Privacy Policy LTP

1. Who are we and what do we do?

We are LTP Advies B.V. (LTP). LTP is the oldest HR consultancy in the Netherlands and advises various companies on a wide range of issues. Our core services include assessments for selecting and developing new and existing employees, personal development, team/organisational development and to conduct analysis (the Services).

Those analysis consist of applied analytics on candidate and employee related data to analyse patterns and make predictions concerning various aspects of recruitment and people development. (People Analytics).

As your privacy is extremely important to us, we consider it our responsibility to protect it. In this Privacy Policy, we explain which types of Personal Data we process through our Services. We also explain the purposes for which we use Personal Data, what role we play in processing Personal Data, and how long we retain Personal Data.

For more information on our services, visit www.ltp.nl/en (the Website).

2. Privacy and Privacy Legislation

We process Personal Data. Personal Data refers to any information that can directly or indirectly identify a person. This corresponds with the definitions of the General Data Protection Regulation (GDPR)[1] and other relevant laws and regulations on protecting personal data (collectively: the Privacy Legislation).

3. Our position as Controller

We collect and process Personal Data in connection with our Services. We determine the purpose and means of this processing of Personal Data. This means that we act as a controller within the meaning of the Privacy Legislation.

4. What personal data do we process and for which purposes do we use them?

As the controller, we may process Personal Data if you use our assessment system (Assessment System), or our Services through the Persona.fit application (App), if you purchase our Services as an employee (Customers) and/or if you visit our Website.

If you want to use our Services through the Assessment System:

Personal data:

Purpose(s):

Basis/Bases:

Contact data:

First name and surname, email address, your telephone number (if you contact us by telephone), and your place of residence (if you take the assessment on location).

If your potential or existing employer invites you for an assessment, we obtain your contact details from the employer.

We use these data:

  • To identify candidates and address them appropriately;
  • To contact candidates, including to invite them by email to complete the questionnaire(s) and to provide support in using our Services; and
  • For marketing purposes, such as providing updates on the development services we offer; and
  • If you are going to take the assessment on location, we process your telephone number and place of residence to arrange a suitable appointment.

We may process these data based on a legitimate interest, namely to contact the participant to provide our Services.

Profile data:

Date of birth, level of education, gender, employer’s name, your current and/or future position, and relevant sector.

We use these data:

  • To create unique user IDs; and
  • To identify the right characteristics and norms and to generate group or other analyses; and
  • To further develop and refine our Services, such as improving our questionnaires and feedback description.

 

We may process these data based on your consent.                 

Assessment and coaching results:

  • Unique user IDs; and
  • Answers to the questionnaire(s) and their completion date.

We use these data:

  • On the basis of applied People Analytics draw up individual and/or group reports and provide feedback to the candidate and –  with consent – to your potential or existing employer;
  • To develop and refine our Services, such as improving our questionnaires and feedback description; and
  • In anonymised form, to perform scientific research.

We process the assessment and feedback results based on your express consent.

After completion of the assessment, we ask your separate consent to share your assessment data with your potential or existing employer.  Note: this is not mandatory. LTP has agreed contractually with your potential or existing employer that there will be no consequences for not giving consent.

If you want to use our Services through the App:

Personal data:

Purpose(s):

Basis/Bases:

Contact Details:

First name and surname, email address, and your telephone number if you contact us by telephone.

If your potential or existing employer invites you for an assessment, we obtain your contact details from the employer.

We use these data:

  • To identify candidates and address them appropriately; and
  • To contact candidates, including to invite them by email to complete the questionnaire(s) and to provide support in using our Services.
  • For marketing purposes, such as providing updates on the development services we offer; and

We may process these data based on a legitimate interest, namely to contact the participant to provide our Services.

Account data:

First name and surname, email address, password, gender, and selected language.

We use these data:

  • To register your account and grant you access to it;
  • To give you an overview of your assessment and feedback results;
  • To access your messages in your App inbox; and
  • To create unique user IDs.

We may process these data based on your consent.

 

Assessment and feedback results:

  • Unique user IDs, your email address, and the email addresses of those from whom you request feedback;
  • The answers to the questionnaire(s), the response time, and completion date of the questionnaire(s); and
  • Feedback obtained about yourself/feedback given about the person giving you feedback.

