Privacy Policy
The Privacy Policy is a document related to the Terms of Use for Candidates (“Terms of Use”) and the Terms of Use for Employers (“Terms of Use for Employers”) (jointly referred to as “Terms of Use”). Definitions of the terms used in the Privacy Policy were included in the Terms of Use. The provisions of the Terms of Use are to be applied accordingly with the Privacy Policy.
The Privacy Policy is for information purposes and satisfies our information obligations under the GDPR, i.e. Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).
Anyone who uses the Platform should become acquainted with the Privacy Policy. The Privacy Policy determines the rules for processing personal data of persons using the Platform and using cookie files and other tracking technologies used in connection with the Platform operation.
1. PERSONAL DATA CONTROLLER
The controller of the personal data of the Platform users, including the Employers, Employers’ representatives and the Candidates, is Counselpath LTD (“Counselpath”, “we”, “us”, “our”) whose company registration number is 13323385 and registered office is 167-169 Great Portland Street, London, W1W 5PF, and who is the owner and administrator of the Platform.
You may contact us by sending a message to the e-mail address: contact@counselpath.com or a letter to the correspondence address stated above.
2. DATA PROCESSING METHOD
Within the Platform we may process in particular the following categories of personal data: i) first and last name; ii) employment history; iii) details of professional and business activity; iv) educational background; v) e-mail address; vi) image; vii) other data voluntarily presented by the Candidate in the CV or other materials provided onto the Platform; viii) IP number; ix) LinkedIn ID.
Providing personal data is voluntary, but failure to provide the personal data marked in the form (in particular in the Account registration form) as obligatory will prevent registration on the Platform and use of some of its functionalities. Due to the nature of the Platform and our Services, we cannot provide them on anonymous basis.
The table below summarises the most important information referring to: i) purposes; ii) scope; iii) legal bases; iv) period for which the personal data of Candidates, Employers and their representatives will be processed.
| Purpose | Scope of data | Legal basis | Processing period |
| Providing access to the Platform | IP address | Article 6.1.(b) of the GDPR – processing is necessary for the performance of the Agreement to which the data subject is a party, or undertaking actions upon request of the data subject prior to concluding the Agreement | Until the lapse of the period of limitation of claims connected with making the Platform functionalities available to you |
| Setting up the Account | Candidates: first and last name, last law firm, e-mail address Employers and their representatives: e-mail address | Article 6.1.(b) of the GDPR – as above | Until the lapse of the period of limitation of claims connected with making the Platform functionalities available to you |
| Verifying the Candidate Account | Data included in the CV or LinkedIn profile voluntarily presented by the Candidate | Article 6.1.(b) of the GDPR – as above | Until the lapse of the period of limitation of claims connected with making the Platform functionalities available to you |
| Providing the Services to the Candidate, providing access to job offers published on the Platform | first and last name, e-mail, details of professional qualifications, visa status, professional history data provided by in the CV, candidate preferences on employment opportunities | Article 6.1.(b) of the GDPR – as above Article 6.1.(a) of the GDPR – in the scope of other data provided voluntarily by the data subject | Until the lapse of the period of limitation of claims connected with making the Platform functionalities available to you, and in the scope of data processed pursuant to Article 6.1.(a) of the GDPR, until the data cease to be useful or the consent is withdrawn |
| Contacting the data subjects via e-mail, responding to e-mail messages | E-mail address, first and last name, other data provided voluntarily in the form or an e-mail message | Article 6.1.(f) of the GDPR – our legitimate interest as the controller which consists in responding to queries and correspondence provided directly by the data subjects | Until correspondence ends or you object |
| Issuing accounting documents, keeping books of account | First and last name, address for service, bank account number, details referring to the pursued business activity, other data required by the law | Article 6.1.(c) of the GDPR – implementation of legal provisions | For the term for which accounting documents have to be kept as prescribed by legal provisions |
| Analysing traffic on the Platform | IP address, Cookie files | Article 6.1.(a) of the GDPR – consent given by the data subject | Until the data cease to be useful or the consent is withdrawn |
