10 Chambers AB uses Teamtailor AB as a recruitment partner. The recruitment process is carried out in collaboration with Teamtailor AB and 10 Chambers AB. 10 Chambers AB and Teamtailor AB respect your privacy and are committed to protecting your personal data. The purpose of this privacy notice is to inform you about how we collect, process and share your personal data when you apply for a job with us, and inform you about your privacy rights.
- WHO IS DATA CONTROLLER?
- INFORMATION WE COLLECT AND HOW WE COLLECT IT
- THE PURPOSES AND THE LAWFUL BASIS
- SHARING OF INFORMATION COLLECTED
- TRANSFER TO THIRD COUNTRIES
- DATA RETENTION
- HOW TO EXERCISE YOUR DATA PROTECTION RIGHTS
- CHANGES TO THIS PRIVACY NOTICE
1. WHO IS DATA CONTROLLER?
The data controller for the processing described in this notice is: 10 Chambers AB
If you have questions regarding this Privacy Notice, please get in touch with us by email at: firstname.lastname@example.org.
2. INFORMATION WE COLLECT AND HOW WE COLLECT IT
In the following we will tell you which types of personal data we may collect about you and how we collect it. In section 3 we have in a table explained the purposes for which we process your personal data and the lawful basis we rely on.
We may collect, use, store and transfer different kinds of personal data about you which we have categorised as follows:
A. Identity Data includes name
Contact Data includes email, telephone number and address.
CV Data includes the information you have included in your employment application and CV; e.g. documentation and information about your education, previous work experience, qualifications, language skills, any photos, video or other recorded material which you at your own discretion choose to make available to us.
References includes information obtained from previous employer(s) at our request.
Work Permits includes information on your passport, citizenship, residence and work permit where needed.
Test data includes your response to aptitude, skills or personality tests.
The information is collected directly from you by your application, CV or other material made available to us before or during employment interviews; we also process personal data from candidate profiles you are upload to recruitment platforms. For certain positions we may retain the services of a recruitment agency which will provide information to us. Such recruitment agency may be a data controller in their own right, and you are encouraged to consult the recruitment agency’s information on the processing of personal data. References are taken upon agreement with you.
3. THE PURPOSES AND THE LAWFUL BASIS
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
i. To take steps prior to entering into a possible employment contract at your request by submitting your job application to us cf. GDPR Article 6 (1) (b).
ii. Where we need to comply with a legal or regulatory obligation cf. GDPR Article 6 (1) (c) or if necessary for the establishment, exercise or defence of a legal claim cf. GDPR Art 9 (2) (f).
iii. Where you have provided your consent cf. GDPR Article 6 (1) (a) or Article 9 (2) (a).
iv. Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests cf. GDPR Article 6 (1) (f).
We have set out below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Category of data
Lawful basis for processing including basis of legitimate interest
To manage the recruitment process, incl.:
- to receive and review job applications,
- to arrange and invite to interviews,
- to inform applicants about the progress and outcome of the recruitment process
Necessary to pursue our legitimate interest in managing recruitment processes with the purpose of finding appropriate candidates for jobs within our company
To manage the recruitment process, incl.:
- To enter into employment contract with the chosen candidate
To take steps prior to entering into a possible employment contract at your request by submitting your job application
To screen and evaluate candidates to choose the most appropriate candidate for the job
Necessary to pursue our legitimate interest in evaluating job applicants for the purpose of finding appropriate candidates for jobs within our company
To evaluate the candidates’ qualifications and appropriateness for the job by taking references
Aptitude test may be used where necessary to assess relevant professional and personal skills and qualifications
To confirm and be able to document the candidate’s residence and work permit
(E) Work Permits
To comply with our legal obligation under the Aliens Act to not employ individuals without necessary permits to reside and work in Sweden
To handle complaints related to the recruitment process
(E) Work Permits
Necessary for the establishment, exercise or defence of a legal claim
To the extent that we have referred to our legitimate interest as the legal basis for the processing of personal data specified above we have conducted a balancing test for those interests to ensure that our interest is not overridden by your interests or fundamental rights and freedoms. Please contact us by email at: email@example.com if you wish to receive more information on the balancing test.
