1. Who are we?
We are SAM International A/S, CVR-nr. 40308030, Bødkervej 7B, 2. sal, 7000 Fredericia, Denmark. We are a European recruitment agency working the entire Employee Life Circle – Recruitment, Onboarding, Development and Outplacement.
A data controller determines the purposes for which and the manner in which personal data is processed. Personal data is data that can identify you as a living individual. SAM International A/S (henceforth SAM) is the data controller of the personal data you choose to upload to us through our website and of the data which will be collected by way of cookies on our website.
At SAM we take data privacy seriously. We appreciate and recognise the trust you place in us when providing us with your personal data and are conscious of our responsibility when processing your personal data. We are committed to safeguarding the privacy and the security of your personal data and take the outmost care and all necessary and adequate measures to protect your personal data and ensure your rights as a data subject. Your personal data will be used lawfully, fairly and in a transparent manner.
- explains on what lawful basis and why we collect and process your personal data
- explains how we collect and process your personal data
- sets out the nature of the personal data that we collect about you
- explains the variety of choices and rights you have in regard to your personal data
- explains the implications of choosing not to provide the personal data requested
- explains the consequence(s) of withdrawing your consent to our processing of your personal data
- sets out how long we will keep your personal data
- explains when, why and with whom we may share your personal data
- explains how we may contact you and how you are able to reach us and how you may complain about our processing of your personal data
3. The purposes of and the lawful basis for collecting and processing your personal data?
At our website, we offer you the opportunity to apply for jobs, find available job openings, set up a search agent, register and upload your cv or resume to our databank and to learn about SAM as a company and about the many services we provide. Depending upon the opportunity you seek out, we may ask for, collect and process your personal data. You are not obligated to divulge any personal data. If you do not divulge personal data, there may be limits on the services we are able to provide to you because we use your personal data to match you with a potential employer.
Constituting the lawful basis for collecting and processing your personal data, we adhere to and comply with the requirements of the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (also known as the GDPR) and what may otherwise follow from applicable national law.
Among the valid legal bases, a data controller may rely upon for lawful processing, we typically base our processing of your personal data on having been given your consent – that is to say we must have obtained this consent prior to our processing of your personal data:
- If you choose to apply for a job, set up a job search agent, or register and upload your cv or resume to our cv database i.e., make use of our job opportunity services, we will ask for your consent to use your personal data prior to the upload. Once given (by way of a freely, specific, informed and unambiguous indication of your wishes either by a clear affirmative action or by a statement), the legal basis for our use of your personal data is in place and valid.
- In the course of the recruitment, different test and analysis tools may come into play. You will be asked to give your consent prior to undergoing this testing and evaluation.
- If it is felt necessary to contact a reference, it will only take place if you have provided contact details of said reference and have given us your consent to contact the reference.
- At times, we will perform an external search ((a.k.a. headhunting). Most often, this search is based on the legitimate interest of finding talented candidates to recruit, however it may also be based on the information or mediation of an offer. When engaging in an external search, our search will not include more data than strictly necessary and relevant to the job and we respect the potential candidate’s restrictions in terms of availability to the job market.
Following our search on the web, if you are seen as a potential candidate, we will contact you and ask for your consent to proceed. At this point, we will:
- inform you about the personal data collected up to the point of contact
- provide you with information like the reason why we contact you
- advise you of the sources from which we have gathered your personal data
- inform you of the recipients to receive the personal data
- specify the retention period
- give the legal basis and the rights to object to further use
- When asking for your consent, we will attempt to communicate within the same channel where we found you – e.g., LinkedIn, LinkedIn Recruiter or Xing. If you decide to give us your consent, we will ask you to upload your consent by registering your cv or resume in our CV database. Without this consent there will be no export of the data into our CRM- or e-mail program and our recruitment efforts will cease.
At any given time, you are entitled to withdraw your consent to our processing of your personal data. Once you withdraw your consent, it will take effect from this point in time. Your withdrawal of your consent therefore does not affect the legality of our processing up until this point in time.
