Procesing of personal data when recruiting
Below, please find information about how we process personal data on applicants during recruitment. This applies no matter if you apply unsolicited or apply for a specific position, apprenticeship or internship.

The aim of collecting personal data about you during the recruitment process is to assess whether you are a qualified candidate for a vacancy at Fynbo Foods A/S. This also applies to unsolicited applications, which are evaluated specific.

When you apply for a position, apprenticeship or internship with us, we receive and process a number of personal data about you. This means we are data controllers for the personal data we process about you.

In connection with the recruitment process, we process general personal data about you, but we may also process special personal data, your CPR (Danish Personal ID) No. or information on crimes – however, we recommend that you only submit general personal data (not sensitive) in connection with your application. Below, you can read more about the data about you that we process when you apply for a position, apprenticeship or internship with us.

If you have any questions regarding our processing of personal data, you are very welcome to contact us:

Fynbo Foods A/S
Sigenvej 9, DK-9760 Vraa
CVR-no. 26612608
Contact person: Legal Counsel and HR Manager Maria Bukdahl Rukjær
Email: persondata@fynbofoods.dk
Tel.: 0045 98996800

When we receive your application
When we receive your application you will receive an acknowledgement of receipt as soon as possible.

Under the recruitment process, it is the personal data that appears in your application, CV and other attached documents that is registered. This will typically be as follows: Name, address, date of birth, gender, phone number, email address, marital status, children, education/training, career history, professional and personal skills, information on driving license (truck certificate) and recommendations/references. You register all your data in our online recruitment system delivered by HR-ON ApS, which thereby becomes data processor. If you – notwithstanding our recommendation above – choose to register sensitive personal data, e.g. data about your health, we will process such data.

We apply GDPR Art. 6 (1) (b) as a legal basis with regard to personal data you have sent us with a view to employment. In case of sensitive data, we generally apply GDPR Art. 9 (2) (a), (b) or (c) and Art. 6 (1) (a) or (f) as legal basis. The legal basis is evaluated individually from case to case. 

We assess the application
We specifically assess the qualifications of every single applicant in relation to the position advertised. Once we have read the applications, we select candidates for interview(s). The candidates who have not been called for an interview will be notified as soon as possible – at latest, when another candidate has been employed.

If you have sent or handed in an unsolicited application, we evaluate your application in order to find out whether we have a vacant position, apprenticeship or internship matching your profile and skills. If that is the case, we will call you for an interview. However, if it is not the case, we will save your data for 6 months in case a relevant position should show up. At any time, you can delete your data using the link in the email you received as an acknowledgement of receipt. As an alternative you can always contact us at persondata@fynbofoods.dk. Before the expiry of 6 months, we will ask for your consent to save the data for a longer period.

When we have selected you for a job interview
In connection with the job interviews, we receive further information about you, which we note for the purposes of the continued recruitment process. Further, we may for instance have correspondence with you per email (information about and negotiation of employment terms, etc.), and such data is also processed and used during the recruitment process.

We apply GDPR Art. 6 (1) (b) as a legal basis with regard to personal data you have provided yourself with a view to employment. With regard to correspondence regarding employment terms, etc., we apply the legitimate interest rule under GDPR Art. 6 (1) (f) as a legal basis.

Data from social media
When recruiting for jobs, apprenticeship or internship with a focus on customers and collaborative relationships, it may be relevant for us to undertake a social-media search e.g. LinkedIn, Facebook and Instagram. A Google search may also take place.

We apply the legitimate interest rule under GDPR Art. 6 (1) (f) as a legal basis for collecting data on candidates from social media. We do this in order to be able to assess whether you have a profile that is compatible with the company and is appropriate to the specific job.

Data from personality test
The company carries out a personality test in connection with recruitment for certain jobs. We always assess whether this is relevant to the position in question. The purpose of the test is to assess your skills and qualifications as a potential employee, as well as whether your profile is compatible with the company and is appropriate to the specific job.

We use your consent under GDPR Article 6 (1) (a) as a legal basis for the processing of this data, and you will thus be asked to give your consent before the test is carried out.

You may withdraw your consent at any time. You can do this by contacting us using the contact details above. If you withdraw your consent, this withdrawal will only take effect as from that point in time. It will thus not affect the legality of our processing of the data up to the time when you withdraw your consent.

Data from previous employer
For certain jobs, it is necessary to collect references from previous employers. If we collect references from one or more of your previous employers, we will register the data we receive.

We use your consent under GDPR Article 6 (1) (a) as a legal basis for the processing of this data, and you will thus be asked to give your consent before we contact one or more of your previous employers.

You may withdraw your consent at any time. You can do this by contacting us using the contact details above. If you withdraw your consent, this withdrawal will only take effect as from that point in time. It will thus not affect the legality of our processing of the data up to the time when you withdraw your consent.

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

If, because of your citizenship, you are required to have a EU-residence card or a residence and work permit in order to work legally in Denmark, we will also collect copies of such documents.

We apply Article 6 (1) (c) of GDPR as a legal basis when obtaining a copy of your passport and any residence and work permits, as we are obliged to do so pursuant to Section 59 (5) of the Danish Aliens Act.

Storage and deletion
If your application is rejected, we will delete the data we have registered about you within 6 months, but we will delete the results of your personality test (made as a part of our recruitment process) after we have rejected your application. If we would like to store your application for a longer period, we will ask for your consent via our online recruitment system. If you are appointed, we will store the data that has been used in the recruitment process in your staff folder.

In case an unsolicited application is rejected, we will save your data for 6 months in case a relevant position should show up. At any time, you can delete your data using the link in the email you received as an acknowledgement of receipt. As an alternative, you can always contact us at persondata@fynbofoods.dk. Before the expiry of 6 months, we will ask for your consent to save the data for a longer period.

Other recipients who can process your data
In connection with the recruitment process, there may be others who receive your personal data. This could be public authorities or providers that supply systems and assist with administrative functions, e.g. recruitment agency, provider of personality tests or public authorities in connection with establishment of flexible jobs, jobtraining, etc.

Your rights
Under the legislation of GDPR and the Danish Data Protection Act, you have a number of rights. Please contact us if you wish to invoke your rights (see contact details above).

Right to assess: You have the right to assess the personal data about you that we process. 

Right to rectification: You have the right to have incorrect data about you rectified. 

Right to erasure: In exceptional instances you have the right to have data about you erased prior to our general deletion erasure process. 

Right to restriction: In certain instances, you have the right to have the processing of your data restricted. If you have the right to have the processing restricted, we may in future only perform data processing - apart from storage - with your consent, or in order to establish, assert or defend a legal claim, or in order to protect a person or a wider public interest. 

Right to objection: In certain instances, you have the right to object to our otherwise legal processing of your personal data. 

Right to transmit data: In certain instances 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 data controller to another without hindrance.

Withdrawal of consent: If you have given consent to us in relation to processing of personal data, you are entitled to withdraw your consent at any time. After a withdrawal, we will stop processing the personal data covered by the consent, unless we have another legal basis of processing the data.

You can read more about your rights in the Danish Data Protection Agency's guidelines on the rights of those registered at www.datatilsynet.dk.

Complaining to the Danish Data Protection Agency
You can lodge a complaint with the Danish Data Protection Agency about our processing of your personal data. You will find the Danish Data Protection Agency's contact details on its website www.datatilsynet.dk.

Question
If you have any questions, please do not hesitate to contact us – find contact details above.

Version 5, December 2020