RECRUITMENT PRIVACY NOTICE
1 Introduction
1.1 In this privacy notice, you can learn more about how Hobbii A/S ("Hobbii", "we", "us", "our") processes your personal data in connection with the recruitment process.
1.2 We provide you with this information as we are required to do so under the EU General Data Protection Regulation (the "GDPR").
2 Controller
2.1 Hobbii acts as a data controller for the processing of your personal data in connection with the recruitment process. You can find the name and contact details in the contact section below.
3 Purposes of processing your data
3.1 Receipt of applications etc.
3.1.1 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.
3.2 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 relating to work assignments, skills and performance, and information about your personal appearance 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.
3.3 Social media
3.3.1 If relevant, we will obtain available information published by you on social media, such as LinkedIn and Facebook.
3.4 References
3.4.1 If we wish to obtain information about you from your current or former employer using your references, we will first ask for your consent. Unless you are otherwise specifically notified by us, the information we obtain in that connection will include the following categories: Information about your previous employments, including information relating to work assignments, skills and performance, your personal appearance and interpersonal skills, and the reason for not being or no longer wanting to be employed by the employer in question.
3.5 Use of personality and competency tests
3.5.1 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.
3.6 Criminal record
3.6.1 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.
3.6.2 Please note that no processing of personal data takes place regarding criminal records, 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).
3.7 Job interviews
3.7.1 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.
3.8 Drafting of employment agreement
3.8.1 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.
4 The legal bases for the processing of your personal data
4.1 In the table below, you can see the legal bases for our processing of your personal data. The legal bases for each of the activities explained above are stated in the table.
Processing activities
Legal basis
Receipt of applications etc. and conducting interviews
The legal basis for processing the personal data is 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.
Further, our processing of data that you make available to us on your own initiative is deemed to be performed on basis of your consent (in accordance with the relevant consent provisions of the GDPR and/or national data protection laws[1]).
Social media
The legal basis for processing the personal data published by you is 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 in relation to the contents of the position.
References
The legal basis is the consent you give for the purpose of using your references; see article 6(1)(a) of the GDPR.
Use of personality and competency tests
The legal basis for processing the personal data is 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.
Drafting of employment agreement
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.
5 Recipients of your personal data
5.1 Certain data will be made available to our processors, for example our IT system providers etc.
6 Transfer of your personal data to third countries
6.1 We transfer your personal data to the US when making data available to our processors.
6.2 The basis for our transfers is the Commission Decision of 4 June 2021 on standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council.
6.3 If you want additional information about our transfer of personal data outside the EU and EEA, including a copy of the relevant security measures, etc., you may make a request for such additional information by contacting us (see contact information below).
7 Storage of your personal data
7.1 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.
7.2 When it is stated below that your personal data will be erased, we may instead anonymise the personal data, and then the personal data can no longer be used to identify you. Anonymised data are not covered by the GDPR as they are no longer personal data.
7.3 If your application is rejected, Hobbii 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 Hobbii enters into an employment agreement with the selected candidate and generally no more than 6 months after the date when you were informed of the rejection.
7.4 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.
8 Your rights etc.
8.1 You have special rights to help you control your personal data, and we wish to make it easy for you to exercise those rights:
8.2 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 below under "Contact".
If you withdraw your consent, the withdrawal will not affect the lawfulness of processing that has already been carried out based on your consent.
8.3 Right of access
You have the right to have confirmed whether we collect or process your personal data, and, if so, you have the right to request a copy of your personal data in a digital format.
8.4 Right of rectification
You have the right to require that we correct any inaccurate personal data concerning you, and that we complete incomplete personal data.
8.5 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 for which it was originally collected.
8.6 Right to restrict processing
In certain circumstances, you have the right to request that we restrict the processing of your personal data, e.g., if you believe that the personal data is not accurate or lawfully processed.
8.7 Right to object to the processing
In certain circumstances, you have the right to request that we stop processing your personal data.
8.8 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.
8.9 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.
8.10 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 (in Danish). Please contact Hobbii if you wish to exercise your rights. The relevant contact details are stated below.
9 Mandatory processing of personal data
9.1 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.
9.2 It should be noted in that respect that under the Danish Health Information Act (helbredsoplysningsloven), an employee must state of its own motion or at the employer's request to that effect whether the employee knows that (s)he suffers from an illness or shows symptoms of an illness which will significantly affect the employee's ability to carry out the work in question.
9.3 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.
9.4 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.
9.5 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
Hobbii A/S
CVR no. 36909587
Dortheavej 12A, st. tv.
2400 Copenhagen NV
Denmark
Email: people@hobbii.dk
[1] Relevant provisions may be: Articles 6(1)(a) and 9(1)(a) of the GDPR, depending on the specific information provided by you.
