Legal & Policy
Privacy Policy
Your privacy is important to us. We respect your privacy regarding any information we may collect from you across our website.
We ask that you read this privacy policy carefully as it contains important information about who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.
Who we are
We are Gentis. Gentis has entities at the following locations:
- Gentis France of 18 rue de Londres, 75009, Paris, France;
- Gentis Belgium of 2 Boulevard de la Woluwe, 1150 Brussels, Belgium and Roderveldlaan 4, 2600 Berchem, Belgium;
- Gentis Morocco of Imm. les Quatre Temps 3, Lotissement la Colline, Lot 14, 2ème étage, Sidi Maarouf, 20190 Casablanca, Morocco;
- Gentis Canada of 1010 Rue Sainte-Catherine Ouest, Suite 200 - Mezzanine, H3B5L1 Montréal, Québec, Canada; and
- Gentis Dubai of The One Tower, Sheikh Zayed Road - Dubai - United Arab Emirates.
In this policy, Gentis, we, us, ours refers to the Gentis entities collectively above, unless otherwise stated.
Gentis collects, uses and is responsible for certain personal information about you. When we do so, we are regulated under various privacy laws.
When you are usually resident in the European Economic Area and the United Kingdom, you benefit from the protection of the UK GDPR, UK Data Protection Act 2018 for personal data processed regarding individuals in the United Kingdom and the EU General Data Protection Regulation for data processed regarding individuals in the European Economic Area (collectively, referred to in this policy as the “GDPR”).
For our operations in Morocco, Dubai and Canada, our appointed representative in the European Economic Area (EEA) is our Belgian entity referred to above. For our processing activities in in Morocco, Dubai and Canada as well as in Saudi Arabia and where an individual is usually resident in either of those regions, they may also benefit from protection under privacy laws in those regions which may also apply to Gentis' processing operations. For regional specific terms which may be applicable to you if you are usually resident in any of these regions, please see Part C of the Schedule to this Policy.
We are responsible as ‘controller’ of personal information for the purposes of the applicable privacy legislation.
The personal information we collect and use
Information collected by us In the course of our activities as a recruitment and staffing specialist, we collect different kinds of information depending on whether you are a job seeker or contractor wishing to utilise our recruitment services to find your dream job or assignment, or whether you are a client who has contacted us to help you to find your next star employee or contractor.
When we refer to clients in this policy, we also refer to our commercial business suppliers, partners and vendors. References to candidates includes permanent and contractor candidates as well as applicants to work for Gentis.
For our clients, we store the following personal information when you provide it to us: Your name, your job title and role within your organisation, your office or head office address, your professional contact details (such as telephone numbers, fax numbers and email addresses).
For our candidates, we have set out a table at the Schedule below which sets out the information collected by us or obtained from third parties.
Information collected from other sources We may obtain personal information from our clients from other sources, such as:
- From professional social media sites or job boards where such information is in the public domain.
- From any professional marketing materials or other publications (including your company’s website) which have been issued and maintained by your company.
- From information that may have been gained or exchanged from trade fairs, industry talks or networking forums.
- From your company itself, where we have initially been dealing with another department or another group entity.
In respect of our candidates, we may collect information from third parties such as job boards, social media, previous employers, education providers, or government bodies. More information about this is set out in the Schedule below.
How we use your personal information In respect of our clients, we use any information we collect about you to:
- Best provide our recruitment services, tailor-made to suit the needs of our respective businesses;
- Contact you in order to provide our recruitment services and to administer your account with us and your relationship with us;
- Negotiate and enter into a commercial agreement with you which governs the provision of our recruitment services to you and sets out yours (and our) rights and obligations, such as dealing with payment, and sending related correspondence.
In respect of our candidates, we have set out a table at the Schedule below which sets out how we use your information in order to provide you with the highest quality recruitment services.
