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Processing of personal data in connection with

Recruitment

Task
Application, CV, and associated attachments
TYPES OF PERSONAL DATA

Applicants:

  • Personal data (non-sensitive), including but not limited to name, contact details, date of birth, education, information about previous employers, experience, and references.
  • Special categories of personal data (sensitive data), should the applicant exceptionally provide such information to us.
  • Confidential personal data, should the applicant exceptionally provide such information to us.

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PURPOSE

The personal data is processed for the purpose of assessing whether the applicant is a qualified candidate for the position in question.

The application, CV, and related attachments are stored so that the applicant may be considered for any future positions relevant to their profile.

If the applicant is hired, the application, CV, and related attachments are stored to document the history of the employment relationship.

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LEGAL BASIS

We rely on Article 6(1)(f) of the GDPR to process non-sensitive personal data in connection with an application, as we have a legitimate interest in assessing whether the applicant is a qualified candidate for the position in question.

If you are not offered a position but wish for us to keep your application, CV, and related attachments for the purpose of potentially offering you a future vacancy, we will process your personal data based on your consent, pursuant to Article 6(1)(a) of the GDPR.

If you are hired by the company, we process your personal data to the extent necessary prior to entering into the employment contract, pursuant to Article 6(1)(b) of the GDPR.

As a general rule, we do not collect special categories of personal data (sensitive data) about applicants. However, it cannot be ruled out that an application or CV received from an applicant may contain such data. In such cases, the information is processed in accordance with Article 9(2)(f) of the GDPR.

In the event that an application exceptionally contains a civil registration number (CPR number), this is processed in accordance with Section 11(2)(3) of the Danish Data Protection Act.

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RETENTION PERIOD

Applications and attachments are deleted six months after receipt if the applicant is not hired by the company.

If the applicant is hired, the application and attachments will be deleted no later than five years after the termination of employment.

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RECIPIENTS

We do not disclose your personal data to external parties unless it is necessary and there is a legal basis for doing so. This may include public authorities, private companies or individuals, foundations, associations, etc., depending on the nature of the matter.

We entrust information to our data processors (e.g., IT providers).

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Task

Criminal record certificate

TYPES OF PERSONAL DATA

Applicants:

  • Non-sensitive personal data, including name, contact information, and date of birth.
  • Confidential personal data, including information regarding criminal offenses and civil registration numbers (CPR numbers).

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PURPOSE

The purpose of the processing is to assess the applicant's suitability for the position.

Applicants will only be asked to provide a criminal record certificate if they are offered employment.

Furthermore, the purpose of the processing is to fulfill our obligations under the Anti-Money Laundering Act to screen employees prior to hiring, in order to prevent employees from abusing their position for money laundering, terrorist financing, or complicity therein.

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LEGAL BASIS

We process non-sensitive personal data pursuant to Article 6(1)(f) of the GDPR, based on our legitimate interest in assessing the applicant's suitability for the position.

We process information regarding criminal offenses pursuant to Section 8(3), second sentence, of the Data Protection Act, cf. Article 10 of the GDPR, for the purpose of pursuing a legitimate interest in assessing the applicant's suitability for the job.

Personal data processed in connection with the screening of the applicant prior to employment is done pursuant to Article 6(1)(c) of the GDPR and Section 8 of the Anti-Money Laundering Act.

The applicant's civil registration number (CPR number) is processed pursuant to Section 11(2)(3) of the Data Protection Act.

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RETENTION PERIOD

The criminal record certificate is deleted no later than three months after receipt.

If we receive a physical criminal record certificate, it is shredded after the information has been registered in the employee's master database.

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RECIPIENTS

We do not disclose your personal data to external parties unless it is necessary and there is a legal basis for doing so. This may include public authorities, private companies or individuals, foundations, associations, etc., depending on the nature of the case.

We entrust information to our data processors (e.g., IT suppliers).

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Task

Internet searches, including social media

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TYPES OF PERSONAL DATA

Applicants:

  • Personal data (non-sensitive).
  • Confidential personal data, including information regarding criminal offenses
  • Special categories of personal data (sensitive).

As this concerns information accessed through internet searches, it is not possible to provide an exhaustive list of the types of personal data.

