Privacy Notice

This notice together with the terms of use at sets out the basis on which any personal data that is collected from you, or provided by you, will be processed by Create Action OÜ. Please read the following carefully to understand the views and practices regarding your personal data and how we treat it.

Create Action OÜ takes the privacy of your information very seriously. This Privacy Notice is designed to tell you about our practices regarding the collection, use and disclosure of personal information which may be collected in person from you, obtained via our websites or collected through other means such as by an online form, email, or telephone communication.

This notice applies to personal information provided by our clients and suppliers about their employees and other individuals affiliated with them and also to candidates or prospective candidates (“Candidates”) whose data we process for proposed roles with our clients or prospective clients. Where a given role with our client is to be filled by a limited company or other corporate contractor we may process data relating to that company’s directors or shareholders and in this policy a “Candidate” may include directors and shareholders of corporate contractors.

In this notice “you” refers to any individual whose personal data we hold or process (i.e: an individual candidate or potential candidate, an individual affiliated with a corporate contractor candidate, or an individual or employee associated or affiliated with our client or supplier.

Who Create Action are and what we do

Create Action a consultancy, recruitment agency and recruitment business. In summary, personal data is collected of the following types of persons to allow us to undertake our business;

  • Prospective and hired candidates for internal roles;
  • Prospective and placed candidates for temporary roles;
  • Prospective and placed candidates for permanent roles;
  • Prospective and live client contacts;
  • Supplier contacts to support their services;
  • Employees, consultants, temporary workers;

In general, our services are related to the provision of recruitment services to clients and we do not process personal data on a large scale, but we will hold certain data in relation to Candidates and individuals affiliated with our clients and suppliers, and this notice sets out the basis on which we hold that data.

This notice is governed by the EU General Data Protection Regulation (the “GDPR”) from 25 May 2018.

Legal Basis on which we process personal data

As a recruitment business and recruitment agency we introduce candidates to clients for temporary worker placements, permanent worker placements or independent professional contracts.  The exchange of personal data of our candidates and our client contacts is a fundamental, essential part of this process.

In order to support our candidates’ career and our clients’ resourcing needs we require a database of candidate and client personal data containing historical information as well as current resourcing requirements.

To maintain, expand and develop Create Action’s business we need to record the personal data of prospective candidates and client contacts.

Create Action collects information about you to carry out our core business and ancillary activities.​

Personal data we hold about you will be processed either because:

  • the processing is necessary in order for us to comply with our obligations under a contract between you and us, specifically for the provision of our services; or
  • the processing is necessary in pursuit of a “legitimate interest”, a legitimate interest in this context means a valid interest we have or a third party has in processing your personal data which is not overridden by your interests in data privacy and security
  • for certain ‘special categories’ of sensitive personal data including data relating to health and ethnic background which we may process from time to time we will process this data on the basis of your consent.
Personal data we collect​
  • We may collect and process the following personal data (information that can be uniquely identified with you) about you:
  • for individuals associated with our clients we may hold contact information such as names, email addresses, phone numbers, addresses, and job titles and/or specific roles within your organisation (“Client Contact Information”);
  • for individuals associated with our suppliers and other third parties we interact with we may hold contact information such as names, email addresses, phone numbers, addresses, and job titles and/or specific roles within your organisation. (“Third Party Contact Information”);
  • for Candidates we may have personal information about you, your background, work history etc. This information may include name, address, telephone number, email address, CV, work history, educational qualifications (“Candidate Information”);
  • a record of any correspondence or communication between you and us (“Communication Information”);
  • marketing information we may hold about you in order to provide information about our services this may include names, email addresses, phone numbers, addresses, and job titles and/or specific roles within your organisation (“Marketing Information”).
  • We will collect information either from you directly or from a third party (for instance your employer or an introducer). If we do obtain your personal data from a third party your privacy rights under this notice are not affected and you are still able to exercise the rights contained within this notice.
  • Although you do not have to supply any personal information to us in practice we may be unable to provide our services to you without personal data (for instance we will need contact information in order to communicate with you). You may withdraw our authority to process your personal data (or request that we restrict our processing) at any time but there are circumstances in which we may need to continue to process personal data.
Where we collect your information​
  • We typically collect personal information when you fill in forms, upload your CV on our site or via forms and when you correspond with us by phone, email or otherwise.
  • We may also collect personal information about you through other sources such as LinkedIn, Xing and other social media, job board websites, online CV libraries, recommendations and referrals, hiring platforms and through the use of business development tools.
Create Action will use this information​
  • Administering our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to allow you to participate in interactive features of our service, when you choose to do so;
  • as part of our efforts to keep the site safe and secure;
  • to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
  • to make suggestions and recommendations to you and other users of the site about goods or services that may interest you or them.
Automated Decision Making

Create Action do not undertake automated decision making or profiling. Create Action do use computer systems to search and identify personal data in accordance with parameters set by a person. A person will always be involved in the decision-making process.

