Privacy Policy

The purpose of this document is to

• Establish the rules regarding the protection of personal information processed by Grupo Egor as a result of its activity; and
• Inform data subjects and the community about the processing of personal data within the scope of the Egor Group’s activity, in a simple, clear and accessible manner, at all times.

The Privacy Policy contains the following information:

• The identity and contact details of the Egor entity and other categories of entities that may jointly assume responsibility with Egor for the processing of personal information;
• The contact details of the Egor Group Data Protection Officer;
• The purposes for which personal information is processed;
• The legal basis for the processing;
• The categories of recipients with whom the personal information is shared;
• If the personal data is transferred to a country that is not a Member State of the European Union, or the European Economic Area, the information under which that State provides adequate safeguards for the protection of the personal information transferred;
• The period of retention of the personal data or, if this is not possible, the criteria used for this;
• If the processing of the data is based on the Egor Group’s legitimate interests, information on those interests;
• If the processing of the data is based on consent, the existence of the right to withdraw it without this compromising the lawfulness of the processing carried out on the basis of the consent previously given;
• The rights of the data subject and how to exercise them with the Egor Group entity responsible for the processing;
• The right to lodge a complaint with the supervisory authority;
• The voluntary or mandatory nature of the communication of personal data and the consequences of the non-communication;
• The existence of automated decisions, including profiling, where applicable;
• If personal data is collected through an intermediary, Grupo Egor guarantees the data subject information on the origin and categories of data collected.

For additional information, or to clarify any doubts about the Egor Group’s Privacy and Personal Data Processing Policy, questions should be directed to its head office, mentioned in the “Presentation of the Egor Group” section of this Privacy Policy.

 

The Data Protection Officer can be contacted at the following email address: privacidade@egor.pt

 

Presentation of the Egor Group

The Egor Group  comprises a group of legally autonomous companies, with a common Vision, Mission, Values and Quality and Privacy Policies.

 

The Privacy Policy is a public statement, shared through available communication media and applicable to all Egor Group entities – Egor Portugal, Egor Empresa de Trabalho Temporário, Egor Outsourcing, Egor Consulting, RH Portugal, RH Norte, Medaute, Cross Jobs,

 

Egor Alchemy, Egor People & Change and Egorgest SGPS, S.A., headquartered at Avenida José Malhoa, 16F, 4th floor, Lisbon.

 

The Privacy Policy applies to information collected through the following channels:

 

Egor’s institutional website;

Job advertisements or spontaneous applications;

Social networks (Facebook, LinkedIn);

In person, by SMS, email, letter or other means of communication.

The companies of the Egor Group are guided by the protection and guarantee of the security of the information they access, whether it is personal data, strategic information, financial information or of any other nature, to provide a service or participate in projects.

 

Any of the Egor Group entities may be responsible for processing personal data.

 

However, it may happen that partners or clients of the Egor Group are jointly responsible for data processing with the Egor Group entity.

 

This may be the case, for example, with partners and clients who select human resources as part of recruitment processes, the user of temporary work and the beneficiary of the provision of services. If this is the case, each of these entities will provide the data subject with information on the data processing carried out under their respective responsibility.

 

In cases of joint responsibility for data processing, the Egor Group entity and its clients or partners will enter into a data processing agreement.

 

The agreement signed between the Egor entity and its partners will duly reflect the rights and duties of the parties concerning the exercise of rights by data subjects and the information duties provided for in the applicable legislation. Regardless of the terms of the agreement, the data subject is guaranteed the possibility of exercising their rights before any of the parties. Upon request, the essence of the agreement will be made available to the data subject.

The personal data of data subjects may be processed by entities subcontracted by the Egor Group. In this case, agreements on the processing of personal data will be signed under the applicable legislation, to ensure compliance with the principles of data processing and the legal rules applicable to subcontractors. Grupo Egor ensures that these entities are equipped with technical measures to ensure compliance with current legislation on the protection of information security.

Egor processes the personal information of the following categories of data subjects:

 

• Applicants for job offers;
• Workers who sign an employment contract with any of the Egor Group entities;
• Trainees taking part in training courses under contracts for the provision of training services to clients;
• Trainees who sign a training contract with any of the Egor Group entities;

The Privacy Policy contains specific information on the processing of personal data concerning the aforementioned personal data processing activities.

Data subjects have the right to file a complaint with a supervisory authority regarding the processing of data carried out by any of the Egor Group entities.

In Portugal, the National Data Protection Commission is responsible for receiving and processing complaints from data subjects.

3.1. CANDIDATES FOR JOB OFFERS

Purpose and legal basis

 

• Purpose: Registration and conservation in the Egor Group databases of applications for available job offers.

For the Egor Group to process the personal information of candidates for job offers, their consent is necessary. Consent is conditional on prior reading of this Privacy Policy and must be unambiguous, free, and provided in writing or by validating an option digitally.

 

At any time, the holder may cancel the consent granted for the processing of their data, without this compromising the lawfulness of the previously consented processing.

 

In some cases of applying for a job offer, the Egor Group may understand that the processing of personal data is based on the company carrying out pre-contractual measures at the request of the data subject.

In these cases, it is considered that the submission of an application by the data subject on an online recruitment page constitutes a request, by the data subject, that the Egor Group take steps aiming to the possible conclusion of an employment contract.

For recruitment projects, Egor will request data such as academic qualifications and professional experience or other information relevant to open opportunities, and may, in certain situations, and to the extent current legislation determines, require additional data, such as data relating to possible criminal convictions or infractions.

 

The candidate’s personal data, including the CV made available through the Egor platform at the time of application, will be sent to Egor’s clients or potential clients, who maintain active recruitment processes compatible with the candidate’s professional experience. If the candidate has a profile on a public platform for strictly professional purposes (for example, LinkedIn), the information disclosed there may be considered by Egor and sent to Egor’s clients or potential clients, as complementary information to that made available by the candidate.

If the candidate is not selected within the scope of the recruitment process to which he/she has applied, the Egor Group will continue to look for employment opportunities compatible with the candidate’s qualifications and professional experience, under the legitimate interest of the Egor Group.

 

The recruitment of human resources for placement in available jobs in the structures of its clients or partners constitutes a fundamental part of the Egor Group’s commercial activity.

 

Experience in providing human resources placement services and daily contact with candidates leads the Egor Group to conclude that the significant majority of candidates for job offers seek placement in a job compatible with their qualifications – and not exclusively to the job offer for which they applied.

 

The possibility of keeping the data subject’s application for new job opportunities without the data subject necessarily being obliged to provide new consent and submit a new application corresponds to a legitimate interest of the Egor Group, both from the point of view of pursuing its activity and from an administrative point of view.

 

In any case, and at any time, the data subject may object to their candidacy being considered in future recruitment processes compatible with their professional experience.

 

The Egor Group will not require any conditions for the exercise of the right to object, other than the need for the holder to exercise this right in writing, so that the Egor Group can prove the exercise of the right by the legitimate holder of the personal data.

 

If the data subject exercises the right to object, the Egor Group guarantees the cessation of the respective processing and the deletion of the data.

 

Once the data has been deleted, the holder may, at any time, re-register on the application submission platform, having to register again for this purpose.

 

Recipient categories

• Egor Group employees authorized to process personal data;
• Customers or partner entities of the Egor Group that maintain active recruitment processes for jobs compatible with the candidate’s academic training and/or professional experience;
• Companies subcontracted by the Egor Group which ensure a processing that offers guarantees of security and compliance with current legislation regarding the protection of personal data

Transfers of personal data to countries outside the European Union or the European Economic Area.

• The Egor Group platform for submitting applications is called Bullhorn and is owned by the Bullhorn Group, Inc.
• The Bullhorn platform is domiciled in the United States of America.
• Upon submission of the application, the personal data provided by the holder will be transferred to the databases of the Bullhorn, Inc. group, in the United States of America.
• The transfer of personal data to the United States of America is carried out under the Commission Implementing Decision (EU) 2016/1250 of 12.07.2016 on the level of protection ensured by the EU-US Privacy Shield, based on the Directive 95/46/EC of the European Parliament and of the Council, under which an adequate level of protection is guaranteed to personal data whenever they are transferred from the Union to organizations in the United States that are on the “Data Protection Shield list”. Privacy”, as is the case with the Bullhorn Group, Inc.

 

Conservation period

 

• Candidates’ personal data will be kept for a maximum period of 5 years, during which the application may be considered for other job opportunities compatible with the candidate’s professional and academic experience.
• During this period, the candidate may be contacted regarding job offers compatible with their academic qualifications and/or professional experience.
• If the holder requests the deletion of their data and imposes a legal obligation on the Egor Group to preserve them or, if they are necessary within the scope of a legal process, the limitation of processing is guaranteed, and the deletion will occur once the legal deadline for retaining them or after the court decision transit period has elapsed.