4. How do we collect and process your personal data and what is the nature of this personal data?
Besides the situation where you are merely visiting our website, cf. about cookies below, we collect the personal data we deem necessary to be able to match you with available job-openings and potential employers, and the information needed to allow us to assess your eligibility through the different stages of a recruitment. The personal information includes your name, address, telephone number, e-mail address and subsequently educational records, qualifications and skills, cv, resume, current and previous employment and contact details of references. The information may also include day of birth, citizenship, title, gender and what may be learned from test and analysis tools, occupational-, psychological- and cognitive-wise.
We do not collect or process sensitive personal data about you. Sensitive personal data consist of information about ethnic or racial origin, political opinions, philosophical or religious beliefs, biometric data, genetic data, data concerning health or information concerning a natural person’s sex life or sexual orientation.
We will not collect social security numbers as we treat such as sensitive personal data.
We will not collect personal data relating to criminal convictions and offences or related security measures.
As indicated previously, we typically only collect personal data following your consent, cf. your decision to provide us with your personal data by uploading said data through our website at: www.sam-int.com. If we receive personal data in any way other than through an upload, we will contact you and ask you to upload through our website and we will then delete the data received. If your upload has contained sensitive data (thereunder your social security number) or other data we will not collect (relating to criminal convictions and offences or related security measures), we will contact you and you will be asked to re-upload without such data. We will then proceed and delete the data first uploaded.
5. Who do we share your personal data with and to what extent?
By providing your personal data, we can match your experience, skills and education with the needs of our client(s) – that is to say with your potential future employer – and thereby ascertain if you fit the profile for an available job opening. If we find you eligible for an available job opening, we will share your personal data with the client who has initiated a search for said job opening. Once the client receives your personal data, the client then also becomes data controller with all the responsibilities appertaining thereto. If our client finds your profile interesting and chooses you to advance in the recruitment process, we may ask for and collect additional personal data from you and subsequently pass this on to our client.
During the recruitment process, we will divulge your name, age, gender and mail to the selected provider responsible for our test and analysis tools.
If it is felt necessary to contact a reference, it will be with your prior consent.
We share your data with our group entities all of which are situated inside the European Economic Area (EAA).
We have entered into agreements and share data with selected European suppliers who process data on our behalf; e.g., suppliers of IT-support (development, hosting, maintenance and support), and storage service providers including cloud. We demand that our storage service providers have contracts compatible with the GDPR in place if outsourcing.
It stands to reason that we will disclose personal data to authorities to the extent we are under statutory obligation to do so.
6. What rights do you have in relation to your personal data i.e., personal information held by us?
Aimed at giving you as citizen control over your personal data, the General Data Protection Regulation gives you a number of rights in relation to and how we use our personal information, cf. what may follow in addition from national legislation. If you would like to exercise any of these rights, please contact us. The rights are as follows:
- The right to be informed:
- The right of access:
- The right to correction (rectification):
You have the right to have inaccurate or incomplete information about you rectified/updated.
- The right to erasure (a.k.a. the right to be forgotten):
You have the right to have information about you erased or removed, prior to the time of our general ordinary erasure, where there are no compelling reasons for us to hold on to the information. This right is not a general right; exceptions exist.
- The right to restrict processing:
You have the right to have the processing of your personal data restricted, i.e., you are entitled to block or supress further use of your information. This right is not a general right: exceptions exist. If you have this right, it means that in the future we may only process the information – other than for storage – if you have given your consent, or for the purpose of determining, relying on or defending a legal claim or to protect a person or vital public interests.
- The right to object to processing:
You have the right to object to certain types of our otherwise lawful processing of your personal data.
- The right to data portability:
You have the right to obtain and re-use your personal data for your own purposes across different services. It means that should you for instance decide to move, copy or transfer your information from us as data controller to another, this will be an easy process which will be safe and secure, without affecting the usability of your personal data. You have the right to receive the personal data you have provided about yourself in a structured, commonly used, machine-readable and interoperable format.
- The right to withdraw your consent:
As emphasised earlier, if you have given your consent to provide us with your personal data, you have the right to withdraw your consent at any time.
