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Information regarding processing of personal data for job applicants and potential job applicants

Introduction

This privacy policy ("Privacy Policy") describes how

• Columbus A/S, company reg.no. 13228345, Lautrupvang 6, Ballerup, Denmark 2750,
• Columbus Sweden AB, company reg no. 556817-7124, Drottninggatan 71d, 111 36 Stockholm,
• Columbus Global s.r.o., company reg. no. 02823721, Na Radosti 486/55 Praha 5 - Zličín, Hlavní město Praha, 155 21 Czech Republic,
• Columbus Poland, NIP 8971803243, Aleja Juliusza Słowackiego 64, 30-024 Kraków, Poland,
• Columbus Deutschland GmbH, HRB 94582, Kaistrasse 5, 40221, Düsseldorf, Nordrhein-Westfalen, Germany,
• Columbus AS, Grev Wedels Plass 9, 0151 Oslo, Norway, company reg. no.: 883 561 872, or
• Columbus Global UK Ltd., company reg. no. 02890010, Lugano House, Lake View Dr, Nottingham NG15 0ED, England,

process your personal data when you apply for a job at any of the mentioned Columbus-entities, or when you have correspondence with a Columbus entity about potential recruitment via LinkedIn, including about saving your profile and contact information for future positions in our system.

In the following “Columbus” refers to the relevant Columbus entity where you have applied for a job or the entity that has contacted you about potential recruitment opportunities on LinkedIn.

Job applicants

Processing of personal data

Providing your job application data is voluntary. However, if you decline to submit the requested candidate data, our ability to consider you as a candidate may be limited.

Kindly note that you should not submit your national ID-number in your job application.

This Privacy Policy covers any data you submit to Columbus, for and during the recruitment and selection process. This may include but is not limited to the following information:

• Your name, contact details such as telephone number and e-mail address, birthday, picture and candidate status.
• The information included in your CV, LinkedIn profile application letter or any other annex you may submit such as job history, academic background and results, skills and competencies, personal interests, and languages spoken.
• Job preferences and type of employment sought.
• Names and contact details of any references.

Columbus may collect data directly from you or from third parties, for example from professional networking/job posting sites on the internet, or if Columbus requests to do a background check or requests/receives an employment reference from recruitment agencies. Columbus will only contact third parties listed as references if you consent hereto.

Purpose of the processing

• The personal data you provide in your application as well as data that may be collected during the recruitment process will be processed to assess your application and your qualifications for the job. Your personal data may be used to verify your information, to conduct reference checks, and to communicate with you.
• If your application is successful, and you are offered employment at Columbus, the data collected will become part of your employment record and will be used for employment purposes.
• If you give your consent hereto, we may store your application as well as CV and annexes to the application for longer than our retention period with a view to consider you for any future positions, which are relevant to your profile.

Legal basis for processing

Our processing of your personal data in connection with the review of your job application and the recruitment process will be processed based on GDPR Article 6 (1) (f), UK GDPR Article 6 (1) (f) as applicable. Columbus has a legitimate interest in recruitment and in assessing whether you as an applicant are qualified for the job in question.

If you are offered employment at Columbus, we will process your personal data based on GDPR Article 6 (1) (b), UK GDPR Article 6 (1) (f) as applicable, to enter into a contract with you.

If you consent to Columbus storing and saving your job application for a longer period than our retention period, our legal basis for processing your personal data will be GDPR Article (1) (a), UK GDPR Article 6 (1) (a) as applicable.

Recipients of your personal data

Columbus may disclose or transfer your personal data to the following recipients:

• Affiliates of Columbus.
• Suppliers, business partners or other collaborators who support us with the recruitment process.
• Public authorities.

Certain recipients process personal data on behalf of Columbus and may only process your personal data in accordance with the instructions given by Columbus. These third parties may not process your personal data for their own purposes.

Transfer of your personal data to a third country (outside of EU/EEA and/or UK)

We may transfer your personal data to “third countries” outside the EU/EEA, including the United States, and India. Such transfers are based on either the standard contractual clauses of the European Commission (here), adequacy decisions from the European Commission (here) or another applicable legal basis for such transfer under GDPR Article 46. If you are applying for a job at Columbus Global UK Ltd. (England), any transfers of personal data to countries outside the UK, are based on either the Agreement from the Information Commissioner’s Office (here), the International Data Transfer Addendum from the Information Commissioner’s Office (here), an adequacy regulation, or another applicable legal basis for such transfer under UK GDPR Article 46.

