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Guidelines for processing of personal data in connection with recruitment
In connection with recruitment at JN Data, we process your personal data as stated in this policy. The relevant rules currently applicable to our processing of personal data are set out in the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016) and the Danish Data Protection Act (Act no. 502 of 23 May 2018 (Databeskyttelsesloven)). This Privacy Policy concerns our processing of personal data as data controller, but solely in connection with recruitment.1. Who do we process personal data about?JN Data processes data about applicants and potential applicants for vacancies in JN Data.2. What categories of personal data do we process?‘Personal Data’ includes any data that is personally identifiable and concerns a natural person, such as the person’s name, email address, civil registration (CPR) number and address as well as data about the person’s physical, mental, financial, cultural or social circumstances. In connection with recruitment, JN Data processes so-called ordinary, sensitive, and confidential data, including data about criminal offences.3. Where do the data come from?We collect the personal data directly from you or from third parties, such as your former employer.4. How do we process the data?‘Processing’ of personal data covers any activity involving personal data such as collection, registration, systematisation, organisation, storage, adaptation, alteration, search, use or disclosure.5. Why do we process the data?We process data about you, but only to the extent necessary for the following specific purposes:
Application, CV and accompanying appendices:
-The personal data are processed for the purpose of assessing whether the applicant is qualified for the position in question.
Criminal record, photo ID and original exam certificate, diploma etc.:
- The purpose is to assess the candidate’s suitability for the job.
Searches on the internet, including social media:
Video surveillance:
- Video surveillance is used in particularly exposed areas. The purpose is the prevention and solve criminal offences such as vandalism and burglary. Video surveillance is used in the reception area, among other areas. Video surveillance is not installed in the premises where recruitment interviews are conducted.
Job agent:
- If the applicant subscribes to one or more job agents, personal data will be processed for the purpose of sending emails with job postings in the categories selected by the applicant.
Personality tests:
- Personality tests completed during the recruitment process are used as a dialogue tool.
References from previous employers:
- The personal data are processed for the purpose of assessing whether the applicant is a qualified candidate for the position in question.
6. To whom do we disclose your data?We only disclose your personal data to external parties if necessary, and if there is a legal basis for this:
- JN Data uses a data processor if this is a prerequisite for the performance of the purpose. The data processor solely processes personal data in accordance with JN Data’s instructions and therefore must not use the personal data for the data processor’s own purposes, or make use of subprocessors without prior approval from JN Data.
- Personal data will not be disclosed to third parties unless such disclosure is necessary in connection with legal proceedings for criminal offences.
- If the data subject has consented to JN Data obtaining references, the applicant’s information that the data subject has applied for a job with JN Data may be shared with the persons stated as references by the applicant.
7. On what legal basis do we base our processing of your data?We collect and process your personal data based on the following lawfulness of processing (i.e. legal basis):
-The processing of ordinary (non-sensitive) personal data in connection with an application is necessary for the purpose of assessing whether the applicant is a qualified candidate for the position in question. The processing of (non-sensitive) personal data about applicants is therefore carried out based on the lawfulness of processing set out in Article 6(1)(f) of the General Data Protection Regulation.
- If the applicant consents to JN Data storing the application, CV and accompanying appendices so that the applicant may be considered for any future positions of relevance to the applicant’s profile, the lawfulness of processing is set out in Article 6(1)(a) of the General Data Protection Regulation.
- If JN Data chooses to employ the candidate in question, we process personal data about the candidate to the extent necessary prior to the conclusion and performance of a contract in accordance with Article 6(1)(b) of the General Data Protection Regulation.
- As a general rule, JN Data does not collect special (sensitive) personal data about applicants. However, it cannot be ruled out that an application or CV received from an applicant contains special (sensitive) personal data. In such case, the data are processed in accordance with Article 9(2)(f) of the General Data Protection Regulation.
- To the extent that the application contains the applicant’s civil registration (CPR) number, this is processed in accordance with section 11(2), para (3), of the Danish Data Protection Act.
- The processing of (non-sensitive) personal data is necessary for JN Data to pursue a legitimate interest, see Article 6(1)(f) of the General Data Protection Regulation. The legitimate interest is our assessment of the applicant’s suitability for the job.
