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Privacy Notice - Job Applicants

This Privacy Notice was last updated on December 27, 2022.

IDENTITY OF THE DATA CONTROLLER

The data controller is Pharmacosmos A/S, Roervangsvej 30, DK-4300 Holbaek, Denmark.

1. Processing of your personal data

For the purpose of administering and processing your application, and to assess your eligibility for the role for which you are applying, Pharmacosmos A/S (“Pharmacosmos”) will collect and process personal data concerning you. In doing so, we become the data controller in respect of the personal data reprocess about you. 

Our contact details are:
Pharmacosmos A/S
Roervangsvej 30
DK-4300 Holbaek
Denmark

E-mail: dataprotection@pharmacosmos.com

We kindly ask you not to include any special categories of personal data in your job application, unless you believe such information is strictly relevant and necessary for us to assess your application.

This may be information relating to your health, union membership or racial or ethnic origin. If you believe such special categories of data are strictly relevant and necessary for us to be able to process and assess your application, we will consider your forwarding of such data to us as your specific and explicit consent for us to process this data for the purposes set out in this privacy notice.

If relevant for the position you have applied for, we may ask you to provide us with a copy of your criminal record and subsequently process information herein when assessing your application. Providing us with a copy of your criminal record is subject to your consent but please note that if you do not want to provide this information, this may affect your chances of being offered a position with us.

Below, you will find a description of the personal data concerning you that Pharmacosmos will collect and process as well as the purposes for which, and the legal basis on which, Pharmacosmos will process the data. You will also find a list of your rights under the applicable data protection law.

2. Confidentiality and information about processing of your personal data

All data will be treated as confidential information by those who are allowed to process it and will only be used for the purposes described in section 4. 

Your personal data will be stored or processed by Pharmacosmos or third parties on a need to know basis. Third parties are understood as IT hosting, supply and service companies that Pharmacosmos uses for its IT environment or external recruitment agencies that Pharmacosmos uses for recruitment purposes. This is further addressed below.

3. What types of personal data does Pharmacosmos collect?

"Personal data" means any information relating to you. Pharmacosmos – and, where necessary, third parties – will collect, process, store and use the following types of personal data: 

  • Identification data, such as your name, nationality, driving license details (where needed to fulfil employment duties).
  • Personal information, such as your date of birth, gender (if included in the CV).
  • Contact details, such as your home address, telephone number and e-mail address.
     
  • Education and work experience, such as contact details for your current/former employer, information about your educational background, work experience and other related experience.
     
  • Other application data, such as the information contained in your application form/CV.
     
  • Information collected as part of the interview process, such as notes taken during your interview, information provided by recruitment agencies and personality test and/or capability test where relevant.
  • Background check information, such as information obtained through reference checks and confirmation of your education and employment history, and criminal record data, where relevant and appropriate to the role for which you are applying.

4. For what purposes does Pharmacosmos use your personal data?

We collect and use your personal data for a variety of purposes linked to your application for a role with us (“Processing Purposes”), which we have set out below together with examples of relevant data: 

  • Administering and processing your application (including processing a job offer should you be successful), which involves the processing of identification data, contact details, information about your education and employment history, information obtained during your interview, and information contained in your CV and accompanying documents.
  • To determine your eligibility for the role for which you are applying, which involves the processing of identification data, contact details, information about your education and employment history, and information obtained during your interview and contained in your CV.
  • Conducting background checks as part of your application, which involves the processing of identification data, contact details, information about your education and employment history, and criminal record datain the event that Pharmacosmos needs to conduct or obtain the results of criminal record background checks in relation to you in the process of your application, where this is relevant and appropriate to the role for which you are applying, e.g. in order to prevent fraud, misuse of company IT systems or money laundering.
  • Complying with applicable laws, such as employment laws, and employment-related requirements, as well as the administration of those requirements, which involves the processing of identification data and contact details.
  • Communicating with you, other Pharmacosmos employees and third parties (e.g. referees, including former employers, listed in your CV or provided by you, external recruitment agencies), which involves the processing of types of personal data as per section 3 above (i.e. identification data, personal information and contact details).

Responding to and complying with requests and legal demands from regulators or other authorities within or outside your home country, which involves the processing of identification data and contact details

5. Why does Pharmacosmos need to collect, process and use your personal data?

Pharmacosmos needs your personal data to carry out a variety of activities linked to your application for a role with us and to Pharmacosmos’ compliance with its obligations as a business in relation to the recruitment process.

