PERSONAL DATA

1. Types of processed data
• Personal ID information, such as names and addresses;
• Electronic ID information, such as email addresses, mobile phone numbers and cookies;
• Personal details such as age, sex, date of birth, place of birth, marital status, nationality and language;
• Immigration status, such as the existence of a valid work permit for Belgium;
• Psychological descriptions, such as personality, thanks to a psychometric test;
• Academic career;
• Professional qualifications, including professional training and possession of a driving licence;
• Professional experience;
• Affiliation/involvement with professional organisations;
• Publications;
• Information about current employment;
• Information about recruitment;
• Information about the end of employment;
• Career details;
• Information about how work is organized;
• Salary details;
• Appraisal;
• In-job training;
• Images;
• Security information, such as passwords;
• Information about leisure activities and interests.

Applicants are never, in principle, required to disclose so-called sensitive information as defined by the privacy regulation, apart from when it is specifically required by law or authorized by a particular circumstance. This is why when a candidate fills an application form or completes a profile or interacts in any way whatsoever with Kuge Group, he/she is generally asked not to provide information of this type, in other words, details revealing your racial or ethnic background, political opinions, religious or philosophical beliefs or membership of a union, as well as genetic or biometric details, information about your health, or information about your sexual activities or orientation, criminal convictions and offences.

2. Data collection

Your personal data is collected in different ways.

• Submitting an application

 Kuge Group processes all the information provided by applicants when they fill in a registration form either in response to a job vacancy or when submitting a spontaneous application. To complete these registration forms, applicants are invited to provide their contact details (surname, first name, telephone number and email address), as well as send a CV.

Having sent this data to Kuge Group, applicants may, if they want, sign in to their personal, secure profile to change the information already provided and/or add to their profile by providing other details needed for the purposes described below: professional experience, training, languages spoken, preferred salary, photo etc..

• Telephone and/or video interview

 If an applicant chooses to provide the abovementioned information via a registration form and/or a spontaneous application, he/she explicitly agrees that Kuge Group will use these details to contact him/her by telephone and/or email to receive more information about the services offered by Kuge Group and, if he/she would like, to provide more information about his/her professional expectations.

• Recruitment interview

If an applicant agrees to have an interview with Kuge Group, he/she explicitly agrees that Kuge Group can use his/her personal data to invite him/her to this interview and to assess him/her during this interview, including with psychometric tests, as well as to check the references and information provided. The above implies, among other things, that Kuge Group will, if applicable, get in touch with the businesses and/or organizations mentioned by the applicant.

3. Purpose of the data treatment

This information is processed by Kuge Group to recruit new employees and to analyze and manage applications. This involves:

- Gathering data via a registration form or an ad hoc application, the applicant’s personal profile, a telephone or even video interview, a face-to-face interview, psychometric tests, personality questionnaires etc.;

- Saving this data;

- Viewing this data;

- Checking and analysing this data;

- Producing statistics, market research etc. in order to improve the candidates' experience;

- Proactive communication to applicants of new job vacancies that might meet the professional

expectations expressed by the applicants when they filled in a registration form and/or their profile. 

It is because the candidate has given his/her permission for this that Kuge Group can process this personal data. Kuge Group needs to collect this data to fulfil the purposes mentioned above. In fact, if this data is not collected, Kuge Group would not be able, for example, to manage incoming applications correctly. That having been said, as this data processing is based solely on the candidate's consent, he/she is free to withdraw that consent at any time without detracting from the legality of any data processing carried out before this consent is withdrawn.

Candidates’ data is only shared with:

- The candidates themselves;

- Employees of Kuge Group ;

- Kuge Group subcontractors (for example the hosting company, the recruitment tool provider) insofar as it is necessary for the fulfilment of their roles or if required by law ;

- The public authorities in circumstances where it is required by law.

5. Personal data retention period

When an applicant fills in a registration form, submits a spontaneous application and/or completes his/her personal profile, he/she explicitly accepts that his/her data will be kept in a database managed by Kuge Group. 

The data is kept as long as is necessary for the recruitment process of the candidate concerned, for the existing job offer(s) for which he/she has expressed interest and during 2 yearsafter the

end of the corresponding selection process(es), which allows Kuge Group during this period of time to manage the administrative and legal monitoring of this application, but also to submit to the candidate new job offers that can meet his/her professional expectations. However, in exceptional circumstances, the data may be kept longer if an administrative and legal monitoring demands that it is kept for longer.

The candidates will be informed by email 4 weeks before their data is due to be deleted. Candidates may then, if they want, explicitly ask Kuge Group to keep their data longer, in order to allow Kuge Group to contact them proactively to suggest a job vacancy that might be of interest to them. In this case, the same procedure will be applied before the end of this new period of 2 years, and so on. In the absence of reaction of the candidates at the end of this period of 4 weeks, the data will be automatically and permanently deleted.

6. Your rights

Candidates, by connecting to their personal profile, have at any time the right to access, to edit, to correct and to delete their personal data. They are also free to withdraw their consent to the processing of their personal data. This withdrawal will automatically lead to an immediate and irreversible deletion of their personal data.

By sending a dated, signed request (including electronically) by email to dpo[at]kugegroup.com or by standard post along with proof of ID, any applicant can get a free copy (including electronically) of his/her personal information from Kuge Group, as well as being able to correct or to delete incorrect or incomplete data information, or limit how it is used, within 1 month of receipt of the request.

All applicants also have the right to transfer their data. After this deadline of 1 month, if there is no response or reaction from Kuge Group, the candidate can assume that his/her request has been rejected. 

If Kuge Group has passed on concerned data to other people, Kuge Group will take all reasonable measures to inform these people of the request to delete any link to this data or any copy or reproduction of it.

If an applicant would like to make a complaint, he/she can do so by contacting the Autorité de Protection des Données // Privacy Commission, rue de la presse, 35, 1000 Brussels, www.privacycommission.be

7. Personal data protection

Applicants’ personal data is processed in Belgium and stored in a data centre in the Netherlands. 

The recruitment tool provider takes appropriate technical and organisational measures to protect applicants’ data, in particular against unauthorised handling and access, and will make every effort to make sure that these measures are as up-to-date as possible, given the state of knowledge, costs for implementation and the nature, scope, context and purposes of the processing as well as the risks for the applicants.

Legislation regarding privacy can sometimes be adapted and improved, so this document is also subject to change. Kuge Group therefore recommends that you consult it regularly if you visit its websites, and will make sure that any changes, modifications and adaptations are clearly marked.