Privacy Notice

This Privacy Notice (“Notice”) describes how Protiviti EOOD, a limited liability company having its seat in Sofia and registered address at 1766 Sofia, Ring Tower Blv. Okolovrasten pat 251E, registered with the Bulgarian Commercial Register under Company registration No. 200796649 (“We”, “Us”, “Our” or “Protiviti”), may use, process, store and disclose Personal Information that We may collect about individuals, including if you register with Us via Our Associate Registration process, through this website and from other sources, such as when you apply for a job through job sites such as Totaljobs, Indeed, Jobsite, and Jobserve. The types of data We collect are described in the section below ‘Your Personal Information and how We collect it.’

We act as a controller under the meaning of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“General Data Protection Regulation” or “GDPR”) and We are responsible for the Personal Information We process. This Notice informs you how We protect your Personal Information and informs you of your privacy rights.

It is important that you read and acquaint yourselves with this Notice together with any other notice We may provide (e.g. the notice contained in Our associate registration form) and on specific occasions when We are collecting or processing your Personal Information so that you are fully aware of how and why We are using your Personal Information. This Privacy Notice supplements other notices you may receive from Us and is not intended to override them.

This website is not intended for use by legal minors and We do not knowingly collect data relating to legal minors.

Contact details:

If you have any questions about how We use your Personal Information, contact Us at: [email protected].

1. Your Personal Information and how We collect it

Use of or registering with this website

When you use or register with this website, such as searching for information or applying for a job, We may ask for certain Personal Information including your name and contact information (email, home address and phone number). Depending on the nature of your enquiry or activities on Our website, We may also ask for and/or collect:

• your job search criteria, salary expectations and preferences;
• job title, company name, employment history, employment experience, educational history, skills and salary;
• information about your professional interests through white papers or newsletters you collect, as well as professional interests that you describe to Us;
• other background information together with any login ID and password created by you;
• information you provide including in emails, letters or during telephone calls
• technical data including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. We may also receive technical data about you, if you visit other websites employing Our cookies. Please see Our Cookie Policy for further details;
• profile data including your username and password, your interests, preferences, feedback and customer survey responses;
• usage data including information about how you use Our website and services;
• marketing and communications data including your marketing and communication preferences.

In relation to a job applicant, the Personal Information and information set out above provides Us with an explanation of a job applicant’s past work experience, including details of any gaps or periods of unemployment and academic background, and may be used to obtain references. We may directly contact your referees only subject to your prior written explicit consent. We may ask you to provide proof of identity for verification purposes only (without copying or retaining such documents), as well as other original, documentation in paper format, including evidence of immigration status and qualifications and We may verify some or all the information you provide in relation to your application for a job. We may process your Personal Information relating to criminal convictions when you apply for job position at Protiviti and there is a legal requirement under law for the processing of this data. We may use a third party to perform background screening and verification services and We will inform you at the time.

You can request Us to send you job alerts through the website by completing your job search criteria and preferences. You can stop receiving these job alerts at any time by clicking on the unsubscribe link contained in the job alert email. If you provide Us with information about 3rd parties, We will assume that the 3rd party in question has given you consent to do so and to Protiviti collecting, processing and transferring their Personal Information to the same extent as yours.

2. Registering as an associate for work finding services

We will collect your Personal Information directly from you and from other sources including when you apply for a job via a Job Board, directly through Our website, from social media sites such as LinkedIn, or when you provide Us with your details during a job fair, promotional, networking or training event. When you ask Us to provide you with work finding services, We will ask you to register as an associate. During Our associate registration process We will collect your Personal Information directly from you, your CV, from employment and educational referees (where you have consented to Us contacting your referees) and via online tests you may perform at Our request. Our clients may request additional Personal Information about you in relation to their job vacancies and requirements. The categories of Personal Information We may collect include:

• your identity (your full name, gender, date of birth, personal identification number);
• evidence of your right to work in Bulgaria, which may include a photograph, nationality, place of birth, residence and work permits, driving licence (where relevant for your job profile) etc.(in accordance with the requirements of Bulgarian law);
• contact details including your email, home address and phone numbers;
• bank account (so We can make payments to you and account for tax if you are working as an associate supplied by Protiviti);
• your job search criteria, preferences and expectations;
• your qualifications, skills, experience and training;
• current remuneration and other benefits;
• educational history;
• employment history;
• details of employment or educational referees;
• references;
• details of disabilities (where you provide this with your consent and it is relevant);
• other information contained in your CV or that you choose to provide to Us;
• technical data including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. We may also receive technical data about you if you visit other websites employing Оur cookies. Please see Оur Cookie Policy for further details;
• profile data including your username and password, your interests, preferences, feedback and customer survey responses;
• usage data including information about how you use Our website and services;
• marketing and communications data including your marketing and communication preferences.

To provide you with work finding services Our consultants will send you job alert emails matching your job search criteria and preferences. From time to time, you may also receive job alerts which Our consultants consider you may find interesting.

If you provide Us with information about 3rd parties, We will assume that the 3rd party in question has given you permission to do so and to Protiviti collecting, processing and transferring their Personal Information to the same extent as yours.

3. Our clients and suppliers

If you are a client or supplier of goods and services, We will collect and process information about individuals in your organisation to enable Us to communicate with them and to provide Our services or receive goods and services. We may also find the details of corporate contacts published on other websites and social media. We may enter the individual’s name and business email address into Our database as a designated corporate point of contact for that client or supplier, together with the individual’s other business contact data. Usually, the only Personal Information We process is the individual’s name for the purposes of contacting that client or supplier in relation to Our services or as a recipient of the client’s or supplier’s goods and services. If the individual corporate point of contact is also a registered associate, We may be processing additional Personal Information for other purposes described in this Privacy Notice. The source of a corporate point of contact may be the individuals themselves, or their name and business details may be provided to Us by a member of their HR or procurement department or another manager within the organisation. We may send business-to-business email marketing to corporate points of contact. An individual corporate point of contact can ask Us at any time to stop sending business marketing emails to their business email address by contacting: [email protected].

4. How We use your Personal Information

We use, process, store and disclose your Personal Information and other data We collect including during Our associate registration process, for the purposes of performing the services requested and functionalities offered by the site and to provide you with work finding services including sending you job alerts through this website and by email, temporary assignments project related work and permanent and fixed term contract placements in Finance, Accounting, Risk and Compliance, Technology, Operations, HR and other related roles, employment opportunities and career-related information. Protiviti will process your Personal Information in accordance with Our Limited Company Contractor Agreement (provided during Our associate registration process) and We will disclose your Personal Information to Our clients in relation to their job vacancies.

We use, process, store and disclose your Personal Information and other data We collect when you apply for a job at Protiviti (including emails, letters and during telephone calls and conversations) for the purposes described in this Notice and your potential employment relationship including: (a) processing and updating your Personal Information through the use of Our HR online systems, learning platforms, performance management, payroll and pensions systems; (b) business planning, reporting and forecasting; (c) safety and security issues; (d) responding to your enquiries and complaints; and (e) to fulfil legal and statutory obligations.

We will also process your Personal Information for other legitimate business purposes, such as producing statistics, analysing how successful Our marketing campaigns are, the number of visitors to Our website and complying with other contractual, legal and regulatory obligations and duties.

Currently, We do not use automated decision-making technologies to make final or conclusive decisions about you. A member of our staff will always be involved in the provision of work finding services.

5. Change of Purpose

We will only use your Personal Information for the purposes for which We have collected it (e.g., the provision of work finding services if you are an associate or to consider you for employment if you are a job applicant), unless We reasonably consider that We need to use it for another reason and that reason is compatible with the original purpose.

If We need to use your Personal Information for an unrelated purpose, We will notify you and We will explain the legal basis, which allows Us to do so.

