Privacy Policy

1. GENERAL INFORMATION

1.1 This document concerns Hammer Andersen I/S, CVR-no. 29231974, Hammer Andersen Industrial ApS, CVR-no. 41350075 and Hammer Andersen ApS, CVR-no. 41350075 with registered addresses at Virumvej 90 B, 2830 Virum and Skæringvej 94, 8520 Lystrup (“Hammer Andersen”, “we” or “us”) and contains Hammer Andersen’s Privacy Policy regarding the processing of Personal Data, as further described in this document (this “Privacy Policy”).

1.2 We are a recruitment company, and we process personal data for the purpose of filling positions at our clients’ companies as well as helping people advance in their careers.

2. DEFINITIONS

2.1 “Applicable Data Protection Legislation” refers to the General Data Protection Regulation (Regulation No. 2016/679), which is supplemented and implemented by Act No. 502 of 23 May 2018 (the Data Protection Act) and related national legislation, as well as the European Parliament and Council Directive 2002/58/EC of 12 July 2002 on the processing of personal data and the protection of privacy in the electronic communications sector (the E-Privacy Directive) and national implementations thereof.

2.2 “Personal Data” means any type of information about a natural person that, directly or indirectly, can be identified by an identifier such as name, address, location data or IP addresses.

2.3 “Processing” means any activity to which personal data is subjected, such as collection, organization, storage, deletion or disclosure.

2.4 “Data Controller” refers to us in this case, as we determine the purposes and means by which the Processing of Personal Data is carried out.

3. PROCESSING OF PERSONAL DATA

3.1 We process the following Personal Data about you if you register in our CV database or apply for a position via our website:
(a) email;
(b) full name;
(c) address;
(d) citizenship;
(e) gender;
(f) date of birth;
(g) mobile number;
(h) education level; and
(i) CV.
The above Processing of Personal Data is necessary to register you in the CV database or to enable you to apply for a position.

3.2 In addition, we may process the following information about you as registered in the CV database, if you have provided us with this information:
(a) which industries you have been in for the last 5 years;
(b) which geographic area you wish to work in;
(c) whether you wish to relocate from your current residence;
(d) an indication of salary level;
(e) which languages you speak and write at a business level;
(f) whether you are subject to a non-compete and/or non-solicitation clause;
(g) application;
(h) photograph; and
(i) other documents in the form of diplomas.

3.3 In specific cases, we may also process the following Personal Data about you:
(a) from any references, we may obtain additional information about you as a candidate for a potential position, and this information may contain Personal Data about you;
(b) information about you from any completed personality or aptitude tests;
(c) information about you that we record when you attend an interview with us;
(d) criminal records, if specifically requested by our client; and
(e) publicly available information that you have on your LinkedIn and Facebook profiles.

3.4 When you subscribe to our job agent, we register your email. If you have provided us with the following information, we also process: your full name, the workplaces, job titles and industries you are interested in.

3.5 We process the following Personal Data about you when you register with us as a Corporate Client:
(a) contact information for specific employees at the company, in the form of name, email address, telephone number;
(b) contact information in the form of full name for the employees at the company who are to be trained in our services;
(c) CVR number; and
(d) payment information.

3.6 We process the following Personal Data about you when you subscribe to our newsletter:
(a) the name of the company where you are employed;
(b) full name; and
(c) email.

4. PURPOSE OF THE PROCESSING

4.1 We process the above Personal Data for the following purposes:
(a) to register you in our database, to process your application, and to provide and deliver our Services;
(b) to manage our customer relationship with you and to provide and deliver our Services to you;
(c) to inform you about service notifications and to communicate with you; and
(d) to deliver marketing material from us.