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PURPOSE

Personal data is processed for the purpose of assessing whether the applicant is a qualified candidate for the position in question.

Special categories of personal data (sensitive data) are processed to a limited extent, and only if the applicant has clearly made the information public themselves.

Social media searches are not part of the standard recruitment process, and information is only collected to the extent that it is deemed relevant to the recruitment process.

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LEGAL BASIS

We rely on Article 6(1)(f) of the GDPR for the processing of personal data (non-sensitive), and the legitimate interest we pursue is to prepare for job interviews.

Special categories of personal data (sensitive data) are only processed when the information has clearly been made public by the applicant, pursuant to Article 9(2)(e) of the GDPR.

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RETENTION PERIOD

Personal data will be deleted no later than one month after the recruitment process has concluded.

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RECIPIENTS

We do not disclose your personal data to external parties unless it is necessary and there is a legal basis for doing so. This may include public authorities, private companies or individuals, foundations, associations, etc., depending on the nature of the case.

We entrust information to our data processors (e.g., IT suppliers).

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Task

Job agent

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TYPES OF PERSONAL DATA

Applicants:

  • Personal data (non-sensitive), including, among other things, email address, name, and information about selected categories/areas of interest.

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PURPOSE

If the applicant subscribes to job alerts, personal data is processed for the purpose of sending emails with job postings within the categories selected by the applicant.

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LEGAL BASIS

If the applicant subscribes to job alerts, we process personal data based on consent, cf. Article 6(1)(a) of the General Data Protection Regulation.

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STORAGE PERIOD

Personal data is processed until the applicant actively unsubscribes from the service.

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RECIPIENTS

We do not disclose your personal data to external parties unless it is necessary and there is a legal basis for doing so. This may include public authorities, private companies or individuals, foundations, associations, etc., depending on the nature of the case.

We entrust information to our data processors (e.g., IT suppliers).

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Task

Personality tests

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TYPES OF PERSONAL DATA

Applicants:

  • Personal data (non-sensitive): results from personality tests.

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PURPOSE

Personality tests taken in connection with the recruitment process are used as a dialogue tool during the recruitment process.

Personality tests are offered to the extent that the test results may be relevant to discuss in relation to the position in question.

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LEGAL BASIS

We use Article 6(1)(f) of the GDPR for the processing of personal data (non-sensitive), and the legitimate interest we pursue is to use the results in connection with the recruitment decision.

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RETENTION PERIOD

Personality tests taken during the recruitment process are deleted six months after the test is completed.

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RECIPIENTS

We do not disclose your personal data to external parties unless it is necessary and there is a legal basis for doing so. This may include public authorities, private companies or individuals, foundations, associations, etc., depending on the nature of the matter.

We entrust information to our data processors (e.g., IT providers).

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Task

References from previous employers

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CATEGORIES OF PERSONAL DATA

Applicants:

  • Personal data (non-sensitive): reference information about the applicant.

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PURPOSE

The applicant's personal data is processed for the purpose of assessing whether the applicant is a qualified candidate for the position in question.

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LEGAL BASIS

We process reference information about the applicant pursuant to Section 12(3) of the Data Protection Act, provided the applicant consents to us contacting one or more specific individuals for the purpose of obtaining references in connection with the recruitment process.

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RETENTION PERIOD

Information regarding applicants who are not offered a position will be deleted no later than six months after the recruitment process has concluded.

If the applicant is hired, the information will be deleted no later than five years after the termination of the employment relationship.

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RECIPIENTS

We do not disclose your personal data to external parties unless it is necessary and there is a legal basis for doing so. This may include public authorities, private companies or individuals, foundations, associations, etc., depending on the nature of the matter.

We share information with our data processors (e.g., IT providers).

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  • CLM Advokater
    Advokatanpartsselskab
    CVR no.:
    45 44 90 33
  • Contact
  • P:
    +45 44 22 59 00
  • M:
    mail@clmadvokater.dk
  • Esbjerg
    A:
    Bavnehøjvej 5, 6700 Esbjerg
  • Copenhagen
    A:
    Nyhavn 16, 3. th., 1051 København K
  • Legal
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