CBRE RECRUITMENT PRIVACY NOTICE – POLAND Who are we? CBRE is the world's leading commercial real estate services firm with offices located around the globe. We have over 90,000 employees worldwide. The scope of services provided by CBRE includes: strategic consulting in the field of investment and leasing, corporate services, property and project management services, company administration, mortgage banking, valuations, development services, investment management services, consulting and analytical services. The administrator, which is the entity deciding how your personal data will be used, is CBRE spółka z o.o. (Hereinafter "CBRE") with its registered office in Warsaw, Rondo ONZ 1, 00-124 Warszawa.
At CBRE we take your personal data very seriously. This 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 for
• 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 requested
• explains the different rights and choices you have when it comes to your personal data
• explains how we may contact you and how you can contact us.
We keep our privacy notice under regular review. If we change this privacy notice, we will publish the updated version here. This privacy policy was last updated in June 2018.
What personal data do we collect about you? We collect the information necessary to be able to find available opportunities and further information needed to assess your eligibility through the various stages of the recruitment process. This includes personal information such as name, title, addresses, telephone numbers and personal email addresses, date of birth, recruitment information (including copies of work permission documentation, references and other information included in a CV or cover letter or as part of the recruitment process), details contained in letters of application and resume/CV (including previous employment or work background; education history; professional qualifications; professional memberships; interests; language and other relevant skills; certificates and certification expiration dates) project assignments and time spent on assignments; skills and experience; development programmes planned and attended; willingness to relocate, current salary information, educational records, work history references, results of any tests, including psychometric tests we carry out during the recruitment process), feedback from interviewers and assessors and notes taken during interview. CBRE does not routinely require a photograph during the application process; should you choose to include a photograph on your CV, CBRE will process this on the same basis as your CV.
All personal data will be stored in our recruitment system HR Link.
Where do we collect personal data about you from? The following are the various sources from where we may collect personal data about you:
• Directly from you. This is information you provide while searching for a new opportunity and/or during the different recruitment stages.
• From an agent/third party acting on your behalf. e.g. headhunter.
• Through publicly available sources. We use the following public sources including LinkedIn, pracuj.pl, Indeed and other Job Board websites and online CV libraries.
• By reference or word of mouth. For example, you may be recommended by a friend, a former employer, a former colleague or even a present employer.
How and why we use your personal data? We use your personal data to match your skills, experience and education with a potential position within CBRE.
How long do we keep your personal data for? We keep your personal data for the following period:
• Candidate data: Two (2) years
• Interview notes: Six (6) months
Your personal data is shared with the hiring manager who initiates a search for personnel, to ascertain if you are a good fit for the available position.
What is the purpose and legal basis for processing your personal data by CBRE? CBRE collects your personal data when you apply for a job at CBRE, which is collected mainly via CVs and / or forms sent to CBRE by e-mail. We also collect additional personal data as part of the on-boarding process after presenting you job offer.
We collect and process your personal data based on:
a) a legal obligation resulting, inter alia, from art. 221 and art. 183a § 1 of the Labor Code
b) the necessity to take action on your request before the conclusion of the employment contract (Article 6 (1) (b) of the GDPR), in particular as regards negotiating working conditions
c) a legitimate interest (Article 6 (1) (f) of the RODO) and
d) consent (Article 6 (1) (a) and (GDP)), for example, when personal data that go beyond the scope of data, which the obligation to provide results from the provisions of applicable law, will be processed as part of the recruitment processes.
CBRE may process your personal data for the following purposes: a) conducting the recruitment process, including negotiating working conditions
b) combating discrimination in the employment process
c) organization of travel and accommodation of the candidate during the recruitment process
d) handling complaints, requests and applications in connection with the ongoing recruitment process
e) providing physical security in CBRE, in particular in the field of video monitoring
f) running a recruitment recommendation program
g) in case it finds application, for internal reporting within CBRE, including management reporting
h) performance of obligations resulting from legal provisions, including tax and accounting regulations
(i) in the event of its application, for purposes related to the conduct of court, arbitration or mediation proceedings
j) Statistical
k) archive
l) ensure accountability.
To obtain additional information about what personal data about you may be collected, used, transmitted and otherwise processed by CBRE and the purposes for which it can be collected, used, transferred and otherwise processed, please visit
[CBRE privacy policy website] Do you have the obligation to provide your personal data to CBRE? The obligation to provide personal data by you results from art. 221 of the Labor Code, as well as other legal provisions. In terms of: name and surname, contact details, education, employment history, providing data is necessary to enable CBRE to recruit and conclude a contract with you. If you do not provide us with this information, recruitment may be difficult or impossible. In the remaining scope, providing data is voluntary.
Who can you contact for more information on the processing of your personal data by CBRE? If you have any questions related to the processing of your personal data by CBRE in the recruitment process, you can contact CBRE using the contact details provided: hrwarsaw@cbre.com.
Does CBRE profile your personal data or process it automatically in a way that affects your rights? Please be advised that your personal data will not be used by CBRE for automated decision-making, and based on personal data received from you, no profiling will be made, understood as the automated processing of your data, which relies on their use for assessment certain factors regarding, in particular, the analysis or prognosis of aspects related to the effects of your work, your economic situation, health, personal preferences, interests, credibility, behavior, location or movement.
Do we use Cookies to collect personal data on you? To provide better service to you on our websites, we use cookies to collect your personal data when you browse. Please click here to view our cookie policy for more details.
TO WHAT COUNTRIES IN THE EUROPEAN ECONOMIC AREAS, CBRE PROVIDES YOUR PERSONAL DATA? Please be advised that your data may be transferred by CBRE to countries outside the European Economic Area, ie to the United States. This transfer will be based on Commission Implementing Decision (EU) 2016/1250 of 12 July 2016, adopted by Directive 95/46 / EC of the European Parliament and of the Council, on the adequacy of protection provided by the EU-US Privacy Shield or on the basis of a contract data with standard contractual clauses included with the recipient, accepted by the European Commission or by the competent supervisory authority and then approved by the European Commission. In both cases, the procedure followed guarantees the highest standards of protection of personal data being transferred.
WHAT RIGHTS DO YOU HAVE IN RELATION TO THE DATA WE HOLD ON YOU? As regards the processing of your personal data by CBRE, you may request CBRE to:
• access to your personal data, including the transfer by CBRE of a copy of your personal data in possession of CBRE
• rectification of your personal data if personal data are incomplete or incorrect
• deletion of personal data, including where the data is no longer necessary for the purposes for which it was collected by CBRE; you report previously to the processing of this data; data is processed unlawfully; data should be deleted in order to fulfill the obligation arising from the law;
• opposition to the processing of personal data in the event that CBRE bases its processing on the necessary processing in the legitimate interest of CBRE (or third parties) and / or for statistical purposes and this is related to your particular situation;
• limiting the processing of your personal data, for example, if you question the correctness of the processing, the compliance of the processing with the law, or if your personal data is no longer needed by CBRE or you object to it.
• data transfer, if the data is processed on the basis of an agreement concluded with you and this processing takes place in an automated manner.
In order to exercise your rights, contact us - in written or otherwise, for example electronic - with our HR department at hrwarsaw@cbre.com or CBRE Sp. z o. o. - Rondo ONZ 1, 00-124 Warsaw.
You have the right to lodge a complaint regarding the processing of your personal data by CBRE to the President of the Office for Personal Data Protection (address: Office of the President of the Office for Personal Data Protection, 2 Stawki Street, 00-193 Warsaw).
The right to withdraw consent If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful).
We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:
• baseless or excessive/repeated requests, or
• further copies of the same information. Alternatively, we may be entitled to refuse to act on the request. Please consider your request responsibly before submitting it. We'll respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we'll come back to you and let you know.
WITH WHOM CBRE SHARES YOUR PERSONAL DATA? Please remember that your personal data may be shared with affiliated entities of CBRE (including entities from the USA) for purposes related to current and future recruitment. We also provide your personal data to Online Technologies HR Sp. z o.o. being a processing entity acting on behalf of CBRE
HOW LONG DOES CBRE STORE YOUR PERSONAL DATA? CBRE shall store personal data on the basis of statutory retention periods, commonly recommended retention periods, and for the period necessary to achieve the purposes set out in this information clause, unless a longer retention period is required or permitted by law.
Your personal data will be processed for the period necessary to carry out the recruitment process, for a period of time until its completion, and after that for a period of time and to the extent required by law or for CBRE to implement a legitimate interest of the administrator. In the case of your consent to the processing of data, in particular for the purposes of future recruitment processes or related to data processing to an extent beyond the categories of data whose obligation to provide follows from the provisions of applicable law, your personal data will be processed until withdrawal this consent.
CBRE stores data for statistical and archival purposes for the period required by law or for CBRE to implement a legitimate interest of the administrator. In case of withdrawal of consent, it will anonymize the data.
How will we contact you? We may contact you by phone, email or social media. If you prefer us to contact you in a particular way, please let us know via email on hrwarsaw@cbre.com.
How can you contact us? If you have any further questions, comments or requests regarding the privacy notice or the processing of your personal data, please contact
If you wish to access your data subject rights please send an email to hrwarsaw@cbre.com.
