In order to fully comply with the current legislation of the Russian Federation, Get Experts Recruitment LLC (hereinafter referred to as the Operator) considers compliance with the principles of lawfulness, fairness and confidentiality in the processing of personal data, as well as ensuring the security of their processing, to be its most important task.
This Personal Data Security Policy in Get Experts Recruitment LLC (hereinafter referred to as the Policy) has the following specific features:
it has been developed in order to meet the requirements of the current legislation of the Russian Federation in the field of processing and protection of personal data;
it discloses the methods and principles of processing personal data by the Operator, the rights and obligations of the Operator when processing personal data, the rights of subjects of personal data, as well as includes a list of the measures used by the Operator to ensure the security of personal data during their processing;
it is a public document declaring the conceptual foundations of the Operator’s activities in the processing and protection of personal data.
Prior to the processing of personal data, the Operator notified the authorized agency for the protection of the rights of subjects of personal data of its intention to process personal data. The Operator, in good faith and within the established period, updates the information specified in the notice.
The basic concepts used in the Policy
Personal data – any information relating directly or indirectly to an identified or identifiable natural person (subject of personal data.)
Operator of personal data (operator) – a state authority, municipal agency, legal entity or natural person, that independently or jointly with other persons organizes and/or carries out the processing of personal data, as well as determines the purposes of processing of personal data, the list of personal data to be processed, and the actions (operations) performed with personal data.
Processing of personal data – any action (operation) or a set of actions (operations) with personal data performed using with or without automation tools. The processing of personal data includes, inter alia: collection, recording, systematization, accumulation, storage, clarification (updating, modifying), extraction, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, and destruction.
Automated processing of personal data – processing of personal data using computing equipment.
Dissemination of personal data – actions aimed at disclosing personal data to general public.
Provision of personal data – actions aimed at disclosing personal data to a specific person or range of persons.
Blocking of personal data – temporary suspension of the processing of personal data (except when processing is required to clarify personal data.)
Destruction of personal data – actions, which result in impossibility to restore the content of personal data in the information system of personal data and/or in destruction of physical carriers of personal data.
Depersonalization of personal data – actions, which result in impossibility to match the personal data with a specific subject of personal data without additional information.
Information system of personal data – a set of personal data contained in databases and information technologies and equipment engaged in their processing.
Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state to a public authority of a foreign state, a foreign natural person or a foreign legal entity.
Special categories of personal data – sensitive categories of personal data relating to race, nationality, political opinions, religious or philosophical beliefs, trade union membership, health status and intimate life.
Biometric personal data – information that characterizes the physiological and biological characteristics of a person, which may serve as a basis to determine his/her identity.
Personal data permitted by the subject of personal data for dissemination – personal data, access whereto has been granted to a general public by the subject of personal data in a form of consent to the processing of personal data permitted by the subject of personal data for dissemination based on the procedure established by the Federal Law.
Person responsible for the arrangement for the processing of personal data – a natural person or a legal entity appointed by Get Experts Recruitment LLC to be responsible for the arrangement for the processing of personal data.
The processing of personal data should be limited to the achievement of specific, predetermined and legitimate purposes. The subject of personal data, when giving consent to the processing of his/her personal data, must be informed about the purposes of their processing. The purposes of processing must be included in the form of consent of the personal data subject. It is not allowed to process personal data if such processing is inconsistent with the purposes of collecting of personal data.
Basic Rights and Obligations of the Operator.
The Operator may:
receive from the subject of personal data reliable information and/or documents containing personal data;
require the subject of personal data to timely clarify the personal data provided.
The Operator shall:
process personal data based on the procedure established by the current legislation of the Russian Federation;
consider the appeals of the subject of personal data (his/her lawful representative) concerning the processing of personal data and give reasoned answers;
provide the subject of personal data (his/her lawful representative) with free access to his/her personal data;
take measures to clarify and/or destroy the personal data of the subject of personal data based on his/her (his/her lawful representative’s) application with legitimate and reasonable requirements;
arrange for the protection of personal data in accordance with the requirements of the legislation of the Russian Federation.