5. AUTOMATED INDIVIDUAL DECISIONS, INCLUDING PROFILING

5.1 Your Personal Data is not subject to automated processing.

6. LEGAL BASIS

6.1 Below you can see for each processing purpose on what basis we process your Personal Data:

Personal Data	Purpose	Legal Basis for Processing
- email; - full name; - address; - citizenship; - gender; - date of birth; - mobile number; - education level; and - CV.	To register you in our database, to process your application, and to provide and deliver our Services. See item above: 4.1(a).	You have given consent for the processing of the Personal Data at the time of your registration.
- which industries you have been in for the last 5 years; - which geographic area you wish to work in; - whether you wish to relocate from your current residence; - an indication of salary level; - which languages you speak and write at a business level; - whether you are subject to a non-compete and/or non-solicitation clause; - application; - photograph; - other documents in the form of diplomas; - information about you that we record when you attend an interview with us; - information about you from any completed personality or aptitude tests; and - publicly available information that you have on your LinkedIn profile.	To process your application and to provide and deliver our Services. See item above: 4.1(a).	The processing is necessary to pursue our legitimate interests. Our legitimate interest in the processing is to find the right candidate for a specific position.
- from any references, we may obtain additional information about you as a candidate for a potential position, and this information may contain Personal Data about you	To process your application and to provide and deliver our Services. See item above: 4.1(a).	You have given consent for the processing of the Personal Data. The consent is obtained via email when relevant for a specific position.
- criminal record, if specifically requested by our client.	To process your application and to provide and deliver our Services. See item above: 4.1(a).	You have given consent for the processing of the Personal Data. The consent is obtained via email when relevant for a specific position.
CORPORATE CLIENTS - contact information for specific employees at the company, in the form of name, email address, telephone number; - contact information in the form of full name for the employees at the company who are to be trained in our services; - CVR number; and - payment information.	To manage our customer relationship with you and to provide and deliver our Services. See item above: 4.1(b).	The processing is also necessary to comply with a legal obligation imposed on us, as we are required to store certain information according to the Accounting Act. See more under section 10.
- name, - email, and - telephone number.	To inform you about service notifications and to communicate with you. See item above: 4.1(c).	The processing is necessary to pursue our legitimate interests in communicating with you.
- name of the company where you are employed; - full name; and - email.	To deliver marketing material from us. Consent is given by subscribing to newsletters on our website. See item above: 4.1(d).	You have given consent for the Processing of your Personal Data.

6.2 You have an unconditional right to object to the Processing of your Personal Data for direct marketing purposes. You also have the right to withdraw your prior consent. The withdrawal of your consent has no consequences for the lawful Processing of Personal Data prior to the withdrawal, and we may continue to process your Personal Data on another legal basis, apart from direct marketing.

6.3 If you object to the Processing of your Personal Data, which is based on our legitimate interests, we will immediately cease processing your information for these purposes.

7. RECIPIENTS OF PERSONAL DATA

7.1 We may share and disclose your Personal Data to the following relevant recipients:
(a) Employees at the recruitment companies Hammer Andersen I/S, Hammer Andersen Industrial ApS and Hammer Andersen ApS;
(b) an external recruitment system and CV database from Talentech Danmark ApS, including Talentech Talent Recruiter, as the provider of the CV database;
(c) external providers of personality and aptitude tests; e-stimate from e-stimate ApS, Wave from Saville Consulting Danmark A/S and Extended Disc from HR Solutions A/S.
(d) our partner Certa Intelligence & Security A/S to conduct background checks – if applicable, you will give separate consent for the disclosure of your Personal Data;
(e) our clients, if you have given your consent for us to disclose your Personal Data; and
(f) external auditors, advisors and public authorities.

7.2 We follow the Danish Data Protection Agency’s guidelines on transferring Personal Data to third countries.

7.3 When you visit our website, you may be directed to other websites where the Processing of your Personal Data is not under our control. The privacy policy of the other websites governs the Processing of your Personal Data on that website.

8. RESPONSE TO LEGAL REQUESTS AND PREVENTION OF DAMAGE

8.1 We may access, preserve and disclose your Personal Data in order to respond to a legal request (for example, search warrants, court orders, subpoenas or similar), or if it is necessary to detect, prevent or prosecute fraud or other illegal activities, or to protect ourselves, you or other users, including as part of an investigation.

9. COOKIES, PIXELS AND OTHER SYSTEM TECHNOLOGIES

9.1 We collect and store information using technologies such as cookies, pixels and local storage (on your browser or device).

9.2 Our website provider is Dan ApS. The Data Controller for the website is Hammer Andersen. The Data Processor for the website is Dan ApS https://www.dan.dk/. Data for Dan ApS is stored in Denmark. However, there is an integration on the website from Talentech Talent Recruiter. The respective parties are Data Processors for their respective integrations. See possibly earlier in the text.

9.3 The website and our recruitment system use two different sets of first-party cookies during their operations. The first set consists of so-called session cookies, which are necessary to identify users and enable them to log in to the system, update their CV or apply for positions. The second set consists of Google Analytics cookies, which are used to collect reports on visits to the website and to refine the user experience and usability. All cookies are first-party cookies and collect anonymous data. All data is strictly for internal use and is not shared with any third parties.

10. RETENTION OF PERSONAL DATA

10.1 When you are registered in our CV database or have applied for a position with us, you can view some of the Personal Data we have about you by logging in with your username and password. You can always delete your profile in our CV database yourself. You can also ask Hammer Andersen to delete your data from our systems.

