Last Updated: May 22, 2019
Users are encouraged to read and review this Data Protection Policy before accessing or using Brickfield Consultants Ltd.’s website (www.brickfieldrecruitment.com) (the “Website“).
The present Data Protection Policy is applicable to Brickfield Consultants Ltd., doing business as Brickfield Recruitment, and its affiliates (collectively, “Brickfield“) and sets forth the terms and policy concerning the collection, usage, handling and protection of users’ personal data. As a recruitment firm, Brickfield may collect personal data about businesses, companies, applicants and other users of the Website.
1. APPLICATION OF THIS DATA PROTECTION POLICY
Your access or usage of the Website signifies your acceptance of the terms set forth in this Data Protection Policy (the “Policy”), as may be revised from time to time. Any submission or provision of personal information through or on the Website will be governed by this Policy.
This Policy has been drafted and established in accordance with the General Data Protection Regulation (GDPR) and applicable laws of the United States. This legislation applies to residents and members of the European Union (EU) and the European Economic Area (EEA).
3. DATA PROVISION
Users are not required to provide personal data to access the Website, however, users may be asked to provide Brickfield with personal information in order to register, create a profile, apply for opportunities listed, send inquiries, benefit from certain services offered by Brickfield, or access certain portions of the Website. Users are not obligated to provide any personal data to Brickfield, however certain services or portions of the Website may not be accessible or usable by users who have not provided information.
4. PERSONAL DATA
Personal data constitutes information about an identifiable individual (also referred to as a natural person). Such information may include but is not limited to the individual’s name, email address, telephone number, current and past employers, work experience and other relevant information. Brickfield undertakes to collect only personal data provided voluntarily by users to Brickfield or by way of the Website.
Under the General Data Protection Regulation, Personal data refers to “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”. This definition has been reproduced and copied above in italics for information and reference purposes.
Considering Brickfield will have the ability to collect, record, organize, structure, store, adapt, alter, retrieve, consult, use, disclose, disseminate, destroy, erase, restrict or otherwise make available personal data, Brickfield is subject to the obligations contained in the General Data Protection Regulation. Brickfield therefore warrants and represents that Brickfield will comply with all applicable provisions of the General Data Protection Regulation.
5. COLLECTION AND HANDLING OF DATA
Upon Brickfield’s collection of your personal data, Brickfield undertakes to comply with all applicable legislation regarding the safeguard, protection and non-disclosure of personal data. Brickfield has implemented strict procedures to ensure the safeguard and protection of personal data provided to Brickfield, through its Website or using other means.
The procedures established by Brickfield apply to all Brickfield officers, directors, employees, consultants and other third parties who may access personal data stored or collected by Brickfield. Brickfield undertakes to disclose personal data to employees and affiliates solely on an “as needed” and limited basis. The disclosure of personal data must be done for a specific and clearly defined purpose. The recipients of the personal data will be subject to obligations similar and at least as strict and enforceable as those set forth in this Policy.
Brickfield undertakes to process all personal data in a lawful, fair and transparent manner, in accordance with the obligations set forth in the General Data Protection Regulation.
6. USAGE OF THE PERSONAL DATA
Upon Brickfield’s lawful collection of personal data, Brickfield undertakes to abide by the following principles and guidelines relating to the usage thereof. Brickfield will use personal data only for purposes of fulfilling the mandate specified with the Website user. Brickfield will use personal data to the extent that the usage is required under Brickfield’s legitimate interests in fulfilling the purposes detailed in this Policy.
The communication or usage of personal data by Brickfield may be necessary to comply with legal obligations, regulations or court orders as described in this Policy. Brickfield is also authorized to use personal data for reasons of public interest and in relation to the public domain. Lastly, with the user’s specific consent, Brickfield may use personal data for the purposes and to the extent specified in the user’s consent.
7. PURPOSE OF THE COLLECTION
Brickfield is authorized to collect and store personal data for the purposes listed in this Section of the Policy. By providing personal data to Brickfield, you agree that it may be used by Brickfield in the following instances:
- to provide the recruitment services as well as corresponding and ancillary services described on the Website;
- to provide you with personalized offers and recommendations;
- to inform you of opportunities or candidacies that may be of interest;
- to communicate with you regarding services, events or other information;
- to respond to inquiries and questions;
- to send you promotional offers and marketing materials, only with your prior consent;
- to assess trends, preferences and features of the Website;
- to improve and assess the services offered by Brickfield;
- for research purposes on prospective candidates and recruitment opportunities;
- to ensure compliance with any court order or legal obligations.
All personal data collected by Brickfield will be limited to what is strictly relevant and necessary to fulfill the purpose set forth herein. This is constitutes a data minimization obligation.
