Data Privacy Policy
Who This Policy Covers
This policy applies to:
- Candidates who submit a profile, CV, portfolio, or coding assessment to Vantael.
- Clients who submit job orders, company information, or hiring contacts to Vantael.
- Website visitors who interact with Vantael’s site or forms.
What Data We Collect
From Candidates:
- Contact information (name, email, phone)
- CV, portfolio, and GitHub links
- Skills, years of experience, and rate expectations
- Pre-screening and coding assessment responses
- Interview notes (AI-paraphrased from recorded or live sessions)
From Clients:
- Company name, country, and contact details
- Job order details (role, stack, budget range)
- Communication and engagement history
From Website Visitors:
- Form submissions (job orders, candidate applications, contact inquiries)
- Basic usage data where applicable (e.g., page visits), to the extent enabled on Vantael’s site
Why We Collect It
Vantael collects and processes personal data solely to operate its placement service:
- To screen and match candidates against active client job orders.
- To generate structured candidate briefs for clients.
- To coordinate interviews, offers, and post-placement check-ins.
- To maintain records required for invoicing and fee collection.
- To communicate updates relevant to an active search or application.
Vantael does not sell personal data, and does not share candidate data with a client without the candidate’s prior consent.
Legal Basis for Processing
Vantael processes personal data on the basis of:
- Consent — candidates and clients actively submit information for the specific purpose of being matched or sourcing talent.
- Contract necessity — data processing required to deliver the placement service to a client or candidate.
- Legitimate interest — limited internal recordkeeping (e.g., pipeline tracking) necessary to operate the agency.
How Candidate Data Is Shared
- A candidate’s CV, portfolio, or profile brief is shared with a specific client only after the candidate has consented to be considered for that specific job order.
- Vantael does not broadcast candidate profiles to multiple clients simultaneously without consent.
- Vantael does not sell, rent, or trade candidate data to third parties for marketing purposes.
How We Protect Your Data
- Candidate and client records are stored in access-controlled storage (structured, permission-limited cloud storage).
- Only Vantael’s operating team can access candidate and client records; access is not broadly shared.
- Signed candidate consent is required before any CV or portfolio is shared externally with a client.
- Vantael follows a recruitment-only scope: it does not process data for payroll, statutory benefits, or employment purposes, which limits the volume and sensitivity of data handled.
Data Retention
- Candidate records are retained for as long as the candidate remains active on Vantael’s bench, or as needed to support an active or recent placement.
- Client records are retained for the duration of the business relationship and as required for invoicing and audit purposes.
- Candidates and clients may request earlier deletion at any time (see “Your Rights” below).
Your Rights Under the Data Privacy Act (RA 10173)
As a data subject, you have the right to:
- Be informed that your personal data is being processed, and how.
- Access the personal data Vantael holds about you.
- Object to processing of your data, including for specific purposes such as being shared with a particular client.
- Correct inaccurate or outdated personal data.
- Request deletion or blocking of your data, subject to legal or contractual retention requirements.
- Data portability, where applicable.
- Lodge a complaint with the National Privacy Commission (NPC) if you believe your data has been mishandled.
To exercise any of these rights, contact Vantael at [insert privacy contact email].
National Privacy Commission (NPC) Registration Status
Vantael’s registration status with the National Privacy Commission is [insert current status — e.g., “registered” or “voluntary registration in progress”], consistent with the Philippine Data Privacy Act’s registration thresholds for entities processing personal data.
Third-Party Tools
Vantael uses a limited set of operational tools to run its placement process (e.g., structured spreadsheet-based candidate tracking, scheduling tools, e-signature tools, and AI-assisted CV screening). These tools process data strictly to support the purposes outlined above and are not used to sell or broker personal data independently.
Changes to This Policy
Vantael may update this policy as its process, tools, or legal obligations evolve. Material changes will be reflected with an updated “Last updated” date at the top of this page.
Contact
Questions about this policy or a request regarding your personal data can be directed to: privacy@vantaelsearch.com
This page is based on Vantael’s internal compliance plan and general Data Privacy Act (RA 10173) principles. It is not a substitute for review by a licensed Philippine data privacy counsel, which Vantael’s own business plan flags as an outstanding action item before public launch.
