Privacy Policy for Job Applicants
Thank you for applying for a job with KK Group.
1. Data Controller
As part of our recruitment process, KK Group (“we”, “us” or “our”) will process your personal data collected during our recruitment procedure, as set out in this privacy policy. The data controller and the responsible for the processing of your personal data is the legal entity in the KK Group to which you apply (the legal entity in the KK Group to which you apply will be referred to as "KK Group" throughout this document). A list of all legal entities of the KK Group is available here, and you can find more information on the relevant data controller in the posted job opening.
In case of questions regarding the processing of your personal data within the recruitment process or regarding data protection in general, or if you have any trouble identifying the data controller, you can always contact KK Group A/S at GDPR@kkgroup.com.
Please be aware, that we recommend that you do not disclose sensitive personal data, such as information revealing racial or ethnic origin, religion, trade union membership, sexual orientation, health, etc. in your application. In the unlikely event that a certain health condition is required for the ability to perform the duties related to the position in question, we might – after a concrete assessment – request health information from you. In such case our legal basis for such processing of personal data is Article 9(2)(b) of the GDPR. If you are located in Mainland China, we will process your sensitive personal data (incl. health information) on the basis of your consent to the addendum “Processing Personal Sensitive Data of Mainland China Candidate”, cf. Article 13.(1) and Article 29 of the PIPL.
2. How we process your personal data during the recruitment procedure
2.1 If you seek employment with a KK Group entity in Europe
In order to evaluate your application, we will process the personal data, which you have disclosed in your job application and CV as well as any attachments. We will also evaluate your performance and competencies during potential interviews. Under the General Data Protection Regulation (“GDPR”) and Member State law, KK Group is required to inform you of the legal basis for processing your personal data. For the purpose of comply with the GDPR and Member State law, the legal basis for our processing of your personal data is our legitimate interest in processing the information you have given us, cf. Article 6(1)(f) of the GDPR.
Further, we might search the internet for relevant and available information, including content from social media (only from vocationally-oriented networks). We will typically search for information regarding your previous jobs, activities, competencies and performance. We process your personal data on the basis of Article 6(1)(f) of the GDPR, as we have a legitimate interest in finding the most suitable candidates for the position.
If the job position requires you to complete personality tests or similar, you will be informed hereof when we have processed your application. The results of such tests will be treated confidentially but will be included in our evaluation of your application. Our legal basis for such processing of personal data is Article 6(1)(f) of the GDPR.
It may be necessary for us to request your residence permit to verify your eligibility to work in the country where you have applied for a job. We may also request that you provide us with a copy of your passport. We may only request such information and documents from you and you are only required to submit them if and to the extent that this is relevant to establish your citizenship in order to ensure that you are allowed to work in the EU. Such information and documents will be treated confidentially. The legal basis for such processing of personal data is Article 6(1)(f) of the GDPR, as KK Group has an overriding interest in assessing whether the candidate can legally work in Europe.
As part of our evaluation of you and your application, we may wish to take references from your previous and/or current employers. We will only take up references from persons you have explicitly stated in your job application or have informed us of, or if we have explicitly informed you that references will be taken based on the CV prior to your submission of the application. Our legal basis for such processing is Article 6(1)(f) of the GDPR, whereas our legitimate interests in the processing of such data is to gain information on you as a potential employee.
If the position in question involves financial responsibilities (e.g. bookkeeping or accounting), we might – after a concrete assessment – collect and use information about your credit information and rating. This is only permissible in exceptional cases if and to the extent KK Group has an overriding interest in knowing about your financial status. Our legal basis for such processing of personal data is Article 6(1)(f) of the GDPR and/or other applicable laws, whereas our legitimate interests in the processing of such data is to ensure that you are financially responsible.
We may also process your personal data for the purpose of establishment or defence of legal claims - our overriding legitimate interest according to Article 6(1)(f) of the GDPR provides the legal basis for this data processing. Our legitimate interest is to pursue the purposes referred in the previous sentence.
The provision of your personal data is not mandatory, however, if you do not provide us with your personal data, we may be unable to process your job application.
2.1.1 If you apply for a job with KK Group in Poland
If you apply for a job with KK Group in Poland, we will process your name, date of birth, contact details indicated by you and other personal data, which you have disclosed in your job application, CV and any attachments as well as evaluate your performance and competencies during potential interviews in order to evaluate your application. The legal basis for our processing of such personal data is our legitimate interest in processing the information you have given us, cf. Article 6(1)(f) of the GDPR. We also process such personal data based on and to the extent we are obliged to so under the Polish labor law. The legal basis for our processing in this respect is our necessity to fulfil a legal obligation connected with the given recruitment process cf. Article 6(1)(c) of the GDPR.
Further, we may request that you provide us with a medical test in regards to whether you are suitable to work in the relevant position. The medical test only states whether you are suitable for the position, and does not contain any health data in scope of Article 9 of the GDPR. We may only request such information and documents from you and you are only required to submit them if and to the extent that this is relevant for the position you have applied for. Such information and documents will be treated confidentially. The legal basis for such processing of personal data is Article 6(1)(c) of the GDPR, as KK Group has an overriding interest in complying with local polish law.
The data processing is carried out in accordance with Article 22¹ §1 of the Polish Labour Code, which defines the scope of personal data required for recruitment purposes.
Processing of your personal data collected during the recruitment process will only be processed for future job openings if you have provided your consent to this, cf. Article 6(1)(a).
We may also process your personal data for the purpose of establishment or defence of legal claims - our overriding legitimate interest according to Article 6(1)(f) of the GDPR provides the legal basis for this data processing. Our legitimate interest is to pursue the purposes referred in the previous sentence.
The provision of your personal data is not mandatory, however, if you do not provide us with your personal data, we may be unable to process your job application.