At all times, users may opt out of receiving written communications or notifications from Brickfield. Users may send Brickfield an email to request to opt out of receiving further correspondences.
8. COURT ORDERS AND LEGAL OBLIGATIONS
Brickfield will not disclose or communicate personal data provided on the Website to any third party, except in accordance with this Policy.
Brickfield reserves the right to communicate or disclose personal data to comply with any applicable law or regulation. Brickfield is not obligated to inform the user of the collection and processing of the personal data if this collection and processing is required under applicable laws. Personal data relating to taxation and employment relating to the public sector may communicated by Brickfield without the user’s specific consent.
If a valid court order requires the provision of personal data by Brickfield, Brickfield will provide the required personal data in accordance with the instructions and requests stipulated in the court order. In such case, Brickfield undertakes to give the user notice of Brickfield’s obligation to disclose to allow the user may institute all appropriate proceedings to secure a protective order or an appropriate remedy.
9. MAINTENANCE AND STORAGE OF PERSONAL DATA
Brickfield undertakes to use all reasonable commercial efforts to maintain accurate and updated personal data about users. If Brickfield is informed of erroneous or invalid personal data, Brickfield will erase and rectify such personal data promptly for accuracy purposes.
Brickfield will not store and collect personal data for any unreasonable or exaggerated duration. The data will remain on file for the duration that is necessary as established in consideration of the purpose and the consent provided by the user. Brickfield’s storage and maintenance of personal data will be limited in time and scope as to comply with all applicable legislation.
Brickfield may store personal data for a longer duration, exceptionally, if the ongoing storage is required or preferable for public interest considerations.
10. PROTECTION OF PERSONAL DATA
The personal data collected by Brickfield will be processed and handled in a manner that protects the security and confidentiality of the personal data. As such, the systems used and procedures implemented by Brickfield are meant to protect the personal data’s integrity and confidentiality against unauthorized disclosures, destruction, damage, deletion or other breaches.
11. USERS’ RIGHTS
All users who provide personal data to Brickfield will have certain rights connected to the personal data provided. Users will have the right to be informed of Brickfield’s usage of their personal data. This information will be provided by Brickfield to the user upon the user’s written request.
Users will also have the right to request the correction or rectification of incorrect or incomplete personal data. Users may request that personal data be removed from Brickfield’s servers and files. Brickfield will then remove and destroy the personal data from its servers.
Users also have the right to access the personal data the user provided to Brickfield and may request that its communication and disclosure be subject to more restrictions than those contained in this Policy.
Requests of any nature pertaining to personal data should be directed to Brickfield by way of email or by using the “Contact” section of the Website.
12. PRIOR CONSENT
Where possible, Brickfield will obtain the user’s consent prior to any collection, handling, usage and storage of the user’s personal data. The consent provided by the user must be explicit and in writing. Users who are below the age of than sixteen (16) years old may not provide valid consent and are not authorized to use the Website or provide personal data to Brickfield.
13. SPECIFIC SERVICES
If Brickfield is to collect personal data to fulfill its contractual obligations under a specific agreement with a Website user, the user’s consent is not required. Such contractual obligations may include a delivery that cannot be performed without the User’s address, or an application made on behalf of a user, which must include the user’s coordinates and past experience. In such cases, the user’s personal data may be disclosed by Brickfield to perform specific services stipulated in an agreement with the user.
14. TRANSFERS OF PERSONAL DATA
Any personal data will not be transferred outside the European Union or internationally unless the transfer complies with the limitations and regulations set forth in the GDPR. Brickfield will transfer personal data only to countries that abide by data protection regulations and orders. Such countries include but are not limited to the United States.
As is the case with many website operators, Brickfield reserves its right to use “cookies” on the Website. Cookies are small data files that are downloaded onto a user’s computer when the user visits a particular website. It is possible to disable these cookies by turning them off a browser, but some parts of the Website may not function properly if cookies are turned off or removed.
16. THIRD PARTY WEBSITES
This Policy applies solely to the Website despite that it may link to other web sites or refer to employers. Any links to third party websites by the Website are provided for convenience and informative purposes. Such third party websites are not governed by this Policy and Brickfield has no control over the third party’s usage of personal data.
This Policy may be amended or modified at any time by Brickfield. The revised Policy will be published on the Website and will be applicable to all users and personal data secured or transmitted on the Website once the revised Policy is published on the Website.
18. QUESTIONS AND CONCERNS
All questions and concerns regarding this Policy or the information contained therein should be directed to Brickfield by email or by using the “Contact” section of the Website. Brickfield undertakes to promptly analyze and respond to all user’s inquiries and comments.