10.2 We retain your Personal Data for the following period:

Category of Personal Data	Retention Period
Application for a specific position	When you apply for a position through the system, we automatically delete your data after 6 months. One month before the period expires, we send you a reminder email asking if you wish to remain in our CV database. This must be accepted, otherwise we will delete your data.
Registration in the CV database	If you register in our CV database, we automatically delete your data after 18 months. One month before the period expires, we send you a reminder email asking if you wish to remain in our CV database. This must be accepted, otherwise we will delete your data.
Criminal record	A criminal record, obtained in relevant cases through you. You must give consent for this, even if it is you who obtains the criminal record. You must also give consent for us to disclose the record to our client. We delete the record at Hammer Andersen after it has been sent to our client.
Communication via LinkedIn	We often communicate with candidates via LinkedIn’s email system. These email dialogues will be deleted no later than after 6 months. LinkedIn data and emails via LinkedIn’s email system are stored by LinkedIn.
Personality test and/or aptitude test	We may collect information about you if you are required to complete a personality test or aptitude test. You will always receive a full report of your analyses, so that you see the same report/material that both Hammer Andersen and the company you are being presented to receive. The reports will be stored by our personality analysis provider (see providers in item 7.1) for up to 6 months, after which they will be deleted.
Background check	Reports and data provided via Certa Intelligence & Security’s background check will be deleted both at Certa and Hammer Andersen after processing is completed. You must give separate consent for the background check, as well as for the areas we typically wish to cover. You must also give consent for us to disclose the results of the background check to our client.
Correspondence between Hammer Andersen and candidates	Correspondence between Hammer Andersen and candidates is deleted after 6 months. Note that if you apply by email, you will be asked to apply via our recruitment system. Your submitted email will be deleted immediately thereafter.
Correspondence between Hammer Andersen and companies containing candidate data,	Correspondence between Hammer Andersen and companies containing candidate data is deleted after 6 months – except emails containing data of employed candidates via Hammer Andersen. These are deleted after 18 months.
Personal Data on clients	We retain information on our clients in accordance with accounting rules, which require retention for 5 years plus the ongoing calendar year after the end of the financial year.
Consent - registration of Personal Data	If we have obtained your consent to register your Personal Data, we will retain this consent in accordance with applicable rules.
Consent -marketing	If we have obtained consent for marketing, we will retain the consent as long as we use it and until two years after it was last used.
Consent – disclosure to client	If we have obtained your consent to disclose your Personal Data to a company for which we are performing a recruitment task, we will retain this consent in accordance with applicable rules.
Consent - reference	In the same email you give us consent to contact the persons for reference information, as well as that we may disclose the content of the conversation in writing and/or verbally to the company for which you are in a recruitment process. Your consent is retained as evidence that we have received your consent.

10.3 We store information in an anonymized form for statistical purposes. This means that it is not Personal Data, as the information cannot be attributed to a natural person.

11. CHILDREN

11.1 The service is not aimed at persons under 18 years of age (“the Child”). We do not collect Personal Data about persons under 18 years with knowledge thereof. Please contact ha@hammerandersen.com if you become aware that a child, for whom you are a parent or guardian, has given us access to Personal Data without your consent, in order to exercise your right to obtain access to, rectify, delete, restrict the Processing of Personal Data or object to the Processing.

12. YOUR RIGHTS

12.1 When you are registered in our CV database or have applied for a position with us, you can view some of the Personal Data we have about you by logging in with your username and password. Here you can create, delete, and edit your Personal Data yourself. You can also have us help you with this.

12.2 You are entitled to request access to and further information about the Processing of your Personal Data, or request that we rectify, complete, delete, or restrict the Processing of your Personal Data. You are entitled to request a free copy of your Personal Data that we process twice (2) per year. We are entitled to charge a reasonable fee based on our administrative costs if you request additional copies.

12.3 You are entitled to have the Processing of your Personal Data restricted if; (i) you contest the accuracy of the Personal Data, (ii) the processing is unlawful and you have requested a restriction thereof, (iii) we no longer need your Personal Data for the original purpose, but we require it to establish, exercise or defend rights, or (iv) an assessment of which interest weighs more heavily in connection with a request for deletion is underway.

12.4 Where our Processing is automated and based on consent or the fulfillment of a contract, you have the right to data portability. Data portability means that you can receive the Personal Data you have provided us in a structured, commonly used and machine-readable format, and that you have the right to transfer the Personal Data to another data controller.

13. CONTACT INFORMATION

13.1 If you wish to exercise your rights, or if you have any questions regarding our Processing of your Personal Data, please contact Hans Hammer Andersen by email at ha@hammerandersen.com or telephone 31 444 777. We will take the necessary steps to verify your identity so that we disclose Personal Data to the correct person. This can be done by confirmation via your registered email in the system. If this is not possible, we will ask you to present a passport and/or driver's license. In your communication with us, please provide your full name, your address and/or the email address used for registration. Additionally, we will ask you to indicate which position you have applied for and which company you have applied to.

13.2 If you wish to complain about our Processing of your Personal Data, you have the option to submit your complaint to the competent local supervisory authority. You can read more about the local supervisory authorities at the following link: https://ec.europa.eu/newsroom/article29/items/612080.

14. NOTICE OF CHANGES TO THIS PRIVACY POLICY

14.1 If we make changes to this Privacy Policy, we will notify you about these changes on our website and simultaneously send you an email with the updated policy. If the changes require your consent, we will provide you with additional separate notification and request your consent in accordance with Applicable Data Protection Legislation.