 

Rights of data subjects and form of exercise

• The data subject has the following rights:
• Information about the processing of personal data concerning you;
  • Access or Rectification;
  • Deletion of data, as long as there are no valid grounds for its conservation (see the applicable Privacy Policy points, in the segment relating to the retention period);
  • Portability of personal data, in cases where processing is carried out by automated means and is based on consent or a contract;
  • Limitation to treatment or Opposition to treatment;
  • Submitting a complaint to the supervisory authority, which, in Portugal, is the National Data Protection Commission;
  • If applicable, the right to information about automated decisions and profiles that may be created, as well as about the terms of exercising the right to object;
  • If the processing of data is based on the legitimate interests of the Egor Group, the holder will have the right to be informed about these interests;
  • If data processing is based on consent, the existence of the right to withdraw it without compromising the lawfulness of the processing carried out based on previously given consent;
  • The data subject may exercise his or her rights upon request to the Egor Group, whose contact details can be found in point 6.
• To ensure security in the process, proof of identity of the holder is required, to ensure the confidentiality of personal information.

 

Communication of data by the holder

• The communication of personal data for the purposes of the recruitment process is voluntary. However, the personal data requested by the Egor Group are necessary for the recruitment process(es) to which the holder applied, so the omission or refusal to communicate such data may impede their full continuation and consequently the eventual selection of the application presented, to conclude an employment contract.

Automated decisions

 

• In some Recruitment and Selection processes, Psychological Assessment, Assessments or other services, a psychological assessment of the candidate may be necessary. The assessment consists of carrying out tests aimed at perceiving the candidate’s cognitive and/or behavioral characteristics that are necessary and appropriate for the job position for which the holder has applied, or the nature of the service being provided;
• The tests are carried out using automated means but, under no circumstances, is the decision on the candidate’s behavioral and cognitive suitability made in an automated way;
• The Egor Group guarantees in all cases human involvement in the decision on whether to continue the evaluation process of the professional in question, regardless of the test result;
• Before carrying out any test using automated means, the Egor Group will provide information on the logic behind the test, as well as its importance within the scope of the recruitment process, or others involving psychological assessment, and the expected consequences of such processing for the data subject;
• Carrying out the test constitutes a legitimate interest, except in cases where the Egor Group considers that carrying out the test falls within the scope of pre-contractual measures at the request of the data subject;
• The Egor Group guarantees the holder’s right to object with regard to the definition of profiles, for reasons related to their particular situation;
• In addition to the right to object, the Egor Group guarantees the rights of access, rectification and deletion of data, as well as the right to limit processing;
• In cases where Egor acts as Subcontractor, the controller will provide the information inherent to data processing.

 

3.2. WORKERS

Purpose and legal basis

• Conclusion, execution and administrative management of the employment contract concluded with one of the Egor Group entities;
• Compliance with legal obligations of one of the Egor Group entities, as an employer.

Recipient categories

• Egor Group employees authorized to process personal data;
• Customers or partner entities of the Egor Group, which may be beneficiaries of services provided or companies using temporary work, in whose facilities the holders carry out their functions. The sharing of personal data with these entities is exclusively aimed at identifying you within the structure of these entities or fulfilling legally stipulated legal obligations.
• In specific cases where the provision of work implies or  assumes the sharing of other workers’ data that is processed in the client or partner’s facilities or systems, the latter will be considered responsible for the processing of this data and will ensure all legal obligations inherent to such status;
• Companies subcontracted by the Egor Group that ensure processing that offers guarantees of security and compliance with current legislation regarding the protection of personal data;
• Entities to which the employer is legally obliged to communicate the holder’s personal data, such as courts, the tax authority or police or inspection entities (Authority for Working Conditions and Foreigners and Borders Service);
• Entities to whom,  to fulfil legal obligations, the employer communicates the holder’s personal data, such as for the purposes of contracting occupational medicine services and insurance companies,  to guarantee the conclusion of a contract of occupational accident insurance.

Transfers of personal data to countries outside the European Union or the European Economic Area

 

Professional data may be transferred to countries that are not Member States of the European Union or the European Economic Area, with the data subject being duly informed if this occurs.

 

Conservation period

• Candidates’ personal data will be kept for a maximum period of 10 years, which is based on the obligation set out in Article 123, no. 4 of the Corporate Income Tax Code, which provides that books, accounting records and respective supporting documents must be kept in good order for a period of 10 years;
• If the holder requests the deletion of their data before the 10-year period has elapsed or if they are necessary within the scope of a legal process, the limitation of processing is guaranteed, and deletion will occur once the legal period for retaining the data has been completed. same or after the deadline for transiting the court decision.

Rights of data subjects

• See point 3.1. of this Privacy Policy, in the section Rights of data subjects

Communication of data by the holder

 

• The communication of personal data is necessary for the employment contract, as the holder’s personal data are essential to its conclusion, execution and management, as well as to the fulfillment of legal obligations arising therefrom on the part of the employer. Consequently, the omission or refusal to communicate such data will prevent the conclusion of an employment contract.

