Privacy Policy

DATA PROTECTION AND PRIVACY STATEMENT FOR OUTSOURCEPOINT

GLOSSARY

A. LAWFUL BASIS

“Performance of Contract” means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. “Comply with a legal or regulatory obligation” means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to. “Consent” means any freely given, specific, informed and unambiguous indication of your wishes by which you, through a statement or a clear affirmative action, signifies agreement to the processing of your Personal Data.

1.  Who are we?

Outsourcepoint (“we”, “us” “our”) is a professional, specialist recruitment organisation which focuses on Tax, Accounting, Payroll management and Manpower Outsourcing. We provide permanent and temporary recruitment services to clients looking to recruit talent for their businesses. Our services are provided at our office and through e-channels such as our website. Outsourcepoint is committed to and respects each individual’s right to privacy. This Policy explains what we do with your personal data, whether we are in the process of introducing ourselves to you, helping you to find a job, continuing our relationship with you once we have found you a role, providing you with a service, receiving a service from you, using your data to ask for your assistance in relation to one of our Candidates, or you are visiting our website. Our channels are not meant for children and we do not knowingly collect data relating to children. This Privacy Policy applies to the personal data of our Website Users, Prospective Candidates, Candidates, Clients, Suppliers, and other people whom we will contact in order to find out more about our Candidates or whom they indicate is a reference or contact in accordance with the National Information Technology Development Agency Act 2007 (the “Act”) and the Nigeria Data Protection Regulation (NDPR) 2019 (the “Regulation”) as amended or updated from time to time, in Nigeria.

For the purpose of the NDPR and this policy, we are the ‘data controller’. This means that we are responsible for deciding how we hold and use personal data about you. However, depending on the relevant transaction, we may act as the “”data administrator/processor”. We are required under the NDPR to notify you of the information contained in this privacy policy

You have the right to make a complaint at any time to the National Information Technology Development Agency (NITDA) or Nigeria Data Protection Bureau (NDPB) Office, the Nigerian supervisory authority for data protection issues. We would, however, appreciate the chance to address your concerns before you approach the agencies, so please contact us in the first instance.

2.  Information we may collect

We may collect and process the following data about you:

a.   Where you are a Candidate or prospective Candidate, we collect the information necessary to be able to find available opportunities and further information needed so our recruiters can assess your eligibility through the different stages of recruitment. This relates to our business which is recruitment but also applications to work for Outsourcepoint. This information may include your name private and corporate email address, postal address and telephone number; financial information; curriculum vitae; work history; your educational records and training, work performance, compliance and identity documentation; references and links to your professional profiles available in the public domain e.g. LinkedIn, business Facebook or corporate website. Depending on the nature of a role considered for, we may need to collect and process special categories of personal data about you which may include information about your health (including details of any sick leave taken during your previous roles), details of any disability, details of any offences you have committed or are alleged to have committed and whether you are a member of any professional or trade associations.

b.   Where you are a Supplier, we collect the following types of data (collectively Supplier Data):

• Identity Data and Contact Data of Supplier personnel;
• Supplier bank account details; and
• Details about payments to Suppliers and other details of goods and/or services provided to us by Suppliers.

c.   Where you are a Client, the following types of data (collectively Client Data):

• Identity Data and Contact Data of Client personnel;
• recruitment data about potential Client staff, including references and other information included in a CV or cover letter or as part of a job application process;
• employment data of Client personnel which we process in order to provide our services to you, including, in respect of each individual, payroll information, the start date and, if different, the date of their continuous employment, leaving date and their reason for leaving, location of employment or workplace, employment records (including job titles, work history, working hours, holidays, training records and professional memberships), compensation history, performance information, disciplinary and grievance information; and
• Client bank account and payment card details, details about payments from Clients and other details of services provided to Clients by us.

d.   People whose data we receive from candidates and staff, such as referees, emergency contacts and dependants: In order to provide Candidates with suitable employment opportunities, to provide for certain eventualities for them and our Staff and to allow Staff to access certain benefits or employment rights, we need some basic background information. We ask for very basic contact details, so that we can get in touch with you either for a reference or because you’ve been listed as an emergency contact or a dependent for one of our Candidates or Staff members.

e.  Technical Data includes 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 our Website.

f.  Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.

