Privacy policy
Adera Executive Search OÜ (hereinafter referred to as Adera Executive Search, we or us) values the privacy and data protection rights of our clients and candidates (hereinafter referred to as You). This Privacy Notice explains how we collect and use your personal information and what we do to ensure that your personal information is protected. The purpose of this Privacy Notice is to help you understand why and how we process your personal data and what your rights are in relation to your personal data.
This Privacy Notice applies to you if you are using our services as a job seeker or to obtain career or personal advice, if you are a company looking for employees, if you send us an email or web enquiry, or if you use our or our company’s website www.aderaexecutive.com.
1. Definitions
Personal data – any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification code, location data, a network identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Processing of personal data – any operation or set of operations which is performed upon personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation and alteration, retrieval, consultation, use, disclosure, alignment or combination, restriction, erasure or destruction, by transmission, dissemination or otherwise making available.
Controller – means the natural or legal person who is the primary collector of personal data. The controller determines the purposes and means of the processing of personal data.
Processor – means a natural or legal person who processes personal data on behalf of and under the instructions of a controller.
Third party – a natural or legal person, public or local authority, agency or body;
Personal data breach – means a breach of requirements leading to the accidental or unlawful destruction, loss, alteration or unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.
Client – a company seeking to recruit, to carry out assessments of the suitability (competences, personality and abilities) of its employees in order to promote teamwork or employee development.
Client Employee – is a person working in the Client’s company.
Candidate – is an individual who is looking for a new job, who Adera Executive Search wishes to involve in a confidential search process to fill a vacancy, or who wishes to seek advice from Adera on self or career development.
2. Data controller
Adera Executive Search is the controller or processor of personal data in various processing operations. In order to ensure that your privacy rights are protected, Adera Executive Search adheres to the principles of confidentiality of personal data and discloses personal data only to a strictly limited extent.
Adera Executive Search OÜ
Asula 1B-51
Tallinn 11312
Email: adera@aderaexecutive.com
The Client is the controller of the personal data, including the Candidate’s personal data, which is transferred to the Client, being by its nature the co-responsible controller and is responsible for any misuse of the data.
3. What type of personal data we process
Personal data – first name and surname, personal identification number, date of birth, photo.
Contact details – telephone number, e-mail address, home address
Profile details – your current and previous work experience and education, skills, abilities and also the results of psychometric tests, if you have taken them. Background checks and references from former employers/colleagues/superiors are also part of your profile.
Client Employee Information – Client and Adera Executive Search consultant evaluations of Client employees and psychometric test results.
Psychometric data – results of personality and aptitude tests, assessments of Candidates and Client employees by Adera Executive Search consultants.
Client Data – personal or contact details of company representatives, such as the Board of Directors or the Supervisory Board.
4. For what purposes and on what legal basis do we process your personal data?
Adera Executive Search processes personal data for the purpose of performing and ensuring performance of a contract entered into, for compliance with a legal obligation, for legitimate interest or on the basis of the data subject’s consent.
4.1. Processing of data for the performance of a contractual obligation
We process personal data for the performance and fulfilment of a contract if we are committed to the result set out in the contract, to which the rights and obligations of the contracting parties are also linked, and this cannot be achieved by avoiding the processing of personal data.
Purpose of processing – Categories of personal data
Billing (billing, invoicing and collection of payments) – Personal data, contact data
4.2. Processing of data to fulfil a legal obligation
The processing of personal data for the fulfilment of legal obligations is carried out where Adera Executive Search is obliged to process personal data because it is required to do so by applicable law, such as the Employment Contracts Act or the Accounting Act.
Purpose of processing – Categories of personal data
Accounting (including storage of accounting records) – Personal data, contact data
Responding to requests for information from public authorities and public bodies – Personal data, contact data.
4.3. Processing of data on the basis of the legitimate interest of Adera Executive Search
Legitimate interest as a lawful basis for the processing of personal data means that, in particular for the purpose of providing a higher quality service and for the promotion of our business, we process the personal data of the data subject on the basis of our own commercial interest, bearing in mind the fundamental rights and freedoms of the data subject. When processing personal data on the basis of legitimate interests, it is important to ensure a balance between the legitimate interests pursued by Adera Executive Search and the privacy rights of the data subject. In order to establish a legitimate interest, Adera Executive Search undergoes a three-step test: an interest test or purpose test, a necessity test and a balancing test.
Purpose of processing – Categories of personal data
Adera Executive Search intra-group data exchanges – Personal data, contact data
Marketing activities – Personal data, contact data
Customer relationship management, development (responding to enquiries, general customer service, information exchange) – Personal data, contact data, service data.
