General privacy policy
This recruitment privacy policy should be read together with our general privacy policy, available here: https://nexioprojects.com/privacy-policy/. The recruitment privacy policy explains how Nexio Projects collects, uses, shares and protects personal data in the course of recruiting new talent. Unless otherwise indicated, the data controller for the processing of personal data as described in this privacy policy is Nexio Projects NL B.V.
By continuing with your application and submitting your personal data, you acknowledge that this recruitment privacy policy applies and that you have also read our general privacy policy.The two policies are mutually connected and should be interpreted and applied in conjunction with one another.
1. The use of the Careers Portal by Nexio Projects for talent acquisition
This paragraph only applies to the processing of personal data of Candidates who apply for jobs at Nexio Projects through the Careers Portal. Nexio Projects uses Recruitee (a product of Tellent B.V.) as its data processor to facilitate this recruitment process. Nexio Projects is the data controller for all personal data of Candidates processed through the Careers Portal. Our Candidates carry the benefit of this privacy policy for the processing activities that relate to their applications. Please refer to section 7 for more information about that separation of responsibility.
Nexio Projects processes the personal data of Candidates for the following purposes:
Purpose and data categories :
Recruitment process in the Careers Portal
Data: name and contact details; CV and application materials; activities in the Careers Portal; other personal data entered into or submitted through the Careers Portal
Nexio Projects relies on the following legal bases for processing personal data through the Careers Portal: where you have actively applied for a position, the processing is necessary for taking steps at your request prior to entering into a contract (art. 6(1)(b) GDPR); for additional processing activities that go beyond what is strictly necessary for the application procedure (such as retaining your profile for future opportunities) Nexio Projects relies on your consent (art. 6(1)(a) GDPR) or on its legitimate interests in identifying and attracting suitable candidates (art. 6(1)(f) GDPR), where those interests are not overridden by your rights and freedoms.
Nexio Projects will delete personal data that is listed in this paragraph after the recruitment process is concluded and the personal data is no longer necessary for any of the purposes listed in this paragraph. More information about retention periods is available on request.
2. Applicants to Nexio Projects jobs (nexioprojects.com/careers)
This section applies to applicants of jobs at Nexio Projects as shown on our Careers Site (nexioprojects.com/careers and nexioprojects1.recruitee.com) and any other candidates or potential candidates for any jobs with Nexio Projects.
Nexio Projects may collect your personal data for recruitment purposes in one of the following three ways:
You apply for a job at Nexio Projects: If you apply for a job at Nexio Projects then we process your personal data to facilitate the entire job application procedure on the grounds of our legitimate interests for recruitment. Your data will be kept by Nexio Projects for up to 365 days after the end of the application procedure. If you provide your consent for it, Nexio Projects may keep your profile in its talent pool for Nexio Projects to reach out to you about future job opportunities and to otherwise process your personal data in relation to recruitment for job openings at Nexio Projects for up to 365 days. This retention period reflects the time reasonably needed to respond to any queries or disputes arising from the application process and to consider the candidate for comparable roles that may arise within that period. Personal data will be deleted sooner if it is no longer necessary for those purposes.
We source you through publicly available resources: Nexio Projects may, based on its legitimate interests for recruitment, search through publicly available resources such as LinkedIn to find candidates that have skills, experience and interests that match with Nexio Projects' staffing needs. If Nexio Projects believes that you may be a match with Nexio Projects' staffing needs, then Nexio Projects will, based on its legitimate interests for recruitment, process your personal data for the purpose of reaching out to you and asking for your consent to match you with job opportunities at Nexio Projects and to otherwise process your personal data in relation to recruitment for job openings at Nexio Projects.
Where Nexio Projects identifies you through a publicly available resource, we will inform you of the processing of your personal data at the time of our first contact with you, in accordance with our obligations under Article 14 GDPR.
If the consent is not provided then your personal data will be automatically deleted within 365 days after it has first been collected. If consent is required under applicable law to contact you, we will only contact you if you have consented.