3.  How is your personal data collected?

We collect your personal data either from you or third parties through:

a.  Direct interactions: You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• apply for our services;
• create an account on our Website;
• request marketing to be sent to you; or
• give us some feedback.

b.  Our provision of services to you. We may collect Identity Data, Contact Data and Client Data from you as a result of us providing our services to you.

c.  Automated technologies or interactions. As you interact with our Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also collect Client Data and Supplier Data from you (as applicable) through our use of software and other technology solutions which we use to provide services to Clients.

4. How we use the information

We may use your information in the following way and in consideration of the applicable legal basis under the NDPR which we rely on to use your information:

a.  Candidate Data: The main reason for using your personal details is to help you find employment or other work roles that might be suitable for you. The more information we have about you, your skillset and your ambitions, the more bespoke we can make our service. Where appropriate and in accordance with local laws and requirements, we will also use your personal data for things like marketing our services to you. Where appropriate, we will seek your consent to undertake some of these activities. The lawful basis for this is Performance of a contract with you.

b.  Supplier data: To register you as a new Supplier, placing orders for and subsequently receiving goods and/or services from you. The lawful basis for this is Performance of a contract with you.

c. Where you are a Client, to process and deliver your order for services, including:

• Providing payroll services
• to establish a customer relationship and to communicate with you
• Providing other HR services
• Managing payments, fees and charges
• Collecting and recovering money owed to us The lawful basis for this is Performance of a contract with you.

d.  To deliver relevant Website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.

e.  We use your data to help us to improve your experience of using our website or our mobile apps, for example by analysing your recent job search criteria to help us to present jobs to you that we think you’ll be interested in. In addition, we use your data to provide you with the service you registered for or the services you participated in, for example sending you a newsletter or taking part in an online survey.

We may anonymise your personal information in such a way that you may not reasonably be reidentified by us or any other company. We may use this anonymised information for any other purpose.

5.  Promotional offers from us

We may use your Identity, Contact, Client, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing. You can ask us or to stop sending you marketing messages at any time by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, service experience or other transactions.

6.  Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

7.  Disclosure of Data

We only share and disclose your information in the following situations

a.  for the purposes set out in the table in paragraph 4 above.

b.  Compliance with Laws: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

c.  Vital interests and Legal Rights: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

d. We may disclose your information to third party service providers to ensure effective provision of our services to you. All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.

e.  We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

With your consent we may disclose your personal information for any other purpose.

8.  How long will we retain your data

All personal information shall be retained, stored and destroyed by us are in line with legislative and regulatory guidelines. We only retain your information for as long as is necessary for us to use your information as described above or to comply with our legal obligations. However, please be advised that we may retain some of your information after you cease to use our services, for instance if this is necessary to meet our legal obligations, such as retaining the information for tax and accounting purposes.

When determining the relevant retention periods, we will take into account factors including: our contractual obligations and rights in relation to the information involved;

a.  legal obligation(s) under applicable law to retain data for a certain period of time;

b.  statute of limitations under applicable law(s);

c.  (potential) disputes;

d.  if you have made a request to have your information deleted; and

e.  guidelines issued by relevant data protection authorities.

Otherwise, we securely erase your information once this is no longer needed.

9.  Security and Storage of your data

Safeguarding personal data and respecting confidentiality of your information is important to us. All information you provide to us is stored securely and we take necessary steps, including putting in place appropriate technical and organisational measures, to protect your personal data. While we have security measures in place to protect against the loss, misuse and alteration of personal data under our control we cannot guarantee that loss, misuse or alteration of personal data will not occur. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

10.  Using our Electronic Channels

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. Our websites may include links to external websites operated by other organisations which may collect personal data about you when you visit them. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for the privacy practices of any third-party websites. Please check these policies before you submit any personal data to these websites.

11.  International data transfers

Information that we collect may be stored, processed in, and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy. Any such information transferred to other countries shall be in compliance with the relevant laws as highlighted above.

12.  What rights do you have in relation to the data we hold on you?

By law, you have a number of rights when it comes to your personal data. This is briefly described below, you may refer to the appropriate laws, regulations or regulators for further guidance. Please note that these rights are applied in accordance with the appropriate legal basis.

It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details provided.