Privacy policy for candidates
for Great Northern A/S

Thank you for applying for a job at Great Northern A/S (“(Great Northern)”, “us”, “we” or “our”).

In connection with recruitments at Great Northern, we process your personal data as stated in this policy in order to assess whether you are a qualified candidate for a vacant position with us.

We recommend that your application does not contain a civil registration number or sensitive personal data, such as information revealing racial or ethnic background, religious affiliation, trade union membership, sexuality, health information, etc. If the holding of a position exceptionally places special demands on health-related conditions, we will, if necessary – after a specific assessment thereof – ask for your consent to process such data, cf. Article 7, Article 6 (1) (a) and Article 9 (2) (a) of the General Data Protection Regulation and Section 11(2)(2) of the Danish Data Protection Act.

Below you can read more about what information we process about you when you apply for a position with us.

1. contact information
Great Northern is the data controller with regard to the personal data collected and processed in connection with the processing of your application. You can contact us here:

Great Northern A/S
CVR-nr. 35801987
Great Northern Ave. 1
5300 Kerteminde
Phone +45 3333 7711
E-mail: info@greatnorthern.dk

2. Processing your application
We process the information, including personal data, contained in your application and CV in order to evaluate your application.

This will typically be the following information: Name, address, photo, date of birth, gender, phone number, email address, marital status, education(s), career history, driving license information and recommendations/references.

If you are invited for an interview, we will receive additional information about you during the interview, which we will note down for use in the further recruitment process.

We use Art. 6 (1) (b) GDPR as a basis, as this is processing of personal data prior to the conclusion of an employment contract. In addition, the processing is carried out on the basis of Article 6 (1) (f) GDPR in order to pursue our legitimate interest in carrying out the recruitment process.

3. Information from recruitment agencies, publicly available information, social media, etc.
As part of the recruitment process, we may receive information about relevant candidates for a position from external recruitment agencies and/or headhunters etc. if the recruitment agency and/or headhunter is entitled to share the information with us. We may also search the internet for relevant and publicly available information, including content in public registers, media archives, social media, such as LinkedIn, Facebook, Twitter, Instagram, etc. We will typically look for information about your previous employment, activities, skills and performance.

We use the balancing of interests rule in Article 6 (1) (f) of the General Data Protection Regulation as a basis for obtaining information about candidates from recruitment agencies/headhunters, social media, etc. We do this in order to assess whether you have a profile that fits the company and the specific position.

4. Information from personality tests, skills tests or similar
If recruitment for the position you have applied for requires you to complete personality tests, skills tests or similar, you will be informed of this when we have processed your application. We always assess whether it is relevant in relation to the position in question.

The purpose of the tests is to assess your skills and qualifications as a potential employee and whether your profile fits the company and the specific position.

Processing of the personal data collected as part of the test is based on Article 6 (1) (f) GDPR as we have a legitimate interest in finding the most suitable candidates for the position in question. However, we will use your consent under Article 6 (1) (a) and Article 9 (2) (a) GDPR as a basis if the test in question contains sensitive personal data. You can withdraw your consent at any time. You can do so by contacting us using the contact details above.

If you withdraw your consent, it will only take effect from that time. It will therefore not affect the lawfulness of our processing of the data up to the time you withdraw your consent.

5. Information from previous employer or others
In some positions it is necessary to obtain references from previous employers, colleagues, personal network or similar. If we obtain such references, we may make a note of the information we receive.

We obtain your consent and thus use Article 6 (1) (a) of the General Data Protection Regulation and Section 12 (3) of the Danish Data Protection Act as the basis for processing before we contact references that you have not provided yourself. We will in any case obtain your consent to contact references if we wish to obtain information of a more subjective nature (e.g. professional or social skills), sensitive information or information about criminal offenses, in which case we will use Article 6 (1) (a) of the General Data Protection Regulation in conjunction with Article 9 (2) (a) and Section 12 (3) of the Data Protection Act.

6. Copy of passport or other identification documents
If we handle travel bookings for you in connection with the recruitment process, it may be necessary to obtain information about your passport or other identification documents.