We use these data:

  • To identify the right characteristics and norms and to generate group or other analyses (people analytics);
  • On the basis of applied People Analytics draw up individual and/or group reports and provide feedback to the candidate and –  with consent – to your potential or existing employer;
  • To develop and refine our Services, such as improving our questionnaires and feedback description; and
  • In anonymised form, to perform scientific research. 

We process the assessment and feedback results based on your express consent.

After completion of the assessment, we ask your separate consent to share your assessment data with your potential or existing employer. 

Note: this is not mandatory. LTP has agreed contractually with your potential or existing employer that there will be no consequences for not giving consent.

If you purchase our service as a Customer:

Personal data:

Purpose(s):

Basis/Bases:

Customer’s contact data:

Contact person’s first name and surname, telephone number and email address.

We use these data:

  • To identify and address the contact person appropriately;
  • To make and maintain contact.

We may process this data because this is necessary to perform the agreement with our customer.

Payment details

Bank details (account number, account holder name, BIC details).

We use these data:

  • To enter them in our accounting records for the Dutch tax authorities;
  • To process, audit and manage customer payments.

We may process this data because this is necessary to perform the agreement with our customer.

We are also legally obliged to process and/or share all or part of these data for or with the Dutch tax authorities.

If you visit our Website:

Technical information

Information about the type of device used to access our Website, IP address and information on the type of browser used.

We use these data:

  • To communicate in the same browser language; and
  • To adapt our Website to the device used.

We may process these personal data because we have a legitimate interest in a proper functioning Website.

Newsletters

Email address and name.

We use these data:

To keep you informed of our Services and any updates to them through our newsletter.

We may process these data based on your consent.

Each newsletter has an unsubscribe link.

Contact details if you contact us through the Website

Your stated name, email address, telephone number, the name of your organisation, and any other personal data contained in the chat message or contact form you have sent.

If you contact us by email, we process only your email address and any personal data contained in your email.

We use this information:

  • To contact the potential or existing customer and/or candidate based on the message sent; and
  • To assist you with any comments, questions and/or complaints you submit to us.

We may process these Personal Data because we have a legitimate interest in contacting and helping potential or existing customers and/or candidates based on their comments or questions.

Social media data

Information that you make public, when you leave a response or otherwise post something on our social media channels.

We use this information:

To communicate with you and process your message/feedback on our social media channels.

We may process these Personal Data because we have a legitimate interest in processing these data and because you voluntarily disclose this information.

Our social media channels are also managed by the social medium itself. Check each social medium’s privacy policy here to see how it processes Personal Data:

LinkedIn: Privacy Policy 
Twitter: Privacy Policy 
Facebook: Privacy Policy

5. Do we share your Personal Data with others?

Processors
For the purpose of our Services, we use several parties that process Personal Data on our behalf (Processors). For example, we use Processors for using the IT and other services of third parties such as hosting and data storage provider (AWS), ERP system (AFAS), marketing tools (such as MailChimp and Pipedrive) and email provider Outlook. If you have given your express consent, your personal data will also be shared with your potential or existing employer. We have made arrangements with all our Processors in processing agreements which – in line with this Privacy Policy – set out what these parties may do with, how they must protect and when they must delete Personal Data.

External Controllers 
Payments can be processed through our external payment provider Mollie. Payments made in this way are subject to the terms and conditions of the relevant service. The Personal Data you provide to this payment provider are processed in accordance with its privacy policy.

We are legally obliged to include some Personal Data in our accounting records that have to be shared with the Dutch tax authorities. The Dutch tax authorities will process these Personal Data as the Controller in accordance with its privacy policy.

Apart from the above cases, we will not share your data with third parties unless we are legally obliged to do so.

6. How long do we retain personal data?

We retain personal data only for as long as we need them for the above purposes. We apply at least the following retention periods:

Personal Data of candidates | We retain these data for five (5) years from when you provide the Personal Data to LTP, unless you withdraw your consent earlier. In that case, the Personal Data provided on the basis of the consent are deleted.

Personal Data of website visitors | These data are retained for as long as needed for their respective purposes. Among other things, you can edit or remove data that you share on our social media pages.

Personal data in our accounting records for the Dutch tax authorities | We retain these data for seven (7) years unless we are legally obliged to retain them longer.

