Who we are and how we process your personal data
PageGroup including its subsidiaries (hereinafter collectively: "PageGroup", "us" or "we") is a specialist recruitment company operating under the brands Michael Page, Page Personnel, Page Executive and Page Outsourcing. The protection of personal data relating to you is important to us. This Privacy Policy informs you about the categories of personal data we collect, the purposes for which we use them and how we process your data, when you visit our website, when you apply for a job with us, when we introduce ourselves to you, when we provide recruitment and employment services to you, when we maintain a relationship with you after we have provided a service for you or when you provide a service for us. The following information is directed at you if you fall into one of the following categories of individuals:
- candidates for whom we provide employment services or who apply to us for a vacant position and contact us through our website, job boards, social media pages or through other sources;
- clients and their contacts with whom we have a business relationship and whom we support in filling vacant positions;
- potential candidates as well as potential clients and their contacts with whom we come into contact in order to present our products and services;
- service providers and their contacts who provide various services for us;
- users of our websites and apps
(jointly referred to as "you" or "yours").
Controller
The controller of your data is the PageGroup company that contacts you and processes data from you on its own responsibility when you visit the website, when the respective entity provides recruitment and employment services to you, maintains the relationship with you after the entity has found a job for you, sends you marketing communications, hires you for a vacant position or in case you provide a service to the to the respective entity. To access a complete list of PageGroup's European subsidiaries, including their contact details, please click here.
Details of data processing
Below you will find an overview of what kind of personal data we process about you, for which purposes, on which legal basis and where we collect this data.
If you do not provide us with your personal data, even though we need to collect it in order to process an order from you or fulfil a contract with you, or because we are required to do so by law, we may have to refuse your order or be unable to fulfil our contractual obligations to you.
Users of our website or apps
Purpose | Data categories | Legal basis | Collection of your Data | Recipients of your Data |
When you visit our website or app, we process your data for the following purposes:
In this context, we also use various cookies and other technologies. For further information, see our Cookie Policy. | In this context, we process the following data:
| The data processing is based on the following legal bases: Art. 6 (1) (b) GDPR - establishment, performance, or termination of the contract with you Art. 6 (1) (f) GDPR - our legitimate interest in the security, stability, and usability of our website Art. 6 (1) (a) GDPR – your consent | We collect the data directly from you. | In context of this data processing, it is possible that the following internal and external service providers have access to your data:
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We process your data to provide you with personalised advertising on the website based on your browsing behaviour. To do this, we use various cookies and other technologies. For further information, see our Cookie Policy. | In this context, we process the following data:
| The data processing is based on the following legal basis: Art. 6 (1) (a) GDPR - your consent | We collect the data directly from you. | In context of this data processing, it is possible that the following internal or external service providers have access to your data:
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Candidates
Purpose | Data categories | Legal basis/legitimate interest | Collection of your Data | Recipient categories |
We process your data in order to provide employment & placement services to you or to conduct an application process with you to establish an employment relationship with you. In this context, we may use your data to communicate with you, answer your questions, analyse your CV, and find a suitable position for you, create a candidate profile for you, providing salary advice, arrange interviews, conduct aptitude tests with you, forward your application documents to the employer of your choice. | In this context, we may process the following data:
| The data processing is based on the following legal bases: Art. 6 (1) (b) GDPR - establishment, performance, or termination of the contract with you Art. 6 (1) (c) GDPR - compliance with legal obligations in the area of labour and social law Art. 6 (1) (f) GDPR - our legitimate interest in efficient work organisational processes, work & service-sharing within the PageGroup as well as our legitimate interest in maintaining our customer relationship with you. We only process your special categories data on the basis of your consent pursuant to Art. 6 (1) (a) GDPR and insofar as we are obligated to do so for reasons of labour and social law, and finally for reasons of equal opportunity. In these cases, we base the processing of your data on Art. 9 (2) (b), (g) and (h) DSGVO. | We collect the data directly from you. In addition, we may also collect your data from third parties, namely from
We will only contact those reference providers, that you have indicated to us during the application process and our services. | In order to provide our employment services, we may share personal information about you with potential employers who offer job openings in which you are interested. In the context of the data processing described here, it is also possible that both internal and external service providers have access to your data. These include processors as well as our controllers from the following areas:
Our contractors are contractually obligated by us to maintain confidentiality and to comply with data protection standards and regulations. |
