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Privacy Statement

Who is Brunel?

Brunel International N.V., including its subsidiaries (hereinafter referred to as: "Brunel") is a business services provider specialised in the flexible deployment of knowledge and capacity. 

Brunel takes the careful handling of personal data and data protection when providing its services very seriously. Naturally Brunel complies with the applicable laws and regulations. Brunel is responsible for processing personal data, as described in this privacy statement. This privacy statement applies to current and future candidates, employees, representatives of business relationships and users of the Brunel websites. This privacy statement explains what personal data is, which data Brunel processes, for what purpose and the way in which this is done. It also explains the data subjects’ rights and how to these can be exercised.

What is personal data?

Personal data means all information about an identified or identifiable natural person, such as contact details, curricula vitae ('CV') and online identifiers. Sensitive personal data include, for example, data on racial or ethnic origin, criminal record, religious or philosophical beliefs, trade union membership and information concerning the state of health or sexual behaviour.

Which personal data does Brunel process and for what purpose?

Brunel processes personal data for various purposes. For example, Brunel processes personal data when searching for candidates and within the context of concluding (employment) agreements. Sometimes Brunel is legally obliged to process certain personal data and at other times, Brunel processes personal data based on either its own legitimate interest or the legitimate interest of another party, such as a client. 

In principle, Brunel does not process sensitive personal data, unless this is necessary, e.g. in case it has to process data from medical examinations for specific functions, and if there is a legal basis for Brunel to do so.

This privacy statement concludes with an overview of the processing purposes and the types of personal data to be processed for those purposes.

When does Brunel share personal data?

Sharing within Brunel
Brunel only shares personal data within the Brunel group with employees authorised to access this data. All employees are subject to confidentiality.

Sharing with clients
Brunel shares the personal data of candidates and employees with clients. When proposing candidates and employees to (potential) clients, Brunel uses a Brunel CV compiled by Brunel's employees based on job application data of data subjects. 

Sharing with processors
Brunel uses processors that process personal data for Brunel. Brunel concludes processing agreements with all processors of personal data. Brunel assesses the security measures and compliance with the privacy regulations in advance and monitors this as well as compliance with concluded processing arrangements on a regular basis. 

Sharing with other responsible parties
Brunel works with external parties that offer services, whereby personal data can be exchanged. These are, for example, parties carrying out screening, providing training or booking flights and/or hotels. Brunel makes arrangements with these parties with regard to the careful handling of personal data. 

Brunel only discloses personal data at the request of the police and the authorities if there is a legal obligation to do so.

Does Brunel transfer personal data outside the European Economic Area (EEA)?

Yes. Brunel has an Inter Group Agreement in place for the transfer of personal data to its subsidiaries located in countries outside the European Economic Area (EEA).

If Brunel transfers personal data to external parties outside the EEA where an adequate level of protection is absent, Brunel will continue to monitor the processing of personal data. Brunel uses legal transfer mechanisms to ensure that the personal data is sufficiently protected. Examples of these include the use of EU Standard Contracts or contracting with parties certified under the EU-US Privacy Shield.

How long does Brunel retain personal data?

Brunel does not retain personal data for longer than is necessary for the fulfilment of its purposes. In some cases, Brunel is obliged to retain personal data for a longer period of time, for example because of tax obligations. After expiration of the retention period, or following successful deletion requests from data subjects, Brunel deletes the personal data from its systems. 

For the two situations below Brunel applies the following retention periods:

  • Recruitment via external sources: up to 28 days after candidates have been found by Brunel, Brunel will contact the candidates to express its interest in them;
  • Personal data of candidates who do not currently work for and have not worked in the past for Brunel, but who have expressed their interest in Brunel: 2 years after the entry date of the personal data in Brunel's record-keeping system.

What rights do data subjects have?

Brunel respects the rights of data subjects with regard to their personal data. Some rights can be exercised at all times; other rights can be exercised under certain conditions only.
For example, Brunel cannot grant the request of a data subject to delete its personal data if there is a legal obligation to retain that personal data for a certain period of time. 

Data subjects can exercise the following rights:

  • Withdrawal of consent given for processing personal data;
  • Access to personal data;
  • Correction of inaccurate personal data;
  • Deletion of personal data if Brunel no longer needs it;
  • Objection to the processing of personal data on the basis of a legitimate interest of Brunel or another controller, if data subjects have major interests
    for making such an objection;
  • Restriction on the processing of personal data in cases determined by law;
  • Data transfer of own personal data provided to Brunel in cases determined by law;
  • Lodging complaint with the national supervisory authority about the processing of personal data by Brunel to the.

The aforementioned rights can only be exercised in respect of the personal data of the data subject. Data subjects are not allowed to exercise these rights in respect of the personal data of others. Brunel may request data subjects to provide additional identification in this regard.

