1. Introduction
In this privacy policy, you can learn more about how the Paper Bottle Company A/S ("PaBoCo", "we", "us", "our") processes your personal data as part of the recruitment process.We provide you with this information as we are required to do so under the General Data Protection Regulation (the "GDPR").
2. Controller
PaBoCo acts as a data controller for the processing of your personal data in connection with the recruitment process.
You can find our contact details [see section 10] below.
3. Description of the processing
Below, you will find the specific purposes for our data processing, the categories of personal data that we process, and the legal basis for such processing.
Receipt of applications etc. and conducting interviews
When we receive your application, we will read it and select the persons who we will call for an interview. The selection is based on your qualifications in relation to the specific position(s). You will be called for the interview by email or telephone.
As part of the recruitment process, we will receive and process the personal data that you have included in your application, CV and any other material that you may have forwarded along with your application. We may also ask you to send us additional information. The information obtained in this connection will include information about your previous employments, including information related to work assignments, skills, performance and interpersonal skills. We will also obtain other information about you if we consider such information to be necessary for the assessment of your application.
Article 6(1)(f) of the GDPR as we pursue the legitimate interest in the processing of the personal data being necessary for our assessment of you as a person and your skills in relation to the contents of the position.
Review of social media
If relevant, we will obtain available information published by you on social media, such as LinkedIn and Facebook.
Article 6(1)(f) of the GDPR as we pursue the legitimate interest in the processing of the personal data being necessary for our assessmentof you as a person in relation to the contents of the position.
Processing references
If we wish to obtain information about you from your current or former employer using your references, we will first ask for your approval. Unless you are otherwise specifically notified by us, the information we obtain in that connection will include information about your previous employments, including information relating to work assignments, skills and performance.
Article 6(1)(f) of the GDPR as we pursue the legitimate interest in the processing of the personal data being necessary for our assessment of your qualifications to perform a specific job function.
Use of personality tests and competency tests
During the recruitment process relating to some positions, we may use a personality test and/or a competency test. Typically, the tests are taken after our first interview with you. The purpose of the tests is to identify your personal preferences and skills, forming a basis for a dialogue with you about your personal resources and conduct. The tests will be part of the overall basis for selecting the right candidate for the position.
Article 6(1)(f) of the GDPR as we pursue the legitimate interest in the processing of the personal data being necessary for our assessment of your personal skills based on the tests.
Review of criminal records
During the recruitment process, we may ask you to show your criminal record certificate. Whether a criminal record certificate is required depends on the position, including the responsibilities and powers involved. If we consider it to be relevant to the position for which you have applied, we will ask you to request a personal criminal record certificate.
No processing of personal data takes place, as you will in any case only be asked to show us a physical copy of the criminal record certificate (and you are thus not asked to send us a copy via email or otherwise provide us with a copy for us to keep).
Job interviews
If you progress in the recruitment process, we will conduct interviews where we will focus on your professional and personal skills as well as the challenges etc. of the job. We will write down some of the information disclosed during the interview(s). We only use the relevant information in the assessment of whether you should be offered a position.
Article 6(1)(f) of the GDPR as we pursue the legitimate interest in the processing of the personal data being necessary for our assessment of your personal skills.
Drafting of employment agreement
If we offer you a position, we will process the personal data necessary for staff administration purposes. In that case, you will receive further information on this.
The legal basis for processing the general personal data stated in the application documents may also be 6(1)(b) of the GDPR as it may be necessary to process the personal data in question for the purpose of drafting an employment agreement, if relevant.
4. Categories of recipients
Certain personal data will be made available to our data processors, e.g. providers of technical assistance with regard to our IT systems, email systems and HR systems, etc. We also make certain personal data available to our advisors, e.g. HR advisors.
5. Transfer to third countries
We use Microsoft Outlook for our email services. Thus, when you contact us via email, personal data is transferred to recipients located in so-called third countries (countries outside the EU and EEA), including the United States. Unless the country in question has been approved by the European Commission as having sufficient level of protection (including companies located in the US that are covered by the EU-US Data Privacy Framework (e.g. Microsoft USA)), the basis for the transfer is the European Commission's Standard Contractual Clauses.