Who we share your personal information with Typically, for our candidates, the types of organisations with whom we share your information include our clients, who are seeking individuals with a profile similar to yours in order to offer employment opportunities, as well as between our group companies.
This data sharing enables us to best help you in your job search, and also allows us to fulfil our sourcing obligations to our clients. We will always ask for your consent before sharing your personal data with our clients.
Similarly, we share client data with our candidates when we think that we have found a good fit. This data is limited to information about the role, the company, any specific requirements or details. If the candidate is offered an interview with you, we will also provide the candidate with the hiring manager’s name, professional contact details and office address. Again, we will only ever share such information provided that our client contact has confirmed to us that we can do so, and that they are happy to meet with the candidate.
We also share your personal data with our group or associated or affiliated companies, including Wiggli, our sister company which provides an innovative recruitment tool which allows clients and candidates to benefit from the latest technology that improves Gentis’ staffing services. Wiggli, a trading name of Hireme SA, is located at 2 Boulevard de la Woluwe, 1150 Brussels, Belgium and registered on the Belgian Company Register under BE 0678.483.029. For more information about Wiggli, how they act as controller or processor of your personal data and for access to Wiggli’s privacy policy, visit: https://www.wiggli.io. If you have an issue with how Wiggli processes your personal data, you should contact Wiggli directly and/or review their privacy policy on the link provided above.
If you would not like your personal data to be shared with WiggliWiggli, then you are able to delete your data from your account and/or decide to close your account directly. Likewise, if you wish to unsubscribe from any Wiggli emails, please utilise the ‘unsubscribe’ link in the emails you receive. Please note that we do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We might also share data pursuant to data processing agreements, such as on external IT servers or on cloud-based storage. We might also give your details to our third-party providers, such as external finance, external marketing managers or external lawyers to make sure that we are able to complete our contractual obligations to you, or indeed for the smooth running of our business in the event that we do not have an adequate back-office or administration support system internally. In any case, we always make sure that we have appropriate technical, security and organisational methods in place to secure the confidentiality and proper processing of your data, and we require that our third-party providers adhere to these guarantees too.
On occasion, some of those third-party recipients may be based outside the United Kingdom and European Economic Area — for further information including on how we safeguard your personal data when this occurs, see ‘Transfer of your information out of the UK and EEA’.
We will also share candidate and client information with law enforcement or other government or official authorities, and our external lawyers, if required by applicable law or in pursuit or defence of a claim in accordance with applicable laws.
How long your personal information will be kept For our clients:
We will hold any personal data about our client contacts for no longer than is reasonable to carry out our recruitment services pursuant to the intended conclusion of a contract, during the performance of the contract, and after its termination (for example, keeping any data in accordance with legal or fiscal obligations to in pursuit or defence of a claim). It may be that some personal data is retained on these documents, but this is purely incidental to documents which are generally required strictly for commercial purposes. Where possible, we will ensure that any personal data is anonymized where it is not strictly necessary.
As a general rule, we will keep all client contacts on file for a period of 6 years following our last meaningful contact with you, unless you expressly tell us otherwise, and before we delete your data we will always periodically check with you to see whether our recruitment services are still of interest, unless you tell us otherwise.
For our candidates:
We keep the personal information that we obtain about you during the recruitment process for no longer than is necessary for the purposes for which it is processed. How long we keep your information will depend on whether your application is successful and whether you become employed by one of our clients, the nature of the information concerned and the purposes for which it is processed.
Generally, we will keep recruitment information (including interview notes) for 3 years following our last meaningful contact with you, but before we delete your personal data, we will check with you to see whether you still want us to keep your details on file should you wish to use our services for your future job hunt.
Sometimes we may hold some data for longer than this, taking into account the limitation periods for potential legal or contractual claims. For example, if your application is successful, we will keep only the recruitment information that is necessary in relation to your employment with the client and pursuant to our contractual obligations with them.
Marketing We will use your personal data to send you updates (by email, text message, telephone or post) about our services.
