Privacy Policy

PRIVACY POLICY

1.  Scope

All data subjects whose personal data are collected in accordance with the GDPR

2. Responsibilities

2.1 The Data Protection Officer is responsible for ensuring that this notice is made available to data subjects before Think Attitude collects or processes their personal data.

2.2 All employees of Think Attitude who interact with data subjects are responsible for ensuring the data subject’s attention to this notice and securing consent to the processing of their data.

 

3.  Privacy Policy
3.1 Who is our Data Protection Officer?
Due to the size of its human resources and the type of personal data processed, Think Attitude does not require a Data Protection Officer (DPO). However, given the relevance of the issue in its activity, it has appointed a data protection officer who can be contacted directly at the following address:

• R. Carlos Testa, Nº 1, 5º C, 1050-046 Lisbon // Portugal
  Ph.+351 213540781
  E: rgpd@thinkattitude.com.pt

3.2 What Personal Data does Think Attitude process?
The personal data Think Attitude collects or intends to collect, and process are: 

Type of personal data:	Source: The source from which Think Attitude obtained the data if not from the data subject. (Create a note if this data came from public sources):
Identification	Own
Address	Own
Contacts	Own
CV	Own
Professional Experience	Own

The personal data we collect shall be used for the following purposes:

• Obtaining candidates with the characteristics and professional skills that best adapt to the demands and needs that our clients have expressed in the specifications they have given us.

Think Attitude identifies the legal basis for processing personal data prior to any processing operation by clearly establishing, defining, and documenting it.

The specific purpose for processing the personal data and the legal basis for doing so under:

• Consent obtained from the data subject;
• A contract to which the data subject is a party;
• Legal obligation that Think Attitude is obliged to comply with;
• Protect the vital interests of the data subject, including the protection of rights and freedoms;
• Official authority of Think Attitude or to carry out processing that is in the public interest;
• Necessary for the legitimate interests of the data controller or third parties, unless the processing would be contrary to vital interests, including rights and freedoms;
• National law.

All special categories of personal data processed and the legal basis for doing so under:

• Explicit consent obtained from the data subject;
• Necessity for rights or obligations of employment;
• Protect the vital interests of the data subject, including the protection of rights and freedoms;
• Necessary for legitimate activities with appropriate safeguards;
• Personal data made public by the data subject;
• Legal claims;
• Substantial public interest;
• Preventive or occupational medicine, for the assessment of the employee’s working capacity, medical diagnosis, provision of health care or social assistance, or management of health and social assistance systems and services, under the basis of appropriate contracts with health professionals and safeguards in place;
• Public health ensuring that there are appropriate safeguards for the protection of the rights and freedoms of the data subject, or professional secrecy;
• National laws in terms of processing of genetic, biometric or health

The legitimate interests pursued by us, or third parties we use, are as follows:

• Select the best candidate for the job in question in a timely manner and with the best pay and working environment conditions.

3.3 Consent

By agreeing to this privacy policy, the Data Subject is giving permission to process their personal data specifically for the purposes identified.

Consent is required for Think Attitude to process the types of personal data, but it must be explicitly provided. Where we are asking for sensitive personal data, we will always make explicit, why, and how the information shall be used.

The Data Subject may withdraw consent, insofar as feasible, at any time by means of the mechanisms we make available to them in line with the respective procedure.

3.4 Disclosure
Think Attitude does not disclose your personal data to third parties without first obtaining your consent. The following entities will receive your personal data for the following purposes as part of the processing activities that the company performs:

Organization	Measures to protect your personal data	Example of measures:
Name and place
SS	Measures defined by the MTSS	NA
Potential Clients	Measures defined in the employment contract	NA

3.5 Retention Period

Think Attitude shall process personal data and store personal data for the period set by our policy described in the personal data retention procedure.

3.6 Your rights as Data Subject

At any time and while we are in possession of, or processing your personal data, the Data Subject has the right to request us to:

• Provide you with additional information about our use of your personal data.
• You have the right to request a copy of the information we hold about you.
• Provide the personal data, at your request, to another data
• You have the right to correct data that we hold about you that is inaccurate or incomplete.
• That we delete personal data whose use is no longer legitimate.
• You have the right to object to certain types of processing, such as direct
• You have the right to object to automated processing, including profiling.
• We will limit how we use your personal data until the complaint submitted is investigated in accordance with clause 3.6.

Their exercise of these rights is subject to certain exceptions aimed at safeguarding the public interest (prevention or detection of crimes and acts of terrorism), requirements of the tax and social security system or professional secrecy.

3.7 Complaints

If you are dissatisfied with our use of your personal data, or with our response after exercising any of these rights, you have the right to lodge a complaint with your supervisory authority:

National Commission for Data Protection – CNPD

Rua de São Bento, No. 148, 3º
1200-821 Lisbon
Ph: 351 213928400
Fax: +351 213976832
e-mail: geral@cnpd.pt

3.8 What kind of identification will I need to present in order to have this access

Think Attitude accepts the following forms of identification when information about your personal details is requested:

• Citizen Card
• Identity Card
• Passport
• Residence Permit

Contact details of the Data Protection Officer:

	DPO
Name:	Nádia Nunes
Address:	Rua Carlos Testa Nº 1, 5º C 1050-046 Lisbon
E-mail:	rgpd@thinkattitude.com.pt
Phone no.:	+351 213 540 781

Approval of and responsibility for the document:
The Data Protection Officer (DPO) is in charge of this document and is responsible for ensuring that it is reviewed in accordance with the GDPR review requirements.

This document has been approved and signed by the Manager and is issued under a verified version signed by the Manager.

Date:04/01/2021

 

History of Changes

Version	Description of Change	Approval	Date
1	Original	Manager	21/11/2019
2	Email Update	Manager	04/01/2021