You can find a list over Microsoft's sub-processors here.
If you want additional information about our transfer of personal data to third countries, including a copy of the above-mentioned standard contractual clauses, you may make a request for such additional information by contacting us (see section 9 below).
6. Storage of your personal data
We are required to only store your personal data for the period necessary for us to fulfil the purposes for which they were collected. For that reason, we have established the time limits for erasure set out below. As a general rule, we erase or anonymise your personal data according to the time limits stated below unless it is necessary that we continue to store them, e.g. for the purpose of particular cases or the like.
If your application is rejected, we will generally delete the information that we have processed about you during the recruitment process when it is completed. This will typically coincide with the time when we enter into an employment agreement with the selected candidate and generally no more than 3 months after the date when you were informed of the rejection.
If we employ you, the personal data that we have processed during the recruitment process will, if relevant, be stored in your personnel file in accordance with the applicable retention periods. In that case, you will be further notified of the processing of your personal data.
7. Your rights
You have the following rights:
• Right to withdraw consent: Where you have given your consent for our processing of your personal data, you have the right to withdraw your consent at any time. You can withdraw your consent by contacting us (see contact details below). If you withdraw your consent, the withdrawal will not affect the lawfulness of processing that has already been carried out based on your consent.
• Right of access: You have the right to have confirmed whether collection or processing your personal data has taken place, and, if so, you have the right to request a copy of your personal data in a digital format.
• Right of rectification: You have the right to require that we correct any inaccurate personal data, and that we complete incomplete personal data.
• Right of erasure: In certain circumstances, you have the right to request that we erase personal data concerning you; for example, if it is no longer necessary for the purposes in which it was originally collected.
• Right to restrict processing: In certain circumstances, you have the right to request that we restrict the processing of your personal data, for example, if you believe that the personal data is not accurate or lawfully processed.
• Right to object to the processing: In certain circumstances, you have the right to request that we stop processing your personal data.
• Right to data portability: In certain circumstances, you have the right to receive the personal data you have provided us with in a structured, commonly used, machine readable format, and the right to have us transmit the data to another entity, where technically feasible.
You can read more about your rights in the Danish Data Protection Agency's guidelines on data subjects' rights, which is available at www.datatilsynet.dk. Please contact us if you wish to exercise any of your rights. The relevant contact details [see section 10] are stated below.
There may be conditions or limitations on these rights. It is therefore not certain for example you have the right of data portability in the specific case - this depends on the specific circumstances of the processing activity.
8. Complaint to a supervisory authority
If you want to lodge a complaint with a supervisory authority about our processing of your personal data, you can do so by contacting the Danish Data Protection Agency via their website, www.datatilsynet.dk.
9. Mandatory processing of personal data
Under the data protection rules, you are entitled to be informed of whether the provision of personal data is a statutory requirement, or a requirement necessary to enter into a contract, and of whether you are obligated to provide the personal data and of the possible consequences of failure to provide such data.
It should be noted in that respect that under the Danish Health Information Act, an employee must state of their own motion or at the employer's request to that effect, whether the employee knows that they suffer from an illness or shows symptoms of an illness which will significantly affect the employee's ability to carry out the work in question.
Further, as a potential future employee, you are subject to the general duty of transfer which means that you must not knowingly withhold information that may be relevant to your opportunity for being employed.
Moreover, it should be noted that if you are offered a position, we will use certain personal data about you to draft your employment agreement, including your name and address; see the provisions of the Danish Employment Contracts Act.
If you do not wish to provide the information that you are required to provide under the provisions of the Danish Health Information Act and/or according to your duty of transfer or the information necessary for drafting an employment agreement, or any other information which we are required to collect from you by law, we will be unable to offer you a position.
10. Contact information
Paper Bottle Company A/S
Fabriksvangen 5A
3550 Slangerup
CVR no.: 28993854
+45 23 10 64 19
tim.silbermann@paboco.com