- Data about criminal offences are processed for the purpose of safeguarding a legitimate interest, see Section 8(3), second sentence, of the Danish Data Protection Act and Article 10 of the General Data Protection Regulation. The legitimate interest is the consideration for security which presupposes an assessment of the applicant’s suitability for the job.
- The processing of data on the applicant’s civil registration (CPR) number is carried out with lawfulness of processing in accordance with section 11(2), para (3), of the Danish Data Protection Act.Searches on the internet, including social media:
- The processing of (non-sensitive) personal data is necessary for JN Data to pursue a legitimate interest, see Article 6(1)(f) of the General Data Protection Regulation. JN Data has a legitimate interest when preparing for recruitment interviews.
- Special (sensitive) personal data will only be processed if the data have been manifestly made public by the applicant, see Article 9(2)(e) of the General Data Protection Regulation.
- The processing is necessary for JN Data to pursue a legitimate interest, see Article 6(1)(f) of the General Data Protection Regulation. The legitimate interest is security considerations, including prevention and clearing up of vandalism and burglary.
-Data about criminal offences are processed for the purpose of pursuing a legitimate interest, see section 8(3) of the Danish Data Protection Act and Article 10 of the General Data Protection Regulation. The legitimate interest is security considerations, including solving vandalism and burglary.
- The applicant consents to JN Data’s processing of data, including storage and establishment of contact in accordance with Article 6(1)(a) of the General Data Protection Regulation.
- JN Data processes (non-sensitive) personal data from personality tests completed by the applicant in accordance with Article 6(1)(f) of the General Data Protection Regulation, as the data are of relevance to the recruitment decision.
- The applicant consents to JN Data contacting one or more specific persons for the purpose of obtaining references and to process the applicant’s personal data in this connection in accordance with section 12(3) of the Danish Data Protection Act.
8. When do we erase your data?We erase your data registered with us when they are no longer necessary for the purpose(s) for which they were collected and processed:
- If you are not offered a position, we will store your application and any additional personal data collected in connection with the recruitment process for a maximum period of 12 months after our rejection of your application.
- If you are called in for an interview, you will be requested to present your criminal record, photo ID as well as original exam certificate, diploma etc. We will record having seen these data, but the documents will not be stored.
- Video surveillance tapes are erased after 180 days. Recordings may be kept for a longer period if they are to be used in a specific legal dispute. In this case, the person involved in the dispute will be notified.
- The data will be stored in accordance with the time period set by you (one week, one month, three months or one year).
- If you are not offered a position, we will store your application and any additional personal data collected in connection with the recruitment process for a maximum period of 12 months after our rejection of your application.References from previous employers:- If you are not offered a position, we will store your application and any additional personal data collected in connection with the recruitment process for a maximum period of 12 months after our rejection of your application.
9. What rights do you have?- You have a right of access to the data we process about you as well as to a number of other data.
- You have the right to have inaccurate data about you rectified.
- In special cases, you have the right to have data about you erased before our normal general erasure of data.
- In certain cases, you have the right to have the processing of your personal data restricted.
- In certain cases, you have the right to object to our otherwise lawful processing of your personal data.
- In certain cases, you have the right to receive a copy of your personal data or to have personal data transmitted directly from JN Data to another data controller.
- If our processing of your personal data is based on your consent, you have the right to withdraw your consent at any given time. You can do so by contacting us using the contact details provided below. If you choose to withdraw your consent, this will not affect the lawfulness of our processing of your personal data based on your previously granted consent and up to the time of your withdrawal thereof. If you withdraw your consent, it will therefore only have effect on the processing from the time of your withdrawal.
- You can read more about your rights in the Danish Data Protection Agency’s guidance on the rights of data subjects, which you find at www.datatilsynet.dk.
- If you wish to exercise any of these rights, have any questions or wish to complain about the processing of your personal data, please feel free to contact gdpr@jndata.dk.
10. Right to lodge a complaintYou can lodge a complaint with the Danish Data Protection Agency at the address: Datatilsynet, Carl Jacobsens Vej 35, DK-2500 Valby, about our processing of your personal data. See more at www.datatilsynet.dk.