You are referred by someone: Someone who knows you might refer you to us because that person believes you have skills, experience and interests that match with Nexio Projects' staffing needs. Upon receiving your contact details and determining that you are a good match we will, based on our legitimate interests for recruitment, reach out to you to ask for your consent to match you with job opportunities at Nexio Projects and to otherwise process your personal data in relation to recruitment for job openings at Nexio Projects. If the consent is not provided then your personal data will be automatically deleted within 365 days after it has first been collected. If consent is required under applicable law to contact you, we will only contact you if you have consented.
The following personal data can be processed for a job application procedure or other recruitment activities:
Any personal data that you provide through our job application form or that we collect during the recruitment process including, but not limited to:
Contact details such as full name, email address, phone number
Cover letter, resume and LinkedIn profile
Which job you are in a hiring process for
Statuses, notes, evaluations and planning related to a hiring process that relates to you
Email and SMS communications
Please note that your application materials may contain special categories of personal data within the meaning of Article 9 GDPR, such as information relating to your health, nationality, or trade union membership. Nexio Projects does not request such information as part of its application process. To the extent that you voluntarily include such information in your application, Nexio Projects will treat it as having been manifestly made public by you (art. 9(2)(e) GDPR), unless you indicate otherwise. Where the processing of special categories of personal data is strictly necessary in the context of employment law obligations, Nexio Projects will rely on Article 9(2)(b) GDPR in conjunction with Article 22 UAVG.
3. Interview and meeting recordings
Where you have given your explicit prior consent, Nexio Projects may record interviews conducted via video call for internal evaluation purposes. We will notify you by e-mail before each interview and ask for your consent. You may decline or withdraw your consent at any time before the interview starts. Your application will be assessed solely on its merits, and your decision regarding consent to recording will have no bearing whatsoever on the outcome of your application or any subsequent hiring decision.
Access to recordings is restricted to members of the hiring panel directly involved in your recruitment process. Nexio Projects will delete interview recordings within 365 days of the interview date, or sooner once the recruitment process has concluded and the recording is no longer needed. The legal basis for this processing is your explicit consent (Article 6(1)(a) GDPR).
4. Newsletters, events and demos
Nexio Projects may also process the personal data of anyone that registers or requests for a newsletter of Nexio Projects, a product demo by Nexio Projects, a webinar or event of Nexio Projects, or to be contacted by a business partner of Nexio Projects to learn more about the services of that business partner. In such cases Nexio Projects may process personal data for the following purposes:
Purposes and data categories (summary)
Event participation / attendance
Data: name; contact details (email/phone); job title and organisation
Newsletter delivery
Data: name; job title and organisation; email address
Sales and marketing of Nexio Projects services
Data: name; job title and organisation; contact details (email/phone); contents of communications with our sales/marketing teams
Improving our services (based on your feedback)
Data: name; job title and organisation; contact details (email/phone); contents of communications with our sales/marketing teams
Strategic decision making (e.g., which services/partners to focus on)
Data: name; job title and organisation; services you have shown interest in
Connecting you with a business partner (on your request)
Data: name; contact details (email/phone); job title and organisation; services you have shown interest in
Where appropriate, Nexio Projects will ask your consent for the processing. In other cases Nexio Projects relies on legitimate interests for the processing of the personal data for the purposes described above. Such legitimate interests are the same as the purposes that Nexio Projects processes personal data for. The personal data that is stored for the processing described in this paragraph will be deleted when it is no longer needed for the purposes listed in this paragraph. More information about retention periods is available on request.
5. Social media and distributed content
Nexio Projects may use the services of its partners to stay in touch with you or to provide you with content. For example, we may provide you with articles through our LinkedIn page. Services of Nexio Projects' partners may also be used for Nexio Projects and its partners to process personal data or place cookies on your device for the following purposes:
Purposes and data categories (summary)
Sales and marketing of Nexio Projects services
Data: social media profile; unique identifiers for social media; contact details (such as email)
Improving our services and user experience
Communicating with clients and potential clients on social media
Nexio Projects may also process public social media posts to stay up-to-date on and respond to social media activity in relation to its business.
