Recruitment Privacy Policy

5th of MAY, 2024

Version: 3.0

1. Information

The General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and the Council of 27 April 2016, hereinafter referred to as "GDPR") and the applicable legislation ensure the protection of individuals with regard to the processing of personal data and the free movement of such data. The GDPR defines personal data as “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”.



Use of data processors

Data processors are third parties who provide elements of our recruitment service for us. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. We may share your information with client companies, however, we will ensure that they process it securely and keep it only for the stipulated period.

If you use our online application system, you will provide the requested information to Workable who provide this online service for us. Once you apply on Workable’s website , they will hold the information you submit and Mindera will have access to it.

By submitting your job application and/or using Workable you acknowledge and agree to the practices described in this policy and Workable’s policy. We can receive your application via email, or through employment agencies. This privacy policy also applies to you.



Information provided by the candidate

When the candidate completes the application form, the following personal information is requested:

  • first name and last name;
  • e-mail address and phone number;
  • It’s also required to share your profile on GitHub, GitLab.com and/or Bitbucket or others that the candidate deems relevant. Not mandatory;
  • ability to work in the country for which you are applying for employment.

When the candidate shares their resume with us, they have the power to control the information they share. It’s important that you share your information with us, such as:

  • education level;
  • professional experience;
  • positions in which you have expressed your interest or for which you would like to apply;
  • certificates of studies, as well as any supporting documentation attached to your resume, such as copies of certificates and diplomas;
  • spoken languages;
  • pay details such as salary information depending on your region;
  • information provided by you may be reviewed or analyzed on a case-by-case basis by the end user, at their own risk/responsibility.

We don’t need to known your personal data in relation to your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation. If you share this data, we will consider that you authorized it to be processed, however, we’d advise against it/rather you don’t in order for better compliance with the principle of minimization, in accordance with GDPR.

We may, however, for certain roles, need to run a Background Check on you, if you consent to do so, because some of Mindera’s International Clients demand that those be ran on the employees that work on their projects, so it will be a requirement related to the performance of the contract and because of the nature of job.

Background checks are legal provided they comply with the GDPR and national data protection laws. However, there are specific regulations and restrictions that recruiters need to be aware of when conducting background checks.

For instance, GDPR specifies that personal data should not be kept for longer than necessary for the purpose for which it was collected, and, Mindera, taking into consideration the need to know principle, will not have access to your background check’s personal data, nor will it be stored.

Mindera will use specialized companies with whom it has previously audited to validate that they comply with GDPR and to ensure the candidate meets the company's standards and requirements to verify a potential hire’s work history, education, professional qualifications, and any criminal records.

These results will never be shared with us. Mindera will only know if you have the profile needed, asked for and analyzed by the subcontracted Recruitment Companies.

Also, we will never use background check information to discriminate based on protected characteristics, such as age or gender, or other similar personal information.



Assessments

We may ask you to participate in the first assessment and/or first call; completing exercises in Devskiller amongst others and/or attending interviews. The information will be generated by you and us. For example, you can complete a written test or we can take interview notes. This information is maintained by Mindera.

If you are unsuccessful following assessment for the position you have applied for, we would like your details to be retained in our talent pool, for a period of one year. During this period, we would proactively contact you should any further suitable vacancies arise.



Purposes of the Processing of Personal Data

The personal data processed will only be used for the following purposes:

  • Management of spontaneous applications and recruitment processes;
  • Management of applications for courses offered by Mindera;
  • Communication by email or phone;
  • Communication with you by LinkedIn, Cord or Instagram;
  • Send you notifications and/or messages about new positions that may match your profile;
  • Assessments;
  • Communication and clarification;
  • Processing of information requests;
  • Verify, maintain and develop systems or statistics;
  • Access Mindera technology and developments, in different workflows, directly or through third parties.

