1. Who are we?
Hyphen is a service company active in consultancy and interim management. We are based in Belgium and are represented by Guy Vaes.
2. Why do we have a privacy policy?
Because of the nature of our business we do have to process a lot of personal data. To make sure your data is protected and only used where needed we are committing to you to keep the highest standards on privacy as possible. Under the GDPR (that is the new privacy law applicable within the EU) we are obliged to inform you what we do with data collected via electronic means. This privacy policy is therefore applicable to all information transferred to us through electronic means (website, e-mail).
Please do note when you contact us through another electronic medium (like Facebook or Twitter), the privacy policy of that website precludes this privacy policy in case of collision.
3. How can you reach us?
For any questions, enquiries or other actions on privacy matters you can contact us through the following channels:
- Phone: +32 3 361 01 01
- E-Mail: privacy@hyphen.be
- Address: Scheldestraat 11, 2000 Antwerp
- Website: www.hyphen.be
4. Which data information do we collect and what do we use it for?
For the processing of the following data as a future or current customer of hyphen, we ask your permission. We will also process these when it is necessary for the execution of the contract between you and hyphen.
Personal identification data
Name, title, address (private, work), previous addresses, telephone number (private, work), identification data assigned by the responsible party: we process this data to identify you within hyphen.
Financial details
Identification and bank account numbers, credit or debit card numbers) / Professional activities / Agreements and arrangements (freelancers): we need such information to make payments to freelancers when they are on our payroll.
Personal characteristics
Personal details (age, gender, date of birth, place of birth, marital status, nationality): we need your nationality to see if you qualify for certain positions where a Belgian or EU / EEA nationality requirement applies, as well as to verify whether you need certain documents to work. We do not expect any other data on personal characteristics. If however you decide to share them with us, you agree that we are allowed to process them to complete your profile.
Training and education
Academic curriculum / Professional competence / Professional experience: Academic curriculum / Professional competence / Professional experience: to offer you the best possible vacancies, we need your academic background.
Profession and employment
Current position / recruitment / termination of the job / Career / Wages / Assets held by the person / organization of the work / Evaluation / Training as a function / Use of IT resources: to offer you the best possible vacancies, we would like to have a detailed profile of your work experience in order to find a job that matches your previous experience and competencies.
Leisure activities and interests
We do not expect any information about hobbies and interests from candidates. If however you decide to share them with us, you agree that we are allowed to process them to complete your profile.
5. Who has access to your data?
The consultants of hyphen, have access to your data, strictly when necessary to perform a processing described above.
We always ask your consent before we transfer any personal data. Your data is also transferred to our customers who are looking for a talented employee. We always ask you for permission before we transfer your personal details. The categories of data sent to the customer depend on the specific circumstances and on what you have provided to us in your CV. That is why we kindly ask you not to provide information at this stage that you do not yet want to disclose. This can of course have an effect on the effectiveness of our matching. Therefore, we ask you to consider how detailed you want to be when drawing up your CV.
We will not transfer your data to customers outside the EEA (European Economic Area) without your specific consent.
6. How long is my data kept?
We keep your data as long as we are in contact with you. If we no longer have contact with you for 2 years, we will delete your data from our systems. However, if we have reason to believe that we meet one of the exceptions from the right to be forgotten (see below), we will not delete your data.
7. What are my rights?
Right of access
Every person has the right to access his data. This means that we have to inform you what happens with your data and further detail your rights. In this policy you will find the answers to those questions.
We also have to provide you with a copy of your personal data. You will receive a copy on simple request through one of the above stipulated channels. Please do note that only the first copy is free of charge. We will send you the information through e-mail unless you specifically request to receive the information by post, or when an e-mail is not possible due to technical circumstances.
It is possible that certain documents may contain personal data from other persons who enjoy the same protection as you. We therefore might have to anonymise certain documents, which could take some time. We will always inform you if we are unable to fulfil the request within one month.
Right to rectification (Right to correction)
If we are in possession of incorrect or no longer up-to-date data, we will adapt this again on simple request through one of the above-mentioned channels. If we would assume that the data we have of you is no longer up-to-date, we might contact you to verify this.
Right to erasure (Right to be forgotten)
Under a limited number of circumstances, you can ask us to delete your data. When you meet one of the criteria below, we will delete your data without delay. We will however keep your e-mail address and/or phone number and/or address and/or name on a black list, so our system will notice that you no longer wish to be contacted.
Criteria for erasure:
- We no longer process or need your data
- You withdraw your consent to processing which was based solely on consent
- You invoked your right to object (see below)
- Your data was unlawfully processed
- There is a legal obligation to delete the data
- Your data was collected in relation to the offer of information society services.
To the right to be forgotten there are also some exceptions in which case we cannot delete your data. If this would be the case, we will inform you about this. The reasons not to abide your request would be one of the following:
- The right of freedom of expression and information prevails
- For compliance with a legal obligation
- For reasons of public health
- For archiving, research or statistical purposes in accordance with article 89 of the GDPR
- For the establishment, exercise or defence of legal claims.
Right to restriction of processing
You can notify us in a case where you assume that we are incorrectly processing your data. This could be the case if we are in possession of inaccurate data, if our processing is assumed to be unlawful, if there is a situation at hand of legal claims or if the right to object of article 21 (see below) is invoked. We will cease processing (with the exception of storage) until the matter has been clarified. When an agreement is made, the claim has been deemed incorrect by us, or any other circumstance makes it that the restriction does no longer have a ground to be based on, we’ll notify you on the reasons of the lifting of the restriction.
Right to notification
When a person invokes the above-mentioned rights, with the exception of the right to access, we’ll communicate this to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. We shall inform you about those recipients at your request.
Right to data-portability
Any data you handed us, that we process based on consent, and which we process via automated means, will be transferred to you or another controller (if technically feasible) upon request in a machine-readable format.
Right to object
When we process data based on legitimate interest or on the basis of public interest, you have the right to object. We’ll investigate your objection and will only continue processing after the investigation if we can prove that we have a legal reason to continue the processing. The conclusion of the investigation will be communicated to you.
When you object to direct marketing, we will no longer send you any direct marketing starting immediately from the moment we receive your request.
8. Can I withdraw consent?
Yes, at any point in time you can withdraw your consent to the processing of data. There are however two exceptions. First, if there is another legal ground for processing your data, we still will process your data on that legal ground. Secondly, withdrawing consent may not be used to circumvent contractual obligations. In short, if you withdraw consent it will only work towards the future, all previous processing will be deemed legal, and if the necessity to perform a contract is present the data will be processed further on that basis.
9. I want to file an official complaint, where can I go?
If we were not able to satisfy your request, you always have the right to lodge a complaint. You can do so by contacting the Belgian supervisory authority via https://www.privacycommission.be/en/contact-us in an official language of Belgium.
10. I see some fields on your website are mandatory to fill. Why is that?
To abide legislation or due to contractual reasons, we need sometimes a minimum of information to be able to work, process your data, or to fulfil a legal requirement. Underneath you will find a scheme of mandatory data and the reason why.
We only ask you to give a name and e-mail address to contact and identify you. Everything else you give to us, you do so on a voluntary basis.
11. What about profiling/automated decision making?
Our consultants are looking in person for a job that suits you. You will not be bound by any decision via automatic means.