The General Data Protection Regulation 2016/679 (the “Regulation” or the “RGPD”) applicable as of May 25, 2018 is a direct application rule throughout the European Union and affects all individuals and the treatment of their personal data and the free circulation of these data. It replaces the Organic Law on Data Protection (LOPD) and RD 1720/2007 and introduces changes and novelties.
In order to comply with the legal, technological and administrative requirements determined by the aforementioned Regulations, MCR International SL (hereinafter, MCR or “the company”) and its associated company Talento RH Soluciones SL (hereinafter TALENTO), have undertaken actions necessary to update and intends to provide you with information on the purposes, methods and areas of communication and transfer of personal data that you provide us with as a candidate, when you register through our Websites (hereinafter, Webs), the websites of other companies and social networks, by email or on the occasion of an interview in our offices.
1.- Who is responsible for the treatment of your data?
MCR International SL
c/ Raimundo Fernández Villaverde, 45, 7 a y b
28003 – Madrid
Be informed that MCR acts as the processor of the data files owned by MCR so that the data can be processed for the search, assessment, management and selection of applications for the job offers of MCR or TALENTO and / or from third-party client companies
2.- What data do we process?
We collect your data through the following channels:
1. Data that has been provided to us by you, using our website.
1.1. If you register for a specific job offer published in it or if you send us a spontaneous application or send it by email or send it to our offices, your data will be processed for the purpose of sourcing and recruiting candidates for direct hire by a third company, client of MCR or TALENTO, or your direct contracting by MCR itself or TALENTO.
The data correspond to the following: Files and professional resumés where: email, phone / mobile phone, name, surname, date of birth, address, postal code, town, province, education and profession, current and past professional experience, can be found.
The data obtained by means of the Web will specify what data can be optionally included and what are the minimum mandatory data, which are strictly necessary to fulfil the purposes of treatment.
The refusal to provide the data marked as mandatory will imply the impossibility of participating in recruitment processes. MCR and our associate company TALENTO, have adopted the necessary technical and organizational measures to guarantee the security and integrity of the personal data provided, as well as to avoid its alteration, loss, treatment or unauthorized access.
If you register for a specific job offer, your data will be processed only in the framework of the recruitment process to which you have applied, unless you consent to use it for future processes. If you send us a spontaneous application, we will treat it for those opportunities that suit your profile and professional experience.
The legal basis applicable to the processing of personal data for the purposes set out in the preceding paragraph is the execution of a contract, in accordance with article 6.1.b) of the RGPD.
1.2. Data requested directly by MCR or TALENTO, derived from your registration on other Websites, job pages or social networks managed by third parties (job seekers, University Job Boards, business schools, professional colleges etc.) in which you enrol to job offers that we publish (on behalf of our clients or on their own account) and that correspond to the same personal data mentioned above.
1.3. Information provided during the recruitment process and phone-call phase, personal interview, in which you participate with us and which may correspond to the following personal information: Email, phone / mobile phone, name, surname, date of birth, address , town, province, nationality, marital status, profession, position, company, seniority, among other data. All of this information is also treated with the utmost confidentiality and diligence throughout the entire interview phase.
2. The Data knowingly not provided but achieved from sources accessible to the public. These are data from publicly available sources (censuses, telephone directories, newspapers, bulletins, the media, press archives, data published in the form of lists of people who belong to professional groups, professional social networks) containing relative data to name, titles, profession, academic degrees, group membership, position, studies, languages, photographs, among other query data. They could also come from third parties (for example, through our candidates, as long as they provide us with your data as a contact person for the purposes of references and prior agreement by you).
3.- For what purpose do we process your personal data?
We treat your data for the following purposes, the established conservation periods, and the limitations regarding the provision of services, described below:
1.- To know your professional profile so that it can be processed for the search, assessment, management and selection of applications to participate in recruitment processes for MCR or third-party companies in which you may be interested in, now or in the future, either directly or on a specific proposal of MCR or TALENTO, and, in this way, be able to accompany you in the development of your professional career by sharing, with your prior agreement, your data with other organizations.
As a candidate, we understand that you guarantee that the data you provide us is true and you are expressly responsible for the possible consequences that may cause the falsification of said information.
If you provide personal data of third parties, you must have previously informed said person and obtained their consent about the treatment that MCR or TALENTO will give to their personal data, being responsible for any damages that MCR or TALENTO may incur otherwise.
In the final phase of some recruitment processes, MCR or TALENTO may request references to the companies in which you have indicated to have worked in.
In these cases, your participation in the recruitment process in question will be understood as express consent in favour of MCR to request and obtain these references.
The non-acceptance of this purpose will mean that we will not be able to advance in recruitment processes in which initially you may be interested in participating.
The personal data provided will be kept in our files confidentially and will only be used for the purposes mentioned above (participation in recruitment processes, request for help or feedback in processes, request for references) and will be kept on file unless you express you definite desire that we erase them from our files.
2.- Ask you for evaluations of our work (Satisfaction Surveys as a Candidate) to help us improve. Ask you for help in open recruitment processes or references from people or companies you know. Keep you informed about our own events, follow up on the evolution of your career and other details, such as congratulations on appointments or job / position changes.
The non-acceptance of this purpose entails not being able to contact you in case of new opportunities or monitoring of your professional career.
The personal data provided will be kept as long as you do not ask us to erase them from our files, until that moment we will understand that you are still interested in belonging to the MCR contact network.
3.- Share data with third-party companies and international recruitment consulting networks to which we belong (more information on our website) with the information we have on your profile to offer you professional opportunities that may interest you and related to the business sectors linked to your profile.
Through this purpose, MCR may, even when it involves an international transfer of data within or outside the European Economic Area (EEA), to other companies interested in your application when you are participating in international processes.