Personal data for sending newsletters | These data are retained until you unsubscribe from our newsletter.

Other information | We retain other Personal Data only for as long as needed for the purposes of the processing. This means that other personal data are deleted as soon as they are no longer needed for the purposes for which we have processed them.

We retain personal data for longer than the above periods if we are legally obliged to do so.

7. Exporting data outside the European Union (EU)

LTP does not intend to transfer personal data to parties outside the EU, and will therefore endeavor to only process personal data or have personal data processed within the EU. However, our processors remain the right to transfer personal data to parties outside the EU in case of exceptional emergencies (such as breakdowns and / or natural disasters). This transfer of data outside the EU will be done in accordance with the Privacy Legislation (chapter 5 of the GDPR).

8. How do we protect personal data?

We  work hard to protect personal data from unauthorised or unlawful access, alteration, disclosure, use or destruction. Among other things, we implement these technical and organisational measures to protect personal data:

  • We operate in accordance with the ISO27001 standard on information security; and
  • g. Securing our network connections with Secure Socket Layer (SSL), Transport Layer Security (TLS) or similar technology;]
  • Securing personal data in accordance with the ISO 27001/27002 standard;
  • Limited access to personal and other data for the customers through two-factor authentication;
  • Restricted access to personal and other data for employees and freelancers through two-factor authentication;
  • Annual audits of our security by an external party
  • g. including mandatory or other delays in email transmission.
9. Cookies

We use cookies on our Website. A cookie is a simple small text file that can be placed on your computer when you visit our Website. This text file identifies your browser and/or computer. Next time you visit our Website, the cookie allows our Website to recognise your browser or computer.

We use these types of cookies:

Functional cookies | Functional cookies are essential for the functioning of our Website.
They enable you to navigate around our Website and use its functions. We use these cookies to optimise the functionality of certain Website pages.

Analytical or statistical cookies | We use analytical cookies (such as Google Analytics) to examine the quality and effectiveness of the Website. The statistics are kept anonymous. LTP stores only the session ID, browser language and test ID of the tests being made. For example, we can see how many users visit the Website and which pages they visit. We use this information to improve our Website and Services.

Tracking cookies | Tracking cookies track the browsing and click behaviour of website visitors. Cookies from external providers, including Google, Facebook, Twitter and LinkedIn, may be used to place advertisements based on a user’s previous visits to our Website.

LTP’s Website is also protected by the security cookie ReCAPTCHA, a tool that ensures, among other things, that malicious software and fake visitors are blocked from our Website. This privacy policy explains which personal data are collected for this purpose.

If you do not wish to receive cookies, you can change this through your browser’s cookie settings. Bear in mind that some of our Website’s functions or services may not function, or may not function as well, without cookies.

10. Third-party websites

Visitors to our Website may find hyperlinks and other links on our Website to the websites of partners, suppliers, advertisers, sponsors, licensors or other third parties. We have no control over the content or links that appear on these websites and we are not responsible for the practices of websites linked to or from our Website. In addition, these websites, including their contents and links, can always change. These websites can have their own privacy policies, terms of use and customer policies. Browsing and interaction on any other website, including websites linked to or from our Website, are subject to that website’s conditions and policies.

11. Amendments to this Privacy Policy

As we are constantly looking for ways to improve our Website and Services, we may occasionally update our Privacy Policy. If we make significant amendments to the Privacy Policy, we will notify those concerned.

12. Your rights and our contact details

Under the Privacy Legislation, you have the right to:

  • request us to rectify or update your data;
  • request us to remove your data from our database without giving reasons;
  • request a copy of any of your personal data that we have processed. We can also forward this copy to another data administrator at your request;
  • withdraw your consent to the processing of your data if the processing is based on consent. This does not affect the validity of processing operations before you withdraw your consent;
  • object to our processing of your data;
  • lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) if you believe that we are unlawfully processing your data.

To exercise these rights, ask questions or comment on how we handle personal data, you can contact us using the contact details below. We aim to answer your message within two working days.

LTP Advies B.V.
Prof. W.H. Keesomlaan 6
1183 DJ Amstelveen
The Netherlands

+31 (0)20 305040
info@ltp.nl  
www.ltp.nl/en

Chamber of Commerce number: 34139534
VAT number: NL8102.84.881.B.01

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