Career Connections Privacy Policy

Privacy

Policy

This privacy statement is effective as of November 2024. This privacy statement is updated regularly to reflect changes in our data handling practices or applicable laws.

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INTRODUCTIONS

This Privacy Policy provides information on the processing of personal data by Career Connections Limited (“the Company”, “we” “us” “our”). This Privacy Policy also explains the rights that you have in relation to the processing activities. The Company is committed to ensuring that your personal data is processed lawfully and in accordance with the Data Protection Act, 2019 (the “Act”) and its Regulations.

DEFINITIONS

“Consent” means any manifestation of express, unequivocal, free, specific, and informed indication of the data subject’s wishes by a statement or by a clear affirmative action, signifying agreement to the processing of personal data relating to the data subject.

“Data controller” means an organisation that has full authority to decide how and why personal data is to be processed and has the overall responsibility for the data. This includes deciding on use storage and deletion of the data

“Data subject” means an identified or identifiable natural person who is the subject of personal data.

‘‘Data processor’’ means any natural person or organisation or third party that carries out processing of personal data on behalf of the data controller.

“Data Commissioner” means the regulator appointed pursuant to the provisions of the Act and whose main responsibility is to oversee the implementation and enforcement of the Act.

“Direct marketing” refers to communication, by whatever means, of any advertising or marketing material, which is directed to a data subject using personal data provided by the data subject.

“Personal data” means information relating to an identified or identifiable individual/person. An identifiable individual is one who can be identified directly or indirectly in particular reference to an identifier such as a name, identification number, location data, an online identifier (etc.)

“Personal data breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data transmitted, stored or otherwise processed.

“Processing” means any operation or sets of operations which is performed on personal data or on sets of personal data whether or not by automated means, such as:

collection, recording, organisation, structuring;
storage, adaptation or alteration;
retrieval, consultation or use;
disclosure by transmission, dissemination, or otherwise making available; or
alignment or combination, restriction, erasure or destruction.

“Profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's race, sex, pregnancy, marital status, health status, ethnic social origin, colour, age, disability, religion, conscience, belief, culture, dress, language or birth; personal preferences, interests, behaviour, location or movements.

“Sensitive personal data” means data revealing the natural person's race, health status, ethnic social origin, conscience, belief, genetic data, biometric data, property details, marital status, family details including names of the person's children, parents, spouse or spouses, sex or the sexual orientation of the data subject.

PURPOSE OF THIS PRIVACY POLICY

To perform our functions, we need to collect certain personal data and sensitive personal data. This Privacy Policy:

sets out the types of personal data that we collect about you;
explains how and why we collect and use your personal data;
explains how long we keep your personal data;
explains when, why and with who we will share your personal data;
sets out the legal basis we have for using your personal data;
explains the effect of refusing to provide the personal data required;
explains the different rights and choices you have when it comes to your personal data; and
explains how we may contact you and how you can contact us.

APPLICATION OF THIS PRIVACY POLICY

This Privacy Policy applies to the processing of personal data by the Company’s visitors and users of the Company’s various sites, candidates, participants, employees, attendees of the Company’s events, clients and prospective clients and their representatives, subscribers to the Company’s publications or newsletters or mailing list, visitors to the Company’s facilities and suppliers and business partners and their representatives (referred to as “you” or “your” in this Privacy Policy).

THE PERSONAL DATA COLLECTED

The Company collects personal data directly from you as well as from other available sources to the extent permitted by law.

The Company endeavours to collect only that Personal Data that is necessary for the purpose(s) for which it is collected and to retain such data for no longer than necessary for such purpose(s). Subject to applicable law and practice, the categories of personal data that are typically collected and processed include, but are not limited to:

Candidates: We collect your name, contact information (email addresses and telephone numbers), curriculum vitae information and personality and psychrometric tests assessment information (where applicable).

Participants: We collect your name, contact information (email addresses and telephone numbers) and personality and psychrometric tests assessment information (where applicable).

Clients: We collect your name, contact details or the details of individual contacts at your organisation, your designation, country of residence and KRA PIN.

Employees: We collect your name, contact information (email addresses and telephone numbers), ID/Passport number, KRA PIN details, NHIF details, NSSF details, HELB details, bank account details, next of kin details, photo, social media details, education certificates, credit information, pension and medical onboarding information and residential information.

Associates, Suppliers and Partners: We collect your name, contact details or the details of individual contacts at your organisation, your bank details and KRA PIN.

Alumni: We collect your name and contact details (email addresses and telephone numbers) and Kenya Revenue Authority Personal Identification Number (KRA PIN).

HOW THE PERSONAL DATA IS COLLECTED

We may collect personal data directly from you. For example, we collect data from you when:

you correspond with us by phone or by email;
you visit our offices; and
you visit our website.

