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Case Study Three: Privacy notices

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The law states that when someone’s data is collected, that person needs to be provided with a privacy notice. An Investment management company was fielding job applications, and an employment agency was adding applicants to the Investment management company’s application portal.

The employment agency did not provide their applicant’s contact details and instead where filling it in with the recruiters own details because they did not want to be removed from the employment process and lose out on any fees. As a result, the company was unable to make the privacy notice available to the applicant.

From the situation it was unclear as to whether the employment agency should sign a contract to ensure they delivered the privacy notice, or whether the company should do something else entirely. At Kazient we helped find a solution to this impasse. This predicament also highlights the importance of having strong Data Protection procedures already in place.

Case Study Two: Consent forms

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A non-European bank was recruiting applicants from Europe, bringing them under GDPR regulations. The bank asked employment agencies to complete consent forms for the candidates so that they could accept the information in an appropriate way. However, the employment agencies said this was too burdensome and that no other employers made this request. The bank responded by saying that the law required this.

Kazient were invited to find a solution to the standoff by employing our expert opinion. We were able to identify the correct course of action to take and find the most practical and efficient route to being compliant.

Case Study One: The question of customer data

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In May, the question arose over what legal basis companies could use for certain processing of customer data in the future. Many companies decided to proceed by asking their entire database of customers for consent – by inviting them to respond to an email.

We advised our clients that this was not necessarily the best approach and suggested that they had alternative legal basis such as legitimate interest that could be relied upon and that it would be more productive for companies to ask their customers if they would like to opt out of having their data processed in this way.

In the former, companies found that no more than 7% of respondents gave their consent – wiping out 93% of their database for future marketing. Whereas, with the companies we advised, they found that 2% opted out – so 98% of customers allowed their data to be used by the company going forward.