VALPEO is the party responsible for the processing of personal data. We process your personal data in accordance with the applicable legal provisions resulting from Regulation 2016/679 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 (“GDPR”).
Fabiaan Van Vrekhem
In it, we explain how we handle your personal data, what your rights are, how you can exercise them, etc.
2. Our responsibilities
If you are a registered VALPEO user or complete one of our surveys, we act as the controller of personal data. This means that we determine the means and purposes of the processing of your personal data.
Personal data we collect
When you visit our website, register with us (as a partner, customer or candidate) or sign up to receive our newsletters or request information about our products or services, we may collect, store and use certain personal information about you. The following personal data may be processed:
As a customer or supplier:
- Personal identification data: name, title, address, email address, telephone number.
- Financial identification data: bank account numbers.
- Financial transactions: amounts to be paid and payable by the person on file
- Indemnification: details of the indemnification claimed, the amounts paid or other forms of compensation.
- Professional activities of the person on file: nature of the activity, nature of the goods or services used or supplied by the person on file, business relationships.
- Agreements and settlements: details of settlements or commercial agreements, agreements on representation or legal agreements, details of agents.
As part of our Executive Search, Executive Interim Management and Assessments services:
- Personal identification data: name, title, address, email address, telephone number;
- Personal data: age, gender, date of birth, place of birth, marital status, nationality, language;
- Opinions about personality or character;
- Marriage or current form of cohabitation: name of the spouse or partner, maiden name of the spouse or partner, date of marriage, date of the cohabitation contract, number of children, etc.;
- Details of other family members or relatives: children, dependents, other relatives, collateral relatives, parents and descendants;
- Leisure activities and interests: hobbies, sports, other interests;
- Memberships (other than professional, political or trade union memberships): memberships of charitable or voluntary organizations, clubs, associations, associations, organizations, groups, etc.;
- Academic curriculum: overview of schools, institutions, universities attended, type of courses taken, diplomas sought, examination results, other diplomas obtained, assessment of the progress of studies;
- Professional competence: certificates and vocational training, special driving licences (driver, etc.);
- Work experience: professional interests, research interests, academic interests, specialization subjects, teaching experience, consultations;
- Membership/participation in professional organizations: details of the groups, committees or commissions involved, functions performed, special interests and summary of participation;
- Publications: books, articles, reports, published audiovisual material;
- Current employment: employer, position and description of the position, rank, date of hire, place of work, specialization or type of business, terms of employment, previous positions, and previous experience with the current employer;
- Recruitment: date of recruitment, method of recruitment, source of recruitment, references, details of the probationary period;
- Termination of employment: date of departure, reason for departure, notice period, notice conditions;
- Career: previous positions and employers, periods out of work, military service;
- Assets owned by the staff member: car, tools, spare parts, reference books, other items owned by the clerk;
As part of our Executive Search and Executive Interim Management services:
- Physical Description: Size, Weight, Hair Color, Eye Color, Distinguishing Features;
- Public mandates exercised: positions at municipal, provincial, regional or community or federal level, participation in government commissions or working groups or reflection groups;
As part of our Executive Interim Management and Assessments services:
- Marriage Record: data on previous marriages or unions, divorces, separations, names of former partners;
- As part of our Executive Interim Management service;
- Organization of work: current responsibilities, projects, hourly rate billed, schedule, hours worked.
When using our website: your IP address, surfing behavior, search terms used;
When you sign up for our newsletter: your e-mail address.
We may also receive personal data from third parties (such as credit reference agencies) who are legally entitled to disclose that information to us.
Information collected automatically: Like most website providers, we analyze server log files to compile statistical information about how our website is used. This type of information is collected only at an aggregate level and includes browser types, operating systems, IP addresses, referring/exit pages, platform types, and date/time stamps.
