privacy statement candidates luxemburg

Privacy statement for RiseSmart participants: career transition, career services, potential evaluation

At RiseSmart we attach great importance to protecting the personal privacy of all people whose data we compile. We treat and protect this data with the utmost care, in accordance with the applicable laws in Luxemburg*.

We do everything to protect the data supplied to us against loss, destruction, publication, unauthorised access or improper use.
In this privacy statement we explain who we are and why we require your personal data, which data we compile, how and for how long we process it, who we can pass it on to, what your rights are and how you can exert them.
This privacy statement is intended for you if:

  1. you are following an outplacement, inplacement, orientation counselling, partner relocation programme at RiseSmart (Career Transition), in agreement with your (previous) employer or at your own initiative; 
  2. you are following coaching training at RiseSmart (Career services) at your own initiative or in agreement with your employer; 
  3. you are taking part in an assessment/development centre or testing (Potential Evaluation) at RiseSmart, in agreement with your current or potential employer. 

Who we are 
RiseSmart, a division of Randstad HR Services sa, situated in L-2361 Strassen, 5 rue des Primeurs, is responsible for the processing of your personal details (Controller in the sense of the GDPR). 


When do we compile your personal details? 

We compile your details as soon as you transmit these via our website or on one of our IT applications/tools we make available to you as part of our outplacement programme (Hubble, Spotlight), if you register at our RiseSmart office or in a different way to make use of one of our services.
We also compile your data as soon as your previous, current or potential employer registers you with us in execution of a RiseSmart service offered to and accepted by you (Career Transition, Career Services, Potential Evaluation).
To summarise, we compile your data in the run-up to and the preparation of the execution of one of the services of RiseSmart you have committed to directly or indirectly.


Why do we need your personal details? 

We compile your personal details for the objectives mentioned below and will not use this data for other purposes without informing you in advance and, if necessary, asking your permission.
We use your personal details for concluding and realising the service agreement in question which we entered into with you, with your previous, current or potential employer.
More specifically, we use your personal details to, depending on the agreed service and, when applicable,

1. enter into a service agreement with you and/or with your previous, current or potential employer, carry this out professionally and do the relevant administration;

2. provide the service agreed with you and/or with your previous, current or potential employer, including, but not limited to, determining the exact content and scope of the service;

3. be able to make you offers and/or provide information about the agreed service and other activities and be able to align them better to your wishes and competencies. This is done by our consultants and can be partly automated. This can include services such as psychological guidance, application training, job leads, training courses or workshops, help with writing your CV and/or other agreed forms of support;

4. evaluate and/or strengthen your competencies and improve them in the long term, discover your development potential and guide you, determine your profile and assess your suitability and availability as part of job placement towards getting temporary or permanent work, or to finding any other type of work. Here we can make use of, among others, results of tests we let you take (personality tests, language tests, assessments, etc.) and of (online) reference checks we only carry out with your explicit consent at the people and/or companies you listed. We may also ask you to provide more information about yourself on a voluntary basis to be able to get the maximum result from our services;

5. promote your personal development and usability by offering, among others, (short) courses, guidance, workshops, etc., at RiseSmart or one of the companies of Randstad or a third party (e.g.ADEM);

6. in execution of the service, provide the statutory or agreed reports, results and information to you, your previous, current or potential employer;

7. invoice the RiseSmart service

8. meet certain quality objectives, such as obtaining and keeping certain certificates or quality labels

9. monitor and measure the quality of our services. To this end we ourselves, or a third party we have commissioned to do so, may ask you to take part in surveys and use the obtained information and process it to improve the quality of our services.

10. meet management objectives, including providing management information, carrying out internal checks to prevent fraud and to carry out (internal/external) audits and accounting audits.

11. be able to provide statistical information for studies of interest to RiseSmart. In this case, we use aggregated personal data, whereby you are not individually identifiable in the results that are made public by RiseSmart or shared with third parties.

12. guarantee company safety. To this end we may, for instance, check your identity when accessing one of our offices. We can also check the activities in our systems to prevent misuse of the information of our databases and to protect our interests and those of all people included in our databases.

13. comply with legal obligations and to be able to demonstrate them;

14. allow you to exert your rights (also see point H) and to indicate later on why we acted upon these rights.

We use and process your personal details, depending on the type of processing, on the basis of:

1. our (pre)contractual relation with you and/or with your (previous) employer :
if we conclude a service agreement directly with you, we require several details to be able to prepare, draw up and then properly carry out this agreement (for partner relocation services as example) .
This is also the case if you aren’t a direct party in a service agreement of RiseSmart, but you are the “third-party beneficiary” of this service, and you agreed with the service offered at your previous, current or potential employer (e.g. outplacement, coaching, assessment and development center,).
If you don’t want your personal details to be processed in this framework, we cannot enter into service with you or implement it (further).

2. the statutory obligations related to the execution of the service:
our service is subject to numerous statutory obligations. We have to have all information required to meet these duties or to be able to indicate in case of an inspection that we met our duties on time and for the full duration of these duties.

3. the legitimate interest of RiseSmart or of a third party:
if necessary, we use your data to meet legitimate interests of RiseSmart or of third parties. This can, for instance, happen for access control or internal control and audits to guarantee the safety and continuity of our systems and companies. This legitimate interest also applies if we have to file your data as part of initiating, exerting or substantiating possible legal actions.

Which of your personal details do we process?
We process the personal details that are required for our service. Some of these details (e.g. identity, and contact details) are obligatory to be able to make use of our services. Additional data may be necessary or desirable in order to better align our service to your wishes and qualities or to meet more specific requests of RiseSmart customers (your previous, current or potential employer or the employment unit of your previous employer). If you choose to send us your data, we may use and share this data with third parties (also see point E) in the framework of carrying out the service you requested or accepted.
You are responsible for the accuracy and relevance of the data you supply us with. It is advisable to pass on any changes in your personal details to us as soon as possible, either online via your profile in Spotlight (outplacement), or to your consultant in your RiseSmart office.
Customers can involve RiseSmart via a service agreement (outplacement, coaching, assessments & development center, …) As part of this service agreement, the customer provides RiseSmart with a list of people who are eligible for the service in question.
If you are eligible for this, your name, recent job, private address, phone number, e-mail address, department or business unit and other relevant personal details may be included on this list.
If you register with RiseSmart as a participant, or if you are registered by third parties (e.g. your employer), you or this third party must share all relevant (documents with) personal details with us.
Depending on the service you requested or accepted, this can concern, among others, the following personal details:
• name, address, e-mail address, phone number and other contact details;

• date of birth, age and gender;

• passport photo and video (introduction) – on a voluntary basis;

• curriculum vitae (CV), detailed information about current and previous jobs, current and previous employers, information about diplomas, language skills, job placement, work experience, etc.;

• data, including results, about training courses and/or tests/assessments you have taken yourself or via RiseSmart;

• your objectives/action plan in the area of coaching, competency and/or career development;

• your current or previous wage and expectations of future wage, work to be carried out, sector, employer, working hours, etc.;

• your professional social media profile and other relevant profiles of your network;

• other data that is or may be of interest as part of the assessment of your suitability, such as references and certificates;

• evaluations of your knowledge, skills, attitude, etc.;

• information about the status, progress and milestones in your search for a job;

• results of potential evaluation or Career Services;

• report of your consultant, coach, etc. as a result of interviews, talks, coaching sessions, etc.;

• information about customer satisfaction or other feedback about our service.

We do not register any sensitive personal data, except for when this is necessary to meet certain legal obligations and insofar as permission has been given for this, or if this is otherwise allowed under or pursuant to the law. ‘sensitive personal data’ in this context means race, religion, political persuasion, health, sexual life, trade union membership, criminal convictions and/or personal details about unlawful or disruptive behaviour.

The personal details we compile about you are stored securily. If we use RiseSmart Technology (Spotlight - outplacement), all your personal details and other information of or about you will be compiled in a separate database and your data may be filed on servers hosted in the United States or in other countries. The RiseSmart consultants and coaches and those responsible for RiseSmart Technology have access to your online profile on Spotlight. They can determine needs and action points here, and can, if you are looking for work, post job vacancies on your profile from any office or work location.

Who do we share your personal details with?
Only if necessary for the execution of the RiseSmart service you have chosen or accepted, the realisation of objectives mentioned under point C, observing the statutory requirement (of RiseSmart or of a third party) or the protection of a justified interest (of RiseSmart or of a third party) can RiseSmart transfer some of your personal details:

1. to other partnerships of the Randstad group in Belgium and Luxemburg RiseSmart belongs to, for among others:
o range of supporting activities as part guidance towards finding work/professional development (workshops, job offer, etc.);
o intragroup service (administrative tasks such as invoicing, IT services, etc.);
o inspection and complaints management (legal services)

2. to the holding company of Randstad (of wich RiseSmart is part), or other partnerships in the Randstad group for among others:
o management information;
o internal audits;
o internal services;

3. to customers (your previous, current or potential employer), for among others:
o all compulsory or necessary reports as part of the agreed service and only if this is compulsory or has to be nominative;
o results of assessments and coaching that are also discussed with you;
o invoicing the service;
o audits or inspections at customers;

4. to suppliers of RiseSmart, for among others:
o providing services or carrying out tasks and orders on behalf and at the expense of RiseSmart (e.g. IT providers, cloud providers, research bureaus, entrance security access, submitting subsidy dossiers, etc.);
o providing services to RiseSmart as part of the services (e.g. accident insurance for outplacement);

5. to our auditors, audit and certification agencies, for among others:
o audit of our annual accounts;
o obtaining and preserving certain certificates;
o audit of subsidy dossiers (e.g. European Social Fund);

6. to various public bodies, such as, among others:
o national inspection services;
o pubic employment administration services (ADEM);

7. to all other third parties we are obliged to by law, court order or decree.

RiseSmart will not sell, lease or make your personal details available for commercial purposes to third parties, unless you have given prior consent.
As RiseSmart develops its business, RiseSmart might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, your personal details and other information may be part of the transferred assets.
If our suppliers process your personal details for RiseSmart, they act as processors as laid down in the GDPR. We conclude a processing agreement with these processors and do everything in our power to ensure that they sufficiently protect your personal details.

Your personal details can in certain cases be passed on outside Luxemburg and the European Union. RiseSmart takes the necessary contractual and technical security measures to ensure that all personal details passed on are adequately protected against loss or unlawful processing.

For instance, RiseSmart can use RiseSmart Technology to support the service and to register your personal details. RiseSmart Technology is provided by RiseSmart Inc., our RiseSmart entity in the US, and is supported by RiseSmart HR Services Pvt. Ltd. in India. Customers and other RiseSmart entities and subcontractors can also be situated outside Belgium. RiseSmart has taken the necessary measures to guarantee that the personal details passed on are adequately protected against loss or unlawful processing.
For further questions about this, contact the Data Protection Officer (see further).

How long do we keep your personal details?
We guarantee that we do not keep your data for longer than necessary.
Retention periods depend on the objectives for which we process your data, the service you enjoy and the applicable laws or regulatory stipulations and limitation periods.
We keep your personal data as long as your program is running. After the end of this period, your file remains active for 2 years for Career Transition services, 3 years for Career Services, 2 years for Testing results and 3 years for potential evaluations. These deadlines make it easier to follow up on a follow-up program or answer any questions.
After these active retention periods for the consultants, your data and your dossier will only be archived centrally and passively (including removal of data that is no longer essential) for the time required for statutory retention periods, dispute management and statistical, audit and control purposes.

Security measures?
RiseSmart does everything in its power to optimally protect your personal details against unlawful use. We do this on the basis of physical, administrative and technological measures.
For example: only authorised persons get access to our offices and our systems, and access is limited to the systems they require for professional purposes. These people must know our internal policy on privacy and data protection and be able to apply it correctly. If and insofar as data is provided to third parties, RiseSmart agrees with these third parties that they will also optimally protect the personal details.

What are your rights?
RiseSmart processes your personal details in accordance with the stipulations of this privacy statement. As an involved party you have a number of rights you can exert at any time.

You can exert the following rights:

• Right to object
You can object to the processing of your personal details. You can only do this against processing based on the justified interests of RiseSmart or of a third party (see higher in point C). In the exertion of this right you will have to submit the form indicating which processing you oppose and for which specific reasons. This is necessary in order to be able to make a correct balance of interest.

• Right of access
You can formally ask which personal details are processed about you.
If you have an online profile in Spotlight (outplacement), then you can automatically view a large part of the personal details registered about (and by) you.

• Right to rectification (improvement and addition)
You can request the rectification of all incorrect or incomplete objective (personal) details (wrong address, incorrect spelling of your name,...) you have provided by asking it personally at your contact.

If you have an online profile in Spotlight (outplacement) then you can, without any intervention from Randstad, adapt and complete a large part of your personal details yourself.

If you request relates to other personal details than objective personal data, you have to use the form and indicate which data you want to rectify or complete. Subjective personal details you believe are incorrect (e.g. negative evaluation, unfavourable test results, etc.) are only adapted if we agree with you. If not, then we will not adapt these personal details, but will note your possible additional statements about this.

• Right to data portability
You have the right to transfer the personal details you have submitted to RiseSmart yourself in electronic form to yourself (via the e-mail address you give on your application form) or to a person with processing responsibility you indicated (via his e-mail address you give on your application form).

• Right to erasure (right to be forgotten)
In the cases provided by the GDPR, we will proceed to the removal of your data at your request.

• Right to restriction of processing
You have the right to obtain restriction of processing of your personal details if:
o You contest the correctness of your personal details (for the duration of the checking by RiseSmart).
o The processing of your personal details by RiseSmart would be unlawful, but you don’t want to invoke your right to erase data.
o We no longer need your personal details for the purposes included in this privacy statement (point C), but you do need them for instituting, executing or substantiating a legal procedure.
o You made an objection against the processing of some of your personal details (for the duration of the balance of interest).

You can in principle exert your rights free of charge. You can do this by making use of the following form. 
You can download this form yourself or ask your consultant at a RiseSmart office.

On the form you can find further instructions for filling in and sending your request.

You must always send along a copy of your identity card so we can be certain of the applicant’s identity. Without this copy your request will not be treated.

We will inform you in writing about what we are doing with your request a month after receipt of your completely filled in and properly sent form at the latest.
Depending on how difficult your request is or the number of requests we get from other people, this period may be extended by two months. In this case we will inform you about this extension within a month after receipt of your form.

In some cases (e.g. legal obligations, rights of others, periods of limitation, etc.) you will not be able to or be able to fully exert your rights. You will then get a message about this with the reason why we cannot or can’t fully meet your request.

On our website, we use cookies and web statistics. We do this to view how visitors use our website. This information helps us improve the site. A cookie is a file stored on your computer. These cookies can be recognised during a future visit to our website. You can read more about this in our Cookie Policy on our website.

Questions, remarks, complaints and data leaks 
If you have any questions, remarks or complaints about the protection of your personal details by Randstad or about this privacy statement, contact the Randstad Data Protection Officer via 

You also have the right to file a complaint with the Data Protection Authority (DPA) at the following address: 1, Avenue du Rock'n'Roll 4361 Esch-sur-Alzette Luxembourg
If you know about a data leak, or you assume a data leak, please immediately pass this on to us via


RiseSmart can for various reasons make improvements, additions or changes to this privacy statement. The most up-to-date version can always be viewed on our website.
This version was drawn up in May 2018.

*These are the Act of 2 august 2002 as modified on the protection of privacy with regard to the processing of personal data
and Regulation (EU) 2016/679 of the European Parliament and the Council of 27 April 2016 on the protection of natural persons in relation to the processing of personal data and the free movement of this data (GDPR)

privacy statement

Privacy statement for candidates RiseSmart Luxemburg


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