take to protect your data and how long we retain your data.The GDPR also grants you certain rights as a data subject.
2.1 Identity and contact details
The data controller for your personal data is the following legal entity:
PROGRESSIO BV
VAT: BE 0820 872 002
Belgium
BE 0820 872 002 If you have questions regarding the processing of your personal data, you can always contact us by e-mail or by letter to the postal address mentioned above.
2.2 Purposes
We collect personal data from you as (staff member of) a (prospective) client in order to provide our services and to govern our contacts. We collect personal data from you as (staff member of) a (prospective) supplier in order to receive products or services and to govern our contacts. We collect personal data from you as staff member of a public authority in order to govern our contacts with and obligations towards public authorities.We may also need your personal data in the context of accounting activities and litigation management.
2.3 Legal basis
We mainly collect your personal data as (staff member of) a (prospective) client or supplier because it is necessary to enter into a contract and for the performance of that contract and to govern our contacts. We mainly collect your personal data as staff member of a public authority because we have a legitimate interest to govern our contacts with and obligations towards public authorities.
We may also process your personal data because (i) you have given your consent thereto, (ii) we have a legal obligation (for example, tax and accounting regulations) or (iii) we have a legitimate interest that requires us to process your personal data (for example, in case of a dispute).
2.4 Categories of personal data
For the purposes mentioned above, we may collect and process the following personal data:
- Identification data
- Personal characteristics
- Employment data
- Other information provided to us
2.5 Source of personal data
In general we obtain your personal data in the context of our interactions with you as (a staff member of) a (prospective) client, (prospective) supplier or public authority. This includes interactions via our website, via e-mail, by phone and during meetings, seminars or events. In certain circumstances we may also receive certain data from third parties or retrieve such information from publicly available information.
2.6 Recipients of personal data
For the purposes mentioned above, we may have to provide your personal data to the following third parties:
- Accountants
- Consultants
- Social security authorities
- Public authorities
- Judicial and police authorities
- Financial institutions and insurance companies
Our IT, cloud, software and web development providers may also have access to your personal data.
2.7 Transfer of personal data
Your personal data will not be transferred outside the European Economic Area without appropriate safeguards.
2.8 Retention period
We will delete or anonymize your personal data as (staff member of) a (prospective) client or supplier 10 years after the last contact or the termination of our cooperation with the client or supplier (plus a verification period of 6 months). We will delete or anonymize your personal data as staff member of a public authority 7 years after we have obtained such data (plus a verification period of 6 months)
We may use your personal data for a longer period of time if a legal obligation or legitimate interest requires us to retain your personal data longer or because you have consented thereto.
2.9 Rights
You can always contact us if you would like to:
- Request access to or rectification of your personal data.
- Request erasure of your personal data.
- Request a restriction of the processing of your personal data.
- Object to the processing of your personal data.
- Request transmission of your data to another service provider.
- Send us a complaint if you consider that we are not acting in accordance with applicable data protection legislation.
- If we process your personal data because you have given your consent thereto, you can always withdraw your consent (without this affecting the lawfulness of the processing before the withdrawal).
The aforementioned rights can be exercised by e-mail or by letter to the postal address mentioned under point 2.1, accompanied by a copy of your ID card. We will grant you all rights to which you are entitled in accordance with the applicable regulations.Please also inform us when your personal data is not accurate or no longer up-to-date.
2.10 Automated decision-making
We do not engage in automated decision-making.
2.11 Security
We have implemented appropriate technical and organisational measures to ensure the confidentiality of your personal data and protect your data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.
2.12 Amendments
This privacy notice may be amended from time to time within the boundaries of applicable data protection legislation.
3. Statistical Data
By accessing the website, you agree that PROGRESSIO may collect and store the data listed hereinafter for statistical purposes:
- Your IP address;
- Searches performed through the website’s search function;
- The precise time and date you have accessed the website;
- Which sections of the website you have visited and in what order;
- The location from which you have accessed the website; and
- The url through which you have reached the Progressio website.
The data will be used to monitor what sections of the website are of interest to its visitors and to improve the navigation and the accessibility of information on the website. The data will not be used to identify you as an individual.
4. Cookies
The PROGRESSIO website uses cookies to enhance its visitors’ user experience. A cookie is a small file that the website server will send to your browser and that is then stored on your computer. This cookie will improve the performance of the website (e.g. by diminishing the loading time of the pages) the next time you visit. Cookies may also be used to collect the statistical data mentioned under 3.
You may configure your web browser to issue a warning every time a cookie is installed, or for it to block the installation of cookies. However, blocking cookies issued from the
website may lead to a poorer performance or to the unavailability of certain parts of the website.