How we use the information we collect
We use the information we collect to support products or services offered by us. The following sections describe some of the ways in which we may use your Personal Data:
Fulfill your requests · We may use your Personal Data to respond to your questions and fulfill your requests. If you contact us, we may keep a record of your contact details and correspondence, and we may use any information you provide in your message to respond to your inquiry.
Business Purpose · We may use your Personal Data for our business purposes, such as audits, internal communications relating to candidates and clients, determining the effectiveness of our promotional activities, administering our products and services, maintaining and securing our infrastructure, and for procurement and financial transactions.
Informative notices · VALPEO may, from time to time, send informational e-mails, articles, white papers, proposals, order confirmations and other information relating to our products and/or services. Occasionally, and with your consent, we may use your Personal Data in press releases and direct marketing materials. We may also use your Personal Data, such as email or postal addresses, to conduct surveys.
Customer service · Notifying you of any changes to our service, resolving issues via live chat support or email, including any bug fixes.
Marketing purposes (with your consent) · To send you emails and messages about new features, products and services, and content. Legal basis for this use of data: consent. Here’s what each of these “legal bases” means: Consent = You have given your clear consent to process your personal data for a specific purpose.
Administrative information · We may use your Personal Data from time to time to send you important information about our products and/or services, changes to our terms and conditions and policies, and/or other administrative information. We may also contact you from time to time to verify that your Personal Data that we have collected is accurate and up to date.
Other activities · In addition, we may use and disclose your Personal Data to improve the delivery of our products and/or services, including, but not limited to, the following:
Additional activities. In the context of providing our products and/or services, we use personal information we have collected about candidates to identify professional opportunities that we believe may be of interest. We may contact potential candidates from time to time regarding such opportunities. We may also contact individuals from time to time to request names of or other personal information about potential candidates in connection with a search we conduct and for market intelligence purposes.
We also use personal data to confirm references and conduct education and background checks where necessary. We may further use the personal data we collect to aggregate and disclose diversity statistics and other statistical information about our candidates and placement activities.
Additional activities for our services. In the context of providing our services to our customers, we may use your Personal Data that we have collected through reviews we have conducted about you.
Analysis · We may retain and use information about you, including, for example, your personal data, for research, publication, development, benchmarking and standards, validation, longitudinal studies, trend analysis and to improve and expand our products and/or services or to develop and market new products and/or services. Any published final product may or may not just refer to larger collections of individuals and will not identify you personally or contain results that can be attributed to you.
Key-encrypted data · We may give your personal information a key code, which means that such information is stripped of any information that can identify you (direct identifiers) and replaced with a key code to minimize unwanted or accidental identification. Such key-encrypted information can be decrypted through the use of the key so that it identifies you again. We may use such information for the purposes described in the section above titled “Analytics” and as permitted by applicable law. Any published final product may or may not just refer to larger collections of individuals and will not personally identify you or contain results attributable to you.
As part of our Executive Interim Management service:
- Administration of Employees: the recruitment and selection of Employees, the administration of salaries, allowances, commissions and wages and the application of social legislation with the execution of the contract as the legal basis.
- Employee management: evaluation and follow-up of staff and intermediaries and planning of training and careers based on the execution of the contract.
- Work planning: the planning and follow-up of tasks, workload and performance with the execution of the agreement as the legal basis.
As part of our Executive Search service:
- For recruitment, selection and development purposes by prospective employers, managing recruitment and human resources processes and any related purpose for which you have consented to collection, with the legitimate basis being your consent.
As part of our Assessments service:
- Analysis regarding the qualities required for a particular position, with your consent as a legitimate basis.
3. Disclosure to Customers, Affiliates, Service Providers, and Others
Disclosure to clients · In the context of providing our products and/or services, we may disclose your Personal Data to customers who have purchased our products and/or used our services:
- In the context of providing our products and/or services, VALPEO may disclose assessment and other information to the employer/client who has engaged VALPEO and to designated personnel of the customer. Assessment and other personal information collected by our consultants or provided by our client may be held in a database and/or platform that VALPEO deems appropriate in its sole discretion so that our clients and/or certain personnel designated by our clients will have access both during and after the conclusion of our engagement. If you take our assessments, we will not use your assessment reports in providing our products and/or services without your consent.