We use the balancing of interests rule in Article 6 (1) (f) of the GDPR as the basis for the processing of the data, as our processing of information about your passport or other identification documents is necessary in order to complete the travel booking on your behalf.

If your documents contain a civil registration number, we use consent under Article 6 (1) (a) and Article 7 of the General Data Protection Regulation and Section 11 (2) (2) of the Data Protection Act as the basis for processing.

7. Residence and work permit
It is a condition of employment that you have a valid work and residence permit. To ensure this, we may ask for a copy of your passport in connection with employment.

If, due to your citizenship, you need a work and residence permit to work legally in Denmark, we will also obtain a copy of your work and residence permit via the Danish Agency for International Recruitment and Integration.

We use Article 6 (1) (c) of the General Data Protection Regulation and section 11(1)(1)(1) of the Danish Data Protection Act as a basis when we obtain a copy of your passport and any work and residence permits, as we are obliged to ensure this under section 59(5) of the Danish Aliens Act.

8. Storage and deletion
8.1 If you are not offered a position/unsolicited applications
If you are not offered a position, we will store your application and any additional personal data collected in connection with the recruitment process, including the result of your personality test, for a period of up to 6 months after we have completed the recruitment process, unless you have given your consent to a longer storage of such data, cf. Article 6 (1) (a) of the General Data Protection Regulation and Section 12 (3) of the Danish Data Protection Act.

If we have obtained a copy of your criminal record in connection with recruitment, we will not store the criminal record after the end of the recruitment process.

If we have collected information about your passport or other identification documents in connection with the recruitment process, we will delete this information when it is no longer relevant for the purpose for which it was collected.

8.2 If you are offered a position
If you are offered a position, your application and additional personal data collected in connection with the employment will become part of your personal personnel file with us.

9. Other recipients who may process your data
In connection with the recruitment process, there may be others who receive your personal data. This may be public authorities or providers that provide systems and assist with administrative functions, for example:

– Recruitment agencies
– Supplier of IT systems, including recruitment system
– KIRKBI HR Shared Service Center assisting with employee administration
– Providers of personality and skills tests etc.
– Providers of background checks
– Other third parties providing relevant services under contract with Great Northern

Personal data may also be shared with travel agents who provide services related to travel bookings, travel administration and the like, airlines and advisors in various fields, including lawyers and accountants.

10. Transfer of personal data
In connection with the processing of your personal data for the purposes described in this policy, your personal data will be transferred to data controllers or data processors located in countries outside the EU/EEA.

When making such transfers, we will always take reasonable steps to ensure the confidentiality of your personal data.

In cases where your personal data is transferred to countries outside the EU/EEA, it will be done on the following legal basis:

a. Binding Corporate Rules
b. The country is approved by the EU Commission as having an adequate level of protection
c. If the country is not approved by the EU Commission as having an adequate level of security, we will ensure transfer as follows:
– Using the EU Commission’s Standard Contractual Clauses
– Obtaining your consent to the transfer

We use Microsoft Office 365 with data storage within the EU/EEA.However, data may be transferred or accessed from locations in third countries. Should this be the case, the transfer basis will be the EU Commission’s standard contracts.

11. Your rights
11.1 Data subject rights
Under the legislation of the General Data Protection Regulation and the Data Protection Act, you have a number of rights.

– You have the right to access the data we process about you and a number of additional information
– You have the right to have inaccurate information about yourself corrected
– In special cases, you have the right to have information about you deleted before the time of our general general deletion occurs
– 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 your personal data in a structured, commonly used and machine-readable format and to have this personal data transferred from one controller to another without hindrance (data portability).

If you want to exercise your rights, please contact us at the contact information above.

11.2 Complaints to the Danish Data Protection Agency
You have the opportunity to complain about our processing of your personal data to the Danish Data Protection Agency. You can find the Danish Data Protection Agency’s contact details on the Danish Data Protection Agency’s website www.datatilsynet.dk.

Version 1.0, September 2022