Basic Rights and Obligations of the Subjects of Personal Data
A subject of personal data may receive information about the processing of his/her personal data by the Operator.
A subject of personal may require the Operator to clarify these personal data, block or destroy same if they are incomplete, outdated, inaccurate, illegally obtained or cannot be considered necessary for the declared purpose of processing, as well as take measures provided by law to protect his/her rights.
The right of a subject of personal data to gain access to his/her personal data may be limited in accordance with federal laws, including if the access of the subject of personal data to his/her personal data violates the rights and legitimate interests of third parties.
In order to exercise and protect his/her rights and legitimate interests, a subject of personal data may contact the Operator. The Operator shall consider any appeals and complaints from subjects of personal data, thoroughly investigate the facts of violations and take all measures required to eliminate them immediately, punish liable persons and resolve disputes and conflict situations through the pre-trial process.
A subject of personal data may appeal against the actions or inaction of the Operator to an authorized agency for the protection of his/her rights.
A subject of personal data may withdraw his/her consent to the processing of personal data.
A subject of personal data is entitled for the protection of his/her rights and legitimate interests, including compensation for losses and/or compensation for moral harm through judicial procedures.
A subject of personal data shall provide the Operator with only reliable data about him/herself, as well as provide documents containing personal data to the extent required for the processing.
A subject of personal data shall advise the Operator of the clarification (updating, modification) of his/her personal data.
A person who has provided the Operator with inaccurate information about him/herself, or information about another subject of personal data without the consent of the latter, shall be liable in accordance with the legislation of the Russian Federation.
The purposes of collecting of personal data
The processing of personal data by Get Experts Recruitment LLC shall be limited to the achievement of specific, predetermined and legitimate purposes.
Get Experts Recruitment LLC processes personal data for the following purposes:
inviting and considering candidates (applicants) to fill vacant positions, including by requesting additional information required to assess business qualities in order to make a decision to refuse/enter into an employment contract;
entering into any transactions and contracts with the subjects of personal data, and further performance of obligations thereunder;
informing the subjects of personal data to the extent of their professional activities, including informing about events held and/or organized by the Operator;
organization and holding by the Operator of surveys, interviews, lectures, and other events to be attended by personal data subjects;
performance of staff management and organization of records of employees (workers) of the Operator;
governing labor and other relations directly related to same, including assistance in employment, training and promotion, as well as the establishment of the amount of wages, the calculation of wages and its payment, as well as ensuring personal safety of employees;
enjoyment of benefits, compensations and bonuses provided for by the legislation of the Russian Federation and the acts of the Operator;
arrangement for voluntary health insurance and accident insurance;
assistance in obtaining visas, invitations and travel tickets, as well as hotel reservations;
providing employees with mobile communications;
assistance in providing transportation services;
organization of incentive programs for subjects of personal data;
representation, including execution of powers of attorney;
carrying out business activities, including sending and receiving correspondence and other postal items, translating documents, making business cards and other printed products, as well as providing access to the Operator’s IT resources and support in their use;
receipt (registration) and storage of personal data and their carriers in accordance with the legislation of the Russian Federation and the internal regulations of the Operator for the implementation of activities provided for by the Charter of the Company;
placement of personal data of the subjects of personal data on public resources, including the websites of the Operator and companies belonging to the same group of persons with the Operator, as well as official pages on social networks, for information support in cases provided for by law and internal acts of the Operator, as well as for promoting the brand of the Operator and companies belonging to the same group of persons with the Operator, as well as fostering loyalty to the brand of the Operator;
disclosure of information and ensuring compliance with legal requirements when making management decisions;
providing employees with an electronic signature;
organization of access control to the territory of the Operator;
analytics of user actions on the websites of the Operator and ensuring the functioning of the websites;
serving the legitimate interests of the Operator, including maintaining internal order, protecting property and estate;
compliance with and implementation of the mandatory requirements of the legislation of the Russian Federation in the field of compulsory health and pension insurance, labor, civil and tax legislation, including legislation in the field of consumer protection, occupational safety, etc.;
provision of information to subjects of personal data, including information about the services of the Operator, and sending newsletters, including of advertising and marketing nature;
the subjects of personal data feedback, including the receipt and processing of their requests and appeals;
collection of opinions of consumers of the Operator’s services, in particular concerning the quality of service, including for giving recommendations on the services being provided/already provided by the Operator;
establishment and maintenance of a database of personal data of natural persons – representatives of legal entities and individual entrepreneurs, as well as event participants for business contacts;
establishment and maintenance of a database of personal data of users/visitors of the Operator’s websites, for communication and newsletters;
communication or obtaining/providing of the information required for carrying out activities;
implementation of other functions, powers and duties assigned to the Operator by the legislation of the Russian Federation and internal regulatory documents of the Operator.