We process your data when you register with us and make your application data available to us and eventually to potential employers. If you register with different PageGroup companies, we will combine the applicant data you have provided into one data record and one applicant account for you. A single record avoids duplicities and improve accuracy of the personal data. For these purposes, the PageGroup companies involved will share your personal information as independent data controllers. | In this context, we may process the following data:
| The data processing is based on the following legal bases: Art. 6 (1) (b) GDPR - establishment, performance, or termination of the user contract with you for the provision of our candidate registration service. Art. 6 (1) (f) GDPR - our legitimate interest in efficient work organisational processes, in work & service-sharing within the PageGroup as well as our legitimate interest in maintaining our customer relationship with you In this case, we only process your special categories of data on the basis of your consent pursuant to Art. 6 (1) (a), Art. 9 (2) (a) GDPR. | We collect the data directly from you. | If you apply for a specific position, we will pass your applicants data on to the potential employer you have requested. In the context of the data processing described here, it is also possible that the internal as well as external service providers described above have access to your data. |
We process your data to send you promotional information, newsletters, and other electronic promotional information, to keep you informed about job opportunities, industry reports and insights, events, happenings and other content. | In this context, we may process the following data:
| The data processing is based on the following legal bases: Art. 6 (1) (a) GDPR - your consent Art. 6 (1) (f) GDPR our legitimate interest in direct marketing measures and the sending of advertising content | We collect the data directly from you. | In the context of the data processing described here, it is possible that both internal and external service providers from the following areas have access to your data:
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We process your data to send you satisfaction surveys to find out whether you are satisfied with our services, to improve our existing services and to develop new services. | In this context, we may process the following data:
| The data processing is based on the following legal bases: Art. 6 (1) (a) GDPR - your consent Art. 6 (1) (f) GDPR - our legitimate interest in direct marketing measures and sending of advertising content as well as the improvement and development of our services | We collect the data directly from you. | In the context of the data processing described here, it is possible that both internal and external service providers from the following areas have access to your data:
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In certain cases, it may be necessary for us to check the information you have provided about your work-history, or to check whether you have the qualifications and the necessary reliability for a specific job position. In these cases, we conduct so-called background checks. For this purpose, we consult reference providers and early educational institutions. In addition, we conduct internet research using search engines and publicly accessible online databases. Furthermore, we evaluate national and international press. Only in very limited cases and only insofar as we are legally obliged to do so do we compare your master data with sanctions lists and other public lists and registers, including terror and embargo lists and PEP lists (Politically Exposed Person). | In this context, we may process the following data:
| The data processing is based on the following legal bases: Art. 6 (1) (a) GDPR - your consent Art. 6 (1) (c) GDPR - our legal obligation to conduct background checks Art. 6 (1) (b) GDPR - Establishment, performance, or termination of the contract with you Art. 6 (1) (f) GDPR - our legitimate interest in carrying out background checks to verify your information, our legitimate interest in carrying out background checks to fulfil legal obligations of our clients, the legitimate interest of our clients in carrying out background checks to ensure the required suitability and reliability for special positions and verification of your information. | We collect the data directly from you. In addition, we may also collect your data from third parties, namely:
We will only contact those reference providers that you have indicated to us during the selection process and our services. | In the context of the data processing described here, it is possible that both internal and external service providers from the following areas have access to your data:
Our contractors are contractually obligated by us to maintain confidentiality and to comply with data protection standards and regulations. |
Conducting surveys on talent trends In order to continuously improve our services and keep them up to date, we will selectively invite you to participate in surveys on talent trends. | In this context, we may process the following data:
| The data processing is based on the following legal bases: Art. 6 (1) (a) GDPR - your consent Art. 6 (1) (f) GDPR - our legitimate interest to identify current talent trends and to further develop our services and offers. | We collect the data directly from you. | In the context of the data processing described here, it is possible that both internal and external service providers from the following areas have access to your data:
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Potential candidates and clients
Purpose | Data categories | Legal basis/legitimate interest | Collection of the data | Recipient categories |