We may process your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. Transferring your Personal Information outside of Bulgaria or the European Union (EU) / European Economic Area (EEA)

Protiviti is part of an international group of companies operating globally. We may share some of your Personal Information with Our group companies, including Robert Half Limited a UK based recruitment company, Our parent company Protiviti Inc. and Our ultimate parent company Robert Half Inc., based in the United States, and other group companies within or outside Bulgaria and European Economic Area (EEA), who may use and process your Personal Information for similar purposes as described in this Notice. The data protection laws outside Bulgaria and the EU / EEA may not provide an equivalent level of protection to those in Bulgaria and the EU / EEA and in these circumstances, We will take steps to ensure that your Personal Information is adequately protected, secure, kept confidential and that We have a lawful basis for the transfer. This means that We may require the 3rd party recipient to sign the EU Model Contract clauses approved by the European Commission as providing personal data with the same protection that your Personal Information has when it is processed within EEA.

You can contact Us, if you require further information on the mechanism We use when transferring your Personal Information out of the EEA.

7. Disclosing your Personal Information to members of the Robert Half Group of Companies

We share your Personal Information with Our group companies including Robert Half Limited, a UK based recruitment company providing recruitment and work finding services across its business solution areas.

If you register as an associate with Protiviti, you may also be contacted by Robert Half Limited in connection with job opportunities that Robert Half Limited consider may be of interest to you, such as interim and temporary roles. You may be invited to register directly with Robert Half Limited to enable it to represent you and provide its services. If you have already registered as a Protiviti associate and you later decide to register with Robert Half Limited, We may ask for your consent to share your associate registration documents and your Personal Information with Robert Half Limited for your convenience.

Robert Half Limited has implemented the same high standards of data security as Protiviti and will treat your Personal Information in accordance with the law, respecting your legal rights and as set out in the Robert Half Privacy Notice. Any transfers to the UK would be subject to the adequacy decision approved by the European Commission.

8. Disclosing your Personal Information to 3rd Parties

To the extent necessary or appropriate and without notifying you, Protiviti may disclose your Personal Information to external 3rd Parties (who are not members of the Robert Half group of companies) in the following circumstances:

• to companies and individuals, We employ to perform business functions and services on Our behalf. Examples of service providers include: providing payroll services to enable Us to pay Our employees and temporary workers who work on client premises; background screening and verification services; data storage facilities including in the US and the cloud; hosting Our web servers; analysing data and producing statistics and legal, accounting, audit and other professional services.
• to government agencies including: the Bulgarian National Revenue Agency, police and other law enforcement bodies; regulatory and supervisory authorities.
• to comply with applicable laws, the service of legal process, or if We reasonably believe that such action is necessary to: (a) comply with the law requiring such disclosure; (b) protect the rights or property of Protiviti or its group companies; (c) prevent a crime, protect national security or for fraud detection or prevention; or (d) protect the personal safety of individuals using Our website or members of the public.
• to 3rd parties to whom We may choose to sell, transfer, or merge parts of Our business or Our assets. Alternatively, We may seek to acquire other businesses or merge with them. If a change happens to Our business, We will let you know.
• to IT consultants carrying out testing and development work on Our IT systems, service providers who We may appoint as data processors and to other service providers who may be based in the United States and Australia.

Where applicable, We will impose appropriate contractual, security, confidentiality and other obligations on to 3rd party service providers and processors We have appointed, based on the nature of the services they provide to Us. We will only permit them to process your Personal Information in accordance with the law and Our instructions. We do not allow them to use your Personal information for their own purposes and when Our relationship ends, We will ensure your Personal Information is securely returned or destroyed.

Some of these 3rd parties are also controllers responsible for processing your Personal Information for their purposes, for example, the National Revenue Agency is a controller for tax purposes. We may not be able to impose obligations or restrictions on these controllers in connection with how they process your Personal Information.

