This privacy policy provides information regarding personal data processed by Helvetas Swiss Intercooperation from Switzerland, Skopje Branch (hereinafter referred to as the “Controller”) under the “Education for Employment Project in North Macedonia” (E4E@мк), whenever visiting our website or submitting data to the controller, in any other form. While collecting any type of personal data information, the E4E@мк project acts as a controller in accordance with the Law on Personal Data Protection and in accordance with the stated Law, the project is obliged to inform each entity about the processing of their personal data. The project considers the processing of personal data as a very serious task and all necessary technical and organizational measures are undertaken to protect the processing of the personal data. In addition, when processing the personal data, the project is always guided by the principles related to the processing of personal data, i.e. processing only the necessary data in order to meet and fulfil the legal obligations and authorizations.

This policy applies to all categories of personal data entities, whose data are processed in accordance with the above stated law.

Who are we?

Title: Helvetas North Macedonia, project “Education for Employment in North Macedonia” (E4E@мк)

Address: Str. “Vasil Gjorgov” no. 16 (TC Zebra, 2nd floor) 1000, Skopje

Contact email: e4einfo@helvetas.org

Acting on behalf of the E4E@мк project, the authorized person for personal data protection i.e. Coordinator is: Aleksandra Ilkova, contact: e4einfo@helvetas.org,

Categories of personal data entities

As a controller over the fulfillment of the legal obligations and authorities, set for regular functioning of the organization and for meeting the project goals, as well as in accordance with the nature of the work of the organization, the E4E@мк project processes personal data of the following categories of personal data entities:

• Visitors of the website – navigation data, i.e. cookies necessary for the normal functioning of the website. For more details, see the Cookie Policy.
• Employees – in accordance with the Law on Work/Labor Records, and for the purpose of fulfillment of contractual obligations.
• Candidates for employment – for the purpose of fulfillment of contractual obligations, i.e. for the purpose of employment of a natural person, and in accordance with the will of the candidates in the organization, data for candidates for employment are processed as well.
• Training participants – based on the consent to participate in trainings organized by the project, under the activities the project, personal data of training participants are processed as well.

How do we collect your personal data?

The personal data of all listed categories are being processed or collected for all visitors of our website, during which only navigation data or cookies necessary for the normal functioning of our website are collected (more information available in the cookie policy).

The website offers all visitors the possibility to send the website a direct message through the form placed in the Contact section, as well as to register for trainings.

The website is also used to inform the public about announcements, activities, and data that the project is obliged to publish about the organization, as well as contact information (address of the organization, telephone number, e-mail and information about the coordinator for personal data protection).

Visitors to our website:

When visiting our website, logs with the following data are created for each visitor:

• Your Internet Protocol (IP) address.
• The device you are accessing from, type and model.
• Your operating system.
• Browser type, plugins and version.
• The sections and subsections you visit on our website and the time you spend on each section.
• The URL of the page that redirected you to our website and in some cases, the terms you used when trying to find our website.
• The language of the browser you are using.
• Country (specified via IP address).

Contact form

If you want to send us a message directly through the contact form, you must submit the following categories of personal data:

• Your name
• Your email address.
• Your message.

Registration for trainings

When opening i.e. advertising a training call, the website, in the registration section, allows all entities interested in participation to fill out the form by entering the following categories of personal data:

• Name and Surname
• Organization / Institution
• Telephone
• Email

Personal data of employees

Personal data for all employees are being collected on the basis and in compliance with Article 8 and Article 20 of the Law on Labor Records, which are required to fulfill the contractual obligations, i.e. the data are needed to exercise specific rights and obligations of employment. In that sense, the project processes the following data related to our employees:

• name and surname of the employees;
• name of one of the two parents;
• date of birth;
• place of birth;
• municipality of birth;
• permanent or residence address;
• place of residence;
• municipality of residence;
• ID number;
• Country;
• belonging to a community;
• gender;
• email address;
• telephone;
• data on current employment and previous employment (group, subgroup, category, level and job);
• data for education, professional qualifications and job competencies;
• data on annual assessments; and
• data on the amount of salary and salary allowances;
• number of transaction accounts;

The time period related to storing and safe keeping of personal data for the employees is stipulated by the Law on Labor Records and the list of documentary material which indicates the time-periods for safe keeping of the records. The employees’ files are kept for a time-period of 45 years from the date of termination of the employment. All other data on employees are safe-kept within the deadlines i.e. time-periods provided in the Procedure for limitation of the storage and safe-keeping deadlines and the list of documentary material with storage and safe-keeping deadlines.

Personal data of candidates for employment

The personal data of the candidates for employment are processed via the submission of a CV, employment application, and motivation letter or data submitted during an interview. In that sense, personal data processed for employment candidates includes:

• Name and surname,
• Date of birth,
• Permanent address,
• Information on driver’s license holder,
• Contact (phone number, e-mail),
• Education,
• Occupation / profession,
• Work experience,
• Knowledge of foreign languages,
• Knowledge of working with ICT technologies
• Other relevant knowledge in the field of the job for which he / she is applying

The personal data collected during the whole process of selection of a candidate is processed with the objective of signing an employment contract, as well as for making a decision on the amount of salary. At the end of the procedure, if a candidate has been selected for a job position, he/she will sign an employment contract. Otherwise, the personal data for the candidate, including the documentation that has been submitted to the project (CV, cover letter, copy of diplomas, certificates and other records) will be returned to the candidate or destroyed if submitted in a hard copy. If the project considers that the work experience of a candidate may be needed in the future work of the project/company, explicit consent will be requested from the candidate to continue to store and safe-keep personal data so that the candidate can be contacted at a moment when a suitable job position is vacated. This processing of personal data is based on the explicit consent of a candidate and such consent by the candidate can be withdrawn at any time, free of charge, which shall be performed by deleting the personal data of the candidate.

Personal data of training participants

In order to reach the set goals and objectives of the project, the organization carries out various thematic trainings, to which everyone with a relevant interest can apply. In this direction, on the basis of consent by the persons participating in the training and for the purpose of evidencing that the training was carried out, the following categories of personal data are processed:

• Name and Surname
• Organization / Institution
•  Phone number / e-mail
• Signature.

Given that the work of the project is subject to financial audits, the project has the obligation to safe-keep such data in accordance with the Policy for limitation of the time period for safe-keeping, for a period of ten years from the day of the training. The process of deleting of personal data is carried out in accordance with the internal regulations as well as the rules for archival work.

Personal data of contracted positions (consultants and external collaborators)

Within the framework of reaching the project goals and objectives as well as for executing the project activities, the organization publishes calls for consultants, cooperates with the project partners and maintains an already established cooperation network with external collaborators. Under this process, the project processes i.e. collects personal data of externally contracted persons. The organizations signs contracts with all persons selected for cooperation. Within a given contract cooperation, the following personal data for this category of entities is processed:

• Name and Surname
• Personal Identification Number
• ID Card Number
• Address
• Contact details (phone number, email)
• Occupation / profession
• Working hours
• Bank Account
• Other data related to the fulfillment of the contract

The data is processed in order to execute the contracts with the contracted external (associates and consultants). The data retention period is regulated by the policy for limitation of the storage period and it is 10 years from the day of termination of the contract. The deletion is carried out in accordance with the internal regulations and the rules for archival work.

Personal data sharing

Depending on the category of personal data entities, in order to enforce the legal rights and obligations, the personal data may be shared with third parties. Within an employment of one entity, the data may be shared with the Employment Service Agency, the Health Insurance Fund, the Pension Insurance Fund, the designated commercial bank, the Public Revenue Office. The personal data of training participants and collaborators is not shared.

Disclosure of personal data

The personal data processed by the project is disclosed only on the basis of a written request from authorized persons, on the basis of a given law.

If the controller hires a processor, it does so in full compliance with Article 32 of the Law on Personal Data Protection, and undertakes all technical and organizational measures to protect personal data processing. When selecting a processor, the organization applies a procedure for selection of processors, which as a selection criterion takes into account the level of compliance with the law on personal data protection.

International transfer of personal data

The organization’s headquarters is in Switzerland and the personal data is transmitted i.e. transferred only within the organization but not outside it.

Personal Data Security

The organization undertakes all technical and organizational measures to ensure the security of personal data processing in accordance with the risk of the rights and freedoms of the personal data entities. The organization invests special efforts and resources for training of employees and especially for the coordinator for personal data protection. Data in paper form are stored in separate rooms and access is restricted to non-authorized persons. The data in electronic forms is processed in applications that are useful at the level of organization, in which access is also restricted and all technical and organizational measures are taken to protect such personal data.

Your rights

Your rights regarding the processing of personal data include:

• Right to be informed about the personal data processing
• Right of access to personal data
• Right to correct/amend and delete personal data
• Right to restrict the processing of personal data
• Right to object i.e. file a complaint

For additional information and/or for exercising your rights to personal data protection, you can contact the authorized person for personal data protection.

Right to submit request to the relevant authority

If you consider that the project/organization, while processing your personal data, violates the provisions of the LPDP, you can file a complaint to the supervisory body i.e. the Agency for Personal Data Protection. Request form: https://www.dzlp.mk/node/3274