Where you are an existing client or candidate, we have a legitimate interest in using your personal data for marketing purposes. This means we do not usually need your consent to send you marketing information, but you will always have the possibility to opt-out of such marketing when we collect your personal information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts.
We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat your personal data with the utmost respect and never sell or share it with other organisations outside of Gentis and Wiggli for marketing purposes.
Reasons we can collect and use your personal information– Lawful bases As far as our clients are concerned, we process your personal information (i) with a view to entering into a commercial contract or to perform that commercial contract; (ii) in accordance with our legal obligations (for example, our accounting and tax records obligations); and (iii) in our mutual legitimate interests – we both have the same or similar legitimate interests in collaborating together – to make sure we can secure you top talent!
In respect of our candidates, the table at the Schedule below sets out the reasons we can collect and use your personal information. We have nonetheless provided a couple of scenarios below which we hope are helpful, and which also complement the information in the table.
In the event that a candidate has posted their CV on a job board, we consider that the lawful basis for processing for the recruitment agency and their clients is legitimate interests.
In this instance, the candidate has made their CV available on a job board website for the express reason of employers and recruiters being able to access this data. As such, we consider that our legitimate interests as a recruitment agency and those of our clients to fill vacancies are not overridden by any interests or rights of the candidate. In fact, in this instance, our legitimate interests are likely to align with the interests of the candidate in circulating their CV in order to find a job.
In respect of a candidate’s public professional social media account (such as LinkedIn), we consider the candidate would clearly expect those who view their public profile might use their contact details for recruitment purposes, which means that again, our legitimate interests are likely to align with the interests of the candidate in their search for a job.
Transfer of your information out of the UK and EEA when you are usually resident in these regions We transfer your personal information outside the United Kingdom (UK) and the European Economic Area (EEA), including where you are normally resident outside the UK and EEA.
For both clients and candidates, who have expressed their will to work with our Dubai/Canadian/Moroccan Offices, we transfer your personal information to our Gentis group companies located in those countries, or it will be collected there directly. We may also transfer data between our group entities to provide our services to you.
Morocco, Canada and Dubai do not have the same data protection laws as in the United Kingdom, France and Belgium. However, our Moroccan, Canadian and Dubai subsidiaries are bound by the GDPR when they process personal data belonging to EU/UK citizens. Indeed, our Dubai, Canadian and Moroccan offices apply the high EU/UK privacy standards to all data subjects, regardless of their location.
Also, we may transfer your personal information to other locations outside the UK/EEA, for example, for storage on servers based outside of the UK/EEA or to external advisors.
Where we transfer your personal data outside of the UK/EEA, we do so on the basis of an adequacy decision as approved by the European Commission or UK Government (as applicable).For the countries which do not provide the same personal data protection as within the UK/EU and do not therefore benefit from an adequacy decision or adequacy regulation, we ensure that all transfers are covered by the EU Standard Contractual Clauses and/or the UK International Data Transfer Agreement (the “SCCs’’), as applicable. This also goes for transfers between our European and international entities, except for transfers to our Canadian office, where we rely on the adequacy decision which is in place and which is approved by the European Commission and the UK Government.
The SCCs give you the privacy rights and remedies that you would have if your personal data had been processed within the UK/EU.
If you would like further information, please contact us (see ‘How to contact us’ below). We will not otherwise transfer your personal data outside of the UK/EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.
Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to this privacy policy’ below.
Your rights If you are usually resident in the EEA or UK, you have a number of important rights free of charge. In summary, those include rights to:
- fair and transparent processing of your personal information
- access to your personal information
- require us to correct any mistakes in your information
- require the erasure of your personal information in certain situations
- receive your personal information in a structured, commonly used and machine-readable format
- object at any time to processing of your personal information for direct marketing
- object to decisions being made about you by automated means (profiling) in certain situations
- object to our continued processing of your personal information in certain situations
- restrict our processing of your personal information in certain situations
- withdraw your consent to processing
If you would like to exercise any of those rights, please:
- contact us
- let us have enough information to identify you
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
- let us know the information to which your request relates.