9. Keeping your Personal Information secure

We have put in place appropriate security measures to prevent your Personal Information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, We limit access to your Personal Information to those employees, agents, contractors and other third parties who have a business need to do so.

We have put in place procedures to deal with any suspected Personal Information breaches and We will notify you and the applicable supervisory authority of a breach where We are legally required to do so.

10. How long We retain your Personal Information

Protiviti will retain your Personal Information for as long as necessary to fulfil the purposes that We collected it for, including for example making a job application to Protiviti or requesting Protiviti to provide work finding services. This means We will keep your Personal Information throughout the period of your relationship with Us and whilst We are providing you with work finding services.

If you no longer wish to receive Our services, We will continue to retain your Personal Information if you have requested work finding services on Robert Half Limited’s database for a further period of 2 years after Our relationship ends, only if you give Us your consent to keep it for that period of time. However, We will inactivate your associate record and limit access to your Personal Information during this period. After the 2-year retention period expires, We will anonymise the Personal Information in Robert Half Limited’s database so that We can no longer identify you.

We are required by law to keep basic information about Our Associates, clients and customers (including contracts, evidence of identity, financial and transaction data) for up to 5 years from when Our relationship ends, for legal, compliance and tax purposes.

If you are making a job application, We will not retain your Personal Information for longer than is necessary for processing your job application or for legal or regulatory purposes. Additional requirements and policies will apply, if We enter an employment relationship with you and more details will be provided at that time.

Where there is no retention period stated in law, We determine the appropriate retention period for Personal Information by considering the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of the data, the purposes for which We process it and whether We can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances We may anonymise your Personal Information (so that it can no longer be associated with you and We cannot identify you). We do this for research or statistical purposes in which case We may use this anonymised data indefinitely without further notice to you.

11. Your Legal Rights

You have the right to:

Make a Data Subject Access Request to access your Personal Information at any time. This enables you to receive a copy of the Personal Information We hold about you and to check that We are lawfully processing it.

Request correction of the Personal Information that We hold about you. This enables you to have any incomplete or inaccurate Personal Information We hold about you corrected, although We may need to verify the accuracy of the new data you provide to Us.

Request erasure / deletion / removal of your Personal Information. This enables you to ask Us to delete or remove your Personal Information where We do not have a valid reason to continue to process it. You also have the right to ask Us to delete or remove your Personal Information where you have successfully exercised your right to object to processing, where We may have processed your information unlawfully or where We are required to erase your Personal Information to comply with local law. Please Note: We may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your Personal Information where We are relying on a legitimate interest (or those of a 3rd party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where We are processing your Personal Information for direct marketing purposes. In some cases, We may demonstrate that We have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your Personal Information. This enables you to ask Us to suspend the processing of your Personal Information in the following scenarios: (a) if you want Us to establish the data’s accuracy; (b) where Our use of the data is unlawful but you do not want Us to erase it; (c) where you need Us to hold the data even if We no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to Our use of your data but We need to verify whether We have overriding legitimate grounds to process it.

Data Portability / Request the transfer of your Personal Information to you or directly to another controller. This right only applies to automated information which you initially provided consent for Us to use or where We used the Personal Information to perform a contract with you. We will (unless there is an exemption) assist you by securely transferring your Personal Information directly to another controller where technically feasible or by providing you with a copy in a structured commonly used machine-readable format. The data We can provide is:

Withdraw consent at any time where We are relying on your consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, We may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

We want to ensure We keep your Personal Information accurate and up to date. In addition to your legal rights, you may ask Us to make changes or request a copy of your Personal Information informally, by contacting Us at [email protected].

12. Additional information, response times and fees

We may need to request specific information from you to help Us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights or when you make an informal request). This is a security measure to ensure that Personal Information is not disclosed to any person other than the individual who has the right to receive it. We may also contact you to ask you for further information in relation to your request to help Us locate your data and to speed up Our response.