Where appropriate, Nexio Projects will ask your consent for the processing. In other cases Nexio Projects relies on legitimate interests for the processing of the personal data for the purposes described above. Such legitimate interests are the same as the purposes that Nexio Projects processes personal data for. The personal data that is stored for the processing described in this paragraph will be deleted when it is no longer needed for the purposes listed in this paragraph. More information about retention periods is available on request.
6. E-mails and other communications
Nexio Projects may send you e-mails with information about Nexio Projects Services, or other information that may interest you. E-mails will only be sent based on your prior consent, unless you register for Nexio Projects Services. If you are registered for a Nexio Projects Service you may receive e-mails about similar services or to help you become a successful client. You can contact us by e-mail to opt-out of our e-mails or use the unsubscribe links provided in the e-mail communications that we send you.
Communications between you and Nexio Projects in the context of your application - such as emails and messages sent through the Careers Portal - may be stored as part of your candidate file for the duration of the recruitment process and the applicable retention period set out in Section 2. More information about retention periods is available on request.
If you are offered and accept a position with Nexio Projects, the personal data collected during the recruitment process - including your application materials, evaluation notes, and correspondence - will be transferred to our HR administration systems and processed from that point onwards in accordance with our general privacy policy as it applies to employees. Your candidate profile in the Careers Portal will be removed in accordance with the retention periods set out above.
7. Nexio Projects' responsibility versus responsibility of third-party processors
In many cases Nexio Projects uses third-party services to process personal data on its behalf. In those cases the third party carries the responsibility for processing within the scope of Nexio Projects' instructions. In the words of the European Union's GDPR, Nexio Projects is the controller and the third-party service is the processor. This privacy policy (only) describes the processing of personal data insofar as Nexio Projects is the controller. The details of the processing of personal data by our processors can be found in the privacy policies of those processors. We encourage you to review the privacy policies of our processors before submitting any personal data to them.
For example, Nexio Projects uses Recruitee (a product of Tellent B.V.) to facilitate recruitment. In that context, Nexio Projects is the controller and Recruitee processes personal data solely on Nexio Projects' instructions.
The other paragraphs of this privacy policy provide detailed information about the processing that Nexio Projects is responsible for. For a simplified overview of who the controller is:
Who is responsible (summary)
Careers Portal functionality (candidate data)
Nexio Projects: controller
Recruitee: processor
Billing / administration / sales / strategy / marketing (contacts & clients)
Nexio Projects: controller
Client support and client success (contacts & clients)
Nexio Projects: controller
Monitoring performance (both)
Nexio Projects: controller
8. Transfers outside of the European Union
A processing of personal data under the responsibility of Nexio Projects may involve a transfer of personal data outside of the European Union (such as to the United States of America and the United Kingdom). In such cases Nexio Projects always remains the responsible party for the processing (controller). In the absence of adequacy decisions (such as the Data Privacy Framework and the UK adequacy decision), Nexio Projects uses standard contractual clauses for use between controller and controller (module one) and between controller and processor (module two) as grounds for legitimising such a transfer. Please note that Nexio Projects will never transfer personal data that it processes on behalf of others, as a processor, outside of the European Union, unless instructed to do so. Please contact us for more information about data transfers to countries outside of the European Union.
9. Your rights, requests or questions
Feel free to contact us if you have any questions regarding your personal data. You can also contact us with requests to exercise your rights under European data protection law. Such rights include the rights to: access your personal data and receive a copy of it; have inaccurate personal data corrected; have your personal data erased in certain circumstances; restrict the processing of your personal data in certain circumstances; receive your personal data in a structured, commonly used, and machine-readable format (data portability), where processing is based on consent or contract and carried out by automated means; object to the processing of your personal data on grounds relating to your particular situation; and not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. Where we rely on your consent as the legal basis for processing, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing prior to the withdrawal. Wherever we rely on your consent, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
There are instances where we have a legitimate interest to use your data. Our legitimate interest will vary depending on what we are using your data for, and we explain above what the interest is and how it relates to the processing operations that we are carrying out. Where we process personal data on the basis of a legitimate interest, then, as required by data protection law, we have carried out a balancing test to document our interests, to consider what the impact of the processing will be on individuals and to determine whether individuals' interests outweigh our interests in the processing taking place. You can obtain more information about this balancing test by contacting people@nexioprojects.com.
