PRIVACY POLICY IN CONNECTION WITH RECRUITMENT

1. PROTECTION OF YOUR PRIVACY

We take processing of your personal data very seriously. We ensure a reasonable and transparent processing in accordance with the current rules on processing of personal data.

This Privacy Policy describes how Bekey A/S processes personal data on job candidates in connection with unsolicited applications, applications via our web portal and in connection with recruitment, including through recruitment agencies.

The Privacy Policy also describes how data on reference persons are processed.

We request that job candidates do not send special categories of personal data in connection with recruitment, including data on health.

2. DATA PROTECTION RESPONSIBILITY AND CONTACT DETAILS

FK Distribution A/S is responsible for recruitment on behalf of Bekey A/S.

Bekey A/S is controller in relation to the personal data received and registered on the job candidate in connection with applications and recruitments.

Bekey A/S’ contact details are:

BEKEY A/S

CVR no. 27 50 79 80

Customer address:

Gladsaxe Møllevej 28

2860 Søborg

Telephone: +45 43 43 99 90

 If you have any questions concerning the processing of your personal data, you are welcome to contact us.

3. WE PROCESS THE FOLLOWING PERSONAL DATA ABOUT YOU

We process the following so-called general data on you which we have received from you, your reference persons or retrieved via social media such as LinkedIn or other relevant Internet searches:

  • Name, address, email, telephone number, position
  • Data on qualifications and competencies, i.e. education, diplomas, seminars, certifications, professional experience, language skills, etc.
  • Photo (if provided by the job candidate)
  • Reference persons and contact details (name, telephone number and email)
  • Videos recorded by the job candidate
  • Publicly available information on social media, including LinkedIn (this information is noted and not stored)
  • Evaluation notes and notes from interviews taken by the company’s participants in the recruitment procedure (manager and HR staff), including information on salary/expectations
  • Tests – proficiency test and personality test
  • Any notes from conversations with reference persons (who will only be contacted based on the job candidate’s consent).
  • Any information from recruitment agencies based on the job candidate’s consent

4. PURPOSE AND LEGAL BASIS

4.1 Purpose

The purpose of our processing of your personal data is to recruit staff to Bekey A/S.

We will only process your personal data to the extent necessary to meet the purposes for which they are processed.

If it is considered legitimate in relation to the position you are applying for, and you have given your consent, we will request a copy of your criminal records. We will not store your criminal records, but only note whether your criminal records are satisfactory in relation to the position in question.

4.2 Legal basis

We must inform you of the legal basis of our processing of your data. The legal basis is as follows:

  • Article 6 (1)(b) of the General Data Protection Regulation concerning necessary processing for the purpose of conclusion of an agreement with the data subject or to comply with an agreement with the data subject.
  • Article 6 (1)(a) of the General Data Protection Regulation concerning consent as regards tests and criminal records (presentation).
  • Article 6 (1)(f) of the General Data Protection Regulation concerning legitimate interest, where FK Distribution A/S’ legitimate interest is to fill vacant positions with qualified applicants.

5. RECIPIENTS OR CATEGORIES OF RECIPIENTS

We will not disclose your personal data to a third party in connection with a recruitment procedure without your consent.

If we receive your consent, we may disclose your data

  • in connection with obtaining of references and
  • to named group companies for the purposes of a recruitment procedure in the company in question.

In connection with the recruitment procedure, we use the following processors:

  • Email providers, recruitment systems, test systems and recruitment agencies (the last-mentioned are often independent controllers).

6. REFERENCE PERSONS

We will process contact details on reference persons if you have stated these in connection with your application, or if you give us specific consent to contact the reference persons. The data will not be disclosed and will be processed by the processors mentioned above only to the relevant extent. The data will be deleted at the same date as the application.

7. DELETION

Personal data on job applicants who have received a rejection will be deleted as soon as possible and no later than six months after the rejection. This includes the actual application, all physical and electronic copies of CVs and other documents/photos received in connection with the application and internal emails, notes, etc. together with test results.

Personal data on a job candidate who is employed, including CV, diploma, etc., will be stored as long as these documents are relevant to the employment which is generally in the entire term of the employment and five years after the effective date of termination.

8. YOUR RIGHTS

8.1 Contact details if you wish to exercise your rights

If you wish to exercise the below rights, please contact us using the contact details listed above.

  • Right of access: You are entitled to have access to the personal data processed on you and a number of additional data. However, the right of access may not adversely affect the rights and freedoms of others.
  • Right to rectification: You are entitled to have incorrect personal data rectified.
  • Right to erasure: In special situations, you are entitled to have personal data erased before our general deletion takes place.
  • Right to restriction of processing: In certain situations, you are entitled to have your personal data restricted. If you are entitled to restriction of processing, we may only process your personal data – except for storage – with your consent, for the purpose of establishing, exercising or defending a legal claim or to protect a person or important public interests.
  • Right to data portability: You are entitled to data portability if our processing of your personal data is based on your consent or an agreement, and the processing takes place automatically. This right implies that you are entitled to have your personal data forwarded in a structured, commonly used and machine-readable format, which you are entitled to transfer to another data controller.
  • Right to object: In certain situations, you are entitled to object to our legal processing of your personal data. You may also object to processing of your personal data for direct marketing purposes.
  • Right to withdraw your consent: If our processing is based on your consent, you are entitled to withdraw your consent wholly or partly. The withdrawal of your consent will not affect the lawfulness of the processing made by Bekey A/S until your consent is withdrawn. Withdrawal of your consent will thus only be valid from that point in time.

For more information on your rights, see the Danish Data Protection Agency’s guidelines describing the data subject’s rights on www.datatilsynet.dk.

9. COMPLAINTS

If you wish to complain about our processing of your personal data, you may complain to the Danish Data Protection Agency, which has the following contact details:

The Danish Data Protection Agency

Address: Borgergade 28, 5., DK-1300 Copenhagen K

E-mail: dt@datatilsynet.dk

Telephone no.: +45 33 19 32 00

Website: www.datatilsynet.dk

Updated May 2018. This document will be updated on a regular basis.

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