1. The security policy is a response to how SMART processes personal data of both Candidates and Clients regarding the RODO guidelines.
2. The security policy describes how SMART collects, uses and processes personal data and presents obligations towards people entrusting us with their data.
3. Personal data of candidates are important to us and we undertake to protect their rights to confidentiality of data.
4. This Security Policy applies to the personal data of our Candidates, Clients, Suppliers and other persons with whom contact is aimed at obtaining additional information related to the recruitment process. For the purposes of the existing data protection legislation, including, inter alia, the general regulation on data protection (Regulation (EU) 2016/679) (“RODO”), the entity responsible for data processing is SMART Consulting Sylwia Kłyczek with its registered office in Wrocław, ul. Cukrowa 13e / 2.
5. Whenever SMART appears in the document, it should be understood as SMART Consulting Sylwia Kłyczek with its registered office in Wrocław ul. Cukrowa 13e / 2; office ul. Inowrocławska 17, floor 106.
6. SMART Consulting reserves that periodic changes to this Security Policy are possible. All updates will be published on the website in the Security Policy tab.
7. This Safety Policy is valid at the SMART Consulting site of Sylwia Kłyczek and at the area of SMART Consulting’s clients.
8. Data Administrator (Article 7 (4)) UODO? authority, organizational unit, entity or person referred to in Article 3 determining the purposes and means of processing personal data. On behalf of Smart Consulting Sylwia Kłyczek, the personal data administrator is Smart Consulting employees and authorized associates based on a written power of attorney.
What kind of personal data do we collect?

In order to carry out the recruitment service? On commission? We use and process the data necessary to carry out the process.
Data collected during the process:
• first name and last name,
• age,
• contact details (telephone, email),
• education,
• employment history,
• certificates and skills credentials,
• and data provided by the candidate for the implementation of the project.

In order to provide services to clients, we collect and process information related to people working for the client. We collect and use information about the organization and people working in it in the course of providing such services as: sale of recruitment projects, training and HR projects and consulting projects and presentation of marketing proposals in the above-mentioned scope.
The data we collect:
1. name and surname,
2. business e-mail and business phone.

In order to efficiently cooperate with suppliers, we process personal data of contact persons (telephone, e-mail) and bank account number necessary to make payments.

In order to confirm the competence of the candidates, we process and collect data of people who can provide the so-called references. The scope of data processing is: name and surname, telephone number of the person providing the reference. These data are used only to confirm competence in the recruitment process.

How do we collect your personal information?
We collect personal data in two ways:
• Directly from the Candidate.
• From third parties.

1. Personal data provided directly from the candidate:
• Entering your data on the website www.smartrecruitment via the contact form as part of the recruitment process.
• Leaving a printed version of your CV at the recruitment event, job fair or delivered personally to the SMART office.
• Sending a CV via email to a SMART consultant or going on an interview.
• Applying job offers to positions through the search engine that will redirect you to the website.
• Participation in the competition via a social channel, such as Facebook or LinkedIn.
Personal data that we obtain from third parties:
We also receive personal data of Candidates from other sources and third parties. Depending on the circumstances and applicable laws and requirements, these may include personal data obtained in the following situations:
• Your reference contacts may disclose your personal information.
• Our clients can provide us with your personal information.
• We can obtain information about you by searching for potential Candidates from external sources, such as LinkedIn, Goldenline and another website with job offers.
• If you like our page on Facebook or Linkedin, we will receive personal information from these websites.
We collect personal data in two ways:
• Direct from the customer.
• From third parties.
Personal data that we receive directly from the customer
We receive personal data:
• If the customer contacts us via telephone, e-mail or in a usual manner.
• If SMART employees contact the Customer by phone or e-mail or in a manner customarily adopted by our consultants as part of business development.
Personal data that we obtain from other sources and from third parties:
• Personal data from other sources and third parties in accordance with local law, generally as part of market analysis or research carried out by third parties.
• Analysis of online and other media.
• From lists of participants in significant events.
• From other limited sources and from third parties (for example from our Candidates to the extent that they provide us with your data as their reference contact).

We collect personal data resulting from mutual cooperation necessary to provide a service or product.

4. PERSONS WHO RECEIVE FROM CANDIDATES AND PERSONNELS, FOR EXAMPLE REFERENCE CONTACTS: We collect contact details only if the candidate provides them to us as a reference contact.

We collect data automatically via cookies, showing visits on the website to the extent that browser settings allow.

How do we use your personal information?
Activities in the recruitment process

The main reason for the use of personal data are current and future recruitment processes in which the Candidate concerned is involved or can be met by meeting the criteria in the job description presented to us. Consent to data processing allows you to present such a Candidate to the Client and carry out the recruitment process.
In particular:
• collecting data directly from the Candidate, as well as from other sources and from third parties.
• storing (and updating if necessary) data in our database so that we can contact you again in connection with current recruitment processes.
• provision of recruitment services and improvement of the recruitment process.
• sending information to clients in order to apply for positions or to assess the candidate’s qualifications.
• the possibility of submitting a resume, applying to positions via the Internet or subscribing to notifications about offers that are tailored to the Candidate’s experience.
• the opportunity to participate in specialist on-site and online training.
• the possibility of participating in interactive functionalities of websites.
• fulfillment of obligations resulting from all agreements concluded with customers and suppliers.
• fulfillment of obligations resulting from all agreements concluded between SMART and third parties in connection with recruitment.
• verification of data using external resources (such as psychometric tests or skills tests) or requests for information (such as: references, qualifications, in which it is appropriate and in accordance with local law).
• data processing to enable the transmission of selected, relevant marketing materials or other correspondence, which may be a potential source of interest.

We process our clients’ data in order to establish and confirm the terms of cooperation, the course of cooperation and their effects. The main reason for using information about clients is the effective delivery of candidates in commissioned recruitment projects and marketing activities related to expanding the recruitment and development offer.

We process the personal data of the supplier in the dimension necessary to confirm the concluded cooperation agreements.

We use personal contact details to help Candidates find the right employment offer for them. We verify their qualifications and experience and diagnose the motivation to change jobs. The contact with the reference person is to ensure that the candidate matches the needs of the future employer. We also use personal contact details to contact them in connection with recruitment activities that may interest them.

We use data to improve the use of our website, adjust its content to implemented projects and users’ needs. We may use data on how to use our websites to improve other aspects of our communication with the Candidate or Client and their use.
We stipulate that communication from and to SMART employees including e-mails can be checked through internal or external investigations or court proceedings.
Marketing activities
If appropriate consent is granted, SMART periodically sends information that may be of interest to the Candidate, Customer and third parties in the area of the new SMART services:
• new company services and products launched on the market,
• sale of our recruitment services,
• sending information about industry and networking meetings,
• information and reports on the recruitment and training market.
Who do we share your personal information with?

We provide personal data listed above, to clients (potential employers) for the purpose of the recruitment project, meetings as part of recruitment and employment decisions of the selected candidate.
We process personal data in the scope as above in order to ensure the recruitment process by providing the appropriate quantity and quality of Candidates involved in the recruitment process.
Unless you decide otherwise, we can also process data for the implementation of HR projects, trainings and coaching sessions provided as part of the SMART Consulting activities.

We process personal data in the scope as above in order to cooperate effectively.

We process personal data to confirm the candidate’s references and to present proposals for other recruitment processes that may be of potential interest to those who give references (both as a candidate and as a client).

Unless you decide otherwise, we may share your data with web analytics service providers.
How do we protect your personal information?

1. We are required to take all reasonable and appropriate measures to protect our personal information against abuse, loss or unauthorized access. To this end, we have implemented a number of appropriate technical and organizational measures. These include measures to counter any suspected data breach.

2. If you suspect any abuse, loss or unauthorized access to your personal information, please notify us immediately. Notifications to the address
How long do we keep your personal data?
We store personal data for a period of 10 years, if at that time one of the parties does not make contact, we will automatically delete the data of the Candidate or Client or the person providing the reference.
How do you get access to your personal information, correct it or withdraw it?
One of the main aims of the ROPE is to protect and clarify the rights of EU citizens and persons staying in the EU in the field of data protection. This means that the person providing personal data retains different rights to their data, even after transferring them to SMART.
They are described in detail below.
1. You have access and the right to change, improve and withdraw your consent to the processing of personal data provided to SMART Consulting by Sylwia Kłyczek at any time. Contact us at We will review your application without undue delay (no later than within 48 hours from the date of notification) and in any case, as required by applicable law.
2. Right to object: You have the right to object if we use personal information for purposes other than those set out above. In this case, submit an application for objection by contacting buro @ and within 48 hours you will get our answer.
3. Right to withdraw consent: After consenting to the processing of your personal data for the purposes of specific activities or consent to conduct marketing activities towards you, you may withdraw your consent at any time.
4. Requests by data subjects for access to data: SMART Recruitment guarantees the right to verify at any time what information about the Candidate, Client, Supplier, and person providing references. Any interested person whose data we process has the right to change, update or delete such information. In the event of such a request, we may delete the data to ask for identity verification or to provide additional information about the application; and reject the application if the law allows it, justifying our decision.
5. Right to erase: In some situations (for example in the case of unlawful data processing) there is a right to request? Erasure? personal data. We will respond to your request within 30 days. If the application is successful, we will delete the data, with the reservation that you will remain (your name and surname) in our register as a person who does not wish to contact us. You have the right to refuse permission for such a solution.
6. Data transfer right: You have the right, at your discretion, to transfer your data from us to another data controller.
7. The right to lodge a complaint with the supervisory body: You have the right to lodge a complaint with the competent local supervision authority.

Currently, all our recruitment activities involve making decisions by people, in the future we can use fully automated technologies, such as expert systems or machine learning to carry out the candidate selection process from beginning to end in appropriate cases and in accordance with local laws and requirements.
In appropriate cases, we will ask you for permission to take some or all of these activities. If you do not agree to profiling, your application will continue to be subject to manual verification for the positions you are applying for.
• Article 4 (11) of the RD0 states that consent means “voluntary, concrete, informed and unambiguous representation of the will which the data subject, in the form of a declaration or explicit confirmation action, authorizes for the processing of personal data relating to him”. Means:
• that giving consent is voluntary, without exerting any pressure on you,
• that giving consent is aware of the scope of data processing and purpose,
• consent to the processing of data in the above-mentioned scope regarding recruitment and marketing activities can be found in e-mail correspondence, on the website in the contact form,
• each time we ask for a note on the documents sent to SMART for expressing the appropriate consent.
As part of the Smart Consulting services provided by Sylwia Kłyczek, you can agree to:
• processing of your personal data for the purpose of recruitment projects,
• processing your personal data in order to implement training, workshop and development projects (coaching),
• processing personal data in the marketing field? providing recruitment offers, new solutions in the area of HR, reports and offers of training activities,
• consent for sending by e-mail and telephone (via telephone, e-mail, messenger, portal) commercial information regarding Smart Consulting Sylwia Kłyczek and related entities.
What are cookies and how are we using them?
“Cookie” is a small string of data stored on your computer’s hard drive. Almost all websites use cookies without harming your system.
If you want to check or change the types of accepted cookies, you can usually do this in your browser settings. We also inform about this on our website marketing settings page.
We use cookies to track your activity to provide you with the most efficient experience when you visit our website. We may use information from cookies to make sure that during your next visit we will offer you options tailored to your preferences. We can also use cookies to track network traffic and for advertising purposes.
If you do not want to receive cookies that are not strictly necessary for the operation of the basic functionalities of our website, you may refuse to accept the settings of your browser accordingly. Additional information about cookies and how to disable them is available on the website. There you will also find information on how to delete cookies from your computer.