PRIVACY POLICY PROGRESS GROUP INTERIM

1. General

Data of the temporary employment agency: PROGRESS GROUP BV, business number 0533.902.846, with its registered office at 2660 Antwerp, Smallandlaan 29B, Belgium. The personal data provided by the employee to PROGRESS GROUP are processed in a file for which PROGRESS GROUP is responsible. Only authorized personnel within PROGRESS GROUP will have access to this data. If there are any questions about the processing of personal data, the employee can contact us via the phone number: +32 (0) 3 334 11 14 or email: privacy@progressgroup.be.

2. Definitions

Personal data: all information about an identified or identifiable natural person; a natural person is considered identifiable if they 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.

Special categories of personal data: personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as genetic data, biometric data for the purpose of uniquely identifying a person, data concerning health, or data concerning a person’s sex life or sexual orientation.

Processing: an operation or set of operations performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure, or destruction of data.

3. What personal data is processed?

No special categories of personal data are processed unless necessary in the context of the cases listed exhaustively in Article 9, paragraph 2 of the General Data Protection Regulation (GDPR).

PROGRESS GROUP collects and processes various personal data of its employees, including:

  • Application letters, Curriculum Vitae, any notes made during the job interview;
  • Information relating to payroll and personnel administration, such as the national registry number, residence title and work permit, date of birth, address, marital status, family composition, telephone number, e-mail address, employee’s bank account number, information regarding salary and benefits (mobile phone, car,…), pay slips, individual accounts, holiday certificates;
  • Information about whether or not the person has a driving license;
  • The name of a contact person who can be reached in case of emergency;
  • Information about clothing sizes in order to provide necessary work clothes;
  • Evaluation forms or the determination of a deficiency;
  • Control of email and internet use;
  • Time registration;
  • Photos and videos for promotional purposes and/or communication to clients;
  • Possible camera images recorded by the security cameras within the company showing the employee;

All personal data are processed in accordance with the requirements of the GDPR.

4. Purpose and legal basis for the processing

  • Application letters, Curriculum Vitae, notes made during the job interview are processed for the purpose of going through the recruitment process, with the legal basis being the legitimate interest of PROGRESS GROUP. The legitimate interest is that PROGRESS GROUP must be able to assess applicants and go through the recruitment process.
  • Information relating to payroll and personnel administration is collected and processed for the purpose of carrying out payroll and personnel administration, with the legal basis being the performance of the employment contract and compliance with legal obligations in the field of labour law and social security.
  • Time registration data are collected and processed in order to comply with a legal obligation, process wages correctly, and control working hours, with the legal basis being compliance with a legal obligation, the performance of the employment contract, and the legitimate interest of PROGRESS GROUP.
  • Data relating to email and internet use control are collected and processed to prevent unauthorized actions, enforce rules regarding the use of online technologies, ensure the safety and/or proper operation of IT network systems, and protect the company’s physical installations, with the legal basis being the performance of the employment contract and the legitimate interest of PROGRESS GROUP. The legitimate interest is that PROGRESS GROUP must be able to ensure the aforementioned interests.
  • Information regarding possession of a driving license is collected and processed to check if an employee is allowed to drive a company vehicle for professional purposes, with the legal basis being the execution of the employment contract and compliance with legal obligations.
  • The name of a contact person is collected and processed so that we can contact a family member or close relative in case of emergency, with the legal basis being the need to protect the vital interests of the employee.
  • Evaluation forms or findings of shortcomings are collected and processed to evaluate the employee and possibly hold them accountable, with the legal basis being the execution of the employment contract and the legitimate interest of the employer.
  • Any camera images recorded by the security cameras within the company showing the employee are collected and processed to prevent theft of company goods, with the legal basis being the legitimate interest of PROGRESS GROUP. The legitimate interest is that PROGRESS GROUP must be able to protect its company goods from theft.
  • Photos and/or videos are collected and processed to use them for communication with clients and promotional purposes, with the legal basis being the explicit prior consent of the employee. Before photos and/or videos are taken, the employee is asked for consent. The employee always has the right to withdraw this consent, without this affecting the legality of the processing based on the employee’s consent prior to this withdrawal.
  • Information regarding clothing sizes is collected and processed to provide appropriate work uniforms for the employee, with the legal basis being the execution of the employment contract.