Get Experts Recruitment LLC does not process personal data inconsistent with the purposes of the collection of personal data.
It is not allowed to pool databases containing personal data, processed for any purposes inconsistent with each other.
Legal Framework for the Processing of Personal Data
This Policy has been developed in accordance with the current legislation of the Russian Federation in the field of processing and protection of personal data.
The legal framework for the processing of personal data applicable to Get Experts Recruitment LLC in terms of processing of personal data, in addition to the legislation of the Russian Federation in the field of processing and protection of personal data, also includes:
the statutory documents of the Operator;
agreements entered into by and between Get Experts Recruitment LLC and subjects of personal data;
consents of subjects of personal data to the processing of their personal data;
other grounds when consent to the processing of personal data is not required by virtue of law.
In pursuance of this Policy, the Director of the Operator has approved the “Regulations on the Organization of the Processing and Ensuring the Security of Personal Data in Get Experts Recruitment LLC”, as well as other internal acts of the Operator in the field of processing and protection of personal data.
The Volume and Categories of the Personal Data Processed; the Categories of Subjects of Personal Data
The Operator in its activities ensures compliance with the principles of processing of personal data specified in Art. 5 of Federal Law No. 152-ФЗ dated July 27, 2006 “On Personal Data.”
The Operator processes the following categories of the subjects of personal data:
Applicants;
Employees;
Dismissed employees;
Relatives of employees;
Natural persons whose personal data are processed on behalf;
Candidates;
Natural persons – representatives of legal entities, individual entrepreneurs;
Users/viewers of the Operator’s website;
Visitors to the office;
Proposers;
Participants of events;
Trainees.
Below is the list of the personal data processed for each category:
Applicants:
full name;
date of birth (day, month, year);
place of birth;
nationality;
gender;
type and details of the identity document (series, number, date of issue and issuing authority, unit code);
address of the actual residence;
address of registration at the place of residence/stay;
registration at the place of residence/stay (yes/no);
phone numbers and e-mail addresses or other methods of contact;
information about education, including postgraduate vocational education (level of education, form of education, the educational institution, year of graduation from the educational institution, type and details of the document certifying the education, qualification and specialty according to the diploma);
academic degree and title, dates of awarding the academic title/degree;
information on advanced training and certification (number and date of issue of the certificate of completion);
command of foreign languages, level of command, preferred language of communication;
information about skills and professional experience, including PC experience (level of software proficiency, speed of typing);
professional area;
specialization;
information about work activities and their results, including a list of duties, information about employers (month and year of employment, month and year of termination, position, company), promotions, disciplinary sanctions, transfers to a new position/job, reasons for termination and length of service;
work permit;
desired position;
desired salary and salary level at the current (previous) workplace;
desired type of employment and work schedule;
willingness to business trips and relocation;
important criteria when choosing a job;
information about proposers (full name, place of work, contact phone number);
marital status, children (their number and age);
driver’s license (series, number), category and driving experience;
car owned;
work restrictions for health reasons;
results of job interviews and decision made;
preferences, preoccupations, interests and hobbies;
picture;
signature;
additional information provided for by the requirements of federal laws that determine the cases and specific features of the processing of personal data;
user data (location; OS type and version; browser type and version; provider; original source from where the user went to the website; pages viewed; number of page visits; information about website pages switching; duration of the user session; entry points (third-party websites containing links to the Website); exit points (links on the Website following which the user visits other websites); the language of the OS and the browser;
depersonalized data provided by Internet analytics services;
IP-address;
cookies.