In the event that you consider that said treatment may generate some type of repercussion derived from the loss of control over your personal information as interested party, you can exercise the right of access and / or opposition, as well as voluntarily exclude yourself.
Be informed that you can limit this purpose by exercising the right of opposition by sending an email to the address: email@example.com.
The personal data provided will be kept as long as you do not ask us to unsubscribe, since until that moment we will understand that you are still interested in belonging to the MCR contact network.
In exceptional circumstances, we may use your personal data for the formulation, exercise or defence of a right in a judicial proceeding.
The personal data provided will be kept as long as you do not ask us to unsubscribe, since until that moment it will be understoon that you are still interested in belonging to the MCR contact network.
4.- Who is the recipient of your data?
The personal data treated will only be processed by those duly authorized employees and departments of the Company, for the purposes indicated above. These employees have received adequate operating instructions to perform the tasks assigned to them.
In the event that your application moves forward in the recruitment processes, we may share your data (upon express agreement by you) with third parties (companies or client organizations that require our recruitment services), companies belonging to the international networks to which we belong to, in other countries for the purposes of sourcing and recruiting candidates.
5.- What are your rights when you provide us with your data? ARCO Rights
The rights that may assist you in the treatment of personal data in relation to MCR are: Right to request access to your personal data, to request its rectification or deletion, to request the cancellation or limitation of your treatment, to the opposition of the treatment and data portability.
6.- What does the right of access consist?
You will have the right to obtain confirmation from MCR of whether or not your personal data is being processed, in addition to knowing the purposes of the treatment; the categories of data being processed; the recipients or categories of recipients to whom they have been communicated or will be communicated; and, if possible, the expected period of retention of personal data or, if not possible, the criteria used to determine this period.
In those cases, we would provide you with a copy of the personal data subject to treatment (CV). In addition, when you request it by electronic means, the information will be provided in a commonly used electronic format (email).
You can exercise this right annually. MCR will inform you about the actions derived from your request within a month (which may be extended two more months in the case of particularly complex requests). To request the exercise of the right of access, send an email to firstname.lastname@example.org
7.- What does the right of rectification consist?
You will have the right to obtain from MCR the rectification of inaccurate personal data that concerns you. In addition, taking into account the purposes of treatment, you will have the right to have incomplete personal data completed, including by means of an additional declaration. To do this, you must indicate in your request what information you are referring to and the correction we must make; as well as you will have to attach, when necessary, the supporting documentation of the inaccuracy or incomplete nature of the data object of the treatment.
To request the exercise of the right of rectification, send an email to email@example.com to rectify the incorrect data.
8.- What does the “right of deletion” or “right to be forgotten” consist?
You will have the right to obtain from MCR the suppression of personal data that concerns you when one of the following circumstances occurs: they are not necessary in relation to the purposes for which they were collected or processed; that you withdraw consent and the treatment is not based on another legal basis, that you oppose the treatment and that other legitimate reasons for the treatment do not prevail, that you consider to have been illicitly treated.
At the moment that MCR deletes such data, MCR, taking into account the available technology and the cost of its application, will adopt reasonable measures, including technical measures, with a view to inform those responsible who are treating the personal data of your deletion request, or any link to that personal data, or any other copy or replica of them.
The foregoing shall not apply to exercise the right to freedom of expression and information; for the fulfilment of a legal obligation that requires data processing, or for the fulfilment of a mission carried out in the public interest or in the exercise of public powers conferred on the person responsible; for scientific or historical research or statistical purposes, insofar as the right of deletion could make it impossible or seriously hinder the achievement of said objectives; for the preparation and exercise or defence of claims.
To request the exercise of the right of deletion send an email to firstname.lastname@example.org
9.- What does the right to limit the treatment consist?
You will have the right to obtain from MCR the limitation of data processing when any of the following conditions is met:
a) When you have disputed the accuracy of your personal data, during the period that allows MCR to verify the accuracy of the same;
b) In the event that you consider that the treatment is unlawful and MCR denies the deletion of personal data and instead requests the limitation of its use;
c) That MCR no longer needs personal data for the purposes of the treatment, but you need it for the formulation, exercise or defence of claims;
d) In the event that you have opposed the treatment, while verifying if the legitimate reasons of MCR prevail over yours.
When you have obtained the limitation of the treatment according to this section, you will be informed by MCR before the lifting of said limitation.
MCR will communicate any rectification or deletion of personal data or limitation of the treatment to each of the recipients to whom the personal data has been communicated, unless it is impossible or requires a disproportionate effort. MCR will inform the interested party about said recipients, by request. To request the exercise of the right of opposition, send an email email@example.com
10.- What does the right to data portability consist?
You will have the right to receive the personal data that concerns you, which you have provided to MCR, in a structured, commonly used and machine-readable format, and to transmit them to another data controller without being prevented by MCR, when the treatment is based on consent and is carried out by automated means.
By exercising your right to data portability, you will have the right to have personal data transmitted directly from controller to controller when technically possible. The right to portability will not extend to the data that MCR would have inferred from data derived directly from MCR’s use of the services provided.
To request the exercise of the data portability right, send an email firstname.lastname@example.org
11.- What does the right of opposition consist?
You will have the right to oppose the processing of data that concerns you, at any time.
In the event that you exercise this right, MCR will stop processing your personal data, unless we demonstrate compelling legitimate reasons for the treatment to prevail over your interests, rights and freedoms, or for the formulation, exercise or defence of claims. To request the exercise of the right of opposition, send an email email@example.com
Be advised that you have the right to file a claim with the corresponding local control authority and that you can contact the Spanish Data Protection Agency to obtain additional information about your rights.