We try to respond to all legitimate requests within one month. It may take Us longer than a month if your request is particularly complex or you have made a number of requests. In this case, We will notify you and keep you updated.

You will not have to pay a fee to exercise any of these rights. However, We may charge a reasonable fee if your request is unfounded, repetitive or excessive. Alternatively, We may refuse to comply with your request in these circumstances.

13. The legal basis for processing your Personal Information

We have set out a short description of main ways We will collect, store, process, share and disclose your Personal Information and the legal bases We rely on to do so. We have also identified what Our legitimate interests are, where appropriate.

We will only use your Personal information when the law allows Us to. Most commonly, We will use your Personal information in the following circumstances:

• To fulfil a contract, We are about to enter into or have entered into with you;
• Where it is in Our legitimate interests;
• When it is Our legal or regulatory duty;
• When you consent.

A legitimate interest is when We have a business or commercial reason to use your information in conducting and managing Our business. We will consider and balance any potential impact on you and your legal rights when We process your Personal Information for Our legitimate interests. We do not use your Personal Information for activities where Our interests are overridden by the impact on you (unless We have your consent or are otherwise required for compliance with a legal or regulatory obligation or permitted to by law).

14. Marketing messages

Generally, We do not rely on consent as a legal basis for processing Personal Information except in relation to sending direct marketing communications via email or text message. In some cases, We may rely on legitimate interest for direct marketing communications, but only where you are already an associate, job applicant or client of Protiviti.

We may use your Personal Information to send you automated email messages or marketing materials regarding Our services. If you are a job applicant, We will provide you with relevant job opportunities. From time to time, We may contact you for market research and quality surveys, including evaluating the effectiveness of Our recruitment process. You may receive marketing communications from Us if you provided Us with your details when you entered a competition or registered with Us at a job fair, promotional or networking event or attended a training course and you have given Us consent to send you marketing. We may also use your identity, contact details, technical data, usage data and profile data to form a view and decide which services may of interest or relevant for you.

We have established an email preference centre where you can view and make decisions about your email marketing preferences and opt out of receiving email marketing from Us at any time.

You have the right to withdraw your consent to marketing at any time by:

• following the opt out links contained in Our marketing email messages;
• following the opt out process described in Our text marketing messages;
• Sending an email with “UNSUBSCRIBE ME” in the subject field to: [email protected].

Opting out of receiving marketing messages does not apply to:

• Personal Information that you have provided to Us as a result of your request for work finding services;
• Personal Information that you have provided to Us in connection with a job application;
• Personal Information that you have provided to Us in connection with the performance of a contract between Us;
• Job alerts sent to you through the website in response to your request to receive specific job details. You can select your preferences in the Job Search section and you can stop receiving these alerts at any time by clicking on the unsubscribe link within the job alert email; and
• Job alert emails which you will receive from Our consultants which match your job search criteria confirmed with you during Our Associate Registration process.

We will never sell or disclose your Personal Information to any 3rd parties to use for marketing.

15. Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies We use, please see Our Cookies Policy.

16. Links to other websites

Our website may include links to 3rd party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these 3rd party websites and are not responsible for their privacy statements.

17. Feedback and complaints

You have the right to make a complaint at any time to the Bulgarian Commission on Personal Data Protection, [email protected], 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592. Further information about your rights and how to make a formal complaint may be accessed on the complaint section of the CPDP's website: https://www.cpdp.bg/en/index.php. We would ask you to provide Us with the opportunity to discuss your concerns with you before you contact the CPDP so please contact: Data Protection Office, Protiviti, c/o MSP Law Firm, Flat 1, Floor 1, 18A Angel Kanchev Street, 1000 Sofia, Bulgaria or email Us [email protected].

18. Changes to this Notice

If We change this Notice We will post any updates here for your review. If We change material terms We will provide notice of the revised Privacy Notice for 30 days on Our home page at protiviti.bg.

This Notice was last updated: 16 May 2022