If you would like to exercise your rights or otherwise have any requests or questions with regard to your personal data you can contact us at: people@nexioprojects.com.
If you have unresolved concerns, you have the right to complain to a data protection authority in the country that you reside in or, the country of your place of work or the country where the alleged infringement took place. If you are based in the EU, you can find the contact details of your local data protection authority here.
10. Other
Nexio Projects may also process personal data to investigate or address claims or disputes relating to use of its services, to satisfy requirements under applicable laws, regulations, or agreements, or pursuant to legal process or governmental request, including from law enforcement. Nexio Projects relies on compliance with a legal obligation as a legal basis where the processing is necessary for compliance with applicable legal requirements. Otherwise, Nexio Projects relies on its legitimate interests as a legal basis to perform the above activities on the grounds that they are necessary for purposes of Nexio Projects' legitimate interests in investigating and responding to claims and disputes relating to use of its services.
Further, Nexio Projects may obtain your personal data in ways that are not described in this privacy policy. In those cases you will be informed about the details of such processing through other means than this privacy policy. Please note that if Nexio Projects is processing your personal data then you may always reach out to Nexio Projects to request to exercise your rights, such as asking how we process your personal data. Your rights under data protection law are described hereafter in paragraph 9.
Other recipients of personal data:
Nexio Projects may also process personal data of candidates to investigate or address claims or disputes arising from the recruitment process, to comply with applicable legal obligations, or pursuant to legal process or governmental request, including from law enforcement. The legal basis for such processing is compliance with a legal obligation (art. 6(1)(c) GDPR) or, where applicable, Nexio Projects' legitimate interests in investigating and responding to claims (art. 6(1)(f) GDPR)
11. Updates to this policy
From time to time, Nexio Projects will revise this policy. Nexio Projects recommends that you regularly check whether this policy has been revised. However, where possible, Nexio Projects will notify you via e-mail about any substantive or material changes. This policy does not apply to third-party services that may be accessed through links on the Nexio Projects Website.
12. Nexio Projects' identity and address
The contact details of Nexio Projects are as follows.
Postal mail: Nexio Projects NL B.V., Schiekade 10A, 3032 AJ Rotterdam, The Netherlands, to the attention of the People & Culture Team.
Telephone: +31 (0)85 065 6938
E-mail: people@nexioprojects.com
13. Definitions
The following definitions have the following meanings in this privacy policy:
'Browser and Internet Metadata': The metadata of requests and responses sent to Nexio Projects by your device and by Nexio Projects to your device: time, headers, approximate location, device, browser, unique identifiers such as IP-address and referrer;
'Candidates': Any candidate, potential candidate, applicant or potential applicant for a job position at Nexio Projects or visitor of the Nexio Projects Careers Site;
'Careers Site': The website used by Nexio Projects for talent acquisition purposes, including the publication of vacant job positions and job application forms, available at nexioprojects.com/careers and nexioprojects1.recruitee.com;
'Clients': Nexio Projects' paying and non-paying clients for its Services;
'Contacts': Individuals whose personal data Nexio Projects processes in the course of its business operations, including current and potential clients and business partners;
'Nexio Projects': Nexio Projects NL B.V. and its subsidiaries;
'Nexio Projects Services': Any services provided by Nexio Projects;
'Nexio Projects Website': nexioprojects.com and any other websites operated by Nexio Projects;
'Referrers': Anyone who refers a Candidate to Nexio Projects;
'Usage Patterns': Logs and statistics of which pages, functionalities, buttons, links and forms you have used at which time;
'Visitors': Anyone that visits the Nexio Projects Website.