This article explains data protection settings in the Recruiting app. You need to protect your candidates' data under both your requirements and those of the EU GDPR. We’ll cover how to: 

• Add a data privacy statement and a legal notice to your Personio career page
• Anonymize your candidates’ data

Before you start

To set up the data protection features outlined in this article, you need permissions for the Recruiting settings.

Align with your legal department to make sure your data privacy statement and legal notice are up to date.

Add your data privacy statement to your Personio career page

Your data privacy statement tells candidates how you use their information. By law, you must handle candidate data according to data protection laws.

When someone applies for a job, you usually process their data if:

• It's needed to prepare a potential contract with them, and
• They give you their consent

You must also make sure candidates can:

• Easily understand how you use their data
• Access their information when they ask for it

To add your data privacy statement to your Personio career page, follow these steps:

1. Go to Settings > Recruiting > Career page.
2. Scroll down to the Descriptions & translations section.
3. Enter your company’s statement in the Data privacy statement field. Personio automatically adds a template to help you format your statement.
4. Under Translations, add your data privacy statement in other languages, if needed.
5. Save your changes.

Visitors to your career page can access the data privacy statement at the bottom of the page.

Data privacy statement template

Personio provides the template below to help format your data privacy statement. However, this template is just a starting point. You need to customize it for your company's industry, structure, and local laws, and add any missing information. Make sure to include your deadline for deleting or anonymizing candidate data.

Processing of (personal) data by the entity in charge of the online application process

1. General information

This data privacy statement, which refers exclusively to data collected as part of the online application process, is to inform you about how your personal data that is collected as part of the online application process is handled at our end.

2. The controller

The controller under data protection law is:

[Company name and legal form]

[Company address]

Phone: [phone number]

Commercial register entry number: [entry number]

Registration Court: [name of registration court]

Data Protection Officer: [name and contact details of the Data Protection Officer, if applicable]

3. Personal data collected as part of the application process

Personal data means any information concerning the personal or material circumstances of an identified or identifiable individual. This includes information such as, for example, your name, address, telephone number, and date of birth, but also data relating to your specific career, etc., by reference to which a specific individual can be identified with reasonable effort. However, information that cannot be (in)directly associated with your real-life identity is not personal data.

4. Fundamentals and purposes of processing personal data collected from application documents and during the application process

If you apply to us electronically, i.e., via email or using our online form, we will collect and process your personal data for the purpose of executing the application process and preparing contracts.

By submitting an application via our recruitment website, you express your interest in taking up work with us. In this context, you transmit personal data, which we will use and store exclusively for the purpose of your job search / application process.

In particular, the following data is collected during this process:

• Name (first and last names)
• Email address
• Phone number
• LinkedIn profile (optional)
• Channel through which you found us

Furthermore, you can choose to upload expressive documents such as a cover letter, your CV, and reference letters. These may contain additional personal data such as date of birth, address, etc.

Only authorized HR staff and/or staff involved in the application process have access to your data.

The personal data is stored, as a rule, exclusively for the purpose of filling the vacancy for which you have applied.

Your data will be stored for a period of [number] days after the application process has been concluded. This is usually done to fulfill legal requirements and/or defend ourselves against any claims arising from legal provisions. After this period, we are obligated to delete or anonymize your data. In case of anonymization, the data will only be available to us in the form of so-called metadata, without any direct personal reference, for statistical analysis (for example, share of male and / or female applicants, number of applications per specified period of time, etc.).

Furthermore, we reserve the right to store your data for [number] days after the application process has been concluded for the purpose of adding it to our Talent Pool in order to identify any other vacancies that may be of interest to you. This includes, for example, applications for apprenticeships or internships. By accepting the data privacy statement, you consent to any further storage of your data as well as its inclusion in our Talent Pool.

Should you be offered and accept a position with us during the application process, we will store the personal data collected as part of the application process for at least the duration of your employment.

5. Disclosure of data to third parties

Data transmitted as part of your application will be transferred using TLS encryption and stored in a database. This database is operated by Personio, which offers a human resource and applicant management software solution (https://www.personio.com/legal-notice/). In this context, Personio is our processor under Article 28 of the GDPR. In this case, the processing is based on an agreement for the processing of orders between us as the controller and Personio.

6. Rights of data subjects

If we, as the controller, process personal data, you as the data subject have certain rights under Chapter III of the EU General Data Protection Regulation (GDPR), depending on the legal basis and the purpose of the processing, in particular the right of access (Article 15 of the GDPR) and the rights to rectification (Article 16 of the GDPR), erasure (Article 17 of the GDPR), restriction of processing (Article 18 of the GDPR), and data portability (Article 20 of the GDPR), as well as the right to object (Article 21 of the GDPR). If the personal data is processed with your consent, you have the right to withdraw this consent under Article 7 III of the GDPR.

To assert your rights as a data subject in relation to the data processed during this online application process, please refer to our Data Protection Officer (see item 2).

7. Concluding provisions

We reserve the right to adjust this data privacy statement at any point in time to ensure that it is in line with the current legal requirements at all times, or in order to accommodate changes in the application process or other processes. In this case, the new data privacy statement applies to any later visit to this recruitment website or any later job application.

In addition to this data privacy statement, please view our general data privacy statement at [link to own data privacy statement].

Add your legal notice to your Personio career page

If you use the Personio career page, you need to enter the link to your company’s legal notice. The legal notice explains legal information about your company and services. 

To enter the link

1. Go to Settings > Recruiting > Career page.
2. Scroll down to Link to legal notice and enter the link.
3. Save your changes.

Visitors to your career page can access the legal notice at the bottom of the page.
 

Anonymize candidates’ personal data 

You need to anonymize candidate data based on the deadline in your data privacy statement. Once you anonymize data, you can't recover it. The system anonymizes the following candidate information:

• Name
• Gender
• Email address
• Phone number
• Date of birth
• All application documents
• The message history, including all attachments
• Offers
• Evaluations (quantitative evaluations remain)

The application ID, date, and recruiting channel remain in the database. This means that you can still use the data in your reports (in anonymized form). 

If a candidate applies for several jobs, their data remains until you complete the recruiting process for all jobs. 
 

Set up automatic anonymization

Note that you can only use automatic anonymization for candidates in the Rejected or Withdrawn recruiting stage.

Automatic anonymization helps you to comply with data protection rules and increase efficiency. To set up automatic anonymization, follow these steps:

1. Go to Settings > Recruiting > General.
2. Next to Data privacy settings, click Edit.
3. Check the option to anonymize data automatically.
4. Select the number of days from which you want to anonymize the data. The count begins when you move a candidate to the Rejected or Withdrawn stage.
   Note: When you first select the number of days, the system doesn’t update instantly. The same applies if you change the number of days. It runs an update every morning to calculate the days since the disqualification. This also applies to your historic candidate data.
5. Select whether you want the candidate’s name to appear in notification emails. If you select No, no candidate data appears in notification emails.
6. Save your changes.

If a candidate isn’t suitable for an existing job but might be for a future one, you can create a talent pool. You need the candidate's permission for this.
 

Anonymize candidates’ personal data manually 

You can also anonymize candidate data manually. 

To anonymize data in bulk:

1. Go to Recruiting > Applications.
2. Filter and select the relevant candidates.
3. In the menu bar that appears at the top, click the three-dots icon.
4. Select Anonymize and confirm the action.

To anonymize data in a specific application:

1. Go to Recruiting > Applications.
2. Click the relevant application to open the candidate profile.
3. Click the three-dots icon and select Anonymize application.
4. Confirm the action.