- The right to lodge a complaint:
You have the right to lodge a complaint about the way we handle or process your national data protection regulator.
7. Implication(s) of not providing your personal data?
If you choose not to provide the personal data necessary, we may not be able to match you with available and upcoming job opportunities and there may be limitations to the other services we provide.
8. Consequence(s) of withdrawing your consent for our processing of your personal data?
If you choose to withdraw your prior consent for our processing of your personal data, we can no longer process the data and we will delete the data you have uploaded. Inherently, once consent has been withdrawn, we will be unable to match you with available and upcoming job opportunities and to offer you the services we provide otherwise.
9. From which sources do we collect your personal data?
Collection of your personal data may come from a variety of different sources:
- From you directly. This is the information you provide when registering on or uploading to our website or during the different recruitment stages
- From SAM’s group entities
- Through LinkedIn or other publicly accessible sources
- By reference or word of mouth
- The public domain
11. For how long do we keep your personal data?
Generally, we will only retain your personal data for as long as necessary to fulfil the purposes that it was collected for, provided that there are no specific legal reasons and/or legal requirements stipulating a longer period of time.
As to the personal data provided when having:
- Applied for a job; all that is obtained in connection with the application will be deleted 24 months later counting from the reception. In the run-up to the deletion, you will be notified that this is about to occur. After the 24 months, we will ask for your consent to keep your cv for an additional 24 months
- Been tested (IQ- and personality-wise); all results will be deleted after 12 months
- Set up a search agent; all that you have submitted (i.e., your name and e-mail) will be kept until you choose to unsubscribe
- Registered and uploaded your cv or resume to our databank; said cv or resume will be kept and matched with potential jobs for 24 months counting from the upload. Following this period, and within days, we will contact you by e-mail and ask for your consent to keep and match your cv or resume with potential jobs for another 24 months. If you do not respond within a month, we will consider your cv or resume obsolete and all will be deleted from our databank promptly
12. Automated profiling:
We do not carry out any automated individual decision-making or profiling.
13. Candidate experience survey
We may ask you to give us your feedback by taking part in a satisfaction survey. Your feedback will be completely anonymous and no personal data will be collected.
14. What do we do to protect your personal data?
An essential part of how we conduct our business is ensuring that all personal data is kept safe and secure. In doing so, and in order to protect any information we hold from disclosure, misuse, unauthorized access, alteration, destruction or loss, we have set up and use a range of appropriate technical, organisational and administrative security measures. Procedures are in place to deal with any suspected data security breach and when legally required you will be informed
15. How to keep your personal data accurate and up-to-date?
To the best of our capabilities, we will make sure that your personal data is accurate and kept up-to-date. We recommend that you contact us, should the personal data you have uploaded in your job application, cv, resume or in other relevant material change, so that we can update your data without undue delay.
16. Transfer of data to jurisdictions outside the European Economic Area (EAA)?
There is no transfer of your data to jurisdictions outside the European Economic Area (EAA). We share your data with our group entities all of which are situated inside the EAA.
17. How do you contact us?
18. How will we contact you?
When we contact you, it will be by telephone, e-mail or by way of social media. Please let us know, should you prefer a particular way of communication over another.
19. Complaints to a supervisory authority – when and how?
Any complaint about our processing of your personal data – and irrespective of whether you have contacted us or not – can be submitted to Datatilsynet, the national Danish Data Protection Agency. Datatilsynet is the independent authority that supervises compliance with the rules on protection of personal data. Datatilsynet, Borgergade 28, 5, 1300 København K, can be reached by phone by calling +45 33 19 22 00 or by writing to firstname.lastname@example.org. You may read more about your rights here: https://www.datatilsynet.dk/media/7582/registreredes-rettigheder.pdf
If you’re situated outside of Denmark, please be aware that you are entitled to lodge a complaint or contact the data protection authority in any of the countries where we provide services or products to you. SAM and any of SAM’s subsidiaries will be happy to help you find the name and contact numbers of the data protection authority of the countries where we are present. You may read more about your rights here: https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en
20. Amendments and updates – when and why?