Automated decisions

• Within the scope of the employment contract, no decision based on personal data provided by the holder is automated.

3.3. TRAINEES

Purpose and legal basis

• Conclusion, execution and administrative management of the training contract signed with one of the Egor Group entities;
• Training of human resources on a subcontracted basis, as a training entity certified by the Directorate-General for Employment and Labor Relations (DGERT) which has legal obligations.

Recipient categories

• Egor Group employees authorized to process personal data;
• General Directorate of Employment and Labor Relations (DGERT), as the public entity responsible for certifying training entities;
• Customers or partner entities of the Egor Group: the sharing of personal data with these entities aims exclusively to identify the holders for training and evaluation purposes;
• Companies or trainers subcontracted by the Egor Group who ensure processing that offers guarantees of security and compliance with current legislation on the protection of personal data.

Transfers of personal data to countries outside the European Union or the European Economic Area

• Trainee data will not be transferred to countries that are not Member States of the European Union or the European Economic Area.

Conservation period

• The personal data of Trainees will be kept for the period necessary to allow audits to be carried out by DGERT;
• If the holder requests the deletion of their data before this period has elapsed or if they are necessary within the scope of a legal process, the limitation of processing is guaranteed, and deletion will occur once the legal period has been met during which it is still possible to carry out audits by the competent public entity (DGERT).

 

Rights of data subjects

• See point 3.1. of this Privacy Policy, in the section Rights of data subjects

 

Communication of data by the holder

• The communication of personal data is necessary for the training contract, as the holder’s personal data are essential to its conclusion, execution and management, as well as to the fulfillment of legal obligations to which the certified entity is subject, so the omission or refusal to communicate that data will prevent the conclusion of a training contract.

 

Automated decisions

• Within the scope of the provision of Training services, no decision based on personal data provided by the holder is automated.

• In any of the situations provided for in point 2 of the Privacy Policy, the Egor Group undertakes to protect personal data if obtained through an intermediary or through a source other than the holder of the personal data;
• In cases where the holder’s personal information is not collected from the holder, the holder will have the right to information about the origin of the data, including when they come from sources accessible to the public, as well as about the categories of data collected;
• The Egor Group collects personal information from public online platforms when these platforms are intended to publish the candidate’s professional information for recruitment purposes or it is reasonable to assume from the information entered by the candidate that the candidate may be interested in professional opportunities so that any contact by one of the Egor Group employees fits with the holders’ expectations regarding the purpose of collecting their personal information;
• When personal data is collected from sources accessible to the public, such as online platforms, Egor Group entities only collect information relating to the identification (name), contacts (telephone or email) and academic training or professional experience of the holder, so that, in case of compatibility of the information contained on the public platform with a professional opportunity, contact with the holder is relevant;
• At the time of the first communication with the holder, he or she will have access to information about the processing of his or her data or, if this is not possible, within a reasonable period of time, but never longer than one month after the personal data was collected;
• The information contained in this point must be complemented with the information contained in point 3 of this Privacy Policy, depending on the purpose of the processing in question that is applicable.

The Egor Group has implemented automatic technical preservation, deletion and control mechanisms, as well as the daily generation of backup copies and retention of information on external servers that guarantee security, as well as minimizing the use and conservation of personal data for the purpose for which they are intended.

 

It has also implemented administrative and organizational measures, so that its employees or subcontracted entities process personal data in such a way that the principles of data processing are respected, such as lawfulness, purpose limitation and conservation, minimization, integrity, confidentiality and accuracy of data.

 

The Egor Group is guided by strict compliance with its Ethical Code, which includes appropriate practices to achieve the values pursued by the Group.

 

As such, it implemented an Acceptable Use Policy, which aims to apply and implement the Ethical Code in force at the company and ensure full knowledge of current good practices by all human resources authorized to access and process personal data.

 

All Egor Group human resources are bound by confidentiality obligations and are instructed to adopt a preventive attitude concerning personal data that they become aware of as a result of carrying out their duties.

 

To comply with the principle of accuracy, the Egor Group assumes that the personal data provided by the holder is true and accurate, committing to promote the respective amendment or rectification when the holder requests it.

If you have any questions, concerns or suggestions regarding this Privacy Policy, please contact the Egor Group or the Group’s Data Protection Officer.

 

In-person or by post to the address:

Egor Group

A/C Data Protection Officer

Edifício Europa

Av. José Malhoa, 16F – 4th Floor | 1070-159 Lisbon

 

Electronically

To the email address of the Data Controller

Data Protection: privacy@egor.pt