Your personal data will not be used by us for automated decision making, including profiling.
2.2 If you apply for a job with a KK Group entity in Mainland China
In order to evaluate your application, we will process the personal data, which you have disclosed in your job application and CV as well as any attachments and information obtained references from your previous and/or current employers. We will also evaluate your performance and competencies during potential interviews. In addition, we may ask you to complete personality tests or similar. Results of personality tests will be treated confidentially. If the position in question involves financial responsibilities (e.g. bookkeeping or accounting), we might – after a concrete assessment – collect information about your credit information and rating. The legal basis for our processing of your personal data is your consent, cf. Article 13.(1) of the Personal Information Protection Law (“PIPL”) of the People’s Republic of China (“PRC”) if you are located in Mainland China.
Further, we might search the internet for relevant and available information, including content from social media. We will typically search for information regarding your previous jobs, activities, competencies and performance. We process your personal data on the basis of Article 13.(6) of the PIPL, since such data are collected by searching publicly available information on the internet.
If you are located in Mainland China, we may process your personal data for the purpose of establishment or defence of legal claims that you are involved in. The legal basis for such processing is “performing statutory duties/obligations”, cf. Article 13.(3) of the PIPL; for legal claims that you are not involved - the legal basis is your consent, cf. Article 13.(1) of the PIPL.
The provision of your personal data is not mandatory, however, if you do not provide us with your personal data, we may be unable to process your job application.
Your personal data will not be used by us for automated decision making, including profiling.
2.3 If you apply for a job with a KK Group entity in India or Taiwan
KK Group will only collect and process personal data about you, which is considered necessary in relation to the recruitment process when you apply for a job with KK Group. If you apply for a job with a KK Group entity in India or Taiwan, we will process your personal data on the basis of your consent. If you do not provide us with your personal data, you may be ineligible for hiring, assuming certain job duties/positions, or receiving relevant employee benefits.
3. Our storage of your personal data
If you are offered a position with KK Group, your application and additional relevant personal data obtained during the recruitment procedure will be stored in your employee file held by the KK entity with which you are employed.
If you are not offered a position, we will store your application and any additional personal data obtained during the recruitment procedure for a period of 6 months following our rejection, unless you have provided your consent to the storage hereof for a longer period.
If you want us to store your application and CV for the purpose of future job openings, you must provide us with your consent. In such a case we will keep your CV until you withdraw your consent or until 1 year passes as of the date we received your application (whichever occurs earlier).
4. Recipients of your personal data
During the recruitment process, only those KK Group employees (including employees of other legal entities of KK Group) who are directly involved in the recruitment process have access to the candidate's information. This may involve employees of other KK Group entities which provide recruitment assistance or are involved as your potential future manager.
Your personal data may be made available to third parties when providing relevant services to KK Group or by other means process personal data on behalf of KK Group such as providers of our recruitment platforms, personality tests and communication tools as well as external recruiters. Such service providers will only process the personal data exclusively for the purposes of the recruitment process as well as on basis of a data processor agreement and in accordance with our instructions.
If you are located in Mainland China, the personal data disclosed to our group companies will be limited to a scope of strictly necessary for the performance of our legal duties/obligations, cf. Article (3) of the PIPL, or for the response to a public health emergency or for the protection of the life, health and property safety of a natural person in an emergency, cf. Article (4) of the PIPL; we will not disclose your personal data beyond the aforesaid scope unless we obtain your consent in this regard.
We may also share your personal data with other third parties such as:
• Providers of certain tests (if you are located in Mainland China, we share your personal data with the providers on the legal basis of your consent), e.g. personality tests
• External advisors (if you are located in Mainland China, we share your personal data with advisors on the legal basis of your consent)
• Public authorities as required by applicable laws
Your personal data is transferred to data processors and sub-processors which are established in countries outside the EU/EEA, including KK Group entities, that do not ensure an adequate level of data protection. Such transfers are based on the EU Commission’s standard contractual clauses which you have a right to access. Transfers of your personal data to third countries with an adequate level of protection are based on an EU Commission adequacy decision.
If you are located in Mainland China and your personal data is transferred to data controllers or data processors which are in countries/regions outside Mainland China, including group entities, such transfer will be based on the applicable cross-border data transfer mechanisms required by the PIPL. You shall also consent to the addendum “Cross Border Data Transfer - Mainland China Candidate”.
5. Your rights
Any consent that you may have provided during the recruitment procedure may be withdrawn at any time. The withdrawal of your consent will affect the future processing of your personal data but will not affect the lawfulness of processing based on consent before its withdrawal. If you wish to withdraw a consent, you may contact us as stated below.
You have a right of access to the personal data processed about you, subject to certain statutory exceptions. Furthermore, you have the right to object to the processing and request restriction of the processing of your personal data. In addition, you also have the right to request rectification, including completion if necessary or that your personal data is deleted subject to certain exceptions.
In certain situations, you may also request that we provide you with a copy of your personal data in a structured, commonly used and machine-readable format and request us to transmit such personal data which you have provided us with to another data controller.
If you want to exercise any of your rights, if you have any questions regarding this privacy policy or the processing of your personal data, you can always contact us at GDPR@kkgroup.com.
Should you have any complaints regarding the processing of your personal data, please contact us at GDPR@kkgroup.com. You may also file a complaint with the competent data protection supervisory authority in your country. A list of relevant supervisory authorities can be found here.
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If you want us to take your CV into a consideration during future recruitment processes in the KK Group, please include the consent outlined below in your application. Providing consent for future recruitment is entirely voluntary and may be withdrawn at any time without affecting the legality of prior processing.
“I hereby consent that KK Group stores my personal data collected during the recruitment procedure for [insert relevant KK Group entity] in order to be eligible for relevant vacancies with the KK Group in the future.”