Houthoff Coöperatief U.A. and its subsidiaries Houthoff België B.V., Houthoff London LLP and Houthoff New York B.V. (hereinafter jointly referred to as "Houthoff", "we" and "us") respect the privacy of job applicants and observe due care when handling the personal data processed in the context of recruitment, selection and application activities.

This statement applies to all persons applying for a job with Houthoff or participating in recruitment and selection activities. It supplements and should be read in conjunction with the general privacy statement and cookie statement. This privacy statement contains information on:

• The personal data we process when you apply for a job with us;
• For what purposes and on what legal bases we process personal data;
• With whom we share personal data;
• How long we retain personal data;
• What rights you have and how you can exercise them. 

Personal data processed by us

We process personal data as a controller in accordance with the General Data Protection Regulation (GDPR). As such, we are responsible for determining the purposes and means of processing and we have legal obligations to protect personal data and respect rights.

For recruitment and selection procedures, Houthoff collects and processes various categories of:

• Basic information, including your first and last name, prefix and title;
• Contact details, including your email address, postal address, phone number and other contact details;
• Your gender, date of birth, nationality and any other information that may be relevant regarding your identity;
• Your CV, cover letter, diplomas, certificates, references, letters of recommendation and any other information about your education, work experience, skills and qualifications;
• Your availability, salary indication, willingness to travel and any other preferences or wishes and any other notes taken by interviewers during the job interview or other conversations;
• Information obtained in the context of assessments or other tests during the application process;
• Information obtained during a pre-employment screening (PES), such as reference checks, a Certificate of Conduct (Verklaring Omtrent het Gedrag) and an integrity statement;
• Any other personal data voluntarily provided.
  
   

To the extent that we process any special personal data, we do so only if the data subject has intentionally made these public, as referred to in Article 9(2)(e) of the GDPR. 

If you are required to provide certain personal data, for example due to a legal obligation we have or to enable us to conclude an employment agreement with you, we will inform you accordingly and explain the potential implications of not providing these data.

Purposes of and bases for the processing

We only process personal data for the purposes for which they were collected and on one or more of the following bases:

To ensure proper record keeping and internal management.

Purpose of processing	Basis
To select candidates to start an application procedure with and to carry out the application procedure.	Legitimate interest
To complete the precontractual phase with you and to be able to conclude an agreement with you, including an employment agreement.	Legitimate interest Performance of contracts Legal obligations
To answer your questions and to provide information requested by you.	Legitimate interest Consent
To carry out a PES.	Performance of contracts Legal obligations/span> Legitimate interest
To send communications on and invitations to recruitment activities.	Legitimate interest Consent
To ensure proper record keeping and internal management.	Legitimate interest Consent
To handle any complaints you may have and to resolve disputes.	Legitimate interest

Pre-employment screening (PES)

At Houthoff, we place great importance on the integrity and suitability of our future staff. An integral part of our selection process is the PES. Conducting a PES serves our legitimate interest and is necessary to obtain a more complete picture of applicants, so that we can be assured that our current and future employees are honest and reliable.

The purpose of this screening is to verify relevant information on potential employees and to meet the highest ethical and behavioural standards. The screening's nature and contents vary according to the specific position you have applied for. You will be informed accordingly beforehand.  The PES can comprise the following elements:

• Verification of your employment history, education and other information necessary to assess your qualifications and suitability for the position; 
• Performance of an assessment or a personality questionnaire to measure competence, skills and personality traits; 
• Request for a Certificate of Conduct, an integrity statement or any other documents demonstrating reliability; 
• Consultation of public sources, such as the insolvency register, the guardianship and administration register, the Central Judicial Collection Agency, the register of the Netherlands Bar or any other professional organisations, or the internet.

We may engage third party experts for the PES. Applicants are requested to provide the data required directly to these parties. We have concluded a data processing agreement with these parties to ensure that your personal data are protected and properly processed. These parties may only use the personal data for the purposes for which we provided these data to them and must remove the data or return them to us after the end of the screening. 

While participation in the PES is voluntary, it is a condition for entering into an employment agreement with us. If you choose not to provide certain information or not to participate in the screening, you might not be allowed to continue with the selection process or we might not be able to make you an offer. 

Personal data retention periods

We will retain your personal data no longer than necessary for the purposes for which they were collected and processed, in accordance with the GDPR and other applicable legislation. The retention periods vary according to the type of position you have applied for and the outcome of the application procedure.

For every application with Houthoff, your name, the date of the interview and the position you have applied for will be recorded for administrative purposes.

Houthoff applies the following specific retention periods:

1. Starter jobs: trainee lawyer, trainee tax adviser, trainee candidate civil-law notary: personal data, including assessment data, are removed no later than four weeks from the end of the application procedure, unless you enter our service after the procedure or have given us your consent to retain them for longer for future vacancies. In that case, the data will be retained for up to three years after obtaining your consent.
2. Student legal assistant: personal data will be retained for three years, provided that you have given your consent. When submitting your job application via the website, you consent to the processing and retention of your data. If you object to this, please let us know by email. Without consent, all data will be removed from files and systems. If you enter our service, the retention periods applicable to Houthoff employees will apply.
3. Student trainee: personal data will be retained for three years, provided that you have given your consent. When submitting your job application via the website, you consent to this retention period by ticking the appropriate box. If you object to this, please let us know by email. Without consent, all data will be removed from files and systems. If you enter our service, the retention periods applicable to Houthoff employees will apply.
4. Houthoff recruitment events: personal data will be retained for three years, provided that you have given your consent. When submitting your job application via the website, you consent to this retention period by ticking the appropriate box. If you object to this, please let us know by email. Without consent, all data will be removed from files and systems.
5. Third party recruitment events: personal data will be retained for three years, provided that you have given your consent via the third party. Without consent, all data will be removed from files and systems. 
6. Employed by Houthoff: if you enter our service, your personal data will be retained in the personnel file until two years after the end of your employment, unless we have a legal obligation to retain your data for longer or have a legitimate interest in doing so.
   
    

Applicants have the right to submit a request for removal at all times. You can send your request to privacy@houthoff.com. We are not required to comply in all cases, for example if we have a legal obligation to retain your data for longer.

Security of personal data

We have taken appropriate security measures at a technical, physical and organisational level to ensure the confidentiality, integrity and availability of personal data and to protect personal data against unauthorised or unlawful processing, loss, damage or destruction, in accordance with the GDPR and other applicable legislation.

Access to applicants' personal data is limited to our employees who are directly involved in the application procedure. HR staff and other people who are directly involved only have access on a strictly need-to-know basis for the purposes defined above. They will observe confidentiality with regard to your personal data.