- In the context of providing our products and/or services, we may provide Candidate Personal Data, including the results of assessments, to potential employers who have engaged VALPEO to fulfill searches, or to consult resources.
Disclosure to VALPEO companies · Subject to the provisions of the applicable law, your Personal Data may be disclosed to the companies affiliated with VALPEO. Further, from time to time, VALPEO may also disclose your Personal Data to our network of independent consultants who provide Services on behalf of VALPEO for the purposes listed above.
Disclosure to Service Providers · VALPEO collaborates with third parties, who provide services that may include, but are not necessarily limited to; website hosting and IT support and consulting services; data analysis; resume verification; background checks; payroll; public relations services; lawyers, accountants and other administrative and backup and security services. As part of providing these services, such third parties will have access to your Personal Data. In addition, our software development partners may use your Personal Data to modify, improve, refine, and validate their technology and research and development.
Business Transfers · VALPEO reserves the right to disclose or transfer any personal information that we have collected from visitors, or that we otherwise collect in connection with our Services, to a third party, or in the event of a sale of our business or any of our affiliates, or a merger or consolidation involving our company or any of our affiliates, or a sale or transfer of assets or of any portion of our business or the business of one or more of our affiliates.
Other Disclosures · VALPEO may also use or disclose personal data to: (i) comply with applicable laws and regulations; (ii) respond to inquiries or requests from public or government authorities, including those outside your country of residence; (iii) comply with valid legal process; (iv) protect the rights, privacy, safety, or property of VALPEO, users of the Online Systems, or the public; (v) allow us to pursue available remedies or limit the damages we may incur; (vi) enforce our Legal Disclaimer; (vii) enforce our Terms of Service; or (viii) respond to an emergency. We cannot and do not accept any responsibility for the acts or omissions of third parties, such as customers, including the manner in which they use personal information received from VALPEO or from other independent sources.
4. What about really sensitive data?
We do not collect “sensitive data” about you (such as racial or ethnic origin, political opinions, religious/philosophical beliefs, trade union membership, genetic data, biometric data, health data, data concerning your sex life or orientation, and offences or alleged offences), except where we have your specific consent, or where we are required to do so to comply with the law.
5. What about children’s data?
VALPEO is a service directed at and intended for use only by individuals 18 years of age or older. We do not target VALPEO to children and we do not knowingly collect personal data from anyone under the age of 18.
6. Additional Guidelines
VALPEO may, from time to time, sponsor special features or promotions on the website, and additional privacy information may be posted. That privacy information, to the extent it conflicts with this policy, applies to that specific position or promotion.
7. Your Privacy Choices and Rights
Providing personal information to us is voluntary, but if you do not provide certain personal information, you may not be able to participate in our website, products, and/or services.
- You can disable cookies in your browser by changing the settings.
You may contact us at email@example.com if you would like to receive certain information about whether or not we hold personal information relating to you and to obtain a copy of such information.
If you: (i) want to ask questions about how we handle personal data; (ii) review, correct, or update your personal information; or (iii) request that your personal information be removed from VALPEO’s database, please contact us at firstname.lastname@example.org. Please note that we can only provide you with a non-confidential summary of our final assessment report, as such a report contains confidential client information that we are not permitted to disclose. You can request to be removed from VALPEO’s database by placing “Delete User” in the subject line of the email and including your full name, VALPEO reference code, and phone number in the body of the email.
We will endeavor to comply with your request as soon as reasonably practicable and may need to contact you to ensure that we are removing the correct information. Please note that we cannot be responsible for removing your data from our database if that data is part of our products and/or services on behalf of your company. In that case, it may be necessary to address your request to the management of your company. However, we will forward your request to the appropriate person in your company.
