RECRUITMENT PRIVACY

PROCESSING OF PERSONAL DATA IN THE RECRUITMENT PROCESS IN BRØCHNER HOTELS

1 - INTRODUCTION AND DEFINITIONS

• When you apply for a position with Brøchner Hotels A/S and all hotels under Brøchner Hotels group, you give us consent to collect, register and process personal data about you. This consent will be limited for 6 months. The following describes how we process your application and which personal data we collect including which procedure we typically follow. Hotels under Brøchner Hotels group: Hotel Astoria, Hotel Avenue, Hotel SP34, Hotel Danmark, and Hotel Otilia.
• Any reference to "we" or "us" in this policy means a reference to Brøchner Hotels A/S and all hotels under Brøchner Hotels group
• When used in this policy the following words and expressions have the meanings stated below unless the context requires otherwise:
  • "data protection laws" the legislation, as amended from time to time, protecting the fundamental rights and freedoms of individuals and, in particular, their right to privacy with respect to the processing of personal data applicable to [company], including but not limited to the GDPR and the Danish Data Protection Act.
  • "Data Protection Act" means the Danish Act concerning supplementary provisions to the general data protection regulation (databeskyttelsesloven).
  • "GDPR" means the EU General Data Protection Regulation (databeskyttelsesforordningen).
  • "personal data" means any information relating to you as a data subject.
  • "processing" or "processed" means any operation which is performed on the personal data, such as collection, recording, organization, structuring, storage, adaption or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
• You have certain rights because we process your personal data. We will inform you of these in clause 11

2 - ACCEPTANCE OF APPLICATIONS

• When we receive your application we will send you a confirmation stating that we have received it. When we go through the applications we will select the applicants that we call in for an interview. This selection is based on how your qualifications relate to the position or positions. The call-ins for an interview will take place by email or telephone.

3 - COLLECTION OF PERSONAL DATA AND REFERENCES

• As a step in the recruitment process, we receive and process the personal data you have disclosed in your application, your resumé, and other potential documents.
• In addition to the above-mentioned, we will in most cases seek additional information about the applicant(s) that we deem most qualified. We will often seek out relevant available information on the internet, including social media. We might also ask you to send us some additional information. The information that we collect in this connection will, unless we specifically inform you of something else, include the following categories: information about your activities at a former place of employment, including information about your job assignments and competencies, your performance, your personal appearance, and interpersonal skills, and other information about you that has been made publicly available on the internet, to the extent that we deem this information as relevant for the assessment of your application.
• If we would like to collect information about you from your current or former employer by collecting references, we will ask for your consent in advance. If you refuse to consent, we will not collect your references. Please be aware that if you refuse to consent to our collection of your references it might result in our selection of another applicant for the position. The information that we collect in this connection will, unless we specifically inform you of something else, include the following categories: information about your activities at a former place of employment, including information about your job assignments and competencies, your performance, your personal appearance, and interpersonal skills, and the reason why you are no longer employed by or wants to be employed by the employer in question. As a consequence of the collection, we might receive sensitive personal data, including personal data concerning health, cf. art. 9 of the GDPR.
• The basis for processing the personal data that you disclosed in your application. The legal basis is section 6(1) of the Data Protection Act and 6(1)(a) or art. 6(1)(b) of the GDPR.
• The basis for processing the personal data that we collect from your current or former employer is the consent you have given to the collection of references. The legal basis is section 6(1) of the Data Protection Act and art. 6(1)(a) of the GDPR.
• If we seek out personal data concerning you on the internet, the basis for processing is either that you have disclosed the personal data yourself or that our assessment is that the collection follows a legitimate interest, because the purpose is to assess whether you are the right applicant for the position. See also subclause 2.

4 - INTERVIEWS

• During the recruitment process, we carry out interviews where the focus is on both your professional and personal competencies, the challenges of the position, and how it is to work at our hotel(s).
• We take notes of some of the personal data that is mentioned during the interview(s). We only take notes of the personal data that are relevant for our assessment of whether we should offer you a position or not.
• The basis for processing the personal data that you disclose during the interview(s) is either your consent or because it is necessary prior to enter into an employment contract for (see subclause 3.4 above). Also, the collection may follow a legitimate interest, because the purpose is to assess whether you are the right applicant for the position that you have applied for. The legal basis is section 6(1) of the Data Protection Act and art. 6(1)(f) of the GDPR.

5 - USE OF PERSONALITY TESTS

• During the recruitment process, we use personality tests when filling out certain positions. This requires that you consent to our processing of the results of the personality test. [The consent is given in connection with your completion of the test.][ALT: You will be asked to fill out a consent form and you will be provided with a copy hereof afterward.] Please be aware that if you refuse to consent to the use of personality tests it might result in our selection of another applicant for the position.
• The test is usually completed after we have carried out one or more interviews with you. The purpose of the test is to clarify your competencies, so we have a starting point for a dialogue about your personal resources, strengths, and weaknesses.
• The test will never stand alone, instead, it forms a part of the collected material that we use for our selection of the right applicant for the position.
• The basis for the processing of the personal data that we take note of and store in connection with your personality test is the consent that you submit to us. The legal basis is section 6(1) of the Data Protection Act and art. 6(1)(a) of the GDPR.

6 - CRIMINAL RECORDS

• During the recruitment process, we sometimes make use of criminal records. If we consider it relevant to collect your criminal record in relation to the position you have applied for we will ask for your consent to do so.
• Whether to collect criminal records depends on which position you have applied for including the responsibility and executive powers that the position entails.
• The basis for collecting your criminal records is the consent that you submit to us before we request your criminal records. The legal basis is section 8(3) of the Data Protection Act and art. 6(1)(a) of the GDPR, cf. the Danish Executive order on the processing of personal data in the central crime register (bekendtgørelse om behandling af personoplysninger i Det Centrale Kriminalregister).

7 - PERSONAL DATA CONCERNING HEALTH

• In certain situations, we might request personal data concerning your health. This can be relevant in situations where disease could have a detrimental effect on your ability to perform the duties that the position requires.
• If we after a concrete assessment decide that it is necessary to request personal data concerning your health information, we will indicate which diseases or symptoms of diseases we request information about. We will, of course, respect the limits that the law contains on this matter.
• The basis for collecting and storing personal data concerning your health is the consent that you submit to us before the collection takes place. The legal basis is art. 9(2)(a) of the GDPR.]

8 - CREDIT RATING INFORMATION

• If you are applying for a position of trust including if you will be taking on a position as manager with financial responsibilities or accounting and bookkeeping tasks we will want to collect personal data about your credit rating from a credit rating agency.
• If we collect personal data about your credit rating you will receive an individual notice concerning this matter, including that we have run a check on you with a credit rating agency and if we will be storing the credit information afterward.
• The legal basis for collecting and storing personal data about your credit rating is that our assessment is that the collection follows a legitimate interest because the purpose is to assess your financial solidity and credit rating to be able to assess if you are the right applicant for the position that you have applied for. The legal basis is section 6(1) of the Data Protection Act and art. 6(1)(f) of the GDPR.]

9 - THE PROCESS FROM HEREON

• The applicant who has been interviewed will either receive notification by email or telephone. Once we have filled the position we will inform all the applicants we cannot offer a position in writing.
• If you are employed by us, the personal data that we have received and processed during the recruitment process will be filed in your personnel file in accordance with our guidelines on this matter. You will receive information concerning the processing and storage of your personal information in the Employee Privacy Notice.
• If we cannot offer you a position we will delete your personal data as soon as possible and no later than 6 months after you are informed about not being offered a position.

10 - CATEGORIES OF RECIPIENTS ETC.

• The personal data that you have disclosed or transferred to us may be transferred to other hotels in our group.

11 - INFORMATION ABOUT YOUR RIGHTS ETC.

• Data protection law gives you a range of rights in connection with our processing of your application and your personal data.

In this regard, you have the right to:

• be notified if we collect personal data concerning you and store it in our IT system,
• gain access into which personal data concerning you that we have collected and used in our processing of your application,
• object against or request that we restrict the processing or rectify or erase the personal data etc, e.g. if you think that the personal data are inaccurate.

Additionally, you also have the right to data portability if it should become relevant.

• Personal data that is collected as a part of the recruitment process will be processed with the necessary security and confidentiality and the personal data will only be available to a limited number of employees for whom the access to personal data is necessary and relevant, including future managers and employees in the HR division.
• You can withdraw your consent to the processing of your personal data at any time. This is done by contacting us using the contact information provided below in clause 12.
• You can read more about data protection law and your rights on the webpage of Datatilsynet: datatilsynet.dk.
• You have the right to file a complaint with Datatilsynet if you have reason to believe that processing of your personal data does not comply with data protection law. The contact information of Datatilsynet is: Datatilsynet, Borgergade 28.5, 1300 Copenhagen K, telephone: 0045  3319 3200, email: dt@datatilsynet.dk

12 - CONTACT INFORMATION

• If you have any questions regarding this notice, please contact:

Sidsel Koch Hansen
Coordinator of People & Culture
D: 00 3395 7700
E: job@brochner-hotels.dk.