This document is part of Comeet’s assistance to customers. See the overview here.
Some privacy laws require companies to have friendly privacy policies informing data subjects (including candidates) about their data handling practices (“Notice”). Comeet provides you with tools to include the link to your Notice in the first message sent to candidates and also to automatically email the link to your Notice to candidates who have not received it by other communication methods. Please note that you are responsible to determine which laws are applicable to you and to comply with such obligations. Comeet only provides you tools and features, but Comeet does not represent that such tools are compliant with your requirements and obligations.
Under the transparency principle, you are required to explain your data processing practices to candidates. The Notice must be provided in a concise, transparent, intelligible and easily accessible form, using clear and plain language. Comeet provides an example of a Notice for your consideration, which shall not be considered legal advice. Please make sure that you discuss the privacy requirements and obligations for your Notice with your legal counsel. The Notice should describe your specific privacy practices, such as your data retention period choices (please note that Comeet’s platform allows you to determine the retention period that you would like to implement). Please note that you are ultimately and solely responsible for the Notice that you decide to publish, which could create obligations to the Company and rights to the candidates.
Generally speaking, the Notice should also include, at a minimum, the following aspects:
Your identity and contact details, including the contact details of the data protection officer and representative, where applicable.
The categories of personal data that you collect.
The purposes for which you will collect and process the personal data.
Description of the recipients who have, or will have, access to the personal data.
Explanation of the international data transfers and the steps taken to comply with applicable law (if required).
The source from where you obtained the personal data.
The legal basis (if required) that you rely on for the collection and processing of the personal data.
The steps the data subjects (i.e., candidates) need to take to exercise their rights (e.g., right to access, correct and erase their personal data).
The retention period for which you will store and keep the candidates data (Comeet offers you features to set up your data retention and deletion periods).
How data subjects (i.e., candidates) can contact you if they have questions about your privacy practices.
Publish your Notice online, at a publicly available URL.
In Comeet go to Company Settings > Careers Website.
Note: Editing company settings in Comeet requires an Admin, Owner or IT Manager role.
How candidates are notified
First email message
Candidates who are defined as data subjects are notified in the first email message sent to them:
The Notice URL is added to the first message that the candidate receives. For example, when a recruiter reached out to passive candidates who are defined as data subjects, the first message sent to each candidate will automatically include the link to the Notice.
The Notice URL is added to the following messages: Thanks for applying, Thanks for applying for discreet position, and Referred by an employee.