| Concluding and performing the Agreement concluded with the Employer | First and last name of employer representative, e-mail address, bank account number, address for service, Tax Identification Number NIP, company name, place of business | Article 6.1.(b) of the GDPR – processing is necessary for the performance of the Agreement to which the data subject is a party, or undertaking actions upon request of the data subject prior to concluding the Agreement | Until the lapse of the period of limitation of claims resulting from the Agreement |
| Contacting Employers’ representatives | First and last name of employer representative, place of work, e-mail address | Article 6.1.(f) of the GDPR – legitimate interest of Counselpath as the data controller which consists in performing the Agreement concluded with the employer of the data subject | Until the lapse of the period of limitation of claims resulting from the Agreement concluded with the employer of the relevant representative; until the representative objects |
| Sending Newsletter | E-mail address | Article 6.1.(a) of the GDPR – consent given by the data subject | Until the data cease to be useful or the consent is withdrawn |
| Storing and sharing Candidates’ personal data for the purposes of conducting recruitment for the Employers | First and last name, education, employment history, professional licences, other personal data voluntarily provided by the Candidate, in particular in the CV | Article 6.1.(b) of the GDPR – statutory authorisation to process data necessary to perform an agreement or undertaking actions upon request of the data subject prior to concluding an agreement; Article 6.1.(a) of the GDPR – in the scope of other data provided voluntarily by the data subject | Until the lapse of the period of limitation of claims resulting from the agreement concluded with the Candidate, and in the scope of data processed pursuant to Article 6.1.(a) of the GDPR, until the data cease to be useful or the consent is withdrawn |
If Counselpath is advised that you use the Platform functionalities in violation of the generally applicable provisions of law, then Counselpath may process your personal data in a scope required for establishing your liability.
3. TRANSMISSION OF PERSONAL DATA TO THIRD COUNTRIES
Please be aware that the servers on which we store data, including personal data, are located in the United Kingdom, i.e. a third country within the meaning of the GDPR. On 28 June 2021 the European Commission issued Implementing Decision no. C(2021) 4800 final, stating that the United Kingdom ensures the adequate level of personal data protection. In view of the foregoing, transmitting personal data from the EEA may take place without the necessity to obtain additional permits or implement additional safeguards prescribed in chapter V of the GDPR. If the applicable provisions are amended, we will take action to ensure that the processing of your personal data is compliant with the law, and we will update the Privacy Policy.
At the same time, we’d like to state that we ensure compliance with all other provisions of the GDPR.
In each case where personal data are transferred to a third country, you are authorised to obtain their copies.
4. RECIPIENTS OF DATA
Counselpath may transfer Employers’ and Candidates’ personal data to third parties for the purpose of performance of certain activities. The recipients of your data may involve in particular: provider of hosting for the Platform, e-mail operator, software development company, provider of e-mail services, accounting firm, law firm, entities providing cloud and other solutions used by us in our current operations which involve personal data processing.
The personal data collected by us may also be disclosed to competent state bodies or institutions (law enforcement authorities, courts, security service) authorised to gain access to them on the basis of respective generally applicable legal provisions, or other persons and entities – in the cases prescribed by the generally applicable legal provisions.
Each entity to which we transfer personal data for processing on the basis of a personal data transfer agreement (“Data Transfer Agreement”) guarantees the adequate level of security and confidentiality of the processing of personal data. An entity processing personal data on the basis of the data transfer agreement may process personal data through another entity only upon our prior written consent.
If personal data are transferred for processing to a third country, then the provisions of section III of the Privacy Policy apply.
If you are a Candidate, your personal data may be shared with the Employer only in the case where you voluntarily and purposely applied for an Employment Opportunity the particular Employer has advertised on Counselpath. In such a case, the following data will be shared: i) first and last name; ii) e-mail address; . iii); information whether you require a visa to work in the UK; iv) your notice period disclosed in the application process; v) personal data included in your CV submitted as part of the application process.
Please be aware that the Employer with whom we shared your personal data is obliged to treat your data with confidentiality and in accordance with data protection standards prescribed by law, Counselpath Terms of Use and Counselpath Privacy Policy as well as to inform you about the method and scope of the processing of your personal data.
6. RIGHTS OF DATA SUBJECTS
As part of our processing of your personal data, you have the right to:
- Remove the collected personal data referring to you both from our system and from bases of the entities we co-operate with;
- Restrict the processing of your personal data
- Portability of your personal data which we collected, including the right to receive them in a structured form,
- Request us to make your personal data available to you and rectify them,
- Raise an objection against personal data processing,
- Withdraw the consent given to us to process your personal data at any time without affecting the legality of the personal data processing carried out on the basis of the consent before it is withdrawn;
- File a complaint against us to the competent supervisory authority,
You may exercise your rights in particular by means of the communication channels referred to at the beginning of this Privacy Policy.
7. PROFILING
In certain cases we may carry out profiling. We may do this only for the purposes of statistical analysis of our database. We’d like to emphasize that you will not be subject to a decision which is based solely on automated processing (including profiling) and which produces legal effects against you or similarly significantly affects you, as prescribed in Article 22 of the GDPR.
8. OTHER DATA
We may store http enquiries, therefore the files containing web server logs may store certain data related to you, including the IP address of the computer sending the enquiry, the name of your station – identification through http protocol, date and system time of registration on the Platform and receipt of the enquiry, number of bytes sent by the server, the URL address of the site you visited before (if you have entered the Platform through a link), information concerning your browser. Web server logs may be collected for the purpose of proper administration of the Platform. Only persons authorised to administer the IT system have access to the data referred to above. The files containing web server logs may be analysed for the purposes of preparing statistics concerning traffic on the Platform and occurring errors. Summary of such details does not enable a specific natural person to be identified.
We may use web analytic tools, including Google Analytics. As part of them, we have access to anonymised information on individual users, including: information on the operating system and Internet browser used by you, time spent on the Platform, your approximate location. The details referred to in the preceding sentence are not combined with your personal data and do not enable their identification and are not personal data within the meaning of the GDPR.
9. SECURITY
We care about security of your personal data and aspire to provide highest standards of data protection on our Platform. For this purpose, we have implemented appropriate safeguards and means of protection of personal data taking into account risks connected with the processes related to personal data processing. We also apply technological and organisational means in order to secure personal data against being disclosed to unauthorised persons, taken over by an unauthorised person, changed, lost, damaged or destroyed, as well as processed in violation of the GDPR by using, among other things, SSL certificates.
The compilations of personal data are stored on secured servers, moreover, personal data are also secured by our internal procedures related to the processing of personal data and information security policy.
10. COOKIES
We use cookie files for the purposes of correct operation of the Platform and its functionalities (“Cookies”). Cookies are text information recorded on the device of a relevant person (computer, tablet, smartphone) which may be read by the teleinformatic system of the Platform or third parties.
We use two types of Cookies: (a) session cookies, which are permanently deleted upon closing the session of the browser; (b) permanent cookies, which remain on the device after closing the session until they are deleted.
It is not possible to determine the identity of the person or otherwise identify him/her on the basis of Cookie files, whether session or permanent. Cookies prevent the collection of any personal data.
Files generated directly by us may not be read by other websites. Third-party Cookies (i.e. Cookies provided by the entities we co-operate with) may be read by an external server.
You may individually change the Cookie settings at any time, stating the conditions of their storage, through the Internet browser settings or configuration of the service on the Platform. You may individually disable storing Cookies on your device at any time in accordance with the instructions of the Internet browser producer, but this may disable certain parts of or the entire operation of the Platform functionalities. You may individually remove Cookies stored on your device at any time in accordance with the instructions of the Internet browser producer.
We use own Cookies for the following purposes: authentication on the Platform and maintaining a session; configuration of the Platform; improving your experience with using the Platform; statistical analysis, including click number and path taken by users, time spent on the Platform, number of users and frequency of their visits on the Platform.
The table below states the purposes for which we use third-party Cookies:
| Tool: | Purpose of storing: |
| Google Analytics | Cookie files are used for collecting information on the manner in which visitors use the Platform. Such information is used for analysing aggregated data and improving the Platform on this basis |
| Cookiebot | |
| Sign in with linkedin plugin | Cookie files are used for signing to the Platform by the Candidate via LinkedIn profile |
| Google Data Studio | Cookie files are used for conversion of data into anonymized informational reports |
This Privacy Policy comes into effect on 1 December 2021.