4.4 Consent-based data processing
In the case of consent-based processing of personal data, we will only process personal data with your consent for the specific purposes for which you have given your consent.
We also collect references from your former employers, colleagues and subordinates with your explicit consent. We will never contact any referrer whom you have not consented to be contacted.
We will also send details of suitable vacancies with your consent.
Adera Executive Search only conducts personality and aptitude tests with your consent.
Purpose of processing – Categories of personal data
Profiling – Personal data, contact data, profile and psychometric data.
Transfer of your data to the vacancy – Personal data, contact data, profile and psychometric data.
Recommendations – Contact details
Psychometric tests – Personal details, contact details, profile and psychometric data
You have the right to withdraw the consent you have given at any time, if you wish to do so, please contact us at adera@aderaexecutive.com and we will delete the data we process on the basis of your consent.
5. Who else processes your data besides us
Adera Executive Search will have access to your personal data for the employees who work with candidates and the Client’s employees involved in the recruitment project. From time to time we may, with your consent, transfer data to other companies in our group, a list of which can be found on the Adera Executive Search website.
Outside Adera Executive Search:
- We will, with Your consent, transfer data to a Client;
- We will send you a link to a personality and aptitude test. We will provide you with: (i) a link to the Adera Search Agency; (ii) provide you with the information you need to provide us with a personal assessment of your personal data; (iii) provide you with a contact details of the Adera Search Agency;
- (this list is not exhaustive and from time to time we may outsource services in new areas): IT management and maintenance service provider, email server service provider, website administrator, auditor, lawyers;
- where we have a legal obligation to do so, we will transfer your data to public authorities and government bodies (e.g. police, courts, alarm centre, Data Protection Inspectorate).
We have data processing and protection agreements with Clients, personality and ability test providers and service providers. The contracts oblige the service provider to:
– take appropriate measures to protect the confidentiality and security of personal data; and
– process personal data in accordance with the requirements of the applicable legislation.
6. How long we keep your data
We will retain your personal information for as long as we are required to do so by law or as necessary to fulfil the purposes described in this Privacy Notice. Below are some examples of data retention periods:
Retention period – Examples
For example, we will set out the following periods of time for which we will keep your personal data – until you withdraw your consent – for data that you have given your consent to be processed (e.g. contact details).
7 years – For accounting records (e.g. invoices).
3 years (from the expiry or termination of the contract) – We retain profile data to protect ourselves in the event of a dispute or to assert a claim to defend our rights.
7. Security of your personal data
Adera Executive Search has put in place the necessary organisational, physical and technical security measures to protect your personal data. Here are some examples of the measures we use:
Physical measures – paper documents containing personal data are stored in locked rooms and cabinets, IT systems are adequately protected against fire, overheating, water, power outages and power failures.
Technical measures – all workstations are protected by screen locks; particularly vulnerable systems (e.g. laptops, smartphones) are protected using, for example, encryption or other means.
Organisational measures – roles and profiles are assigned to all users of IT systems; access rights are ensured to be revoked when an employee leaves Adera Executive Search; no unauthorised access to rooms used for the processing of personal data is allowed from public areas.
8. Your rights regarding personal data
8.1 You have the right to be informed about the processing of your personal data. To obtain information about the processing of personal data, please submit a written request by e-mail to the e-mail address below.
It is our responsibility to ensure that you are entitled to receive the relevant data. Therefore, when making a request, we will require you to prove your identity or your right to request the data.
8.2 You have the right to have personal data erased if we do not process the data to comply with a legal or contractual obligation.
8.3 You have the right to request the restriction of the processing of personal data and to object to the necessity of the processing.
8.4 You have the right to receive personal data in machine-readable form with you or to transfer it to another responsible employee, where technologically feasible.
If you wish to exercise any of the above rights, please contact us at adera@aderaexecutive.com.
9. Right to lodge a complaint with the Data Protection Inspectorate
If you are of the opinion that the processing of personal data concerning you infringes your privacy rights, you have the right to turn to the Data Protection Inspectorate or to a court to protect your rights and interests..
10. Cookies
A cookie is a small text file that is automatically saved by a web browser on the device a person is using and then stored on your computer’s hard drive. Cookies do not read the information on your computer’s hard drive or the cookies of other parties, they do not harm your computer. Cookies are non-personalised data that cannot be directly linked to a specific individual.
In any case, you can reconfigure your browser so that cookies are not stored or you are notified when cookies are stored. To find out more about cookies and how to manage or delete them, visit http://www.allaboutcookies.org.
At Adera Executive Search we use cookies to monitor the performance of our website and to improve the user experience. You can choose not to use cookies, but this may mean that our website is not working as well as intended.