Cbs international notice on personal data processing job applicants

  1. INTRODUCTION Real estate company CBS International doo Beograd – Novi Beograd, with registered seat at Bulevar Omladinskih brigada 88b, Novi Beograd, Company number 20222891, TIN 104724713 (CBS International) shall process personal information in the course of regular operations and shall, under certain circumstances, communicate this information outside the Republic of Serbia as the country where the personal information was collected. 

In doing the above said, CBS International is fully committed to preservation of safety of all the Personal Information (as defined below) by meeting and exceeding all the applicable standards in terms of data protection prescribed by the Law. 

The Privacy Notice (Notice) shall describe the manner in which CBS International collects, utilizes and processes personal information referring to job applicants. CBS International is the data operator for Your personal information. 

  1. SCOPE AND APPLICATION OF THIS NOTICE This Notice shall be applied to all the Personal Information (defined below) of job applicants, which CBS International shall collect, utilize, disclose or keep. 
  2. WHAT IS PERSONAL INFORMATION? For the purpose of this Notice, “Personal Information” is any data referring to a determined or determinable individual, or which might be used for identification of an individual, and any other data about an individual protected by the applicable Law on Protection of Personal Information (“Official Gazette of RS”, no. 87/2018 – hereinafter “Law”). 

Types of personal information that CBS International may collect from you or about you shall include: 

  • name and surname; 
  • date and place of birth; 
  • phone number and email address 
  • information about current job; 
  • work resume – CV; 
  • cover letter; 
  • information about education; 
  • information about evaluation; 
  • photo of the job applicant 
  1. WHY IS CBS INTERNATIONAL COLLECTING, USING, DISCLOSING OR KEEPING THE PERSONAL INFORMATION? CBS International shall collect, utilize, disclose or keep the Personal Information for the following purpose: 
  • Workforce management: management of employees and future employees, evaluation of job applicants in order to determine which candidates meet the requirements for employment with CBS International, planning and monitoring the need for training and activities for career and skill development. 

The personal data that CBC International is collecting about you are mandatory in order to fulfil legal obligations in context of labour law we are subject to, to perform our obligations when concluding an employment contract with you, or for our legitimate business purposes as the future employer, as described above. 

Job applicants shall be obligated to submit their personal information to CBS International in order to be taken into consideration in the procedure for recruitment of future employees; if job applicants do not want to disclose any Personal Information, then CBS International will consider whether, in the given circumstances, it will be possible to continue employing a person who refuses to disclose the required Personal Information. 

  1. IS CBS INTERNATIONAL PUBLISHING OR TRANSFERRING PERSONAL INFORMATION? CBS International may, from time to time, disclose Personal Information to other subjects within CBS International Group or to third parties for any purpose stated above. Examples of relevant third parties to which CBS International may disclose Personal Information shall include, but are not limited to, Cushman & Wakefield Debenham Tie Leung Limited (company established and registered pursuant to the laws of the United Kingdom of Great Britain and Northern Ireland) and eventually hired agencies for evaluation and recruitment of job applicants. 

When we disclose your Personal Information to third parties performing the services on our behalf, we secure that these service providers use Personal Information exclusively in accordance with our instructions, and we do not authorize them to utilize or disclose Personal Information, except when necessary for the performance of services on our behalf or in order to harmonize with applicable legal obligations. 

CBS International may also disclose Personal Information to third parties in the following situations: 

(i) when such disclosure is prescribed by the law; (ii) for the purposes of, or in connection with, any legal procedure where you or CBS International are the party, or when otherwise required for the purpose of establishment, performance or protection of your rights and the rights of CBS International; (iii) when the bodies for implementation of laws or other state bodies filed a legal request 

for such disclosure; (iv) when we believe that disclosure is necessary to prevent injury or financial loss, or in 

relation with investigation of suspected or actual criminal activity; or (v) if CBS International is selling or transferring all or part of their operations or assets (including status and other changes: merger/acquisition, reorganization, division/separation, deletion, liquidation). 

CBS International shall supervise the use of their computers and e-mail systems by their employees pursuant to their data safety policy and all the applicable laws. 

  1. INTERNATIONAL TRANSFER OF PERSONAL INFORMATION Considering the global nature of our activities, we can disclose your Personal Information to the company Cushman & Wakefield Debenham Tie Leung Limited, company number 02757768, established and registered pursuant to the laws of the United Kingdom of Great Britain and Northern Ireland and their related entities in other countries. 

When CBS International transfers Personal Information, independently or via CBS International Group, outside the Republic of Serbia or outside the member of the Convention of the Council of 

Europe on protection of parties against the automatic personal data processing, CBS International shall do this only in the event of a: 

(i) country for which the European Union determined that has an appropriate level of 

protection of Personal Information; (ii) company with valid certificate – US-EU Privacy Shield for the category of Personal 

Information being transferred; or (iii) where we set up a relevant data transfer mechanism, such as standard contractual clauses, in order to make sure that your Personal Information is adequately protected. 

If neither of the criteria is met, CBS International may continue to transfer Personal Information outside the Republic of Serbia if the employee grants their explicit consent to this, or if the transfer is required by the law. 

Access to your Personal Information by CBS International shall be limited to persons who have to know the information for the purposes described in this Notice, and this may include employees from HR, IT, legal department, finance, accounting and internal audit department. 

  1. PROTECTION OF PERSONAL INFORMATION CBS International shall set up relevant technical and organizational measures established to protect your Personal information from loss or accidental, illegal or unauthorized changes, access, disclosure or use. 

CBS International shall keep the Personal Information relating to you for as long as there is a need for employment, which due to pronounced employee turnover and expansion of activities, may last for a longer or undetermined time period. 

  1. RIGHTS OF PERSONS TO WHOM PERSONAL INFORMATION RELATE CBS International expects the person to whom the Personal Information relate to update their Personal Information. CBS International shall take other reasonable steps necessary to secure that Personal Information is precise and complete for the purpose for which they are collected, utilized, disclosed or kept. 

To the extent required by applicable law, you may have the right to request a copy of any Personal Information that CBS International has about you. 

You may also have the right to: 

  • ask for your Personal Information to be corrected, amended or deleted, or that their processing is limited; 
  • object to the processing of your Personal Information; 
  • accept Personal Information in portable form and accept a copy of Personal Information; 
  • not to have the decision reached only based on automatized processing, including profiling, applied on you, if this decision produces legal consequences for this person or if this decision has a relevant effect on his position; 
  • be informed about the violation of your Personal Information. 

If you want to be informed or if you want to exercise any one of these rights, please use the following contact information: e-mail address:, phone number: +381 11 22 58 777 or mailing address: for CBS International doo Beograd – Novi Beograd, Omladinskih brigada 88b, 11070 Novi Beograd, indicating “For protection of personal information”. 

If CBS International collected your Personal Information with your consent, you are entitled to withdraw this consent at any time, which you may do by using the above stated contact information. 

If you are unsatisfied with the manner how CBS International handles your Personal Information, you also have the right to object – file a complaint to the Commissioner for Information of Public Importance and Personal Data Protection. Details about the mentioned supervisory body can be found on the following webpage:

  1. UPDATING CBS International may update this Notice from time to time, and shall inform you about any relevant changes on their websites, through internal postings, or through appropriate channels of communication. All changes will be valid as of the date of publication unless otherwise noted. 

This Notice produces legal effect with the start of application of the Law, i.e. August 21, 2019. 

10. CONTACT US Should you have any questions or concerns regarding this Notice, or would like to exercise any of your rights, please contact CBS International via the contact details above.