Employment Candidate Privacy Policy

(important information on how we collect, use and store data during our application and recruitment process and why we collect it)

1. What information will you find on this document

Gurtam companies (“Gurtam”, “we”, “us”, “the Company”, “Controller”) respect your privacy and are committed to protecting your personal data. As part of our recruitment process, we collect and process personal data relating to candidates. We are committed to be transparent about how we collect and use your personal data and to meet our obligations under the relevant data protection laws. This Employment Candidate Privacy Policy (“Privacy Policy”) explains what types of personal data we may collect during our application and recruitment process, why we collect it and how it may be used and other useful information.

While this Privacy Policy is intended to describe the broadest range of our information processing activities globally, those processing activities may be more limited in some jurisdictions based on the restrictions of their laws. For example, the laws of a country may limit the types of personal data we can collect or the manner in which we process that information. In those instances, we adjust our internal policies and practices to reflect the requirements of local law.

Gurtam is a “data controller”. This means that we are responsible for deciding how we hold and use personal data about you.

2. Who is responsible for protection of your information and data processing 

Depending on the Gurtam company you are in contact with or applying to, the data controller of your personal data can be either of the following companies:

UAB Gurtam (Lithuania)
Company code: 302506437
Ozo g. 12A (5th floor), Penta Technopolis, 08200, Vilnius, Lithuania;

Gurtam LLC (Georgia)
Tax Code:  405541285
Georgia, Tbilisi, Saburtalo district, Mikheil Tamarashvili avenue, N 13h, office space; 4th floor, block b

Gurtam DMCC (UAE)
Tax Code:  TRN:100504539600003
Unit No: 1801, Indigo Icon, Plot No: JLT-PH1-F3A, Jumeirah Lakes Towers, Dubai

Our e-mail: privacy@gurtam.com.

3. What principles do we follow when processing information about you 

We will comply with data protection law and principles, which means that your data will be:

  • Used lawfully, fairly and in a transparent way.
  • Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  • Accurate and kept up to date.
  • Maintained only for as long as necessary for the purposes we have told you about, i.e. in relation to the recruitment exercise.
  • Kept securely and protected against unauthorized or unlawful processing and against loss or destruction using appropriate technical and organizational measures.

4. Why do we collect information about you

We collect and process your information where it is necessary in order to take steps, at your request, prior to potentially entering into a contract of employment with you.

We may also process your personal data in specific circumstances, such as for example a similar role becomes vacant for which you will be a fitting candidate (where we have your explicit concent), or process it where necessary to comply with a legal obligation or for purposes connected to legal claims. If we use your information to improve our application or recruitment process, we do so on the basis that it is in our legitimate interests to ensure we recruit the best possible candidates.

5. What personal data we collect from you

In connection with your application for work, we will collect, store, and process the personal data about you.

The personal data can include the following:

  • Your full name;
  • Contact details (such as (e.g., e-mail, telephone number, address);
  • Publicly available information (e.g., information from professional social networks);
  • Education history (including copies of relevant degrees, diplomas or certificates if required);
  • Current and past employment details;
  • Immigration status and work permits;
  • Languages spoken and level of proficiency;
  • Recommendations;
  • Other information given in your CV and attachments to it;
  • Interview notes and recordings;
  • Recruiting tasks performed by you;
  • Desired salary;
  • Information required to prepare the employment contract;
  • Other information submitted by you.

We may also collect the following information about you if you choose to provide it:

  • Information about your health, such as any disability you might have;
  • Gender.

Please note that the provision of this information is entirely voluntary and you are under no obligation to provide it. Your decision to provide or withhold this information will not affect your application.

When submitting your application, please do not include any information that is not relevant to the recruitment process.

6. How is your personal data collected

We collect most of the personal data described above from you directly.

However, we may also collect personal data about you from third parties, including:

  • Existing Gurtam employees who refer or nominate you for roles with us;
  • Other Gurtam companies (e.g., when you are recommended for another job position at Gurtam);
  • Recruitment agencies, job portals or other third parties;
  • Governmental authorities (such as local tax authorities);
  • Your named referees who you’ve asked to provide us with references;
  • Where allowed by law, other publicly available sources, such as social media networking sites and recruitment sources (such as LinkedIn, Instagram, Glassdoor, Indeed, Cvbankas.lt, etc.).

7. How we will use your personal data

We will use the information we collect about you for the following purposes:

  • Communicate with you about the recruitment process;
  • Where requested by you, assisting you with obtaining an immigration visa or work permit where required;
  • Carry out background and reference checks as appropriate and in accordance with applicable law;
  • Assess your skills, qualifications, and suitability for the position;
  • Keep records related to our hiring process;
  • To create a pool of candidates for future suitable open positions where we have your consent;
  • Comply with legal or regulatory requirements.

After receiving your CV and cover letter (if applicable), we will process that information to decide whether you meet the basic requirements to be shortlisted for the position. If you do, we shall decide whether to invite you for an interview. If you are called for an interview, we will use the information you provide to us during the interview, to decide whether to offer the position to you. If we decide to offer you the position, we will take up references.

It is in our legitimate interest to decide whether to appoint you to a position since it would be beneficial to our business to appoint the appropriate candidate to that position.

We also need to process your personal data to decide whether to enter into a contract of employment or engagement with you.

If you are offered and accept employment with Gurtam, the information collected during the application and recruitment process will become part of your employment record.

If you fail to provide personal data

If you fail to provide personal data when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we may not be able to process your application further. For example, if we require references for this role and you fail to provide us with relevant details, we will not be able to take your application further.

How we use particularly sensitive personal data

We will use your sensitive personal data only in so far as we are permitted by law to do so:

  • We will use data about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview.
  • We will use data about your nationality to assess whether a work permit and a visa will be necessary for the role.

8. Automated decision-making

Automated decisions are currently not being made, you are not being profiled.

9. Who do we share information about you with

We will only share your personal data with the following third parties for the purposes of processing your application: Gurtam affiliates and third – party service providers. All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal data in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

10. Data security measures

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal data on our specific instructions and they are subject to a duty of confidentiality. 

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

11. For how long we store information about you

We retain your personal data until the end of the recruitment process has been completed and for as long as is necessary to comply with our legal obligations or to enable us to demonstrate, in the case of a legal claim, that we have not discriminated against candidates on any prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent manner. With your explicit consent, we will retain your personal data for three years from the date of your last application in case a similar role becomes vacant for which you will be a suitable candidate. After this period, we will securely destroy or anonymize your personal data. If you become an employee at Gurtam, we will save your information within the employee file in accordance with our internal data retention terms for employee data.

12. What rights do you have

Under certain circumstances, by law you have the right to:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data corrected.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.
  • Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal data to another party.

You have the right to withdraw the consent you gave us in relation to the processing of your personal data at any time. To withdraw your consent, please send an email to privacy@gurtam.com, expressing your desire for withdrawal of your consent. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Once we have received notification that you wish to withdraw your consent, we will no longer process your application and we will dispose of your personal data securely.

You also have the right to lodge a complaint with your local data protection authority or another regulatory body responsible for ensuring the protection of your personal data rights.

13. Contact information

If you have any questions, comments or complaints regarding how we collect, use and store information about you, we are ready to help you. If you need our help, please send an e-mail to privacy@gurtam.com or call +370 682 48819.