Data Retention

We understand our legal duty to retain accurate data and only retain personal data for as long as we need it for our legitimate business interests and that you are happy for us to do so.

The duration for which we retain your personal  information will differ depending on the type of information and the reason we collected it from you.

Unless otherwise specified by applicable law, the required retention period for any personal data will be deemed to be 7 years from the date of receipt by us of that data.

The retention periods stated in this notice can be prolonged or shortened as may be required (for example, in the event that legal proceedings apply to the data or if there is an on-going investigation into the data).

We review the personal data (and the categories of personal data) we are holding on a regular basis to ensure the data we are holding is still relevant to our business and is accurate. If we discover that certain data we are holding is no longer necessary or accurate, we will take reasonable steps to correct or delete this data as may be required.

Sharing your information

We do not disclose any information you provide to any third parties other than as follows:

  • We will disclose Candidate Data to our clients or potential clients and our clients will be the data controller for that Candidate Data;
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation (for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime);
  • In order to enforce any terms and conditions or agreements for our services that may apply;
  • If we are sub-contracting services to a third party we may provide information to that third party in order to provide the relevant services;
  • We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, but we will take steps with the aim of ensuring that your privacy rights continue to be protected;
  • To protect our rights, property and safety, or the rights, property and safety of our users or any other third parties. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
  • Other than as set out above, we shall not disclose any of your personal information unless you give us permission to do so. If we do supply your personal information to a third party we will take steps to ensure that your privacy rights are protected and that third party complies with the terms of this notice.

We will take all reasonable steps to ensure that appropriate technical and organisational measures are carried out in order to safeguard the information we collect from you and protect against unlawful access and accidental loss or damage.

The data that Create Action collect from you may be transferred to, and stored at, a destination outside the European Economic Area (”EEA”). It may be transferred to third parties outside of the EEA for the purpose of their recruitment services. By submitting your personal data, you agree to this transfer, storing or processing. Create Action will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of the site, you are responsible for keeping this password confidential. Create Action ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although Create Action will do their best to protect your personal data, they cannot guarantee the security of your data transmitted to the site; any transmission is at your own risk. Once Create Action have received your information, they will use strict procedures and security features to try to prevent unauthorised access.


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Your privacy rights

The GDPR gives you the following rights in respect of personal data we hold about you:

  • The right to be informed: You have a right to know about our personal data protection and data processing activities, details of which are contained in this notice.
  • The right of access: You can make what is known as a Subject Access Request (“SAR”) to request information about the personal data we hold about you (free of charge, save for reasonable expenses for repeat requests). If you wish to make a SAR please contact us as described below.
  • The right to correction: Please inform us should information we hold about you be incomplete or inaccurate in any way and we will update our records as soon as possible, but in any event within one month.
  • We will take reasonable steps to communicate the change to any third parties to whom we have passed the same information.
  • The right to erasure (the ‘right to be forgotten’): Please notify us if you no longer wish us to hold personal data about you (although in practice it is not possible to provide our services without holding your personal data and we may need to keep your data in some circumstances). Unless we have reasonable grounds to refuse the erasure, on receipt of such a request we will securely delete the personal data in question within one month. The data may continue to exist in certain backup, but we will take steps to ensure that it will not be accessible. We will communicate the erasure to any third parties to whom we have passed the same information.
  • The right to restrict processing: You can request that we no longer process your personal data in certain ways, whilst not requiring us to delete the same data. However again, some of our Services will not be available if processing is restricted.

All SARs and other requests or notifications in respect of your above rights must be submitted to

We will endeavour to comply with such requests as soon as possible but in any event we will comply within one month of receipt (unless a longer period of time to respond is reasonable by virtue of the complexity or number of your requests).

​Changes to this privacy notice​

Any changes Create Action makes to this privacy notice in the future will be posted on this page and, where appropriate, notified to you by email.

Contact us​

If at any time you would like to contact us with your views about our privacy practices, or with any enquiry or complaint relating to your personal information or how it is handled, you can do so via

If we are unable to resolve any issues you may have or you would like to make a further complaint, you can contact the Information Commissioner’s Office for further assistance.

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