Global Data Privacy Statement for Recruiting
- What information we collect as part of our application and recruitment process;
- Why we collect the information;
- How we use the information;
- How you can change and update information
GDPR Cobiro Recruitment & Staffing
This privacy statement is effective from 1st of January 2019 and explains how we collect and use the personal data and associated information of our internal and external job candidates and applicants.
Cobiro ApS recognize and respect the privacy of our applicants, current employees and former employees. This Privacy Statement concerns personal data submitted by you during your online application process, personal data collected by Cobiro ApS as part of the recruitment process, personal data collected by Cobiro ApS as part of a previous employment process and personal data submitted to BambooHR, our Applicant Tracking System (ATS). By applying you consent to Cobiro ApS using, storing and otherwise processing your personal data (including any sensitive personal data) in accordance with the description below.
What information do we collect and how is it used?
To apply for a position online within Cobiro ApS you have to apply through our ATS BambooHR.
When applying for a position at Cobiro ApS, you may be requested to submit personal data to your profile, for example information such as your name, e-mail address, mobile phone number, an attachment of your resume/CV and/or your social media profile such as Linkedin or portfolio.
You may also be requested to provide additional data and information, such as your address, cover letter, relevant education and any other relevant information required for Cobiro ApS to evaluate your application. You will be informed prior to any collection of your personal data, including in case of references being collected during the recruitment process if required according to applicable Danish law. Furthermore, we will obtain consent for collecting references if required according to applicable Danish law.
If you are already employed within Cobiro ApS, personal data collected by Cobiro ApS as part of this employment process, including but not limited to information on your internal job history, appraisals, assessment and profiling results, education and courses will automatically be taken into consideration when you apply for a new position internally. If you have previously been employed within Cobiro ApS, you explicitly consent to your employee data being stored in accordance with the internal policies and applicable local law from this employment, including but not limited to information on your internal job history, reason for termination, appraisals, assessment and profiling results, education and courses.
If you are applying for a position where a criminal history record, credit report or visa/work permit etc. is required by law or internal policy, you may be required to provide these as well, in compliance with local law.
If your application is successful, the job offer may be conditional on pre-employment checks being carried out to Cobiro ApS’s satisfaction.
Cobiro ApS is collecting information that makes it possible for us to assess your candidacy for our available positions. Cobiro ApS is an equal opportunity employer and makes all employment-related decisions entirely on merit and qualifications. Consequently, you should only include information relevant for the review of your application, and disregard information such as your race or ethnic origin, your political or philosophical orientation, your religious beliefs, your union memberships or your sexual orientation.
If you are below the local legal age applicable (18 years in Denmark) please make sure to consult your parents/legal guardian before applying for a position with Cobiro ApS. Please also be informed that Cobiro ApS requires your parents’/legal guardian’s consent before an employment relationship may be established.
Which are the purposes for processing your personal data?
Cobiro ApS processes the personal data submitted by you or collected from other parties for the purpose of assessing your candidacy for our available positions, as well as for HR and personnel administration purposes.
We may further process your personal data for the following purposes:
- Facilitating communication with you for the purpose of recruiting, providing information, references and recommendations
- To accommodate your requests and inquiries for information
HR professionals in the HR department are responsible for the recruitment process, as well as hiring managers involved in the recruitment are entitled to gain access to any and all of the personal data included in your application.
If you are already employed with Cobiro ApS you also explicitly consent to personal data collected by Cobiro ApS as part of this employment process, including but not limited to information on your internal job history, appraisals, assessment and profiling results, education and courses, being disclosed and made available to the HR department responsible for the recruitment process, as well as the hiring managers involved.
If you have previously been employed within Cobiro ApS, you explicitly consent to your employee data being stored in accordance with the internal policies and applicable local legislation from this employment, including but not limited to information on your internal job history, reason for termination, appraisals, assessment and profiling results, education and courses, which will automatically accompany your application when you apply for a new position within Cobiro ApS, and thus subsequently be processed by Cobiro ApS during this recruitment process.
Currently our Applicant Tracking System is located in the US and is listed in the EU-U.S. privacy shield list. The suppliers providing the service on behalf of Cobiro ApS have to meet high data security standards to protect your personal data (including any sensitive data).
The personal data submitted by you or collected by Cobiro ApS during the recruitment process may also be shared with any third party, courts, government body, regulator, law enforcement office or any other applicable authority, if mandated due to legal or regulatory requirements.
On which legal basis do we process your personal data?