In order to present our services and to be able to contact you and answer your enquiries, we process your personal data. We process the personal data about you that you provide to us when you contact us and make an enquiry. In addition, we may process data about you obtained from publicly available sources and from professional and social networks, such as LinkedIn, Xing, StepStone, company or other job boards, in order to contact you if we think you might be interested in our employment services. In addition, we may have been made aware of you through recommendation from another candidate or client and contact you. If you are acting as a business contact on behalf of a company, we will process your professional contact details. | In this context, we may process the following data:
| Art. 6 (1) (a) GDPR - your consent Art. 6 (1) (b) GDPR - establishment, performance, or termination of the contract with you Art. 6 (1) (f) GDPR - our legitimate interest in direct marketing measures and distribution of our recruiting and employment services as well as our legitimate interest in finding new business contacts, customers, and potential candidates | We collect the data directly from you. In addition, we may also collect your data from third parties, namely:
| In the context of the data processing described here, it is possible that both internal and external service providers from the following areas have access to your data:
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Clients (B2B) and our contacts
Purpose | Data categories | Legal basis/ Legitimate interest | Collection of the data | Recipient categories |
We process your data in order to provide our recruiting services to you. In this context, we process your data and those of your business contacts in order to communicate with you and find suitable candidates for your vacancies. | In this context, we may process the following data:
| Art. 6 (1) (b) GDPR - Establishment, performance, or termination of the contract with you Art. 6 (1) (f) GDPR - our legitimate interest in efficient work organisational processes, work & service sharing within the PageGroup group | We collect the data directly from you. In addition, we may also collect your data from third parties, namely:
| In the context of the data processing described here, it is possible that both internal and external service providers from the following areas have access to your data:
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We process your data to send you satisfaction surveys to find out whether you are satisfied with our services, to improve our existing services and to develop new services. | In this context, we may process the following data:
| The data processing is based on the following legal bases: Art. 6 (1) (a) GDPR - your consent Art. 6 (1) (f) GDPR - our legitimate interest in direct marketing and sending of advertising content and to further develop our services and offers. | We collect the data directly from you. | In the context of the data processing described here, it is possible that both internal and external service providers from the following areas have access to your data:
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We process your data to send you promotional information, newsletters, and other electronic promotional information, to keep you informed about job opportunities, industry reports and insights, events, happenings and other content. | In this context, we may process the following data:
| The data processing is based on the following legal bases: Art. 6 (1) (a) GDPR - your consent Art. 6 (1) (f) GDPR - our legitimate interest in direct marketing and the sending of advertising content | We collect the data directly from you. | In the context of the data processing described here, it is possible that both internal and external service providers from the following areas have access to your data:
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Service providers and our business contacts from our service providers
Purpose | Data categories | Legal basis/legitimate interest | Collection of the data | Recipients of your data |
In order to enter into the service contract with you and to receive your services and to communicate with you in the context of our business relationship, we process your personal data. In addition, we process your data for accounting purposes. | In this context, we may process the following data:
| The data processing is based on the following legal bases: Art. 6 (1) (b) GDPR – establishment, performance, or termination of the contract with you Art. 6 (1) (f) GDPR – our legitimate interest in efficient work organisational processes, work & service-sharing in the PageGroup group | We collect the data directly from you. | In the context of the data processing described here, it is possible that both internal and external service providers from the following areas have access to your data:
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We process your personal data to assess your suitability as a supplier of us. For legal compliance obligations, in very limited cases and only insofar as we are legally obliged to do so do we compare your master data with sanctions lists and other public lists and registers, including terror and embargo lists and PEP lists (Politically Exposed Person). | In this context, we may process the following data:
| The data processing is based on the following legal bases: Art. 6 (1) (c) GDPR - our legal obligation to conduct background checks Art. 6 (1) (b) GDPR - establishment, performance, or termination of the contract with you Art. 6 (1) (f) GDPR - our legitimate interest in carrying out assessments to assess your suitability | We collect the data directly from you. We may also use data from public registers and sanction lists. | In the context of the data processing described here, it is possible that both internal and external service providers from the following areas have access to your data:
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Data processing for compliance with legal obligations and defence and assertion of legal claims
Purpose | Data categories | Legal basis/legitimate interest | Collection of the Data | Recipients of your Data |
We process your data insofar as necessary to fulfil official control and monitoring and audit obligations, including official information and notification obligations as well as obligations under commercial or tax law. | In this context, we process the following data:
| The data processing is based on the following legal bases: Art. 6 (1) (c) GDPR – Compliance with legal obligations | We collect the data directly from you. | Within the scope of the data processing de-scribed here, it is possible that the following recipients have access to your data:
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In individual cases, we also process your data for the assertion of and defence against legal claims. | In this context, we process the following data:
| The data processing is based on the following legal bases: Art. 6 (1) (f) GDPR – our legitimate interest in defending against asserting legal claims. | We collect the data directly from you. | Within the scope of the data processing de-scribed here, it is possible that the following recipients have access to your data:
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We will process your data in the event of a restructuring, merger, sale, joint venture, assignment or other transfer or disposal of all or part of our business to the extent necessary for these purposes. | In this context, we process the following data:
| The data processing is based on the following legal bases: Art. 6 (1) (f) GDPR – our legit-imate interest in in a restructuring, merger, sale, joint venture, assignment or other transfer or disposal of all or part of our company Art. 6 (1) (a) – your consent | We collect the data directly from you. | Within the scope of the data processing described here, it is possible that the following recipients have access to your data:
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We also process your personal data in order to fulfil our obligations under data protection law, in particular to guarantee your rights as a data subject. | In this context, we process the following data:
| The data processing is based on the following legal bases: Art. 6 (1) (c) GDPR – compliance with legal obligations | We collect the data directly from you. | Within the scope of the data processing de-scribed here, it is possible that the following recipients have access to your data:
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Cookies, analytics tool & social media
We use social media and employ various cookies and other analysis technologies on our website. For further information, see our Cookie Policy.
Automated decisions and profiling
We do not make decisions based solely on automated data processing; there is always human intervention before a decision is made.
We draw up two types of profiles based on the candidates’ personal data:
- JobMatch is a tool available on our website for candidates to upload their CVs. Matched to your skills, career aspirations and resume information, the tool helps us to recommend jobs that match your aspirations and skills. However, this profiling does not restrict or exclude access to other jobs or positions.
- We use an analysis tool powered by semantic search technology (a type of Artificial Intelligence) that allows us to intelligently search and filter CVs from our data-base. By entering relevant keywords such as years of experience or field of practice into this tool, all uploaded CVs are then analysed, and a pool of candidates is provided by matching the keywords in the candidates’ CVs and ranking the candidates according to their suitability for the job. We use it to make our recruitment processes more efficient, by being able to better match candidates to more suitable jobs. As explained above, there is always a recruiter checking this process, so there are no automated decisions.
Please note that none of these profiling activities have any significant legal or similar effects on candidates. However, if you would like to know more, please contact us.
Data transfers to countries outside the EEA
In some cases, we also process your personal data outside the European Economic Area (EEA). If a data transfer takes place to one of the above-mentioned recipients whose registered office or place of data processing is outside the EEA or a state for which an adequate level of data protection has been established by a decision of the European Commission, we will ensure prior to the transfer that the data transfer is covered by a legal authorization and that guarantees exist for an adequate level of data protection with regard to the data transfer (e.g., through contractual guarantees, officially recognized regulations or binding internal data protection regulations at the recipient) or you have given us consent to the data transfer.
Intra-group data transfers outside the EEA
PageGroup is a globally active group of companies. Our recruitment experts and key business people in functions such as recruiting support, payroll management and IT support are located all over the world. For the above-mentioned purposes, in the context of our cooperation in PageGroup, we transfer your personal data in compliance with Art. 44 et seq. GDPR also to PageGroup companies outside the EEA or allow employees who work in PageGroup companies outside the EEA to access your personal data for the purpose of our cooperation and fulfilment of our contractual obligations with you. A list of PageGroup entities that are located outside the EEA can be found here.
If you are, for example, in Germany, as appropriate for your job search, or if you are looking for a qualified professional to join your organisation or a recruitment partner, we share your personal data with our recruiters specialised in the German market who are based in Turkey (details of the Turkish company can be found in the list mentioned above), if necessary. They process your personal data on behalf of our German entities. In relation to this transfer, an adequate level of data protection is ensured in accordance with the company’s intra-group agreement and the SCCs, as described below.
We have an intra-group data transfer agreement containing Standard Contractual Clauses (SCCs) approved by the European Commission that allow for cross-border transfers of personal data from the EEA to third countries outside the EEA, (as data protection laws outside the EEA may not provide an equivalent level of protection to EEA data protection laws).