Employees:
full name;
date of birth (day, month, year);
place of birth;
nationality;
gender;
type and details of the identity document (series, number, date of issue and issuing authority, unit code);
address of the actual residence;
address of registration at the place of residence/stay;
registration at the place of residence/stay (yes/no);
phone numbers and e-mail addresses or other methods of contact;
information about education, including postgraduate vocational education (level of education, form of education, the educational institution, year of graduation from the educational institution, type and details of the document certifying the education, qualification and specialty according to the diploma);
academic degree and title, dates of awarding the academic title/degree;
special occupational knowledge and skills;
information on advanced training and certification (number and date of issue of the certificate of completion);
command of foreign languages, level of command;
skills and professional experience;
professional area;
specialization;
information about work activities and their results, including a list of duties, information about employers (month and year of employment, month and year of termination, position, company), promotions, disciplinary sanctions, transfers to a new position/job, reasons for termination and length of service;
workplace and position;
employee’s ID No. / identification number / number of the pass to the work grounds;
work time recording (clock-in and clock-out entries, other records of absence from workplace, number of hours worked and number of hours according to the contract or department standards, leave status);
annual paid leaves, study holidays and leaves without pay;
work permit;
desired position;
desired salary;
desired type of employment and work schedule;
willingness to business trips and relocation;
marital status;
family members (wife / husband, parents, children) (stating the degree of relationship (kindred), surname, given name, patronymic, year of birth);
financial information: salary, wage, other accruals and payments, bank accounts used for payroll accounting and other payments, payable and paid taxes and insurance premiums to off-budget funds;
bank details;
Individual insurance account number (SNILS);
taxpayer’s identification number (INN);
details of military service and military registration documents;
driver’s license (series, number), category and driving experience;
car owned;
social benefits granted in accordance with the legislation and legal acts of the Russian Federation;
promotions and awards;
information about disqualification and deprivation of right to hold a specific position and/or to perform a labor function;
information from the materials of internal investigations;
the results of a medical report based on the findings of a health examination on the occupational fitness (unfitness) of the employee;
the results of testing for the new coronavirus infection (COVID-19);
the results of testing for the number of antibodies of the new coronavirus infection (COVID-19);
other information contained in an employment contract, an agreement on individual and collective liability, liability for damages, student agreements, service agreements;
applications installed on the employee’s mobile device used for work purposes;
preferences, preoccupations, interests and hobbies;
business and other personal qualities of a judgment nature;
details of the passport for traveling abroad, including information about the dates of border crossing;
picture;
video;
signature;
additional information provided for by the terms and conditions of the Agreement and the requirements of federal laws that determine the cases and specific features of the processing of personal data.
Relatives of employees:
full name;
date of birth (day, month, year);
type and details of the identity document (series, number, date of issue and issuing authority, unit code);
registration address;
address of the actual residence;
relation degree.