We processes your personal data for the purposes set out in this privacy statement for one or more of the following reasons: (i) because we are required to do so for compliance with a legal obligation to which it is subject, (ii) because such information is necessary for the performance of a contract to which you are a party, (iii) because the processing is necessary for the purposes of the legitimate interests pursued by us, by yourself or by a third party, or (iv) where necessary in order to protect the vital interests of any person.
Where will your information be processed?
Cobiro ApS will make all reasonable efforts to ensure that processing of your personal data by Cobiro ApS outside the EEA will be carried out in a way which provides equivalent protection to the standards applied by Cobiro ApS within the EEA and that external data processors meet high data security standards to protect your personal data.
How long do you keep my information for?
We will keep the personal data submitted by you as part of your job application and job candidacy process and other collected and submitted personal information as part of such application process, including potential assessment tests results, interview conclusions, etc., for a period of 6 months (or until the position is filled, maximum 6 months). The starting point for calculating the retention periods will be, as follows: the registered conversation or notification from the candidate into the ATS, which can be, for i.e. the moment when you upload your CV to the ATS, the moment when you apply for a job, the moment when you contact Cobiro ApS to check on your process and/or with an update to your profile; the rejection of your job application; the moment when you withdrawn your application candidacy for the job, etc.
Cobiro ApS retains your personal data to simplify the application process in the event you should choose to apply for another job at Cobiro ApS during this period.
When the retention period is being reached you will be deregistered and your data will be deleted irrevocably unless you confirm or ask us to do otherwise. You might receive an email asking you for continuous registration. If you do not reply to this mail, your data will be deleted irrevocably after 1 month.
If you are hired by Cobiro ApS, your personal data submitted and all personal data collected through the recruitment process will be stored and processed throughout your employment along with your personal data collected throughout the employment process in accordance with the employment contract. The personal data will be deleted after the end of your employment in accordance with the internal policies in this respect and applicable local legislation (maximum 5 years).
Cookies and other tracking technologies
Cookies may contain information such as registration data and user preferences. When a server receives a request from a computer which stores a cookie from the website, the server is able to use the information stored in the cookie in combination with the information stored on the server. A cookie cannot collect information from your computer and cannot carry any viruses or other damaging files. Please see Cobiro’s Data Privacy Statement here for a description of what cookies are, how Cobiro uses these and what to do if you don’t want cookies.
We have implemented appropriate organizational and technical security measures to protect your personal data. We maintain organizational, physical and technical security arrangements for all the personal data we hold.
We have protocols, controls and relevant policies, procedures and guidance to maintain these arrangements taking into account the risks associated with the categories of personal data and the processing we undertake. Cobiro ApS, Esplanaden 8a, 1263, Denmark, is the legal entity responsible for the collection and processing of your personal data which is not submitted and collected in accordance with an application.
What are my rights?
- Request changes to the personal data we process about you: this right entitles you to know whether we hold personal data of you and, if so, obtain information on and a copy of those personal data.
- Request rectification of your personal data: this right entitles you to have your personal data be corrected if it is inaccurate or incomplete.
- Request the erasure of your personal data: this right entitles you to request the erasure of your personal data, including where such personal data would no longer be necessary to achieve the purposes.
Note that most of the personal data that we hold about you comes from information you completed or provided, therefore, please ensure that you keep your information correct when corresponding with us. Please note, however, that certain personal data may be exempt from the above-mentioned rights pursuant to applicable data privacy or other laws and regulations.
To the extent that the processing of your personal data is based on your consent, you have the right to withdraw such consent at any time by contacting our Data Protection Officer. Please note that this will not affect our right to process personal data obtained prior to the withdrawal of your consent, or its right to continue parts of the processing based on other legal bases than your consent.
If you wish to exercise your right to access your personal data, to object to it being processed or to rectify processed data, please contact email@example.com or send a letter to Cobiro ApS, Esplanaden 8a, 1263 Copenhagen K, Denmark, ATT: CEO.
As the privacy of our applicants and our employees is of utmost importance to Cobiro ApS, this Privacy Statement will be updated on an ongoing basis to make sure that we comply with legal requirements.
If you have any questions about this Privacy Statement or other questions regarding protection of your personal data please contact firstname.lastname@example.org or send a letter to Cobiro ApS, Esplanaden 8a, DK-1263 Copenhagen K, Denmark, Att.: CEO
If you wish to complain, you can contact Datatilsynet (www.datatilsynet.dk)
This Privacy Statement was last updated November 18, 2019.