Some of the aforementioned rights can be exercised by the data subjects via My Brunel  Data subjects can also contact Brunel's Data Protection Officer ('DPO') via dpo@brunel.net or via +31 20 312 50 00. Further the DPO can be contacted with regard to complaints about the processing of personal data.

How does Brunel protect personal data?

Brunel takes appropriate technical and organisational measures to protect the privacy of the data subjects and the confidentiality of their personal data. 

Brunel's infrastructure is constantly monitored. Threats or attacks can be detected at an early stage and action can then be taken. Brunel has policies and procedures in place for the timely reporting of data breaches. In addition, Brunel's infrastructure is scanned for viruses, malicious software and break-in attempts. Brunel arranges for regular checks on its infrastructure and security processes by independent auditors. Brunel sends personal data via a secure internet connection (TLS), identified by "https" and the padlock symbol in the browser's address bar. 

Brunel has also safeguarded within its systems that not everyone within the organisation has access to personal data. Access is restricted to Brunel employees for whom the processing of personal data is necessary in the performance of their duties.

Data subjects can contribute to the protection of their personal data by, for example:

  • securing the My Brunel account with a strong password;
  • entering any changes in personal data in My Brunel themselves. Data subjects may also contact Brunel for this;
  • being careful when disclosing personal data if the data subject responds to jobs and messages posted on social media by Brunel. The information that is posted there may be public.

What are cookies and other similar technical data?

A cookie is a small file that is stored on the data subject's computer. These cookies can be recognised during subsequent visits to the website. Read more about this in Brunel's cookie policy. Apart from cookies, Brunel uses other technical data on its websites, such as web statistics to register the use of its websites and visitor's behaviour. This helps Brunel to optimise its services.

How to contact Brunel?

If you have any questions about this privacy statement, please contact the Brunel head office in Amsterdam using the following contact details:

Brunel International N.V.
John M. Keynesplein 33
1066 EP Amsterdam
The Netherlands 
+31 20 312 50 00

Brunel's Data Protection Officer can be reached on telephone number +31 20 312 5000 or via email: dpo@brunel.net.

Notification of a (possible) security breach

In the event of a (possible) breach of personal data security, data subjects are requested to inform Brunel as soon as possible via dpo@brunel.net stating 'Dataleak' in the email's subject line.

Amendments to the Privacy Statement

Brunel is entitled to amend this privacy statement. Changes will be published in a pop-up on the website. 

This privacy statement was last updated on 12 April 2018.

Overview of the purposes of processing and and types of personal data processed

Using Brunel's website(s)

Purpose of processing:

  • To respond online to vacancies;
  • To create a job alert; 
  • To improve the services that Brunel provides.

Personal data processed:

  • Responding online: first name, surname, email address;
  • Job alerts: email address, search criteria for the desired vacancy;
  • Improving the services: cookies and similar technical data that are strictly necessary and/or voluntarily agreed to, as described in the cookie policy; 
  • Personal data voluntarily provided by data subjects on Brunel’s social media, such as comments to posts and advertisements and private messages via the social media platform.

In the context of recruitment

Purpose of processing:

  • To provide training sessions, exhibitions and in-house days;
  • To assess CVs or professional social media profiles at the request of data subjects; 
  • To search for and approach potential candidates at Brunel's initiative.

Personal data processed:

  • Providing training sessions, exhibitions and in-house days: first name, surname, email address, CV;
  • Assessing of CVs, profile; 
  • Searching for and approaching: contact details, link to social media profile and messages that are sent to Brunel.

Social media and job boards

Purpose of processing:

  • To generate interest in Brunel;
  • To enable data subjects to respond online; 
  • To respond to questions from data subjects.

Personal data processed:

  • Online response: contact details, vacancies and comments of the data subjects; 
  • Brunel's response to questions from data subjects: contact details and vacancy/comments from data subjects.

Events and newsletters

Purpose of processing:

  • To organise events and activities to encourage the involvement in Brunel of candidates, employees, representatives of business relationships and users of the websites of Brunel;
  • To exchange knowledge and interesting topics with data subjects.

Personal data processed:

  • To organise events and activities: contact details, interests, personal data necessary for providing transport and dietary requirements;
  • Newsletters: email address.

For the My Brunel account

Purpose of processing:

  • To create a My Brunel account; 
  • To allow data subjects to respond to vacancies via My Brunel;
  • To record the progress of the application procedure;
  • To record the application history of the data subject;
  • To enable the My Brunel helpdesk to respond to questions from data subjects.

Personal data processed:

  • My Brunel account: first name, surname, and email address;
  • My Brunel profile: social media profile, CV, cover letter, preferred start date and other personal data;
  • Responding via My Brunel: first name, surname, email address, cover letter, CV, diplomas and certificates and references;
  • Recording the progress of the application procedure: first name, surname, email address, telephone number, and the vacancies to which the data subjects responded;
  • Recording the application history of the data subjects: name of the vacancy, date and the data that the data subject has provided for that application; 
  • Questions via My Brunel helpdesk: contact details and subject of the question.