Data retention

We will retain personal information for the period necessary to fulfil the purposes outlined in this Policy.

Unless you as a job applicant have consented to a longer retention period, we will store your job application including annexes for a maximum of 6 months. If you have given consent, we will store your application for up to 24 months.

Potential recruitment, including correspondence on social media

Processing of personal data

Columbus may reach out to you on LinkedIn about potential recruitment opportunities based on your public LinkedIn profile, which we may have found using different search terms, job agents or applications. This Privacy Policy describes how we process your personal data when we contact you on LinkedIn, which may be done via third-party applications. This Privacy Policy also describes how we may save your LinkedIn profile and contact information in our recruitment system so that we can contact you for future job positions if you consent hereto.

Columbus is not responsible for LinkedIn’s own processing of your personal data.

The personal data we process about you may include, but is not limited to the following information:

• Your name, contact details, and profile status on LinkedIn.
• The information included on your LinkedIn Profile, includes job status and qualifications.
• Any information provided in the correspondence with Columbus.

Purpose of the processing

• The purpose of the processing is to potential recruitment and to inform you about Columbus and career opportunities at Columbus. If you consent hereto, we may save your LinkedIn details including contact information in our recruitment system.

Legal basis for processing

• Our processing of your personal data via LinkedIn correspondence will be processed based on GDPR Article 6 (1) (f), UK GDPR Article 6 (1) (f) as applicable. Columbus has a legitimate interest in recruitment and in finding qualified candidates.
• If you consent to Columbus storing and saving your LinkedIn profile and contact information in our recruitment system, our legal basis for processing of your personal data will be GDPR Article (1) (a), UK GDPR Article 6 (1) (a) as applicable.

Recipients of your personal data

Columbus may disclose or transfer your personal data to the following recipients:

• Affiliates of Columbus.
• Suppliers, business partners or other collaborators who support us with the recruitment process.
• Public authorities.

Certain recipients process personal data on behalf of Columbus and may only process your personal data in accordance with the instructions given by Columbus. These third parties may not process your personal data for their own purposes.

Transfer of your personal data to a third country (outside of EU/EEA and/or UK)

We may transfer your personal data to “third-countries” outside the EU/EEA, including the United States, and India. Such transfers are based on either the standard contractual clauses of the European Commission (here), adequacy decisions from the European Commission (here) or another applicable legal basis for such transfer under GDPR Article 46. If Columbus Global UK Ltd. (England) contacts you, transfers to countries outside the UK, are based on either the International Data Transfer Agreement from the Information Commissioner’s Office (here), the International Data Transfer Addendum from the Information Commissioner’s Office ( here ), an adequacy regulation, or another applicable legal basis for such transfer under UK GDPR Article 46.

Data retention

We will retain personal information for the period necessary to fulfil the purposes outlined in this Policy.

Subject to obtaining your prior consent, we will store your LinkedIn profile and contact information in our recruitment system for up to 24 months.

Your rights as a data subject

Columbus has taken all necessary and adequate steps to protect your personal data and to ensure your rights as a data subject.

You have certain rights, which are described below. Please note that certain exceptions may apply, e.g., if the processing is necessary for compliance with a legal obligation or for the establishment, exercise or defence of legal claims. If you have any questions to your rights as a data subject, please contact Columbus – please see the contact information below.

Right of access

• You have the right to know what personal data we process about you, for what purposes we process it, whether we disclose the data to others, along with other information on the processing.

Right to rectification

• You have the right to rectify inaccurate personal data concerning you, including the completion of incomplete personal data.

Right to erasure (right to be forgotten)

• Under certain circumstances, you have the right to erasure and thus to have some or all your personal data deleted before the end of our retention period.

Right to restriction

• In certain cases, you have the right to restrict Columbus's processing of personal data concerning you e.g., if the processing is unlawful and you request restriction of use of personal data instead of erasure or if Columbus no longer needs the personal data for the purposes of processing. Insofar as you can enforce this right, we may only process your personal data to establish, exercise or defend a legal claim, or to protect a person or substantial public interests.