If you would like a copy of the SCCs, please contact us using the contact details below.
Data transfers to external service providers outside the EEA
For purposes mentioned above, we use IT service providers located in the United Kingdom, USA, and Israel. In order to protect your data, we have entered into standard contractual clauses (SCCs) where required.
Please contact us using the contact details below if you would like to receive a copy of the SCCs.
Keeping your personal data secure
We have implemented and maintain appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss or alteration or unauthorised disclosure or access. Only authorised personnel and third-party service providers have access to personal data on a need-to-know basis, and these employees and service providers are contractually required to treat this information as confidential.
How long we store your personal data
We will store your personal data for as long as is necessary to fulfil the purpose for which we have collected them, which may be an ongoing purpose. For example, if you are an applicant, we will store your personal data for the duration of our business relationship with you and beyond, as we often support applicants with jobs for many years and potentially for their entire career.
We keep some personal data longer than others. In determining the appropriate storage period for personal data, we take into account factors such as the purposes for which we process your personal data, including legal, regulatory, accounting and reporting obligations, the nature and amount of personal data we hold about you, and the potential risk of harm to you from unauthorised use or disclosure of your personal data.
Where we process your personal data for direct marketing purposes, we will do so until you ask us to stop, and for a short period of time afterwards (to allow us to carry out your request). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely, so that we can respect your request.
Your data protection rights
EU data protection legislation gives you many rights with regard to processing of data concerning you. These rights include the right withdraw your consent according to Art. 7 (3) GDPR, the right of access to your personal data, and to request a copy of your personal data (Art. 15 GDPR), to rectify (Art. 16 GDPR), erase (Art. 17 GDPR), or restrict the processing of your personal data (Art. 18 GDPR), to obtain the personal data you provide to us in a structured, machine-readable format, and to ask us to transfer this data with another data controller (Art. 20 GDPR).
According to Art. 21 GDPR, you have the right to object to data processing by us at any time for reasons arising from your particular situation, insofar as this is based on Art. 6 (1) (e) DSGVO or on the protection of "legitimate interests" according to Art. 6 (1) (f) DSGVO. If you exercise your right to object, we will cease processing unless we can demonstrate compelling legitimate grounds for further processing that prevail your rights and interests.
You may withdraw your consent once given to receive marketing communications or opt out of data processing for direct marketing purposes by following the steps outlined in our notices and opting out of receiving marketing communications, or by contacting us using the contact details provided in this Privacy Policy. We have also established a Marketing Preference Center where you can view and select your preferences and opt out of receiving marketing communications at any time. To access the Marketing Preference Center, please also follow the steps explained in the Marketing communication.
Please note that these rights may be limited in certain cases. Your rights may be limited, for example, if complying with your request would disclose personal data about another person, if it would infringe the rights of a third party (including ours) or if you ask us to delete information that we are required to retain by law or in whose storage we have overriding legitimate interests. We will inform you of any relevant exceptions on which we rely when we respond to your request.
Furthermore, for processing operations based on the Companies' legitimate interests, we have carried out a legitimate interest assessment to ensure that our interests are not prejudiced by your interests or fundamental rights and freedoms; you can request this assessment via the contacts listed at the end of this Privacy Policy.
Questions and complaints
If you have any questions about this Privacy Policy or the processing of your personal data, or if you would like to make a complaint, you can use our form or send an email to us or to our Data Protection Officer at dpo@page.com.
If you have unresolved concerns or believe that your personal data has been breached, you can lodge a complaint with the competent supervisory authority. A list of relevant authorities in the EEA is available here.
How to contact us
Exercising your rights
To exercise your rights, withdraw your consent to processing or unsubscribe from our commercial communications, you can:
- complete our application form here, or
- send us an email to gdpr@pagegroup.eu, or
- please contact us or our Data Protection Officer at: dpo@page.com
Data Protection Officer (DPO)
Bird & Bird DPO Services SRL
Avenue Louise 235 box 1
1050 Brussels
Belgium
Page Group
Compliance Department
Plaza Europa 21 23, L'Hospitalet de Llobregat,
08908 Barcelona
Spain
Changes to our privacy policy
We may update this privacy policy at any time. Any material changes to this privacy policy shall be duly posted on this website and shall be communicated through other communication channels where appropriate.