Natural persons whose personal data are processed on behalf:
full name;
date of birth (day, month, year);
place of birth;
nationality;
gender;
type and details of the identity document (series, number, date of issue and issuing authority, unit code);
address of the actual residence;
address of registration at the place of residence/stay;
registration at the place of residence/stay (yes/no);
phone numbers and e-mail addresses or other methods of contact;
information about education, including postgraduate vocational education (level of education, form of education, the educational institution, year of graduation from the educational institution, type and details of the document certifying the education, qualification and specialty according to the diploma);
academic degree and title, dates of awarding the academic title/degree;
special occupational knowledge and skills;
information on advanced training and certification (number and date of issue of the certificate of completion);
command of foreign languages, level of command;
skills and professional experience;
professional area;
specialization;
information about work activities and their results, including a list of duties, information about employers (month and year of employment, month and year of termination, position, company), promotions, disciplinary sanctions, transfers to a new position/job, reasons for termination and length of service;
workplace and position;
employee’s ID No. / identification number / number of the pass to the work grounds;
work time recording (clock-in and clock-out entries, other records of absence from workplace, number of hours worked and number of hours according to the contract or department standards, leave status);
annual paid leaves, study holidays and leaves without pay;
work permit;
desired position;
desired salary;
desired type of employment and work schedule;
willingness to business trips and relocation;
marital status;
family members (wife / husband, parents, children) (stating the degree of relationship (kindred), surname, given name, patronymic, year of birth);
financial information: salary, wage, other accruals and payments, bank accounts used for payroll accounting and other payments, payable and paid taxes and insurance premiums to off-budget funds;
bank details;
Individual insurance account number (SNILS);
taxpayer’s identification number (INN);
details of military service and military registration documents;
driver’s license (series, number), category and driving experience;
car owned;
social benefits granted in accordance with the legislation and legal acts of the Russian Federation;
promotions and awards;
information about disqualification and deprivation of right to hold a specific position and/or to perform a labor function;
information from the materials of internal investigations;
the results of a medical report based on the findings of a health examination on the occupational fitness (unfitness) of the employee;
other information contained in an employment contract, an agreement on individual and collective liability, liability for damages, student agreements, service agreements;
preferences, preoccupations, interests and hobbies;
business and other personal qualities of a judgment nature;
details of the passport for traveling abroad, including information about the dates of border crossing;
picture;
video;
signature;
additional information provided for by the terms and conditions of the Agreement and the requirements of federal laws that determine the cases and specific features of the processing of personal data.
Applicants:
full name;
date of birth (day, month, year);
place of birth;
nationality;
gender;
type and details of the identity document (series, number, date of issue and issuing authority, unit code);
address of the actual residence;
address of registration at the place of residence/stay;
registration at the place of residence/stay (yes/no);
phone numbers and e-mail addresses or other methods of contact;
information about education, including postgraduate vocational education (level of education, form of education, the educational institution, year of graduation from the educational institution, type and details of the document certifying the education, qualification and specialty according to the diploma);
academic degree and title, dates of awarding the academic title/degree;
information on advanced training and certification (number and date of issue of the certificate of completion);
command of foreign languages, level of command, preferred language of communication;
information about skills and professional experience, including PC experience (level of software proficiency, speed of typing);
professional area;
specialization;
information about work activities and their results, including a list of duties, information about employers (month and year of employment, month and year of termination, position, company), promotions, disciplinary sanctions, transfers to a new position/job, reasons for termination and length of service;
work permit;
desired position;
desired salary and salary level at the current (previous) workplace;
desired type of employment and work schedule;
willingness to business trips and relocation;
important criteria when choosing a job;
information about proposers (full name, place of work, contact phone number);
marital status, children (their number and age);
driver’s license (series, number), category and driving experience;
car owned;
work restrictions for health reasons;
results of job interviews and decision made;
preferences, preoccupations, interests and hobbies;
picture;
signature;
taxpayer’s identification number (INN);
additional information provided for by the requirements of federal laws that determine the cases and specific features of the processing of personal data;
user data (location; OS type and version; browser type and version; provider; original source from where the user went to the website; pages viewed; number of page visits; information about website pages switching; duration of the user session; entry points (third-party websites containing links to the Website); exit points (links on the Website following which the user visits other websites); the language of the OS and the browser;
depersonalized data provided by Internet analytics services;
IP-address;
cookies.
Natural persons – representatives of legal entities, individual entrepreneurs:
full name;
date of birth (day, month, year);
gender;
type and details of the identity document (series, number, date of issue and issuing authority, unit code);
phone numbers and e-mail addresses or other methods of contact;
workplace and position;
company name and address;
taxpayer’s identification number (INN);
signature;
additional information provided for by the terms and conditions of the Agreement and the requirements of federal laws that determine the cases and specific features of the processing of personal data;
user data (location; OS type and version; browser type and version; provider; original source from where the user went to the website; pages viewed; number of page visits; information about website pages switching; duration of the user session; entry points (third-party websites containing links to the Website); exit points (links on the Website following which the user visits other websites); the language of the OS and the browser;
depersonalized data provided by Internet analytics services;
IP-address;
cookies.
Users/viewers of the Operator’s website:
full name;
e-mail address or other methods of contact;
user data (location; OS type and version; browser type and version; provider; original source from where the user went to the website; pages viewed; number of page visits; information about website pages switching; duration of the user session; entry points (third-party websites containing links to the Website); exit points (links on the Website following which the user visits other websites); the language of the OS and the browser;
depersonalized data provided by Internet analytics services;
IP-address;
cookies.
Visitors to office:
full name;
date of visit;
time of check-in and check-out;
type and details of the identity document (series, number).
Proposers:
full name;
phone numbers;
workplace and position;
e-mail address or other methods of contact;
company name.
Participants of events:
full name;
phone numbers and e-mail addresses or other methods of contact;
workplace and position;
company name and address;
picture;
video;
other additional information that will be obtained during collaboration.
Trainees:
full name;
date of birth (day, month, year);
gender;
type and details of the identity document (series, number, date of issue and issuing authority, unit code);
phone numbers and e-mail addresses or other methods of contact;
education (level of education, form of education, educational institution);
signature;
additional information provided for by the terms and conditions of the Agreement and the requirements of federal laws that determine the cases and specific features of the processing of personal data.
The Operator ensures the compliance of the content and volume of the personal data processed with the declared purposes of processing and, if required, takes measures to eliminate their redundancy with regard to the declared purposes of processing.
The Operator processes sensitive categories of personal data subject to the written consent of the relevant subjects of personal data, as well as in other cases provided for by the legislation of the Russian Federation.
Cookie Policy
This Cookie Policy establishes the procedure and conditions for the use by Get Experts Recruitment LLC of user cookies during their viewing the website https://getexperts.ru.
Cookies are small files stored on a user’s device (personal computer, laptop, tablet, mobile phone, etc.) when the user visits websites. Cookie information is stored in the browser and performs a recognition function when the user returns to the website. Thanks to them, we improve our website and services.
Depending on the browser and device used by an Applicant, different sets of cookies are used, including:
Absolutely necessary. Without them, the browser will not correctly display the website. These include files that are used to store information from data entry forms and items in the shopping cart. These also includes technical data storage files for audio and video files and information about the selected language and font.
Preferences – these files allow the website to remember information that changes its settings: for example, the user’s language or region.
Statistical – these files help the owner of the website understand how visitors use the website (they use Yandex.Metrics.) They allow to collect aggregated depersonalized information for all users.
Marketing – these files are used to track visitors on websites. By using them, the advertiser can learn about the user’s preferences and display the most relevant advertising.
Please note that the Operator uses cookies only on the basis of your consent. You can refuse cookies in your browser settings, as well as in that of your device.
The browser and/or device used by the Applicant may allow to block, delete or otherwise restrict the use of cookies. Please note that if you delete or block cookies, you may not have access to all functions of the website, or not all pages of the website will be displayed correctly.
You may choose whether to use cookies at all, or to adjust the settings of your browser used to view the website. This is available in your browser settings. Please find instructions here:
Edge
Internet Explorer
Chrome
Chrome for iOS
Chrome for Android
Safari for macOS
Safari for iOS
Firefox
Firefox for iOS
Firefox for Android
You may find more information about cookies and managing them following the link.
By visiting the website of Get Experts Recruitment LLC, you agree to this Policy, including the fact that Get Experts Recruitment LLC may use cookies and other data for their subsequent processing by Yandex. Metrics, etc., as well as transfer same to third parties for research, performance of work or provision of services.
The Procedure and Conditions for Processing Personal Data
The Operator processes personal data subject to obtaining the consent of the subject of personal data, except the cases established by the legislation of the Russian Federation when personal data can be processed without such a consent.
The subject of personal data decides to provide his/her personal data and gives consent freely, of his/her own free will and in his/her own interest.
A consent may be granted in any form that allows the web form to confirm its receipt. In cases provided for by the legislation of the Russian Federation, the consent is executed in writing.
A consent may be withdrawn by a written notice sent to the Operator by post.
The Operator processes personal data by the following methods:
non-automated processing of personal data;
automated processing of personal data with or without transmission of the received data via information and telecommunication networks;
mixed processing of personal data.
The Operator shall make no decisions that may have legal implications for the subjects of personal data or otherwise affect their rights and legitimate interests, based solely on the automated processing of their personal data.
The processing of personal data by the Operator includes the collection, recording, systematization, accumulation, storage, clarification (updating, modifying), extraction, use, transfer (dissemination, provision, access), cross-border transfer, blocking, deletion, and destruction of personal data.
The Operator may transfer personal data to the agencies of inquiry and investigation, other authorized agencies on the grounds provided for by the current legislation of the Russian Federation.
Should it be necessary to interact with third parties in order to achieve the goals of processing of personal data, the Operator may transfer personal data to authorized third parties in order to achieve the goals of processing.
The Operator may transfer personal data abroad (to the territory of a foreign state to a foreign natural person or a foreign legal entity.)
The Operator develops public sources of personal data of the Operator’s employees (directories, address books.) Personal data reported by the subject are included in such sources only with the written consent of the subject of personal data or based on the requirements of the current legislation of the Russian Federation.
The Operator processes personal data of subjects of personal data permitted for dissemination based on a separate consent of the personal data subject to the processing of such personal data. The Operator shall provide the subject of personal data with the opportunity to determine the list of personal data for each category of personal data specified in the consent to the processing of personal data permitted by the subject of personal data for dissemination.
The Operator has established the following conditions for the termination of the processing of personal data:
achievement of personal data processing goals and maximum storage periods;
no further need to achieve the goals of processing of personal data;
provision by the subject of personal data or his/her lawful representative of information confirming that the personal data have been illegally obtained or not necessary for the declared goal of processing;
impossibility to ensure the lawfulness of the processing of personal data;
withdrawal by the subject of personal data of his/her consent to the processing of personal data, if the storage of personal data is no longer required for the purposes of processing personal data;
expiry of the statute of limitation for legal relations whereunder the personal data are or were processed.
The personal data shall be stored in a form that allows to identify the subject of personal data within a period not longer than that required for the purposes of processing personal data, except when the period for the storage of personal data is established by federal law and/or an agreement whereto the subject of personal data is a party, beneficiary or grantor.
When storing personal data, the Operator uses databases located on the territory of the Russian Federation.
Measures for the Proper Organization of Processing and Ensuring the Security of Personal Data
When processing personal data, the Operator shall take all necessary legal, organizational and technical measures to protect them from unauthorized or accidental access, destruction, modification, blocking, copying, provision, dissemination, as well as from other illegal actions. The security of personal data is achieved, in particular, in the following ways:
appointment of a person responsible for the organization of the processing of personal data;
implementation of internal control and/or audit of compliance of personal data processing with Federal Law No. 152-ФЗ dated July 27, 2006 “On Personal Data” and regulatory legal acts based on this Law, requirements to the protection of personal data, and internal acts of the Operator;
briefing of the Operator’s employees directly involved in the processing of personal data on the provisions of the legislation of the Russian Federation on personal data, including the requirements to the protection of personal data, internal acts governing the processing of personal data and/or training of these employees;
identification of the threats to the security of personal data during their processing in information systems for personal data;
application of organizational and technical measures aimed to ensure the security of personal data during their processing in information systems for personal data required to meet the requirements to the protection of personal data;
assessment of the efficiency of the measures taken to ensure the security of personal data prior to the commissioning of the personal data information system;
accounting of personal data media;
detection of the facts of unauthorized access to personal data and taking appropriate measures;
recovery of personal data modified or destroyed due to unauthorized access thereto;
putting in place rules for access to personal data processed in the personal data information system, as well as ensuring registration and accounting of all actions performed with personal data in the personal data information system;
control over the measures taken to ensure the security of personal data and the protection level of personal data information systems.
The duties of the Operator’s employees who process and protect personal data, as well as their responsibility, are determined in the “Regulations on the Organization of Processing and Ensuring the Security of Personal Data” of the Operator.
Person Responsible for the Organization of the Processing of Personal Data
The rights, obligations and legal liability of the person responsible for the organization of the processing of personal data are established by Federal Law No. 152-ФЗ dated July 27, 2006 “On Personal Data” and the “Regulations on the Organization of Processing and Ensuring the Security of Personal Data.”
The person responsible for the organization of the processing of personal data shall be appointed and discharged by order of the General Director of the Operator. The appointment of a person responsible for the organization of the processing of personal data should take into account the powers, competencies and personal qualities of the candidate, required to allow to properly and fully exercise his/her rights and bear the obligations provided for by the “Regulations on the Organization of Processing and Ensuring the Security of Personal Data.”
The person responsible for the organization of the processing of personal data shall:
arrange for the implementation of internal control over compliance by the Operator and its employees with the legislation of the Russian Federation on personal data, including requirements to the protection of personal data;
bring to the attention of the Operator’s employees the provisions of the legislation of the Russian Federation on personal data, internal acts on the processing of personal data, requirements to the protection of personal data or procure same;
exercise control over the acceptance and processing of appeals and requests of personal data subjects or their representatives.
Contact details of the person responsible for the organization of the processing of personal data: Get Experts Recruitment LLC, phone: +7 495 228 22 08; e-mail: info@getexperts.ru, Russian Federation 115054 Moscow, Paveletskaya square 2, bld. 2.
Update, Correction, Deletion and Destruction of Personal Data, Responses to Requests from Subjects for Access to Personal Data
In case of ascertainment of inaccuracy of personal data or their unlawful processing, the Operator shall update such personal data or terminate their processing accordingly.
The fact of inaccuracy of personal data or the unlawfulness of their processing can be established either by the subject of personal data or by the competent state authorities of the Russian Federation.
At the written request of the subject of personal data or his/her representative, the Operator shall provide information on its processing of personal data of such a subject.
The request should contain:
the number of the primary identity document of the subject of personal data and his/her representative,
date of issue and issuing authority,
data confirming the relations between the subject of personal data and the Operator (No. and date of agreement, conventional word mark and/or other information), or information otherwise confirming the fact of processing of personal data by the Operator,
signature of the subject of personal data or his/her representative.
The request can be sent in an electronic form and signed with an electronic signature in accordance with the legislation of the Russian Federation.
If the request of the subject of personal data does not contain all the necessary information or the subject may not access the requested information, a reasoned refusal shall be sent to such a subject.
Based on the procedure provided for in clause 11.3, the subject of personal data may demand from the Operator the clarification of his/her personal data, their blocking or destruction if the personal data are incomplete, outdated, inaccurate, illegally obtained or not required for the declared purpose of processing, as well as take legal measures to protect his/her rights.
Upon achievement of the goals of processing personal data, as well as if the subject of personal data withdraws his/her consent, personal data shall be destroyed:
unless the agreement whereunder the subject of personal data is a party or a beneficiary or a grantor provides otherwise;
if the Operator is not entitled to process such data without consent of the subject of personal data on the grounds provided for by the Federal Law “On Personal Data” or other federal laws;
unless another agreement between the Operator and the subject of personal data provides otherwise.
Liability
Persons guilty of violating the rules governing the processing and protection of personal data shall bear liability under the legislation of the Russian Federation, internal acts of the Operator and agreements governing the legal relationship between the Operator and third parties.
Access to the Policy
The current version of the Policy on paper is available at the address: Russian Federation 115054 Moscow, Paveletskaya square, 2, bld. 2.
The electronic version of the current version of the Policy is publicly available on the Operator’s website: getexperts.ru
Amendments
The Policy shall be approved and put into effect by the Director General of the Operator.
The Operator may amend the Policy. In case of amendment, the front page of the Policy shall bear the date of approval of the current version of the Policy.
The Policy shall be reviewed on a regular basis, once a year from the date of the previous revision of the Policy. The Policy shall be re-approved if amendments were made based on the a result of the revision.
The Policy may be reviewed and re-approved before the above deadline, as amendments are made:
to regulatory legal acts in the field of personal data;
to internal regulatory and individual acts of the Operator governing the organization of processing and ensuring the security of personal data.
All relations relating to the processing of personal data not covered by this Policy shall be governed in accordance with the provisions of the legislation of the Russian Federation.
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