Privacy notice for job applicants
The current notification contains information regarding the collection, retention and processing of personal data of job applicants at Gugushev & Partners Law Office (hereinafter “Gugushev & Partners” or GPLO). Additionally, the notification contains information about your rights in relation to your personal data processing, as well as the legal order to lodge a complaint if you consider that your data is processed unduly.
Who bears responsibility for your data processing?
Responsibility for your personal data processing bares Gugushev & Partners Law Office, a law office registered under the Bulgarian Bar Act (bulg. Закон за адвокатурата) under Company file No. 813 of 2010 at the Sofia City Court, BULSTAT: 176026301, VAT reg. number: BG 176026301, with seat and address of management at No. 130 Georgi Sava Rakovski Str., floor 2, ap. 4, Sofia City Province, Republic of Bulgaria and mailing address at Sofia 1000, Aksakov 11A str., floor 5, office 3, web page: https://www.gugushev.com.
In case you request more information, regarding your personal data processing or if you wish to exercise any of your rights as well as if you suspect that your data is used unduly, you may send us a letter to our mailing address or via e-mail at office[at]gugushev.com.
What is the purpose and basis for your data collection?
„Gugushev&Partners“ collects and processes your personal data when you apply for a job at GPLO through our web page or through any of our partners' platform – social networks, mediators and recruitment agencies as well as recruitment portals.
We use the obtained data to review, recruit and evaluate your applications in order to get in touch, organize and conduct the next stages of the interview with the approved by documents candidates as well as to contact you for the next selection stage for the position you are interested in. During the interview, we may collect data through the video footage in our offices for security purposes.
The legal basis for the processing of your personal data is initiating steps for concluding a contract with you as future employee and consultant in GPLO as well as the legal interests of “Gugushev&Partners” in recruitment and protection of its employees and property (it is applicable also with regards to the security activities on the territory of GPLO offices, connected with personal data processing). Without collecting personal data as described above, “Gugushev & Partners” wouldn’t be able to recruit and sign a contract with the approved candidate.
How long do we retain the collected data?
Personal data of people applying for a job in “Gugushev&Partners”, included in the provided documents are retained on this basis for a period of 6 months after the conclusion of the relevant procedure for recruitment of personnel and afterward, all personal data will be deleted unless the candidate agrees that GPLO retains data after this term or in case a specific law requires its retention. This exception is specifically provided by law in the sphere of protection against discrimination in accordance with which GPLO will retain internal documents from the provided recruitment procedure for a period of 3 years after the procedure.
The personal data of the approved candidates are retained and processed by GPLO based on the labour/civil legal relationship with the entity throughout the whole term of the relevant contract and after its expiry as it is provided by the specific procedures of the labour and insurance legislation. Video footage from GPLO offices are retained for a period of 30 days and is deleted afterwards.
What kind of personal data do we collect?
When you apply for a job in GPLO, we collect the following types of personal data:
- Biographical and contact data - this is information, included in the CV you have sent, including names, permanent and present address, contact data, date of birth, data for work experience and education, completed courses, language proficiency, recommendations and images in case you have provided a photo when applying;
- video, data for professional qualities and competencies, behavioral and language proficiency level – we will obtain and use this information during the interview and assessment and selection of your application after the interview;
GPLO doesn’t aim to collect other types of personal data, especially the so-called special categories of personal data, related to applicants’ personal life.
What kind of measures do we take for the protection of collected data?
In order to guarantee that we process your personal data, observing the requirements of the General Data Protection Regulation, we apply technical and organizational measures to ensure an adequate level of data protection, including policy for data protection and filing of the Regulation procedures, anti-virus, anti-spam and anti-malware protection as well as filters for our computers and systems, firewalls, physical security and video footage of our offices and measures for access control and data protection training for our employees. If you suspect any violation, please contact us immediately.
What rights do you have in relation to your data processing?
In relation to your personal data processing, GPLO guarantees the following rights of the candidates:
- right of access, including confirmation if and what kinds of personal data are processed about the candidate, for what purposes and on what legal basis as well as about the applicable terms for retention and possible categories of recipients of this data;
- right of processing limitation by GPLO when the candidate questions data correctness, when he/she has other legal claims or has an objection;
- right to correct wrong data;
- right to objection against the GPLO’s activities in public interest or in its legal interest, which will be respected if GPLO fails to demonstrate the advantage of these grounds over the interests, rights and freedoms of the candidate, or the need to establish, exercise and defend legal claims;
- the right to delete/the right to request to be “forgotten” in respect of the applicant’s objection or if he withdraws his consent;
- the right to lodge a complaint with the supervisory authority, the Commission for Personal Data Protection, or the competent administrative court through GPLO if you believe that the company has violated your rights or processed your personal data in violation of the legal requirements.
As far as processing according to the current notification doesn’t follow the criteria of art. 19 of the General Data Protection Regulation, GPLO doesn’t ensure data mobility for the ob applicants in the company.
How do we share your data with third parties?
We can share your data with our partners within the recruitment procedures as well as with the competent state authorities with regard to their legal obligations. By all means, your data will not be shared with parties, established outside the member-states of the European Economic Area (EU, Norway, Iceland and Lichtenstein), unless with respect to the relevant country is not issued adequacy decision by the European Commission or is applied another data protection tool.
How can you get in touch with the competent supervisory authority?
If you have any complaints, you may address them to the Commission for Personal Data Protection of the Republic of Bulgaria:
- personally at: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, Bulgaria;
- by letter to: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, Bulgaria;
- by fax – 029153525;
- by e-mail: [email protected];
- through the web page of CPDP: https://www.cpdp.bg/
The current notification is in force from 25th May 2018. The last update is from 15th April 2020.