If you would like to unsubscribe from any marketing emails you receive from us, you can also click on the ‘unsubscribe’ button at the bottom of the email. It may take up to 30 days for this to take place.
Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
We hope that we can resolve any query or concern you raise about our use of your information.
The GDPR also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. For a list of EEA data protection supervisory authorities and their contact details see here.
The supervisory authority in Belgium is the Data Protection Authority who may be contacted by e-mail: contact@apd-gba.be or by telephone: +32 (0)2 274 48 00.
The supervisory authority in France is the Commission Nationale de l'Informatique et des Libertés (CNIL) who may be contacted by telephone: +33 (0)1.53.73.22.22.
If you are usually resident in the UK, you also have the right to lodge a complaint with the Information Commission in the United Kingdom. The Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.
Changes to this privacy policy This privacy policy was published on the 25th September 2023 and last updated on 20th September 2023.
We may change this privacy policy from time to time, when we do, the new version will be published on our website, http://www.gentisrecruitment.com, so please check there periodically.
How to contact us Please contact us if you have any questions about this policy or the information we hold about you.
If you wish to contact us, please send an email to DPO@gentis.com, write to us at any of our offices set out on the first page, clearly marking your correspondence with Data Protection Query.
SCHEDULE
Part A
Up to and including the shortlisting stage
| The information we collect | How we collect the information | Why we collect the information | How we use and may share the information |
| Your name and contact details (i.e. address, home and mobile phone numbers, email address) | From you, From Job Boards or Publicly available professional social media profiles | Our mutual legitimate Interests. |
To enable your dedicated recruitment consultant to contact you to progress your application, arrange interviews and inform you of the outcome.
To inform the relevant hiring manager at the client of your application |
| Details of your qualifications, experience, employment history (including job titles, salary, working hours) and interests |
From you, in the completed application form and interview notes (if relevant).
From Job Boards or Publicly available professional social media profiles. |
Our mutual legitimate Interests. |
To make an informed recruitment decision about whether your profile is suitable for our client’s needs or your requirements.
The person making the shortlisting decision will receive pseudonymised or anonymised details only; if you are invited for interview, the interviewer will receive non-anonymised details. |
|
Your name, contact details and details of your qualifications, experience, employment history and interests. |
From you, in the completed application form and interview notes (if relevant).
From Job Boards or Publicly available professional social media profiles. |
Our mutual legitimate Interests. | To see whether any of our clients has any suitable vacancies and to provide you with recruitment services. |
| Your racial or ethnic origin, sex and sexual orientation, religious or similar beliefs. |
From you, in a completed anonymised equal opportunities monitoring form.
From Job Boards or Publicly available professional social media profiles. |
Consent, but also to comply with our legal obligations and for reasons of substantial public interest (equality of opportunity or treatment). |
To comply with our equal opportunities monitoring obligations and to follow our equality standards and ensure that our clients are able to do the same.
For further information, see * below. |
|
Information regarding your criminal record |
From you, in your completed application form or from the Criminal Records Authority (if applicable and where authorised by the law). |
Consent |
To make an informed recruitment decision, and to allow our clients to do the same
To carry out legal checks Information shared with Criminal Record Checks Authorities other regulatory authorities as required by law For further information, see * below |
|
Details of your referees |
From you, in your completed application form. |
Consent: to carry out a fair recruitment process and ensure that your profile is a good match for our client's needs.
Consent: in the regulated sector, to comply with our legal obligations to obtain regulatory references. |
To carry out a fair recruitment process and ensure that your profile is a good match for our client's needs.
To comply with legal/regulatory obligations. Information shared with relevant recruitment consultants, the client, and the referee. |