Pan Resource (referred to as “we”, “our” or “Pan Resource” in this policy) is a privately owned company that provides outsourcing and recruitment services, registered at the Commercial Register at the Registry Agency of Bulgaria with UIC 203148383, registered seat: No.1 Rilska Street,Burgas, and address of management:32 Hristo Botev Street, Burgas, Bulgaria. Pan Resource is 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. 2409/ 06.12.2017 issued by the Employment Agency.
- Basis of Processing Data
- How do we collect your Personal Data
- What Personal Data we collect
- How we process Personal Data
- Sharing of Personal Data
- Consequences of not providing your data
- Your Data Protection Rights
- Data Retention
- Security Measures
- How to Contact Us
Basis of Processing Data
The main grounds used by Pan Resource to process personal data are as follows:
If we have a contract with a Candidate or Client, we will process personal data in order to fulfil the requirements of the contract, or to undertake set up requirements prior to entering into the contract.
Consent may be collected when a Candidate applies to a position advertised through Pan Resource, or when a candidate submits personal data through the Pan Resource website. Where we are unable to collect consent for a particular processing activity we will only process personal data if we have another lawful ground.
How do we collect your Personal Data
Personal data means any information relating to you which allows us to identify you, such as your name, address and contact details.
Pan Resource processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We will never collect any unnecessary personal data from you and do not process your information in any way, other than as specified in this notice.
We have a large variety of sources of Candidate data. We will only ever source data that is necessary to provide services to you and in a way that would be generally expected.
We receive personal data about Candidates from a variety of sources. The primary source is from our Candidates directly. Examples of the sources of personal data of Candidates are as follows:
- the Candidate may send their CV to us with the intention of registering with us to be informed of potential job vacancies;
- the Candidate may apply directly to a position advertised through Pan Resource;
- the Candidate may apply to a position advertised on a third party jobs website;
- the Candidate may be sourced from third party CV providers such as jobs websites who provide CV search facilities and where users have made their CV data available to registered customers of these sites;
- we receive Candidate information when the Candidate interacts with our communications e.g. websites and advertisements;
- we may receive personal data about a Candidate from nominated referees of the Candidate or from other Associated Contacts of the Candidate;
What Personal Data we collect
The personal data that we collect from you may include: –
- Age / date of birth
- Contact details – email, telephone number and address
- Sex / gender
- A copy of your CV / employment history
- Education details / qualifications
- Interview notes
- Right to work documents
- Referee and reference details
- Details of driving license / passport / identity card
- Details of any criminal convictions
- Medical Certificate from your GP, where such is required
- Emergency contact details
- Salary and additional benefits information
- Placement details
- Positions you have previously applied for
- Results from any interview related assessments
- Information on interests and needs regarding future employment, from both written and verbal communication
- Extra information that candidates choose to furnish
- Additional information from referees provided by you
- The dates, times and frequency with which candidates use our services e.g. CV submittal, email exchanges and verbal communication
How we process Personal Data
Our business is to assist and advise Candidates in their search for job opportunities. In providing our services, we may use personal data for the following purposes (we will only ever use the personal data as described here if we have a legal basis for doing so):
- to keep in contact with Candidates, to inform, update and discuss new relevant job opportunities and any subsequent progression through the job search process, for example about interviews, job offers, onboarding, and in the case of contract workers, the timesheet and payment processes;
- to keep up to date information about the Candidate in relation to their job search process and their requirements, in order to assess their suitability for current or future vacancies for example based on their previous skills and experience overall, their own statements about career aspirations, professional development, strengths and weaknesses, their level of managerial experience, professional qualifications;
- to contact referees as part of the recruitment process for permanent roles or as part of the screening process for contract roles;
- to understand the profile of organisations in which Candidates are currently / previously employed;
- to create a record/file for the Candidate on our internal systems to associate all notes and tracking throughout the job search, interview, placement, onboarding and contracting process;
- to understand current and expected salary, notice period and available, current and required locations in order to enhance and impact the success of the matching process and ensure the Candidate is provided with the most relevant opportunities;
- to develop the relationship between Pan Resource and the Candidate and ensure a more personalised service;
- to meet the requirements of the Client application process including checks relating to criminal record, work history, etc.
- to verify the information provided by Candidates using evaluations and tests (including functional capability and psychometric testing) at the request of the Client;
- to retain evidential proof of the identity of the Candidate;
- to share Candidate information with Clients.
- to carry out our obligations under Client contracts;
- to enable Candidates to participate in our career development services
- to tailor our products and services to better identify the right Candidates and present the right opportunities at the right time and meet Candidate and Client needs more effectively;
- to undertake profiling for the purposes of semi-automated or manual decision making about Candidates.
Our business is to find the right Candidates for our Clients and also the right Clients for our Candidates. We use Client Contact personal data as part of that business for the following purposes:
- to keep in contact with Client Contacts to discuss and review their hiring needs and requirements;
- to inform, update and discuss Candidates that might be of interest to the Client;
- to organise and schedule interviews with Candidates;
- to inform the Client about progression of a Candidate through the recruitment process, to discuss the placement and on-boarding of a Candidate, and communication relating to the payment process;
- to discuss any reference or other pre-screening information provided for a Candidate;
- to understand the type of Candidates required by the Client, and build up knowledge and understanding of the Client organisation and its structure;
- to create a record/file for the Client on our internal systems to associate all notes and tracking throughout the job search, interview, placement, on-boarding and contracting process;
- to develop the relationship between Pan Resource and the Client and ensure a more personalised service;
- to send Client Contact information to Candidates in relation to the interview and on-boarding process; and
- to carry out our obligations under our contract with the Client.