Mindera guarantees the confidentiality of all personal data provided. Mindera collects and processes data in a secure manner and prevents its loss or manipulation by using the most appropriate techniques. It should be kept in mind that the collection of data and its flows, in open and not controlled networks, allows personal data to circulate without safety conditions, with the risk of being seen and used by unauthorized third parties, for which Mindera won’t be liable.



Lawfulness for the processing of personal data

Your personal data will be processed:

  • when you give us your consent to the processing of your personal data for certain specific purposes;
  • when they are necessary for the performance of a contract to which you are a party, or for pre-contractual proceedings at your request, in which case you must provide your data under penalty of it being impossible to fulfill the contractual obligations to which Mindera is obliged and to that effect cannot provide its services;
  • when they are necessary to comply with legal obligations;
  • for the purposes of the legitimate interests pursued by Mindera or third parties, unless your interests or fundamental rights and freedoms that require the protection of personal data prevail.


Exercise of Data Subject Rights

In accordance with the provisions of the LDPD and the GDPR, the user may exercise at any time his/her right to information, access, rectification, erasure, limitation, portability and opposition by means of a written request addressed to Mindera, through the following means:

  • Through mail to the following address: Rua Gonçalo Cristóvão, n.º 347, 4.º piso, sala 404, Porto.
  • Through e-mail to the following address: privacy@mindera.com.

If these rights are exercised, then the user must specify the nature of their claim and identify himself. Once the identity of the user has been confirmed, to ensure the request isn’t being made by a non-authorised third party, the claim will be attended to in full accordance with the necessary legal requirements/deadlines.



Who we share your data with

We share your data with Workable which serves as a storage and management tool for the recruitment process.

In addition, we may share your candidate profile with Background Checks companies or our clients, to find out if your profile fits the project.



Security Measures

Mindera states that it has implemented and will continue to implement the security measures (of a technical and organizational nature) necessary to guarantee the protection of the personal data we are provided. We’ve implemented and continue to implement these measures to prevent the data’s alteration, loss, unauthorized processing and/or access, taking into account the current state of the technology, the nature of the data stored, and the risks that it is exposed to.

Mindera guarantees the confidentiality of the data provided through this website. All data will be in a secure infrastructure that is safeguarded through the use of data encryption. You may find that your browser communications are secure if a block appears in the web address bar, or if the address starts with HTTPS instead of HTTP only. However, as the internet is not completely secure, we warn that your personal data can circulate on open networks, without security conditions, that Mindera is not responsible for and cannot be held responsible for, at the risk of being seen and used by unauthorized third parties. This means that any transmission of your personal data will be at your own risk.



Data Retention

The personal data of any candidate who applies to Mindera will be kept in the database for one year after its last update.

The background checks personal data of any candidate who applies to Mindera will not be kept in the database.



Other considerations

Mindera is not responsible for any acts or omissions of third parties, namely, links to other websites and their contents.

In case of a merger, division, transformation, dissolution, or insolvency of the Mindera commercial company, your data may be transferred to third parties, as a commercial asset. In the event of this happening, the transfer of your data will always be in compliance with the applicable law and will always maintain your rights as the data owner, namely as to the consent given and the rights of opposition, access, rectification, deletion, limitation, and portability.

For more information, please contact us by email at privacy@mindera.com .



Privacy Statement

You can read about Mindera’s Privacy Policy here.



You can read about Mindera’s Cookie Policy here.



Terms & Conditions

You can read about Mindera’s Terms & Conditions here.



Workable

You can read about the Workable Privacy Policy here.



DevsSkiller

You can read about DevsSkiller Privacy Policy here.



Supervisory Authority

In accordance with the law, the data subject has the right to submit a complaint regarding the protection of personal data to the competent supervisory authority.



Changes to the Recruitment Privacy Policy

Mindera may change this Privacy Policy at any time. So, it is recommended that users check our Privacy Policy regularly and/or each time they access this website, where it will be properly advertised and easily accessible.