The policy applies to all personal data processed in RJ & Partners as part of its business.
- RJ & Partners. The administrator of personal data
RJ & Partners is the administrator of personal data of clients, clients' contact persons as well as personal data of other people provided by clients (hereinafter also referred to as "the Administrator"), if it is necessary to performing the legal service.
In addition, RJ & Partners is the administrator of personal data of its employees, permanent associates (on the basis of a civil law contract), apprentices, trainees, people cooperating with it sporadically (e.g. notaries, other legal counsels, attorneys), suppliers of goods and services, as well as people who are interested in applying for a job at the RJ & Partners, who submit their recruitment documents (i.e. CVs and cover letters) to the announced recruitment process spontaneously.
Contact with the administrator is possible both via the e-mail address: firstname.lastname@example.org, and the mailing address Robert Jędrzejczyk i Wspólnicy s.k. ul. Moniuszki 1A, 00-018 Warszawa with the inscription "Personal data".
- Goals and basics of personal data processing
RJ & Partners processes personal data for the following purposes:
- providing legal services (e.g. legal advice, legal opinions, representation in court and outside the court, participation in negotiations, preparation of legal analyses for enterprises),
- fulfilling the legal obligation of the Administrator (e.g. handling employees / co-workers of RJ & Partners),
- arising from legally justified interests carried out by the Administrator or a third party, except for situations in which the interests or fundamental rights and freedoms of the data subject, requiring the protection of personal data, prevail over those interests, in particular when the data subject is a child (e.g. keeping correspondence addressed to the Administrator in connection with conducted business activity, processing of personal data to prevent fraudsters, ensuring network and information security, pursuing claims, networking in connection with the business),
- determination, investigation or defence of claims or in the administration of justice by the courts in both court and administrative proceedings as well as other out-of-court proceedings.
The legal basis for the processing of personal data by RJ & Partners is as follows:
- processing based on the consent of the data subjects when RJ & Partners receives recruitment documents (i.e. CV, cover letter) containing data exceeding the scope indicated in art. 221 of the Labour Code (i.e. name and surname, parents' names, date of birth, place of residence, education, course of previous employment), or for the needs of future recruitment processes (Article 6 (1) (a) of the GDPR),
- the processing is necessary for the performance of the contract to which the data subject is a party, or to take action at the request of the data subject, before concluding the contract (Article 6 (1) (b) of the GDPR),
- processing is necessary to fulfill the legal obligation imposed on the administrator (Article 6 (1) (c) of the GDPR),
- processing is necessary for purposes arising from legitimate interests pursued by the administrator (Article 6 (1) (f) of the GDPR),
- processing is necessary for the establishment, investigation or defense of claims or for the administration of justice by the courts (Article 9 (2) (f) of the GDPR).
RJ & Partners does not make any decisions in an automated manner, including not employing profiling.
- Rights of data subjects
o General rules
As a rule, persons whose data is processed by RJ & Partners have the following rights:
- the right to access data (including obtaining copies of data subject to processing),
- the right to rectify or supplement data,
- the right to delete data (‘the right to be forgotten’),
- the right to limit processing,
- the right to object,
- the right to transfer data, if technically possible,
- the right to lodge a complaint to the supervisory body competent to process personal data (i.e. to the President of the Office for Personal Data Protection).
To the extent that personal data is processed on the basis of consent (e.g. data provided in recruitment documents by persons interested in working for RJ & Partners (i.e. CV, cover letter) in scope exceeding the scope specified in Article 221 of the Labour Code (i.e. name and surname, names of parents, date of birth, place of residence, education, course of previous employment), the data subject has the right to withdraw consent at any time.
Withdrawal of consent does not affect the lawfulness of the processing that was made on the basis of consent before its withdrawal. Consent can always be withdrawn by sending a statement to the above e-mail address or mailing address.
- Rights of persons and provision of legal assistance
The GDPR allows for the possibility of restricting the application of certain rights indicated in point 3.1 for the purpose of protection of professional secrecy or prevention of a violations of ethics.
RJ & Partnersis excluded from certain obligations provided for in the GDPR, because it processes personal data in connection with the provision of legal assistance, i.e. personal data of clients, persons representing clients being legal entities or so-called flawed legal entities, including contact persons, and other natural persons whose data are processed in connection with the conduct of clients' matters. Thus, RJ & Partners is exempt from making requests in the field of, e.g. access rights; the right to rectify or supplement data if the specific provisions provide for a separate procedure for rectification; the right to delete data at the request of the data subject; the right to limit processing, the right to oppose.
- Rights of persons and the functioning of the firm
The processing of personal data in connection with the functioning of RJ & Partners (i.e. personal data of employees, co-workers, suppliers of goods and services) is not subject to the restrictions set out in section 3.2.
RJ & Partners, if it has reasonable doubts about the identity of a natural person who reports any of the aforesaid requests, may request from them additional information necessary to confirm their identity.
In any case, RJ & Partners will inform the person who submitted the request to settle their request, including the reasons for a possible refusal to comply, i.e. for RJ & Partners to be exempt from the obligation to exercise the right of access in the field of personal data processed in the profession.
- Recipients of data
RJ & Partners entrusts the processing of personal data only to entities that provide sufficient guarantees to implement appropriate technical and organizational measures to ensure that the processing meets the requirements of the GDPR and protects the rights of the data subjects. Such entities include: entities providing HR and accounting services as well as outsourcing of IT support services of the RJ & Partners, entities providing medical services for employees/co-workers of RJ & Partners, entities providing courier services, translators, notaries, and lawyers and lawyers cooperating with the RJ & Partners. Such entities process personal data on the basis of an agreement with RJ & Partners and only in accordance with its instructions.
RJ & Partners does not transfer personal data outside the European Economic Area, unless required by the legal service. In that case, RJ & Partners provides an appropriate method of data protection for natural persons in accordance with Chapter V of the GDPR.
- Voluntary data provision
Providing data to RJ & Partners is voluntary, however failure to do so makes it impossible to provide a legal service or take part in the recruitment process.
- Data retention period
RJ & Partners stores personal data for a period justified by the provision of a legal service or for a period resulting from legal provisions. Personal data of persons interested in working for RJ & Partners are kept for a period of 2 years. The data processing period may be longer as long as it is necessary to establish or enforce claims or defend against claims, and after this period - only in the case and to the extent that it will be required by law.