We may also need to retain certain information about you, such as your email address, in order to comply with opt-out or similar requests. Please note that this residual information remains in VALPEO’s databases, access logs, and other files, which may or may not contain personal information about you. The residual information will not be used for commercial purposes. However, VALPEO reserves the right to contact former users of our website, products and/or services from time to time.
You can exercise your rights by sending an e-mail to email@example.com
You have the right to access the information we hold about you
This includes the right to ask us for additional information about:
- The categories of data we process
- The purposes of data processing
- The categories of third parties to whom the data may be disclosed
- How long the data is kept (or the criteria used to determine that period)
- Your other rights in relation to our use of your information
- We will provide you with the information within one month of your request, unless this would adversely affect the rights and freedoms of others (e.g. the confidentiality or intellectual property rights of another person). We’ll let you know if we can’t accommodate your request for that reason.
You have the right to request that we correct inaccurate personal data about you
You have the right to withdraw your consent and have us delete your personal data
You have the right to request a restriction of the processing of your personal data
You have the right to data portability
You can object to the use of your data to profile you or make automated decisions about you
- We may use your data to determine whether we need to let you know information that may be relevant to you (for example, tailoring emails to you based on your behaviour). Otherwise, the only circumstance in which we will do so is to provide the VALPEO service to you.
You have the right to be ‘forgotten’ by us
- You can do this by asking us to delete any personal data we hold about you, if it is no longer necessary for us to keep the data for your use of VALPEO.
You have the right to complain about our use of your information
- Please let us know first so we have a chance to address your concerns.
8. How secure is the data we collect?
VALPEO has implemented reasonable organizational, technical, and administrative measures to protect against the loss, misuse, and alteration of personal information about users of our website, products, and/or services, which are under our control. Unfortunately, however, no security system or system for transmitting personal information can be guaranteed to be 100% secure
We have the following measures in place for the security of your data;
- The computers on which data are processed are protected by default with a username and a complex password.
- All computers are equipped with a Small Office Security solution, which is of course always kept “up to date” and automatically performs multiple scans. All Windows installations are automatically updated. The installation is checked at least once a month and started manually if necessary.
- The data is stored on a part of the disk that is set up as a “data vault.” This is encrypted and can only be accessed after starting the computers + Windows login + opening a password vault.
- To avoid data loss in the event of loss of the computers, we make daily backups to an encrypted cloud environment.
- All passwords are managed and stored in the cloud environment.
- Our employees are fully informed about the safe handling of your personal data and are bound by their employment contract to confidentiality.
- No data is kept on paper due to the possibility of online registration and is not accessible to unauthorized persons.
If you have reason to believe that your interaction with us is no longer secure (for example, if you believe that the security of any account you have with us has been compromised), please notify us immediately of the problem by contacting us in accordance with the “Contact Us” section at the top of the homepage.
9. Where do we store the data?
Your Personal Data may be collected, used, processed, disclosed, and transferred to and within Belgium and other countries where we maintain operations or engage service providers. By using our website, products and/or services, you consent to the transfer of information to countries outside of your country of residence, which may have different data protection rules than in your country.
10. How long do we keep your data?
- Business books: 7 years in original or electronic form, with the retention period starting from 1 January of the year following the close of the financial year. Here we follow Article III.86 of the Code of Economic Law and Article 9 of the Royal Decree of 12/09/1983 implementing the law of 17/07/1975 on the Accounting of VALPEO.
- Justifying documents: 7 years in original or electronic form, starting with the retention period following the close of the financial year. Here we follow Article II.86 of the Code of Economic Law.
- Documents that do not serve as evidence against third parties: 3 years in original or copy, again applying Article III.86 of the Code of Economic Law.
11. Third parties processing your data
Tech companies often use third parties to help them host their application, communicate with customers, power their emails, etc.
International Trade Administration (ITA) of the Ministry of Commerce.
Here are the details of our main third-party service providers and what data they collect or we share with them, where they store the data and why they need it: