Michael Page International Nem Istihdam Danışmanlığı Limited Şirketi ("MPI" "we", “us”, or “our”) is part of PageGroup, and trades under the brands Michael Page, Page Personnel, Page Executive and Page Outsourcing. Protecting your personal data is our priority. This privacy policy explains how MPI processes and protects personal data in compliance with the EU General Data Protection Regulation 2016/679 ("GDPR") and Personal Data Protection Act No: 6698 (“the Act”) about:candidates who register with us for roles that we are managing for other employers and for roles at Michael Page, or through our website, job boards, social media sites or other sources;prospective candidates,business contacts at our clients and suppliers; andusers of our websites; (collectively "you" or “your"). It also tells you about your privacy rights including your right to object to our processing. If you would like to contact us, please see the “How to Contact Us” section of this policy.Personal data we collectCandidates When you register with us as a candidate to provide work finding services to you, we process your personal data, including but not limited to your name, contact details and information from your CV. We may also collect, in accordance with the Act, certain sensitive personal data (known as special category data in the Act)relating to your health (for example, disability information for reasonable work adjustment purposes), diversity information, including race, ethnic origin, sexual orientation and religion (for equal opportunity monitoring purposes). We have processes in place to limit our use and disclosure of such sensitive data in accordance with the Act. If you use our website, click on links in emails we send to you, open or forward them, or sign up to receive job alerts or other content from us, we also collect personal data from those interactions. We also obtain personal data about you from third parties, including, referees - when you are offered a job;former employers - to confirm dates of employment;educational institutions - to check your academic qualifications;credit reference agencies - if we need to check your financial standing;publicly available sources such as LinkedIn and social media sites to enhance the information we hold about you, in order to help us find more suitable roles for you; clients to whom we have provided your CV and who have engaged with you as part of a job application or who have given feedback on your CV. Prospective Candidates We collect personal data about you, including your name and contact details and professional biographical details obtained from publicly available sources such as LinkedIn and social media sites, so that we can contact you if we think you may be interested in our work finding services at a future date. We may also obtain your personal data through another candidate or an employer who recommends you as a contact. Users of our website or apps We collect personal data such as your IP address and other data about your device which we need to provide our online content to you. We also collect data about your engagement with our website or apps such as the pages you view. If you contact us, we will also collect information about your enquiry. Clients We collect personal data such as your name, job title and contact details. We also process personal data about what communications we have had with you, including whether you have opened or forwarded any emails, newsletters or other content we have sent to you. We also process feedback that you provide about our candidates. If you provide information to us about a candidate (for example, if you confirm a candidate has worked with you or if you provide a reference), then we will obtain your details from the candidate and we will keep a record of the personal data that you provide to us about that candidate. We process personal data about you from public domain sources such as LinkedIn and social networking sites or because you were a delegate at one of our events or at an event where the event organiser is permitted to share delegate details with us.Suppliers We typically collect your name and contact details as a business contact for your organisation.Providing your personal dataIn some cases, it will be necessary for you to provide personal data to us. If you don’t provide us with the personal data we ask for, we may not be able to provide you with our services. How we use your personal dataCandidatesWe use your personal data to: provide you with work finding services;communicate with you;enable you to upload your CV and apply for jobs;personalise your experience by creating a candidate profile; enable us to monitor equality and diversity;provide you with interviewing and salary advice; andsend you direct marketing for the purposes of informing you about job opportunities, industry reports and insights, events, promotions and competitions, and other content in accordance with your marketing choices. We also run targeted and relevant banner advertising on our website and within your social networks to present you and people like you with jobs and content that we believe will be of interest. We target these ads based on your previous interactions with our website, emails and through your engagements with our consultants. Your interaction with our ads may be used to measure the effectiveness of our ad campaigns and to improve our marketing strategy.Prospective Candidates We use your personal data to:determine if you may be interested in our services and how we can assist you;to contact you and find out if you are interested in our services.Users of our website or appsWe may use your personal data to:improve and personalise your experience when you use our website or apps; andpersonalise advertising you receive from us.ClientsWe may use your personal data:to provide recruitment services to you; to communicate with you;to get feedback from you on our services through client satisfaction surveys, in order to improve our services and to develop new services;to maintain our business relationship with you;to answer your enquiries when you contact us;to fulfil contractual obligations to you;to establish, exercise or defend legal claims; andfor direct marketing purposes.SuppliersWe use your personal data:to communicate with you;to maintain our business relationship with you;to answer your enquiries when you contact us;to fulfil contractual obligations to you;to establish, exercise or defend legal claims; and for direct marketing purposes.You can unsubscribe from receiving marketing communications from us, using the unsubscribe methods contained in communications we send to you or by contacting us. We have also established a marketing preference centre where you can view and make decisions about your marketing preferences and opt out of receiving marketing from us at any time.Back to top ↑Legal Grounds for processing your Personal DataAccording to Articles 5 and 6 of the Act, we rely on the following legal grounds to process your personal data:(a) Performing a contract - where, in order to perform our obligations under a contract with you or to take steps at your request to enter into a contract with us, it is necessary for us to process your personal data; (b) Compliance with a legal obligation - where we need to process your personal data to comply with legal or regulatory obligations.(c) Our legitimate interests or those of a third party - including:providing our services to you;responding to your requests and enquiries;optimising the performance of our website and user experience;informing you about our services and;ensuring that our operations are conducted in an efficient manner.(d) Consent In some circumstances, we will ask for your consent to process your personal data in a way. For example, if you create a user profile or register for our job alerts or other content. To the extent that we are processing your personal data based on your consent, you have the right to withdraw your consent at any time. Please contact us, if you would like to withdraw your consent.Automated Decision MakingWe use a CV parsing tool that enables us to filter through CVs when we receive many applications for roles that we advertise, and to enter relevant key words such as years of experience or field of practice. It then analyses all the CVs uploaded into it and delivers a smaller pool of candidates by matching the key words in candidates’ CVs and ranking the candidates according to their suitability for the role. By doing this, it also eliminates candidates who do not meet the search criteria. Our legal basis for this processing activity is necessity for entering into a contract. You have the right to object to the use of automated decision making and to request human intervention. If you would like to exercise this right, please contact us.Who we share your personal data withIn certain circumstances we will share your personal data with: Other companies within our Group MPI is part of the PageGroup of companies which operates globally. We may share with or give access to your personal data to other companies within PageGroup which are among the Countries announced by the Turkish Personal Data Protection Board (“the Board”) as countries having adequate measures (“Countries”) or if you provided prior explicit consent to this sharing.Furthermore, we have in place an intra-group data transfer agreement containing model clauses approved by the European Commission which permit cross-border transfers of personal data from within the EEA to third countries outside the EEA, (as data protection laws outside the EEA may not provide an equivalent level of protection to EEA data protection laws), (“Model Clauses”). If you would like a copy of the Model Clauses, please contact us.Here you may find a complete list of our European Page entities.Where we need to transfer personal data to another PageGroup company outside the Countriesfor the purposes set out above, we may seek your prior explicit consent and we will comply with any local law transfer requirements.Third PartiesIf you are a candidate, we share your personal data with clients who have vacancies for jobs which you are interested in.We also share your personal data and, where necessary, special category data with third party service providers who perform services and functions on our behalf, such as:conducting employment reference checks;conducting qualification checks;verifying details you have provided from third party sources; conducting psychometric evaluations or skills tests;hosting personal data for us;providing professional advice to us;providing data analytics to us;carrying out testing and development work on our business technology systems;administering surveys or competitions on our behalf; assisting us to communicate with you; andproviding research and mailing house or other direct marketing services. We contractually require minimum standards of confidentiality and data protection from our third party service providers. If we need to send personal data outside the Countries, we will ensure that adequate safeguards are in place, in accordance with the Act.Other Disclosures In addition, we may disclose your personal data: if we are legally required to do so; to law enforcement agencies, regulators or other government officials;to enforce a contract with you; andto the new business owners and their advisers in the event of a re-organisation, merger, sale, joint venture, assignment, or other transfer or disposition of all or any part of our business.Keeping your personal data secureWe have implemented and maintain appropriate technical and organisational measures to protect your personal data from accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. Only authorised personnel and third party service providers are provided with access to personal data on a need to know basis, and these employees and service providers are contractually obliged to treat this information as confidential. How long we hold your personal data forWe will keep your personal data for as long as we need to in order to fulfil the purpose we collected it for, which may be an ongoing purpose. For example, if you’re a candidate, we will retain your personal data for the duration of our business relationship with you and beyond, as we often support candidates with job placements over many years and potentially throughout their careers. We keep some personal data for longer than others. To determine the appropriate retention period for personal data, we consider factors such as the purposes for which we process your personal data, including any legal, regulatory, accounting and reporting obligations, the nature and amount of personal data that we hold about you, and the potential risk of harm to you from unauthorised use or disclosure of your personal data. Where we process your personal data for direct marketing purposes, we will do so until you ask us to stop, and for a short period after this (to allow us to implement your request). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely, so that we can respect your request.Your rights in relation to personal data we hold about you You have several rights under art. 11 of the Act. These rights may include the right to receive confirmation on whether we are processing your personal data, as well as obtaining further information about such processing, and the right to know the purpose for the data processing and if your data is used for such purpose. Furthermore, you have the right to be informed on the third parties to which your personal data is transferred to (inland or abroad); to ask us to correct or delete your personal data and to objection to any adverse conclusion of your data being analysed through automated systems.In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process your personal data to meet a contractual or other legal requirement, or where we are using the data for direct marketing). These rights may be limited, for example, if complying with your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests for keeping. We will inform you of any relevant exemptions we are relying on when we respond to your request. How to Contact UsExercising your rightsTo exercise your rights, or to withdraw your consent to processing, or to unsubscribe from receiving marketing communications from us, you can:email us at personaldataprotection@michaelpage.com.tr , orwrite to us at:Michael Page International Nem Istihdam Danışmanlığı Limited ŞirketiBuyukdere Cad. Kanyon Ofis Binası No 185 Kat 21, 34394 Levent IstanbulTürkiyeQuestions and ComplaintsIf you have any questions about our privacy policy, or about our processing of your personal data, or to make a complaint, you can email us at personaldataprotection@michaelpage.com.trIf you have unresolved concerns, or believe that a personal data breach happened, you have the right to complain with the Turkish Data Protection Board in accordance with the Act.Changes to our Privacy PolicyWe may change this privacy policy at any time. If we do so, we will post updates on this site.
