INFORMATION NOTE PERTAINING TO THE PROTECTION OF PERSONAL DATA PURSUANT TO THE PRINCIPLES AND PROCEDURES OF LAW NO. 6698 ON THE PROTECTION OF PERSONAL DATA (“KVKK”)
We at RB Yönetim Danışmanlığı Anonim Şirketi (“Company”), part of international executive search, leadership and assessment group Odgers Berndtson, value the importance of protecting the personal data we retain about individuals related to the Company, including our clients and suppliers, as well as the executives, employees and shareholders of the organizations, with which we cooperate or engage, along with candidates and our own employees. Accordingly, as data controller, we take all necessary measures regulated and required by applicable legislation including the Constitution of the Republic of Turkey and Law No. 6698 on the Protection of Personal Data (“KVKK”).
With this information note, we aim to provide some details about the key principles of KVKK as part of our obligation to inform the public as stipulated by Article 10 of this Law.
1. Personal Data Processing - Purpose and Principles
The personal data we retain about the individuals related to the Company, including the shareholders and employees of the Company’s clients, as well as those of candidates and the Company’s own employees will be collected, processed, recorded and/or stored by the Company or natural or legal entities cooperating with and authorized by the Company for the purposes of carrying out and improving the services that we provide most effectively and fulfilling our legal obligations in line with the Company’s legitimate interests in compliance with the core principles of:
1.1. Being in conformity with the law and good faith;
1.2. Being accurate and if necessary, up to date;
1.3. Being processed for specified, explicit, and legitimate purposes;
1.4. Being relevant, limited and proportionate to the purposes for which data are processed; and
1.5. Being stored only for the time designated by relevant legislation or necessitated by the purpose for which data are collected.
2. Services Provided for Clients
As a Private Recruitment Office, licensed by the Turkish Employment Authority, we offer primarily the following services:
2.1. Search and/or recruitment consultancy for senior executive roles in organizations or group companies;
2.2. Talent search and market research activities in order to assist our customers to gain a better understanding regarding the available candidates for specific industries and/or expertise; and
2.3. Assessment, leadership development and coaching services aimed at employees of organizations or group companies.
3. Personal Data to be Processed and Sources
As data controller, we collect, process and record personal data including identification, contact, professional résumé, experience, academic and professional education information, references, professional and psychometric assessments, skills, current, past and targeted salaries, and audio and visual data.
Furthermore, pursuant to Labor Law No. 4857 in particular and other applicable legislation, and within the framework of our work relations with our employees, the personal data of our employees are collected, processed, recorded and/or stored by the Company or natural or legal entities cooperating with and authorized by the Company for the purposes of fulfilling our obligations arising from relevant legislations, ensuring occupational safety, and improving employee satisfaction.
The personal data of the real person representatives of the legal entities or natural entities, which we cooperate with and/or procure products and/or services from, are also collected, processed, recorded and/or stored by the Company or natural or legal entities cooperating with and authorized by the Company.
4. Personal Data Collection – Purposes and Methods
Within the scope of purposes stated in article 1 of this information note, “Personal Data Processing - Purpose and Principles”, your personal data may be communicated to us directly by you or persons representing you and/or your employer in verbal and/or written form and/or electronic medium. We are also able to obtain information via social media platforms open to the access of third parties or different third persons that may provide reference about you. Such information may be collected by the Company and/or natural or legal entities processing data on behalf of the Company by various means including websites, different agreements, email, forms, invitations and mobile apps, etc. in verbal or written form or electronic medium.
We may use the personal data we have collected to assess your suitability for the roles within the scope of services we provide as stated in article 2 of this information note, to gain a better understanding of the candidates in the markets in which we operate as a Company or consider them for a position, and to ensure your participation in leadership development and coaching activities.
In the event that one of the roles we search matches your experience and other qualifications, we may include your personal data in the long list report we share with our client after we anonymize your profile, and assist our client in deciding on whether to or not to interview you. Please be informed that in such cases we would not share any personally identifiable data with our clients without obtaining your explicit consent.
We also do not include your personal data in the short list of candidates that we would submit to our client for a specific role without obtaining your explicit consent.
5.Transfer of Personal Data
Within the scope of purposes stated in article 1 of this information note, “Personal Data Processing - Purpose and Principles”, and in accordance with the provisions set out by KVKK and relevant legislation, your personal data may be stored in the Company’s private server/cloud platform hosted within the country and/or abroad, and transferred to data processors, business and program partners, shareholders, performance assistants, subcontractors, and natural or legal third party entities in line with the objectives of the services we provide, and state authorities.
6. Your Legal Rights as a Data Subject
Pursuant to Article 11 of KVKK, you, as the owner of personal data, are entitled to:
6.1. Learn whether or not your personal data have been processed,
6.2. Request information as to processing if your data have been processed;
6.3. Learn the purpose of processing of your personal data and whether such data are used in accordance with their purpose;
6.4. Know the third parties to whom personal data have been transferred within the country or abroad;
6.5. Request rectification in case your personal data have been processed incompletely or inaccurately;
6.6. Request deletion or destruction of your personal data within the framework of the conditions set forth under article 7 of KVKK, “Deletion, Destruction, and Anonymization of Personal Data”;
6.7. Request that the transactions carried out pursuant to your requests as per 6.5 and 6.6 above are notified to third parties to whom personal data have been transferred;
6.8. Object to any result that arises to your detriment by means of analysis of personal data exclusively through automated systems; and
6.9. Request compensation for the damages in case you incur damages due to unlawful processing of personal data
by applying to the data controller.
In the event that you wish to exercise one of your rights stated in this note, you may submit your request to the Company in writing pursuant to article 13, paragraph 1 of KVKK or communicate it by other means to be prescribed by the Personal Data Protection Board. You may forward your written request regarding your personal data by providing your name, surname and contact information and expressing your request in an open and comprehensible manner with your original signature together with documentation proving your identification to Harbiye Mah. Teşvikiye Cad. Belveder Apt. No:15 Kat:6 Şişli, İstanbul or by email to veri.sorumlusu@odgersberndtson.com.tr with your secure electronic signature.
Sincerely,
RB Yönetim Danışmanlığı Anonim Şirketi