Privacy Disclaimer

This general privacy policy (hereinafter ‘Privacy Policy’) governs the processing of your personal data by The House of Procurement, a brand name of Emptum BVBA (hereinafter ‘THOP’, ‘we’, ‘us’, ‘our’, ‘our’) in the context of your visit to our website, in our offices or your communication with us via our website, e-mail, telephone, fax and social media.

1. General

1.1 Your personal data will be processed by The House of Procurement, a brand name of Emptum BVBA and for this purpose established in the name and for account of Grote Braamstraat 3C in 2220 Heist-op-den-Berg, Belgium with company number BE 0880.785.5365.

1.2 Within our organisation, the data are only accessible to employees who, depending on their tasks, must have access to them. If you have additional questions and/or would like more information, please send an e-mail to: gdpr@thop.be

1.3 The General Data Protection Regulation defines personal data as follows:

all information about an identified or identifiable natural person – is considered identifiable: a natural person who can be identified, directly or indirectly, in particular by means of an identifier such as a name, an identification number, location data, an online identifier or one or more elements that are characteristic of the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.
If this Privacy Policy refers to personal data, reference is made to this definition in the Regulation.
no special categories of personal data are processed. Processing of special categories of personal data is understood to mean:
processing of personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and processing of genetic data, biometric data for the purpose of the unique identification of an individual, or data concerning health, or data relating to a person’s sexual conduct or sexual orientation.

2. Types of personal data processed by us

2.1 When you use our website, we collect:

technical information relating to the device you use, such as your IP address, browser type, geographical location and operating system; and information relating to your browsing behaviour, such as the time you spend on a page, which links you click, which pages you visit and how often you visit a particular page.
2.2 When you fill out a contact form on our website, subscribe to our newsletter, participate in a survey or contact us via e-mail, telephone, fax or social media, we collect:

the identity information you provide us with, such as your name, e-mail address, postal address, telephone number, employer and position;
the content of the message and its technical details (with whom you communicate with us, the date, time, etc.); and any other personal data you provide to us.
2.3 When you apply via our website or in any other way; spontaneously or for a vacancy, we ask your consent to the processing of your personal data. To enable us to help you find a suitable job or assignment, we collect your personal data via your CV and registration process. Such data includes, but is not limited to:

the identity information you provide us with, such as your name, e-mail address, postal address, telephone number, employer and position;
your studies and past career; and
any other personal data that you provide to us.
2.4 If you are invited by THOP as part of a selection, interim management or secondment assignment, we will ask your consent for the processing of your personal data.

The THOP employee who has the interview with you will process all the information you provide into a well-founded advice regarding your candidacy, development or further evolution at the organisation for which you are with THOP. This person will also give you a name tag afterwards. If you have provided reference persons, you hereby authorise the THOP employee, within the framework of this request for advice, to contact them and verify relevant information.

The advice or report is intended for the personnel director, the general manager or other authorised representatives of that organisation, and is only sent to them by THOP. Any distribution of the report is their responsibility. THOP will keep this report for a maximum of 3 years. You can consult the report again during this period. THOP employees also have a maximum of 3 years access to this information: of course they are bound by their professional secrecy.

At your request, the THOP employee will discuss all the information obtained with you. This will take place after processing and after the client has received the report. If desired, after the feedback meeting with one of our THOP employees, you can get a printout of the assessment report. The further transmission of this confidential information or the careless storage of this information is then entirely your responsibility.

2.5 When you ask us, as a company, to work with you, we will keep records of you. This information includes, but is not limited to:

the contact information you provide us with, such as name, e-mail address, postal address and telephone number;
your job title;
your business;
the content of the message and its technical details (with whom you communicate with us, the date, time, etc.); and
any other personal data that you provide to us.
2.6 When you give us a business card: if you somehow gave us a business card, we will include you in our database for general contact details. We assume here that by handing over the card you also give your explicit permission to be included in our database.

In addition, we also store certain publicly accessible information about you in our database in order to complete your contact details. This concerns the following sources: public databases on the Internet such as LinkedIn, databases with company data and company websites.

3. Purposes for which we use your personal data

3.1 We process your personal data in order to be able to offer you the requested information, products and services in a personal and efficient manner (contact management and public relations).

The legal basis for this is consent and legitimate interest (in particular freedom of enterprise).

3.2 When you are looking for a job or assignment, we process your personal data (applicant management):

helping you to find a suitable job or assignment;
communicate with you about vacancies and the progress of any applications;
provide your details to suitable future employers, provided that you have given us your specific permission to do so;
provide you with reports of vacancies that we believe may be of interest to you;
helping and advising you in your search for a new job or assignment;
provide you with information on general trends in the job market;
Ask you for feedback about our services; and
meet our obligations to our clients when you are offered a job or assignment.
The legal basis for this is your permission. If you do not provide the requested personal data, we may not be able to assist you in the context of your search for a suitable job or assignment.

3.3 We process your personal data to carry out statistical analyses with a view to improving our website, products and services or developing new products and services. The legal basis for this is justified interest (in particular freedom of enterprise).

3.4 We store your personal data (anonymously) for the purpose of scientific research. The legal basis is justified interest (in particular freedom to conduct business).

3.5 We process your personal data to safeguard our legitimate interests and the legitimate interests of our partners or third parties if and when your registration through our website or other communication channels may be considered (a) a breach of any applicable terms of use, intellectual property rights or any other rights of a third party, (b) a threat to the security or integrity of our website or other communication channels, (c) a threat to the website, other communication channels or underlying systems of our subcontractors due to viruses, Trojan horses, spyware, malware or any other form of malicious code, or (d) hateful, obscene, discriminatory, racist, defamatory, rancid, offensive or otherwise inappropriate or illegal in nature. The legal basis for this is justified interest (in particular the right to protect oneself against fraud)

3.6 We process your personal data to send you newsletters: by post and by e-mail. The legal basis for this processing is your consent or, if you are a customer, the legitimate interest, in particular the freedom to do business.

4. Receivers

  • technical processors on whom we call for support (e.g. an ICT service provider or a hosting partner); client, in the context of our selection, interim management or secondment activities. All data of candidates provided by THOP to the client are exclusively intended for the client and the limited group of persons who take part in the decision.  The further passing on of this confidential information or the careless storage of it, falls under the responsibility of the client.  The client therefore undertakes to do everything possible to guarantee the confidentiality of the information, so that the candidates do not suffer any disadvantage in their professional lives.
    police and other law enforcement agencies if we are obliged to disclose your personal data.
    With a view to personalising marketing messages on websites, we pass on limited information to Facebook and LinkedIn.

5. Location

5.1 We process your personal data within Belgium.

6. Storage period

Your personal data will be stored for the following periods:

  • general contact details: 5 years after the last meaningful contact
  • applicant management: 3 years
  • direct marketing: 5 years after the last meaningful contact
    Fraud prevention and control: 1 month, unless used in the context of judicial proceedings.

Of course, we store your personal data in accordance with any mandatory statutory and limitation periods that may apply. For invoices, for example, this is 7 years.

7. Security

7.1 We will take the necessary technical and organizational measures to protect your personal data against unauthorized access, improper use, unauthorized disclosure, unauthorized modification and theft, as well as accidental loss, manipulation or destruction. Only staff members or third party processors who need to know about your personal data can consult them. Moreover, they are bound by strict rules of confidentiality.

8. Your rights

8.1 You can view your data: if you wish to view which personal data we process about you, you can do so by exercising your right to view. THOP will give you as complete an overview as possible of the personal data that are kept about you. We can already confirm that no special categories of personal data are kept (such as race, ethnic origin, health data, data concerning sexual orientation, …). You can get a copy of the personal data collected (for candidates after a feedback session).

8.2 You can have your data corrected: if there are changes in your personal data (such as name, address, e-mail address, …), you can always have this corrected or completed.

8.3 You may have your data deleted: if you believe that we are processing certain personal data on an unlawful basis, i.e. without having a proper purpose, you may request that your personal data be deleted.

8.4 You may request that the processing of your personal data be restricted: if your data are incorrect and you have asked us to amend them or if you believe that we are processing your personal data on an unlawful basis, you may ask us to limit the processing thereof.

8.5 You may ask to transfer your personal data directly to a third party: if you so wish, you may ask us to transfer the data you have provided to us yourself, to you or directly to a third party. However, the Regulation does provide for a number of limitations to this right, so that it does not apply in all cases. This will, of course, need to be examined on a case-by-case basis.

8.6 You may sometimes refuse to allow your data to be processed fully automatically: some data processing and processes are fully automated without human intervention. However, we do not make use of this in relation to the processing of your personal data. If this is the case, and if you do not agree with such a fully automated process, you can object to this, so that your personal data are no longer processed in this way. Here too, a number of exceptions apply, which must be assessed on a case-by-case basis.

8.7 You can withdraw your consent: if your personal data are processed on the basis of consent, you can withdraw this consent at any time. We will then have to delete your personal data. If you wish to exercise one or more of these rights, please contact us at gdpr@thop.be and clearly specify which right you wish to exercise. In addition, we inform you that you can lodge a complaint with the supervisory authority at any time. We naturally invite you to first discuss your complaints with us in order to reach a rapid solution. Belgian Privacy Commission: Commission for the Protection of Privacy, rue du Prince 35, 1000 Brussels, tel. +32 (0)2 274 48 00, fax +32 (0)2 274 48 35, e-mail: commission@privacycommission.be.

Changes

When we make changes to our privacy statement, we indicate below the date on which the changes were made. This statement was last amended on 2 January 2019.