Jilda Bal İnsan Kaynakları Yönetim Danışmanlığı (“GILDA&PARTNERS” or the “Company”) attaches great importance to the protection of your personal data. In this context, we aim to inform you about the personal data processed by our Company through this Clarification Text, in accordance with Article 10 of the Personal Data Protection Law No. 6698 (“KVKK”) titled “Obligation of the Data Controller to Inform,” the Communiqué on the Procedures and Principles to Be Followed in Fulfilling the Obligation to Inform, and the principles set forth in the Jilda Bal İnsan Kaynakları Yönetim Danışmanlığı Personal Data Retention and Disposal Policy, ensuring the protection of individuals’ fundamental rights and freedoms, primarily the right to privacy.
1. IDENTITY OF THE DATA CONTROLLER
GILDA&PARTNERS holds the title of “Data Controller” concerning the personal data obtained from you, our esteemed candidates, in accordance with KVKK and related regulations. You can reach us through the contact information provided in Article 7 of the Candidate Clarification Notification.
2. PERSONAL DATA PROCESSED
Within the scope of your relationship with GILDA&PARTNERS, the following Personal Data is processed:
(i) Identity Information: Name, surname, Turkish ID number, place of birth, date of birth, photograph, marital status, signature, ID document number, gender
(ii) Contact Information: Address, email, phone, and mobile phone details
(iii) Family Information: Number of children, information regarding spouse and children (identity, age)
(iv) Professional Experience Information: CV/Work-Education background, interview and recruitment evaluations, language proficiencies, education date/place and information, in-service training information/certificates, and professional position
(v) Payment and Financial Information: Bank account number, IBAN number, bank details, invoice/debt information in cases where a company phone is allocated
(vi) Other Information: Military service status, citizenship and work permit status, information provided by references
(vii) Sensitive Personal Data: Health reports obtained during candidate interviews, criminal records, and information regarding disability status
(All the aforementioned data will be collectively referred to as “Personal Data” throughout this text.)
3. PURPOSES OF PROCESSING PERSONAL DATA
Your Personal Data obtained within the scope of your business relationship with GILDA&PARTNERS is processed for the following purposes:
➢ Obtaining health test results during your recruitment process,
➢Conducting GILDA&PARTNERS’ daily operations,
➢ Providing consultancy services in line with customer requests and evaluating candidate applications to be presented to customers,
➢ Sharing candidate CVs suitable for customer demands and operations with relevant customers,
➢ Ensuring the continuity of business activities,
➢ Conducting selection and placement processes,
➢ Ensuring data security and carrying out data storage activities,
➢ Fulfilling GILDA&PARTNERS’ obligations arising from legislation or other legal responsibilities, including providing information to public institutions and organizations,
➢ Following up on lawsuits, enforcement proceedings, administrative and criminal investigations, or prosecution processes related to GILDA&PARTNERS, and fulfilling the burden of proof as evidence in legal disputes.
4. TRANSFER OF PROCESSED PERSONAL DATA
Your Personal Data may be transferred by our Company, in compliance with the provisions of the Law regarding the transfer of personal data and under the conditions specified in Articles 8 and 9 of the Law, to domestic official institutions and organizations, as well as to individuals and legal entities with whom GILDA&PARTNERS has commercial relationships, for the purposes listed below:
➢ Sharing candidate CVs suitable for customer demands and operations with relevant customers,
➢ Ensuring data security and carrying out data storage activities.
In the event of any dispute concerning your relationship with our Company or in response to a request from official authorities, judicial bodies, or law enforcement agencies, your Personal Data may be shared to the extent relevant and limited to such dispute/request, with lawyers and consultants providing legal support to the Company, in compliance with the provisions of the Law No. 6100 on Civil Procedure and other relevant laws and secondary legislation.
5. METHODS OF COLLECTION AND LEGAL GROUNDS FOR PROCESSING PERSONAL DATA
Your Personal Data is processed during the job application period and throughout your employment with GILDA&PARTNERS based on the information you provide verbally or in writing through various channels (e.g., in-person delivery, mail, email, or electronic platforms). It is also processed by GILDA&PARTNERS through automated methods (via electronic systems and software used by the Company) and/or non-automated methods (via physical files and record-keeping) in accordance with Article 5 of the Law and based on the following legal grounds:
➢ Your explicit consent,
➢ As explicitly stipulated in the legislation to which the Company is subject, including but not limited to the Labor Law, Occupational Health and Safety Law, Social Insurance and General Health Insurance Law, Code of Obligations, Tax Procedure Law, Turkish Commercial Code, Identity Notification Law, Income Tax Law, Corporate Tax Law, Check Law, and the Private Pension Savings and Investment System Law,
➢ Where processing of Personal Data belonging to the parties of a contract is necessary for the establishment or performance of that contract, provided it is directly related to the contract,
➢ Where processing is mandatory for compliance with a legal obligation,
➢ Where processing is mandatory for the establishment, exercise, or protection of a right,
➢ Where processing is mandatory for the legitimate interests of the data controller, provided it does not harm the fundamental rights and freedoms of the data subject.
Your sensitive personal data is collected, stored, and processed based solely on your explicit consent.
6. RIGHTS OF THE DATA SUBJECT WHOSE PERSONAL DATA IS PROCESSED
Pursuant to Article 11 of the Law, you have the following rights regarding your Personal Data:
➢ To learn whether your Personal Data is being processed,
➢ To request information if your Personal Data has been processed,
➢ To learn the purpose of processing your Personal Data and whether it is used in accordance with its intended purpose,
➢ To know the third parties to whom your Personal Data has been transferred, either domestically or abroad,
➢ To request the correction of your Personal Data if it has been processed incompletely or inaccurately,
➢ To request the deletion or destruction of your Personal Data,
➢ To request that third parties to whom your Personal Data has been transferred be informed of any correction, deletion, or destruction of your Personal Data,
➢ To object to any unfavorable outcome arising from the analysis of your Personal Data exclusively by automated systems,
➢ To request compensation for damages incurred as a result of the unlawful processing of your Personal Data.
7. CONTACTING US TO EXERCISE YOUR RIGHTS
In accordance with your legal rights stipulated under the relevant laws and regulations, you may submit your requests, along with documents verifying your identity, through the following methods:
(i) By submitting a petition addressed to Jilda Bal to the address Esentepe mah. Büyükdere Cad. No:199/6 Levent 199 Binası 34394 Levent / İstanbul in person with a wet-ink signature, via a notary public, or by registered mail with return receipt;
(ii) By sending an email signed with a secure electronic signature or mobile signature to the registered electronic mail (KEP) address info@gildaandpartners.com, addressed to Jilda Bal; or
(iii) By other methods specified by the Board in the future.
Applications will be accepted following identity verification and will be processed as soon as possible and within a maximum of 30 days, depending on the nature of the request. If a written response is provided to the application, no fee will be charged for up to 10 pages; for responses exceeding 10 pages, a processing fee of 1 Turkish Lira per page will be charged. If the response is provided on a recording medium such as a CD or flash drive, the cost of the medium will be charged.
We respectfully bring this matter to your attention.
JİLDA BAL İNSAN KAYNAKLARI YÖNETİM DANIŞMANLIĞI