6. What is Pharmacosmos’ legitimate basis for processing your personal data?

All of the above Processing Purposes are necessary and standard preparatory steps in the first 6 months of a recruitment process potentially leading to an employment contract for which you have applied. Consequently, our legitimate basis for all Processing Purposes is article 6.1.b of the General Data Protection Regulation (the “GDPR”). 

Prior to obtaining a copy of your criminal record, we will always seek your prior written consent and consequently for this specific purpose our legitimate basis will be article 6.1.a of the GDPR.

7. Transfer of your personal data to third parties

Pharmacosmos may transfer your personal data to third parties for the following processing purposes: 

  • Data processors. Where necessary for the processing purposes described above, personal data may be shared with one or more third parties to process your personal data under appropriate instructions ("data processors"). Data processors, including recruitment companies, IT hosting companies and IT services companies, will be subject to contractual obligations to implement appropriate technical and organisational security measures for safeguarding the personal data and to process the personal data only as instructed.

For a full list of the third parties with whom we may share your personal data, please contact us. Some of the parties with whom we share your personal may be located in countries outside the European Union and/or European Economic Area (EEA).

Some countries where recipients are located already provide an adequate level of protection for personal data. If recipients are located in countries without adequate protections for personal data, Pharmacosmos will take all necessary measures to ensure that transfers out of the EU/EEA are adequately protected, as required by applicable data protection law. This will include using appropriate safeguards such as the EU Standard Contractual Clauses. You can ask for a copy of the relevant EU Standard Contractual Clauses by contacting us (see section 11).

8. How long will Pharmacosmos keep your personal data?

It is our policy not to keep personal data for longer than is necessary. We will keep your  personal data for six months after your application process is completed, which is considered a reasonable time.

9. Your rights regarding your personal data

You are entitled to certain rights when we process your personal data. Below, you will find a summary of these rights. Please contact us using the contact information below, if you wish to exercise any of these rights. 

(i)     Right of access 

You have the right to confirm with us whether your personal data is processed, and if it is, to request access to that personal data and to be informed of the types of personal data processed, the purpose of the processing and the recipients or categories of recipients. 

(ii)    Right to rectification 

You have the right to have your personal data corrected, for example if it is inaccurate or incomplete. 

(iii)    Right to erasure and restriction 

You have the right to restrict or object to the processing of your personal data or request erasing of your personal data (in certain circumstances and subject to applicable law). In the event of an erasure request, we may retain a copy of your personal data for record-keeping purposes and to avoid entering your personal data in our systems after your request. 

(v)    Right to data portability 

You have the right to receive a copy of your personal data, in a structured, commonly used and machine-readable format. 

(vi)    Right to withdraw your consent 

You may at any time withdraw any consent given, for example your consent to us obtaining a copy of your criminal record. If you wish to withdraw your consent, please contact dataprotection@pharmacosmos.com. 

Please note, withdrawal of your consent does not affect our processing of your personal data under the consent prior to the withdrawal.

 (vii)    Right to complain

 You also have the right to lodge a complaint with the competent data protection supervisory authority (see section 10 below).

 To exercise any of these rights, please contact our Data Protection Manager at dataprotection@pharmacosmos.com

10. Complaints

If you are concerned about an alleged breach of privacy law or any other regulation by Pharmacosmos A/S, you can contact us (see contact details below). The complaint will be handled in accordance with applicable law. 

If you are not satisfied with the way in which Pharmacosmos A/S has resolved your complaint, you have the right to complain to the data protection authority in your country (for Denmark: the Danish Data Protection Agency at: dt@datatilsynet.dk).

11. Contact information

If you have questions or you do not feel that your concerns have been addressed in this Privacy Notice, please contact us either by mail, Attention: “Data Protection Manager” to the address: Pharmacosmos A/S, Roervangsvej 30, DK-4300 Holbaek, Denmark or by email to: dataprotection@pharmacosmos.com

12. Updates to this Privacy Notice

From time to time, we may revise this Privacy Notice. Any such changes will be reflected on this page. Pharmacosmos A/S recommends that you review this Privacy Notice regularly for any updates. The date on which this notice was last revised is located at the top of this Privacy Notice.

Privacy notice - job applicants version 4: 2022-12-27

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