About this policy
Atlas Professionals B.V. and its related entities* trading as “Atlas Professionals” (Atlas Professionals) are committed to protecting the privacy of individuals' Personal Information. Atlas Professionals is bound by the various applicable Privacy Acts worldwide and the privacy principles set out in them.
‘Personal Information’ is information or an opinion (whether true or not and whether recorded in material form or not) about an identified individual, or an individual who is reasonably identifiable.
Types of Personal Information
Atlas Professionals collects Personal Information about individuals, e.g. candidates for employment and employees, clients and prospective clients, consultants, subcontractors, suppliers and industry participants.
This can include things such as name, address, telephone number, email address, date of birth, age, gender, marital status, banking details, driver’s licence and other occupational licence details, passport number and/or passport copies, tax file number, information about financial status, credit history and insurances, proof of the right to work in certain countries, resumes, qualifications, next of kin, employment history, references and use of Atlas Professionals’ services.
We aim to collect this information only as reasonably necessary to assist candidates to find employment, to provide proposals and services to our clients and candidates, to understand and forecast our business and to respond to requests for information.
We may also collect general information about you from your access to our websites (for statistical purposes). This general information is usually anonymous and we do not use it to identify you. However, due to the nature of internet protocols, such information might contain details that identify you, such as your IP address, internet service provider, the web page directing you and your activity on our website. We use the information we gather on the website for the purposes of providing our services, responding to any queries you may have, operating and improving the website, fostering a positive user experience and delivering the products and services that we offer.
We collect data from our website using various technologies, including ‘cookies’. A ‘cookie’ is a text file that our website sends to your browser which is stored on your computer as an anonymous tag identifying your computer (but not you) to us. You can set your browser to disable cookies. However, some parts of our website may not function properly (or at all) if cookies are disabled.
How we collect and hold Personal Information
We will generally collect Personal Information directly from you, if you choose to provide this Personal Information to us by creating a personal profile. We will generally only collect Sensitive Information about you with your written consent and if authorised by law. By providing us with Personal and Sensitive Information, you consent to our collection and use of it for the purposes set out in this policy.
‘Sensitive Information’ is a sub-set of Personal Information about an individual’s racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, health information, genetic information that is not otherwise health information, biometric information that is to be used for the purpose of automated biometric verification or biometric identification or biometric templates.
Atlas Professionals takes reasonable steps to hold Personal Information using appropriate physical and/or electronic security technology, settings and applications (e.g. passwords and firewalls), and by training staff who deal with Personal Information on our policies and procedures. These measures are designed to protect Personal Information from unauthorised access, modification or disclosure; and from misuse, interference and loss. Notwithstanding this, you should be mindful that the internet is generally not a secure environment.
Purposes for which Personal Information is collected, held, used and disclosed
Atlas Professionals will only use Personal Information for the primary purpose for which we collect it, or a secondary purpose related to the primary purpose for which you would reasonably expect us to use the collected information.
We will not use your information for an unrelated secondary purpose unless we obtain your written consent and an exception applies (e.g. it is authorised by law; or it is impracticable to obtain your consent and we believe it is necessary to lessen a serious threat to the life, health or safety of any individual).
Some examples of the purposes for which we collect, hold and use Personal Information are to conduct business with or provide services (including providing your details to clients and to prospective employers if you are an applicant for employment or job placement) and otherwise administer clients’ accounts, including responding to audit requests by clients, market or otherwise promote our services, disclose health information to health professionals in a medical emergency, record details of incidents for insurance purposes, contact family if requested or needed, improve our services through audits, surveys etc., obtain professional advice and comply with our obligations under applicable laws.
We may disclose Personal Information to third parties, such as professional advisers, courts, tribunals, regulatory authorities, other companies and individuals for the purposes such as complying with our obligations under contract or as required by law, having services performed such as delivering packages, addressing warranty claims, sending correspondence, obtaining searches from public records and processing payments and recovering unpaid debts. We may also disclose your information to our business associates, auditors, and financial services, IT or insurance providers, for them to provide or offer services to you. We will not authorise third parties to use your Personal Information for any other purpose. If we disclose your Personal Information to third parties, and where applicable under the applicable country-specific Privacy Act, we will make sure to enter into a processing agreement with such third parties, in order to protect the Personal Information we share with them.
Atlas Professionals may use Personal Information we collect for direct marketing if you would reasonably expect it to be used for that purpose, or you consent and another exception applies. We provide an easy opt-out procedure for you to request your information not be used for direct marketing.
Disclosure to overseas recipients
Atlas Professionals has operations and entities based worldwide and the countries in which we operate may change from time to time and we may have clients seeking to employ candidates or engage our services all over the world. We may share Personal Information within Atlas Professionals on a worldwide basis, such as another office of Atlas Professionals, an external or cloud service provider, or a prospective supplier or host employer. We will take all reasonable steps to ensure adequate mechanisms are in place to protect your information.
Access to and correction of Personal Information
You are entitled at any time, upon request and subject to any exception under the applicable country-specific Privacy Act and privacy principles to access your Personal Information held by us. We will respond within a reasonable time after the request is made and give access to the information in the manner requested by you, unless it is impracticable to do so. We will not disclose commercially sensitive information to you.
If any of the information we have about you is inaccurate, out-of-date, irrelevant, incomplete or misleading, or you request we correct any information, we will take reasonable steps to ensure the information held by us is accurate, up-to-date, complete, relevant and not misleading. If you request, we will notify the correction to recipients to whom we have disclosed the information, unless it is impractical or unlawful. If we refuse your request, we will explain the reasons for refusal and advise on the mechanisms to complain.
Data Leak procedure
Everyone is entitled to respect for and protection of his privacy and careful handling of his or her personal data. This means that companies and governments must protect the personal data they process against loss and unlawful processing. If a data breach takes place regardless, this must be reported to the relevant Data Protection Authority if the data breach leads to a considerable likelihood of serious adverse effects on the protection of personal data, or if the data breach has serious adverse effects on the protection of personal data. The data breach must also be reported to the data subjects if it is likely to adversely affect their privacy.
This also applies to Atlas Professionals. When deciding whether a notification of a certain incident needs to take place, a number of comparative assessments must be made. This assessment process is laid down in the Protocol Notification Data Leak Atlas Professionals. As soon as you face a data breach or a presumed data breach, this must be reported immediately to the Global Privacy Officer of Atlas Professionals. This can be done by sending an email to Privacyofficer@atlasprofessionals.com.
If you wish to complain about the way Atlas handles your personal data, please contact Atlas Professionals’ Global Privacy Officer:
Global Privacy Officer
2131 HA Hoofddorp
Or send an email to: firstname.lastname@example.org
Atlas Professionals reserves its right to amend this policy from time to time and re-publish it on our website.
Hoofddorp, the Netherlands
15 March 2018
* (and also its 50%-owned Australian joint venture entity Atlas Programmed Marine Holdings Pty Ltd ABN 69 620 316 252 and its subsidiaries)