We may also collect personal data indirectly from you. For example, we collect data from you when:

where the data is contained in a public record;
where you have deliberately made the data public;
where you have given, us consent to collect the data from another source;
from third parties who collect information about you on behalf of the Company;
where you have an incapacity, and your appointed guardian has consented to the collection from another source;
where the collection from another source is necessary;
for the prevention, detection, investigation, prosecution, and punishment of crime;
for the enforcement of a law which imposes a pecuniary penalty; or
for the protection of the interests of a data subject or another person.

USES OF YOUR PERSONAL DATA

Candidate data: We process personal data to, among others:

assess your suitability for the roles that seek to be filled by the clients;
undertake the recruitment process;
undertake personality and psychometric tests and thereafter generate reports for the clients;
undertake background checks and generate reports for the clients;
effectively communicate and coordinate during the recruitment process; and

Participant data: We process personal data to, among others:

offer the requested services, for example, talent development, coaching, training etc.;
undertake personality and psychometric tests and generate reports for the participants and/or clients;
effectively communicate and coordinate during the talent development process; and

Client data: We process personal data to, among others:

undertake the Know-Your-Customer process;
enter into service contracts;
effectively communicate and coordinate when offering services;
share information through our marketing campaigns;
share information about our events;
make tax payments and returns; and

Employee data: We process personal data to, among others:

assess your suitability for the role we seek to fill internally;
enter into an employment contract with you;
populate your employee file;
undertake the payroll process;
collect emergency contact details;
undertake background and reference checks;
onboard you on our pension and medical schemes;
celebrate your birthday; and
complete the employee details form.

Associates, Supplier and Partner data: We process personal data to, among others:

enter into supplier and partner contracts;
make the necessary payments;
effectively communicate and coordinate during the contract period;
share information about our marketing campaigns;
share information about our events;
make tax payments and returns; and

Alumni data: We process personal data to, among others:

effectively communicate and coordinate;
share information about our events; and

We also process personal data to:

communicate and respond to your requests and inquiries to the Company;
to engage in transactions with business partners;
to analyse, develop, improve and optimize the use, function and performance of our sites and products and services;
to manage the security and operation of our sites, facilities and networks and systems;
to operate our business;
to analyse the trends in our sector of operation;
for research purposes;
for marketing purposes in collaboration with our marketing agents;
help us establish or defend legal claims; and
to comply with applicable laws and regulations.

OUR LAWFUL BASIS FOR PROCESSING YOUR PERSONAL DATA

The Company processes your personal data for the following lawful bases:

where you consent to the processing for one or more specified purposes; or
where the processing is necessary;
for the performance of a contract to which you are a party or to take certain steps at your request before entering a contract;
for compliance with any legal obligation to which we are subject;
to protect your vital interests or that of another person/individual;
to enable us to perform a task carried on in public interest or in the exercise of official authority vested in us; and
for our legitimate interest.

SHARING OF YOUR PERSONAL DATA

Any disclosure of your personal data shall be in accordance with applicable law and regulations. We may disclose your personal data to:

potential employers, where you are a candidate.
individuals and organisations who hold information related to your reference such as current, past or prospective employers, referees, educators and examining bodies.
tax or other authorities when we believe in good faith that the law or other regulation requires us to share this data.
service providers who perform functions on our behalf (including external consultants, business associates and professional advisers such as lawyers, auditors and accountants, partners for assessment tools and training solutions, administration functions, technical and support functions and IT consultants carrying testing and development work on our systems).
third party outsourced IT and document storage providers.
debt-collection agencies or other debt-recovery organisations.
relevant third parties in the event of a reorganisation, merger, sale, joint venture, assignment, transfer or disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
emergency service providers where such disclosure to emergency service providers is necessary for your rescue, health and safety, including your approximate location.

SAFEGUARDING YOUR PERSONAL DATA

We care about protecting your personal data. That is why we have put in place appropriate measures that are designed to prevent personal data breaches. We do this by having in place a range of appropriate technical and organisational measures including measures to deal with any suspected personal data breaches.

If you suspect any misuse or loss of or unauthorized access to your personal data, please let us know immediately by contacting us.

STORAGE OF YOUR PERSONAL DATA

We will only keep your personal data for as long as it is necessary to achieve the purposes for which it was required unless the retention is required or authorized by law, reasonably necessary for a lawful purpose, you have consented to longer retention periods or if the personal data is required for auditing or compliance purposes.

THE RIGHTS YOU HAVE OVER YOUR PERSONAL DATA

The Act accords you several rights over your data.

right to information: you have a right to be informed of how the Company will use your personal data.
right of access: you are entitled to access your personal data that is in our possession or custody.
right to object: you can object to the processing of all parts of your personal data, unless we can demonstrate: a compelling legitimate interest for the processing which overrides your interests: orthat we are processing your personal data for the establishment, exercise or defense of a legal claim.
right to rectification: you have the right to request us to rectify or correct, personal data in our possession or under our control that is inaccurate, outdated, incomplete or misleading.
right to erasure: you can request us to delete or destroy personal data that we are no longer authorized to retain, or which is irrelevant, excessive, or obtained unlawfully.
right to data portability: you have the right to receive personal data concerning you in a structured, commonly used and machine-readable format and to transmit the data to another data controller without hinderance. Where technically possible, have personal data transmitted directly from us to another data controller or data processor.automated decision making you have the right not to be subjected to a decision based solely on automated processing, including profiling, which produces legal effects concerning or that significantly affects you. Career Connections may from time to time make decisions based on automated processing of your personal data. In such instance, you will be informed, in writing, whenever a decision based on automated processing is taken. In addition, you can request us to reconsider any decisions made based on automated processing or to take a new decision that is not based solely on automated processing.
right of restriction: You have the right to request us to restrict the processing of personal data where: you contest the accuracy of the personal data.the personal data is no longer required for the purpose of the processing.the processing is unlawful, or you are opposed to the erasure of the personal data and requested for restriction of its use instead.you have objected to the processing of personal data, pending verification as to whether the legitimate interests of the data controller or data processor overrides those of the data subject.
right to raise a complaint: You can raise a complaint about the processing of your personal data.

If you wish to exercise any of our rights above, please contact us using our contact address. We will endeavour to deal with your request without undue delay. We may ask for identification to ascertain whether we are issuing the data to the right person.

COMPLAINTS MANAGEMENT

If you have any complaint regarding our compliance with this Privacy Policy, please contact us. We will investigate and attempt to resolve complaints and disputes regarding use of personal data in accordance with our policies and the applicable law. You also have the right to file a complaint with the Office of the Data Protection Commissioner.

INTERNATIONAL TRANSFER OF YOUR PERSONAL DATA

To provide you with the best services and carry out the purposes outlined in this Privacy Policy, we may need to transfer your personal data;

to our oversees partners or service providers;
to oversees clients; or
to cloud-based storage providers.

We will only transfer your data outside Kenya where such transfer is compliant with the provisions of the Act.

To ensure that your personal data receives adequate levels of protection, we shall put in place appropriate procedures with the third parties we share your personal data with to ensure that your personal data is treated by those third parties in a way that is consistent with, and which respects the data protection laws.

COOKIES

A "cookie" is a bite-sized piece of data that is stored on your computer's hard drive. They are used by nearly all websites and do not harm your system. We use them to track your activity to help ensure you get the smoothest possible experience when visiting our website. We can use the information from cookies to ensure we present you with options tailored to your preferences on your next visit. We can also use cookies to analyse traffic and for advertising purposes.

Our website only uses first-party cookies. We use the cookies to:

assign a randomly generated number as a client identifier so that no name is attached to the analytics;
calculate visitor, session and campaign data for the site’s analytics reports;
count and track pageviews; and
collect the behavioural data of all website visitors. This includes pages viewed, visitor source and time spent on the site.

Our website does not collect any personal data.

DIRECT MARKETING

You can opt out of our mailing list at any time by contacting us and asking us to stop sending you our marketing emails. Our opt-out process will be simple and free of charge.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service already signed up for.

THIRD PARTY SITES

Our websites may provide links to other locations or websites on the Internet. These links lead to websites published or operated by third parties who are not affiliated with or in any way related to us and have been included in our website for your convenience.

By clicking on a hyperlink, you will leave the Company’s webpage and accordingly you shall be subject to the privacy policies of the other website that you choose to visit and not this Privacy Policy.

YOUR RESPONSIBILITIES

You are responsible for the personal data you make available to the Company, and you must ensure it is accurate, honest, truthful, and not misleading in any way. You remain liable for any claims, damages or loss that may occur due to your provision to the Company of inaccurate information. You will be required to indemnify the Company for any third- party claims that may arise thereto.

You must also ensure that the personal data you provide the Company does not contain material that is obscene, defamatory, or infringing on any rights of any third party.

Further, if you provide any personal data concerning any other person, such as individuals you provide as references (“referee”), you are responsible for providing any notices and obtaining any consents necessary for the Company to collect and use that personal data before you provide the referee’s personal data to the Company.

Should you choose to withhold your personal data, for any reason whatsoever, the Company will be unable to provide you with the services requiring the personal data withheld.

UPDATES TO THIS PRIVACY POLICY

The Company reserves the right to amend or modify this Privacy Policy at any time. If we amend this Policy, you can access the most current version of the policy on our website. Any amendment or modification to this statement will take effect from the date of notification on our website. Your use of our website following an update means that you accept the revised Privacy Policy.

OUR CONTACT DETAILS

We welcome your questions, inquiries, comments, and concerns about privacy. If you have any questions about this Privacy Policy or our personal data processing practices, you can contact the Company using this email address dataprivacy@careerconnectionsltd.com.

The Company’s offices are located at: KAM Building, Mwanzi Road, Westlands, P.O Box 25118-00603 Nairobi.

Your privacy is important to us!

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