5. Duration of processing

In principle, the data will be kept until five years after the termination of the employee’s employment. However, the personal data will, in any case, be kept in accordance with the terms prescribed in the applicable legislation and possibly longer than the aforementioned period if statutes of limitations oblige us to do so. After this period, the data will be deleted or anonymized.

6. Employee’s rights

6.1. Right of access and copy

The employee has the right at any time to view his/her personal data that is being processed, free of charge. The employee also has the right to receive a copy of this, either in paper form or electronically, free of charge. If the employee requests additional copies, PROGRESS GROUP may charge a reasonable fee based on administrative costs.

6.2. Right to rectification, erasure, and restriction

The employee has the right to request PROGRESS GROUP to rectify his/her personal data if they are no longer up-to-date or to supplement them if they are incomplete. He/she also has the right to have the data deleted if one of the cases listed in Article 17 of the GDPR applies. However, the employee cannot object to the processing of personal data necessary for payroll administration and the data that PROGRESS GROUP is obliged to keep and process based on the law. The employee can also ask to limit the processing of his/her personal data if one of the cases listed in Article 18 of the GDPR applies.

6.3. Right to object

In accordance with Article 21 of the GDPR, the employee has the right to object to the processing of his/her personal data for serious and legitimate reasons.

6.4. Right to data portability

Within the limits of Article 20 of the GDPR, the employee has the right to obtain his/her personal data processed by PROGRESS GROUP in a structured, commonly used, and machine-readable form and/or to transfer them to other responsible parties.

6.5. Right to withdraw consent

Insofar as the processing is based on the employee’s prior consent, he/she has the right to withdraw that consent.

6.6. Automated decisions and profiling

The processing of the employee’s personal data does not include profiling, and the employee will not be subject to automated decisions by PROGRESS GROUP.

6.7. Exercising your rights

The employee can exercise his/her rights by contacting PROGRESS GROUP via email: privacy@progressgroup.be.

6.8. Complaints

The employee has the right to file a complaint with the Belgian Data Protection Authority: Address: Drukpersstraat 35, 1000 Brussels, Tel: +32 (0) 2 274 48 00 Email: contact@apd-gba.be. This does not affect the provision for a civil court.

7. Disclosure of data to third parties

Some personal data that PROGRESS GROUP processes from the employee are transferred to third parties. The following data are involved:

  • Information concerning payroll administration is passed on to the social secretariat Prato VZW for the purpose of carrying out the payroll administration and, on the other hand, to the competent government agencies in the context of our legal obligations.
  • The employee’s first name, last name, and email address are passed on to the IT provider Prato VZW for the purpose of managing the employee’s account.
  • The employee’s first name, last name, and email address are passed on to the insurance company AG Insurance for insurance in case of a work accident.
  • The necessary data are provided to Edenred Belgium for the allocation of meal vouchers and/or ecocheques.
  • The necessary data are provided to the occupational physician, mutual insurance company, child benefit fund, and sectoral social funds to fulfill legal obligations or obtain services.
  • All personal data of the employee can be passed on to service providers specialized in labor law and social security law for the purpose of obtaining information.

The aforementioned third parties only process the employee’s personal data under the explicit assignment from PROGRESS GROUP and purely to perform a specific task. PROGRESS GROUP concludes processing agreements with all these organizations and does everything possible to ensure that these organizations secure the employee’s personal data sufficiently.

The employee’s personal data will not be sold, rented, distributed, or otherwise commercially made available to third parties, except as described above or unless with your prior consent.

In rare cases, it may happen that PROGRESS GROUP must disclose the employee’s personal data due to a court order or to comply with other mandatory laws or regulations.

In any case, PROGRESS GROUP will not forward the employee’s personal data outside Europe (third country or international organization).