1. Blake & Partners’s role as a data controller
The data controller responsible for the processing of your data is Blake & Partners SPRL/BVBA, having its registered offices at Avenue Louise 140, 1050 Ixelles, Belgium and registered in the Crossroads Bank for Enterprises under number 0883.621.795.
As a data controller we solely and autonomously determine the purposes and means of the processing of your personal data.
2. What data Blake & Partners collects
We collect and process your personal data only for the purposes set out in this Policy. This information can be submitted to us, or collected by us, in different ways (including via our website, written correspondence and e-mails, meetings with our consultants or via any of our offices or other Blake & Partner group websites).
From our candidates we may collect personal details, including without limitation: name, e-mail address, physical address, telephone number and other relevant information from your Curriculum Vitae (“CV”). We may receive your candidate details and CV electronically through a direct application, via the form on our Website or an application through a third party.
Blake & Partners give candidates the option of submitting CV’s via the Website or by providing your CV to one of our consultants with an eye to a specific job or to have our recruitment consultants inform you as a candidate about positions as they come up.
Your CV will be stored in our database and can be consulted by our consultants.
The CV may be emailed to other Blake & Partner group companies for entry into their database and shared with our clients (see section 4.2).
Given the nature of some CV’s, it may happen that occassionally this includes sensitive personal information (such as political affiliation, ethnic origin or details of criminal convictions). In principle Blake & Partners does not knowingly collect sensitive personal information from individuals and encourages candidates not to submit such sensitive personal information to us. If, however, a candidate transmits sensitive personal information to Blake & Partners, and unless that information is relevant to analyse your professional abilities or personality, we will anonymize and delete it.
Further information can be collected from the candidate during our communications or relationship with you. This can be collected directly from you or from third parties, for example to whom your CV was provided and the job application process is being followed up with.
To provide the client with our services and for client administration we may collect the name of a contact person, e-mail address, country, telephone and cellphone number and fax number.
2.3 Website visitors
As you browse the Website, Blake & Partners will collect the following personal data:
- Identification data: only if you decide to provide identification information on the Website, such as your email address.
3. On which legal basis and for what purposes do we process your data?
We always process your personal data on the basis of and within the boundaries of the legal bases as those are laid down under applicable law. We also ensure to limit the processing of your personal data to what is strictly necessary for the achievement and performance of the purposes described below.
3.1 Your consent
Subject to obtaining your prior and specific consent and in accordance with the applicable law, we may process your personal data, such as candidate’s contact details and the information featured in the CV, when this is uploaded via a direct application using the form on our Website. This personal data is processed in order to evaluate the candidacy, including the researching and verifying of the skills, qualifications and overall attitude of candidates for vacant positions at clients or positions as they come up. This includes also providing the services as a recruitment agency to connect the candidate to a client, keeping contact with an eye to a position as it comes up and further communications regarding the service.
3.2 Performance of our duties
We may also process your personal data where this is necessary for the performance of our legal duties or the performance of our contractual obligation towards you. In such a case, we limit the processing of your personal data to the extent strictly necessary.
(a) Legal obligation
Blake & Partners may process your personal data to be able to respond to queries from regulatory or law enforcement agencies if we are required to do so (see below section 4.3).
We may process candidate’s personal data on the basis of the Terms and Conditions for the evaluation of the candidacy, including the researching and verifying of the skills, qualifications and overall attitude of candidates for vacant positions at clients or positions as they come up. This includes also providing the services as a recruitment agency to connect the candidate to a client and further communications regarding the service.
Client data may be processed based on the necessity for the performance of a contract for the purpose of our client management, including providing the services as a recruitment agency to connect the client to a candidate, communications regarding the service and client administration.
3.3 Legitimate interests of Blake & Partners
When not strictly necessary for any of the abovementioned reasons, Blake & Partners may also process your personal data for other purposes, falling under the achievement and the realisation of its legitimate interests. In such a case, however, Blake & Partners strives to maintain a fair balance between the need to process your data and the preservation of your rights and freedoms, including the protection of your privacy. Whenever this is the case, Blake & Partners will keep you informed about what type of legitimate interest we are pursuing and provide you with transparent information about the processing operations and your rights.
In particular, with regard to candidates, their CV may come to Blake & Partners via an application through a third party and processed based on a legitimate interest.
Against this background, we may process your personal data for the following reasons:
- To evaluate the candidacy from a candidate’s CV via an application through a third party, including:
- the researching and verifying of the skills, qualifications and overall attitude of candidates for vacant positions at clients or positions as they come up.
- providing the services as a recruitment agency to connect the candidate to a client,
- keeping contact with an eye to a position as it comes up
- further communications regarding the service.
- To notify candidates about future job opportunities other than the specific role for which you have contacted us
- To maintain our business relationship, whether you are a website visitor, candidate or client;
- To evaluate and improve our Website;
- For any direct marketing of services, news and industry updates, promotions, events and competitions, reports or other info (subject to a specifc opt-in where needed and opt-out).
4. With whom and how do we share your data?
4.1 Within the Blake & Partners Group
Where you are registered in our database as a candidate, Blake & Partners may share your personal data with other companies within the Blake & Partners Group. These companies within the EEA, including Luxembourg, The Netherlands, Switzerland and Germany hold themselves to the same standards of security and respect for the data protection principles under the GDPR and local data protection laws.
We disclose the personal information of candidates to clients for the purpose of our activities as set out above. Blake & Partners may share this personal data with a client that has communicated to have vacancies in which you are interested. Blake & Partners may alternatively proactively look for the candidates for job vacancies as they come up by sharing an anonymised version of the CV with parties that may be interested.
4.3 For prosecution reasons
Where required in order to investigate the unlawful use of our services or for the purposes of prosecution, personal data will be disclosed to the relevant law enforcement authorities and, where applicable, to any third-party claimants. However, such a course of action will only take place if there is concrete evidence of unlawful conduct or misuse. In such cases, your data may also be shared if doing so is required for the fulfilment of terms and conditions of use or other agreements. If requested, we are also legally obligated to disclose such data to certain public authorities, such as law enforcement bodies, authorities that penalise offences with financial penalties, and financial authorities.
In these cases, data is disclosed on the basis of our legitimate interest in combating misuse, aiding the prosecution of criminal offences, and aiding the establishment, assertion and enforcement of claims, in line with point (f) of Article 6(1) of the GDPR.
More specifically, we use the services of the following processors in particular:
- service providers for the distribution of newsletters;
- business development providers;
- data analytics providers;
- logistics service providers;
- payment service providers for the purpose of processing all payments from you to us or vice versa;
- IT service providers for the provision of hardware and software and for the implementation of maintenance work.
Data is disclosed to processors on the basis of Article 28(1) of the GDPR or, alternatively, on the basis of our legitimate interests in the economic and technical advantages associated with the use of specialised processors and on the basis of circumstances in which your rights and interests in the protection of your personal data are not overridden (see point (f) of Article 6(1) of the GDPR).
5. What are your rights?
5.1 Access, rectification, erasure, portability and objection rights
For all the purposes defined above, and subject to applicable data protection laws, you have the following rights:
- the right to ask us to provide you with copies of personal data that we hold about you at any time, which include the right to ask us: whether we process your personal data, for what purposes; the categories of data; the recipients to whom the data are shared;
- the right to ask us to update and correct any out-of-date or incorrect personal data that we hold about you;
- the right to withdraw your consent where such consent has been given;
- the right to erasure within the limits afforded by data protection legislation;
- the right to oppose to the processing of your personal data, within the limits afforded by data protection legislation;
- the right to data portability within the limits afforded by data protection legislation.
5.2 How to exercise those rights?
You may at any time exercise the abovementioned rights in accordance with data protection regulations, by sending a request with a copy of your ID card (passport or other proof of identity) to firstname.lastname@example.org or in writing to at Avenue Louise 140, 1050 Ixelles, Belgium, and subject to complying with our reasonable requests to verify your identity.
5.3 Right to lodge a complaint
You can also lodge a complaint to the Belgian Data Protection Authority either by post at rue de la Presse 35, 1000 Brussels, or by e-mail at email@example.com or by phone at +32 2 274 48 00 or first-line assistance at +32 2 274 48 78.
6. How long do we keep your personal data?
We will not store your personal data beyond the time necessary for the performance of the purposes for which the data is processed. Specifically, we distinguish between a retention period and an archiving period:
- The retention period is the maximum period of use of your personal data for specific purposes:
- the data processed for the execution of the contractual relationship or the performance of a legal duty is kept for the entire duration of the contract, or as long as the legal duty applies, and for the prescription period upon termination of the contract or of the legal obligation;
- the data processed for other purposes may be retained for a longer period during which we will reassess the need to keep this data and pseudonymize the data where it does not affect the realisation of the purposes.
- The archiving period meets our legal obligation as well as the legal need to retain your data beyond the retention period for evidentiary purposes or to respond to requests for information from the competent authorities.
7. How do we protect your personal data?
We take appropriate technical and organisational measures to safeguard and protect your personal data, against unauthorised or unlawful processing and against accidental destruction, loss, access, misuses, damage and any other unlawful forms of processing of the personal data in our possession.
9. How to contact us?