4. SHARING OF INFORMATION COLLECTED
We use Teamtailor AB as our recruitment partner. Your personal data will be shared with Teamtailor AB for the recruitment purposes only and Teamtailor AB will not use your personal data for their own purposes.
We may disclose personal data to third parties:
- when it is necessary for the purposes listed in section 3
- when required by law we may disclose your personal data to public authorities
- we may assign your personal data, to any person or entity that acquires all or substantially all of our business, stock or assets, or with whom we merge.
- when we believe in good faith that disclosure is necessary to establish or exercise our legal rights or defend against legal claims, protect your safety or the safety of others, investigate fraud, or respond to a government request.
We share information, including personal information, with our trusted third-party service providers that we use to provide services to us and process your data on our behalf and under our instruction, e.g. hosting of data and maintenance IT-systems, hosting and maintaining recruitment portals and platforms, certain recruitment services and test providers. These third-party service providers may have access to or process your personal information for the purpose of providing these services for us. We do not permit our third-party service providers to use the personal information that we share with them for any purpose other than in connection with the services they provide to us. We have entered into data processor agreements with our data processors.
5. TRANSFER TO THIRD COUNTRIES
We will not transfer your personal data to recipients outside EU or EEA unless we have ensured compliance with GDPR Chapter V.
Some of our third-party service providers are established outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA. However, to ensure that your personal information receive an adequate level of protection we have ascertained that sufficient safety measures have been implemented to allow for the transfer, including where the European Commission have deemed the country to provide an adequate level of protection for personal data; or by use of specific contracts approved by the European Commission (Standard Contractual Clauses) which give personal data essentially equivalent protection as it has in Europe.
If you require further information about on our current data processors established outside the EEA and the safety measures in place to allow for the transfer of personal data, you can request it from us – please send your request to us by email at firstname.lastname@example.org.
6. DATA RETENTION
We retain the personal information we collect where we have an ongoing legitimate need or obligation to do so. Where we are no longer obliged to keep your records and do not have an ongoing need to process your personal information, we will either delete or anonymise it.
In relation to applicants who are not offered employment by us, we will normally delete all data after 24 months from the decision not to offer employment. We will retain applicant data for longer periods if the applicant has consented.
For applicants who are employed by us, personal data will be retained in accordance with our Privacy Notice for Employees.
Data may be retained for longer period if we are legally obliged to do so, or if retention is necessary to establish, exercise or defend legal claims.
7. HOW TO EXERCISE YOUR DATA PROTECTION RIGHTS
You have certain choices available to you when it comes to your personal information. Below is a summary of those choices, how to exercise them and any limitations.
Under certain circumstances, you have the right to:
- Request access to your personal information. This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected. Please note that the law prohibits that we delete entries in medical records.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it.
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation whereby you object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party (also known as data portability).
- Where our processing is solely based on your specific consent you have the right to with-draw your consent at any time. Such withdrawal will not affect the lawfulness of processing based on consent before its withdrawal.
If you wish to exercise any of the data protection rights that are available to you then please send your request to us by email at: email@example.com and we will action your request in accordance with applicable data protection laws.
You have the right to file a complaint with the local data protection authority if you are unhappy with our data protection practices. In Sweden you can lodge a complaint with the Swedish Authority for Privacy Protection at https://www.imy.se/en/individuals/forms-and-e-services/file-a-gdpr-complaint/. ;
8. CHANGES TO THIS PRIVACY NOTICE
This privacy notice may be updated from time to time to reflect changing legal, regulatory, or operational requirements. We encourage you to periodically consult our website for the latest information on our privacy practices.
Company policy (name)
Privacy notice – job applicants (TeamTailor)
Policy Holder (name and title)
Ann Keve, Chief Human Resource Officer
Other interest holders (functions)
Policy last revised (date)
10 October 2022
Policy approved by (name/date)
Svante Vinternatt (COO) with the Operations Team, 10 October 2022
Policy valid as of
10 October 2022