Applications to Brunel

Purpose of processing:

  • To assess the suitability and availability of a candidate for a vacancy;
  • To create and share a data subject's CV with clients on the basis of the Brunel format; 
  • To select candidates for vacancies available with Brunel and its clients; 
  • To create digital files of data subjects; 
  • To ensure the satisfaction of data subjects with the application procedures by means of satisfaction surveys;
  • To be able to carry out pre-employment screening; 
  • To be able to carry out pre-employment assessments.

Personal data processed:

  • Personal data: first name, surname, date of birth, gender, nationality;
  • Contact details: address, email address, telephone number;
  • Education and skills: education, training courses, diplomas, certificates, marks, expertise, language skills, membership of professional associations;
  • Work history: previous and current employers, functions and experience;
  • Social media information: link to social media profiles of the data subjects;
  • Application details: CV, cover letter, vacancy, preferred number of hours, transport preferences, possession of a driving licence;
  • Additional person data provided to Brunel by the data subjects, such as a photograph;
  • Notes from Brunel employees;
  • Assessment of the suitability and availability: education, experience, function and budget-related criteria;
  • For creating and sharing a data subject's CV with clients on the basis of the Brunel CV  format: first name, surname, date of birth, place of residence, gender, nationality, profile, relevant training and courses, work experience, languages and software knowledge; 
  • Selection of candidates: education, experience, skills, references, function and budget-related criteria;
  • Digital file: CVs and other documents, such as diplomas, certificates, results of any aptitude tests, interview and/or meeting notes, notes and progress report of applications/mediation; 
  • Satisfaction survey: mobile phone number and/or email address;
  • Pre-employment screenings: relevant diplomas, references from previous employer(s), declarations of integrity, certificates of good conduct, outside activities, statements private investments, credit checks and (bankers) oaths or vows; 
  • Pre-employment assessment: contact details of the data subject, assessment report.

In the context of employment agreements or contracts for services

Purpose of processing:

  • To register personal data required for compliance with laws and regulations; 
  • To perform employment contracts; 
  • To be able to facilitate working in country or abroad.

Personal data processed:

  • To create a personnel file: personal data that needs to be processed on the basis of, for example, labour legislation, and tax and social security legislation, such as a copy of identity documents or passports, visas, work permits, citizen service numbers and documents necessary for Brunel's administration such as contact details and diplomas;
  • Employment screening data: certificates of good conduct, references, declarations of integrity and confidentiality, secondary functions, credit checks, (bankers) oaths or vows and certifications;
  • Employment test data: contact details, assessment reports;
  • Financial information: bank account numbers, salary, rates of independent entrepreneurs;
  • Other information related to preparing the personnel, salary and absenteeism records, such as availability, registration number of the company car; 
  • Working in country or abroad : personal data necessary, for example, for providing transport, work permits and visas, taxes, housing and education and civil service numbers.

With regard to other internal purposes

Purpose of processing:
  • To achieve and maintain quality standards and certifications;
  • To apply for government grants, premium discounts, etc.;
  • To generate management information;
  • To provide internal controls; 
  • To ensure operational safety; 
  • To enable audits to take place.

Personal data processed:

  • With respect to the processing of personal data for these other internal purposes of Brunel, the starting point is that the use of directly identifiable information is limited to the minimum.

Use of helpdesk and webcare

Purpose of processing:

  • To answer questions from data subjects; 
  • To refer data subjects to other departments or partners of Brunel.

Personal data processed:

  • Helpdesk: contact details and subject of the question;
  • Webcare: contact details and subject of the question.

Use of contact forms for potential clients

Purpose of processing:

  • To acquire new clients;
  • To gain insight into the demand for labour in the market;
  • To be able to offer new services to clients; 
  • To make offers and/or to provide information about Brunel's services and other activities.

Personal data processed:

  • Acquisition: contact details of representatives of new clients, information about the sector in which the client operates, open vacancies and preferred profiles;
  • Insight in the demand for labour: information about the relevant sector, nature of outstanding vacancies and preferred profiles;
  • Offering services: contact details of representatives of potential clients, information about the sector in which the client operates; 
  • Offering/providing information about services: contact details of representatives of potential new clients, information about the sector in which clients operate.

Establishing and maintaining business relationships with suppliers

Purpose of processing:

  • To conclude and implement agreements and/or to have them implemented; 
  • To receive offers and information about the services of suppliers.

Personal data processed:

  • Concluding and implementing agreements: contact details of representatives of business relationships: name, email address and telephone number;
  • Receiving offers and information: contact details of representatives of business relationships: name, email address, telephone number.