Sharing of Personal Data
Primarily we will share your information with your explicit consent to prospective employers. We will only make your personal information visible to companies we are working with when you are put forward for an opportunity or where required for the fulfilment and ongoing management of a contract where we have placed or hired you.
Pan Resource will only share necessary personal data with a third party in order to provide our service to you as requested. We share certain aspects of your personal data with our IT service providers, including our CRM provider, our cloud storage provider and email server provider. These providers are not permitted to use this data, except on our behalf, and all personal data is held inside of the EU.
Consequences of not providing your data
You are not obligated to provide your personal information to Pan Resource, however, as this information is required for us to provide you with our services, we will not be able to offer some/all our services without it.
Your Data Protection Rights
You have the following rights under the GDPR, in certain circumstances and subject to certain exclusions, in relation to your personal data:
• Right to access – you have the right to request a copy of the personal data that we hold about you, together with other information about our processing of that personal data.
• Right to rectification– you have the right to request that any inaccurate data that is held about you is corrected, or if we have incomplete information you may request that we update the information such that it is complete. This can be done via the contact details listed below.
• Right to erasure – you have the right to request us to delete personal data that we hold about you (the ‘right to be forgotten’). Data subjects have the right to request erasure of their personal data where Pan Resource does not have a legitimate reason for retaining such data. Where Pan Resource receives a request for erasure from a data subject, then Pan Resource will assess all personal data held on the data subject. All personal data deemed as not held for a legitimate purpose will be deleted/destroyed in line with the Pan Resource retention policy. If you ask us to erase certain personal data and we are unable to do so, we will explain why not.
• Right to restrict or object to processing – you have the right to request that we no longer process your personal data for particular purposes, or to object to our processing of your personal data for particular purposes. Where we store your information because it is necessary for our legitimate business interests we will stop storing your information unless we can demonstrate why we believe we have a legitimate business interest which overrides your interests, rights and freedoms.
• Right to data portability – you have the right to request us to provide you, or a third party, with a copy of your personal data in a structured, commonly used machine readable format. This request may be for all personal data of that data subject held by Pan Resource or a subset of the data. We will respond to the request within 1 month, unless we can show that the request is manifestly unfounded or excessive. Please note that this right can only be exercised in certain circumstances and, if you ask us to transmit your information and we are unable to do so, we will explain why not.
• Right to withdraw consent – if we are processing personal data based on your consent, you may withdraw that consent at any time.
In order to exercise any of the rights set out above, or if you have questions or concerns about how we process your data, please contact us at email@example.com or by post at 32 “Hristo Botev” Street, Burgas 8000, Bulgaria. You also have the right to lodge a complaint with the Commission for Personal Data Protection, whose contact details are as follows:
- Commission for Personal Data Protection, 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592
- Telephone: +3592/91-53-518
- Website: www.cpdp.bg
- Email: firstname.lastname@example.org
Pan Resource only ever retains personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations.
We will keep your details on file for a period of 5 years before seeking confirmation that you are happy for us to continue to hold your data. After which time your data will be deleted from our systems unless we have had meaningful contact to say otherwise or if a law or other regulation requires us to preserve it. Examples of the activities that we would consider evidence of our ongoing engagement with a Candidate and thus a reason to continue holding their data include:
- the Candidate meeting one of our consultants, to register for new opportunities, or for example to update on their situation and seek career advice or some other professional input;
- us sending a Candidate’s CV to a Client for consideration for a role;
- us arranging an interview between the Candidate and a Client;
- us exchanging email correspondence or having telephone conversations with the Candidate;
- the Candidate interacting with us in other ways for example, clicking to open our market insights, newsletters, surveys etc.
We only retain Client Contact personal data for as long as it is needed for the purpose for which it was collected. After that it is deleted from our systems.
Pan Resource takes your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal data. We have put in place appropriate technical and organisational procedures to safeguard and secure the personal data that we receive.
Examples of practical technical security measures to aid GDPR compliance at our firm include:
- Ensuring that IT security is properly managed and overseen by an appropriate person in the firm with adequate support from IT professionals;
- Adequate Access Control is employed, including identity and access management;
- Appropriate IT education to staff is undertaken. This includes demonstration examples of unauthorised data access and malware;
- Employees and other users are required to change passwords on a regular basis;
- ensuring that all computing devices such as PCs and mobile phones are using an up-to-date operating system;
- ensuring all computing devices are regularly updated with manufacturer’s software and security patches;
- using antivirus software on all devices;
- implementing a strong firewall;
- ensuring that data is collected & stored securely
Examples of practical physical security measures employed at Pan Resource include:
- keeping offices and storage units locked and only accessible by authorised personnel;
- implementing clean desk policies;
To protect the privacy and security of personal data, we will also take reasonable steps to verify your identity before granting access to and discussing information as appropriate. Specifically we will only deal with the named individual in relation to their personal data and verify their identity by requesting a combination of their personal information as per their CV that we have on file for that individual.
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How to Contact Us
You can contact Pan Resource by any of the following means: