Data protection policy 

Privacy and data protection are a top priority for MINDSHIFT group (VAM/MINDSHIFT GROUP/The Key Talent Portugal), from now on referred to as the MINDSHIFT group. The site navigation is possible without the submission of personal data, however, if someone wishes to use MINDSHIFT group’s services, the processing of personal data may be necessary. If the processing of personal data is required and there is no other legal basis for such processing, MINDSHIFT group will request consent beforehand to the data holder. The processing of personal data – such as the name, address, e-mail address, or telephone number – must always be in accordance with the General Data Protection Regulation (GDPR) and in accordance with the data protection regulations in the country and applicable to MINDSHIFT group. With this data protection statement, we would like to inform everyone who visits our site about the source, reach and purpose of the personal data we collect, use and process. Additionally, data holders are informed, through this data protection declaration, of their rights.

1. Our name and address 
The responsible for the data management, for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in the Member States of the European Union and other provisions related to data protection, is:

MINDSHIFT – Talent Advisory, Lda

Avenida da República, 45, 8º Esq.1050-187 Lisboa

PortugalTelephone (351) 219 013 322



2. Cookies
Our web pages use cookies. Cookies are small text files that are stored on a device (computer, smartphone, or tablet) via a web browser. With the use of cookies, MINDSHIFT group grants a better and simpler user experience, which would not be possible without them. The information gathered by cookies allows numerical estimates, usage patterns and the adaptation of the site to the interests of its users. This information aims to improve the technical performance of our website and its user experience. The data stored in cookies is used exclusively by us, through the Google Analytics service, and has only statistical purposes. The data holder can, at any time, avoid the use of cookies by our website through the configuration of the internet browser and permanently avoid the use of cookies. In addition, cookies already created can be deleted at any time through the internet browser or other software programs. If the user deactivates the use of cookies in the internet browser, some of the functionalities of our website may not be entirely available.

3. Data collection and general information
Our web pages collect determined data and general information when a data holder or an automated system navigates the site. This data and general information are stored in the server log files. Thus, it can be collected the types of browser and versions used, the operating system used by the access system, the site from which an access system reaches our sites (so-called referents), sub-websites, date and time of access to the Internet site, the Internet protocol address (IP address), the Internet service provider’s access system and other similar data and information that may be used in case of attacks on our information technology systems. This information is required to assure the proper availability of our websites, to optimize and disseminate its contents, to ensure the long-term viability of our information technology systems and technology of the websites, and to provide the authorities responsible for the application of the law the necessary information for criminal proceedings in the event of a cyber-attack.

4. Registration of the applicant: treatment of personal data
The requested data, given voluntarily by the candidates (data holders) in the different forms, is strictly necessary for the applications management, administrative management of the process and for other related activities by the MINDSHIFT group.
The information gathered from the application form will only be kept in the process when the applicant accepts the terms and conditions established for this purpose. The candidates that don’t fill in the fields that the MINDSHIFT group has defined as mandatory will not be able to register their application.
Applicants may be required to carry out additional tests (psychometric, knowledge, skills, etc.) to complete the process.
At the end of each phase of the process, candidates will receive feedback from the MINDSHIFT group and information on next steps.

What information is collected?
• Professional and academic background;

• Language skills and other professional skills;

• Citizen card information;

• Date of birth;

• Nationality and authorization to work in the country;

• Information provided by references;

• The information contained in your resume, the information you provide regarding your professional interests, and other information about your employment qualifications.

Why do we treat personal data?
We use the data mentioned above for the following purposes:

• Analyze and select your application in a recruitment process;

• Creation and management of applications and professional profiles.

We will execute data analysis such as performance evaluation and individual capabilities, including professional skills grading.

Who has access to your data and to whom are they made available?
In accordance with the goals detailed above, access to data is strictly limited to:

• Employees of the MINDSHIFT group who have to access to your personal data for the performance of their duties;

• Service providers who access your personal data in the scope of the information and technology systems sectors.

The MINDSHIFT group will only transfer data to third countries in the European Economic Area (EEA), for companies that comply with all legal data protection obligations, treating them in line with the purposes indicated and previous and documented instructions by the MINDSHIFT group.

5. Retention of personal data
Personal data will be processed and stored only for the period necessary to achieve the purpose of storage, or by legal imposition when applicable.
The data will be stored for the following purposes and time periods:

• Candidate processes: 5 years of inactivity;

• Assessment of employees: 5 years of inactivity;

• Newsletters: 5 years of inactivity.

If the purpose of the storage is not applicable, or if a storage period expires, personal data is regularly erased or locked in accordance with legal requirements. We also inform you that, in case of need, we will keep your data for compliance with legal and tax obligations, prevent illicit actions and resolve disputes.

6. Rights of the data holders 
If the data holder desires to exercise any of the rights listed below, it is possible, at any time, to contact MINDSHIFT GROUP using the information provided in point 1.

Right of access

The owner of the personal data has the right to know from MINDSHIFT GROUP if its personal data is or isn’t processed and, if applicable, to access their personal data and access the information’s foreseen in the law. If the person wants more than one copy of its personal data being processed, MINDSHIFT GROUP may charge a fee for administrative costs.

Right to rectification

The data holder has the right to obtain from MINDSHIFT GROUP, without undue delay, the rectification of inaccurate or incomplete personal data that concerns him.

The right of elimination (Right to be forgotten)

The owner of the personal data has the right to ask MINDSHIFT GROUP to delete its data without undue delay and MINDSHIFT GROUP has the obligation to delete the personal data when applied, namely for one of the following reasons:

• Personal data is no longer necessary for the purpose it was collected or processed;

• The data holder doesn’t give its consent for the processing of data (in cases where treatment is based on consent) and there is no other basis for such treatment;

• The data holder opposes to the data treatment and there are no prevailing legitimate interests justifying the data processing.

Right to limit data management

The data holder has the right to obtain from MINDSHIFT GROUP the limitation of data treatment if one of the following reasons applies in particular:

• Challenge the accuracy of personal data for a period that allows MINDSHIFT GROUP to verify its accuracy;

• The processing of data is legal and the data owner opposes the deletion of its personal data and request, in return, the limitation of its use;

• MINDSHIFT GROUP no longer needs the personal data for treatment purposes, but such data is required by the data holder for the purposes of declaration, exercise or defense of a right in a legal process;

• If the data holder opposes data treatment, until the legitimate reasons for the responsibility for the data management prevail over those of the data holder.

Right to data portability

The data holder has the right to receive its personal data provided to MINDSHIFT GROUP when the latter uses automatic means for processing data, in a structured format, current use, and automatic reading. Besides, there is the right to transfer that data to another responsible for information management. In exercising its right to data portability, the data holder has the right to have its personal data transmitted directly between those who are responsible for the data management, whenever it is technically possible.

Right of opposition

The data holder has the right to object to the processing of its personal data when this is performed within the legitimate interest of MINDSHIFT GROUP or third parties for the purposes of direct marketing or profile definition. MINDSHIFT GROUP ceases the processing of personal data in case of opposition unless there are legitimate and convincing reasons that nullify the data holders’ interests, rights, and freedoms, or to substantiate the exercise or defense of legal claims.

The right of not taking individual and automated decisions, including profiling

The bearer of the data has the right of not being subject to a decision based solely on automated processing, including profiles definition, as long as the decision isn’t required for the conclusion or execution of a contract between the data holder and the responsibility for the data management unless consent has been given.

Right to withdraw consent

If consent is legally required for the processing of personal data, the data holder has the right to withdraw consent at any time, despite that right doesn’t compromise the legitimacy of the processing of the data based on the consent previously given, based on another legal basis, such as compliance with the contract or legal obligation to which MINDSHIFT GROUP is obliged.

Right to complain

The data holder has the right to present a complaint to the competent data protection authority. In Portugal, this authority is the National Data Protection Commission (CNPD). More information about CNPD can be found through the website

7. Data protection dispositions on the application and use of Google Analytics
MINDSHIFT GROUP’s internet pages have a Google Analytics component. Google Analytics is an internet analytical service that allows to gather, compile and analyze data on the behavior of the site visitors. An analytical internet service gathers, among other thing, data on the site from which the user was redirected, which subpages were visited or the frequency and duration a subpage was viewed. Internet analytics are mainly used to favor website optimization and to make a cost-benefit analysis for online advertising.
Google Analytics main goal is to analyze website traffic. Google uses the data and information collected, among other things, to evaluate the utilization of our website and provide online reports on its activities and other services, concerning its use on the internet.

8. The legal basis for processing data
The processing of personal data will have to be supported by a legal basis framed by one of the following situations:

• The data holder has given its consent to the processing of its personal data for one or more specific purposes;

• The data processing is required for the execution of a contract in which the data holder takes part or for pre-contractual procedures requested by the data holder;

• The data processing is necessary for the attainment of a legal obligation to which the responsibility for the data management is subject;

• The data processing is necessary to defend the vital interests of the data holder or another singular person;

• The data processing is necessary for the exercise of functions of public interest or for the exercise of the public authority concerning the responsibility for the data management;

• The data processing is required for the legitimate interests pursued by the responsible for the data management or third parties, except where the interests or fundamental rights and freedoms of the person prevail which require the protection of personal data, in particular, if the holder is a child (doesn’t apply to data processing carried out by public authorities in the pursuit of their attributions by electronic means).

9. Dispatch of personal data as a legal or contractual requirement 
The dispatch of personal data is required by law under determined circumstances (for example, tax regulations) or it can result from contractual dispositions (for example, information on the contractual partner). It might be necessary to conclude a contract in which the data holder provides personal data which must be processed afterwards under this scope. The data holder is, for example, obliged to provide personal data while signing a contract with MINDSHIFT GROUP.

Last update on 2nd May 2019