Right to data portability

• In certain cases, you have the right to receive personal data concerning you in a structured, commonly used, and machine-readable format. Where the processing is based on consent or a contract and the processing is carried out by automated means format, you have the right to transmit this personal data to a third party without hindrance from Columbus.

The right to object

• Under certain circumstances, you have the right to object to Columbus's processing of personal data concerning you.

Withdrawal of consent

• When the processing of your personal data is based on your consent, you may withdraw your consent at any time. Please note that this does not affect Columbus's processing of your personal data prior to the withdrawal of your consent.

For withdrawal of consent regarding correspondence on social media about recruitment and Columbus’ saving of your profile and contact information, please follow this link.

Questions and complaints

If you have a question about this Privacy Policy or our processing of your personal data, you can contact the relevant Columbus entity using the contact information below.

If you wish to file a complaint regarding Columbus's processing of your personal data, you can contact us by using the relevant Columbus entity’s contact information below. If your complaint is not resolved, you can contact the supervisory authority in your jurisdiction.

Columbus

Lautrupvang 6, Ballerup, Denmark

___________________________________________

HR

Mona Prip

Mona.Prip1@columbusglobal.com

____________________________________________

Supervisory Authority

Datatilsynet

Telephone number 33 19 32 00

Website: https://www.datatilsynet.dk/

Columbus

Columbus Sweden AB Drottninggatan 71D 111 36 Stockholm

info.se@columbusglobal.com HR Jeanette Emilsson: jeanette.emilsson@columbusglobal.com

Supervisory Authority Integritetsskyddsmyndigheten Box 8114 104 20 Stockholm Telephone number: +46 8-657 61 00

Email address: imy@imy.se Website: www.imy.se

Contacts in the Czech Republic:

HR Marketa Main: marketa.main@columbusglobal.com

Supervisory Authority Personal Data Protection Office Pplk. Sochora 27 170 00 Praha 7 Czech Republic Telephone number: +420 234 665 800

Email address: posta@uoou.cz

Website: www.uoou.cz/en/

Contacts in Poland: HR Anna Zgrzebnicka-Lechowicz: Anna.Zgrzebnicka.Lechowicz@columbusglobal.com

Supervisory Authority Personal Data Protection Office ul. Stawki 2, 00-193 Warszawa, Poland Telephone number: 22 531-03-00

Email address: kancelaria@uodo.gov.pl

Website: uodo.gov.pl/en/p/contact#

Contacts in Germany: Managing director Holger Küpper: holger.kuepper@columbusglobal.com

Supervisory Authority Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen Postfach 20 04 44 40102 Düsseldorf Germany

Telephone number: +49 (0)211 / 38424 - 0

Email address: poststelle@ldi.nrw.de

Website: https://www.ldi.nrw.de/

Columbus Grev Wedels Plass 9, 0151 Oslo, Oslo HR

Guri Korshavn Guri.Korshavn@columbusglobal.com

Supervisory Authority Norwegian Data Protection Authority (Datatilsynet)

Telephone number: +47 22 39 69 00

Website: https://www.datatilsynet.no/

Columbus, Lugano House, Lake View Business Park, Lake View Drive, Annesley, Nottingham, NG15 0ED

HR - Andrea Ward awar@columbusglobal.com

Supervisory Authority Information Commissioner's Office Telephone number: 0303 123 1113 Website: http://www.ico.org.uk

4. Changes

This Privacy Policy will be updated regularly and when necessary due to changes in applicable law.

About Columbus Global

We bring digital transformation so our customers can thrive far into the future.

Columbus is a global IT services and consulting company, and we are experts in designing, developing, implementing, upgrading, and maintaining digital business applications. Our mission is to help our customers to gear up for the future and to succeed in the digital transformation. Any change is daunting, but we will be there, every step of the way.

Our secret to success is a comprehensive solution portfolio, deep industry knowledge, extensive technical expertise, and profound customer insight. And of course, our entrepreneurial environment, passion to develop ourselves and strong team spirit. This has worked very well for us for over 30 years.

Are you ready to transform with us?

www.columbusglobal.com