Privacy Statement
| Privacy Policy — Statement on the protection of personal data |
| Effective date 25 July, 2022 |
Table of Contents
3.1. Why and how does Unique Human Capital process personal data?
3.2.1. The initial stage — your profile is interesting
3.2.2. Contact phase — we would like to know more about you
3.2.3. Conclusion — you’ve been hired
3.2.4. Conclusion — you’ve received a rejection
3.2.5. If you are applying for a job at Unique Human Capital
3.2.6. Sensitive personal data
3.3.1. Legal basis and purpose
3.3.3. Storage and deletion of clients’ personal data
4.1. Sharing of personal data with clients
4.2. Where is my personal data stored?
4.3. Disclosure to non-secure third countries and the UK
4.4. Is my information secure with you?
5.1.1. Company Page — when you like/share listings from Unique Human Capital’s LinkedIn page
5.1.2. LinkedIn Talent Solutions – when we contact you
6.1. What information do you collect through Google Analytics?
6.2.1. The website’s use of cookies
6.2.2. How long are cookies kept?
6.2.4. How to delete your cookies
9.1. Right to access your information
9.4. Right to restriction of processing
9.6. Right to transmit information
9.7. Right to withdraw consent
9.9. Do you want to exercise your rights?
Data Controller:
Unique Human Capital
Jægersborg All 4
DK-2920 Charlottenlund
CVR number: 31502705
Phone: +45 7020 6700
Email: mail@uhc.dk/gdpr@uhc.dk
1. Introduction
Unique Human Capital’s core business is to create value for our clients. This is done by providing qualified solutions in the field of human capital. We provide high-quality consultancy and advice within Board Search, Executive Search and Search & Selection.
Our solving of tasks and advising clients is based on business understanding and quality. We solve tasks for both Danish and international clients. Quality, expertise and credibility are the drivers of everything we do for our clients, business partners and candidates.
This privacy policy explains how Unique Human Capital processes, uses and protects personal data from candidates and clients that is left in our care. It also explains how, to what extent and for what purposes we collect and subsequently process personal data and information. In addition, you can also find information on how you can direct enquiry to us if you may want your personal data deleted, have it corrected or gain insight into what personal data Unique Human Capital has about you.
Unique Human Capital undertakes to protect personal data and information in accordance with applicable GDPR legislation[1]. When providing personal data to Unique Human Capital, you can be sure that the information will only be used in accordance with the legislation and this privacy policy.
Unique Human Capital may amend this policy from time to time in order to comply with current regulations. In regard to this, you should check this page regularly to make sure you agree with how your personal data is processed and stored — and what we use your personal data for.
- This policy applies when Unique Human Capital is the data controller, that is, when we determine the purposes and methods associated with the processing of personal data
- As part of our services, we specialise in the global search and procurement of candidates for specialist, managerial and executive positions on behalf of our clients
- In this policy, “Client Services” refers to any kind of contractual content that we have agreed with a client — for example, the terms we agree with clients must be part of the process to find candidates for a vacant position with the client
- In this policy, “we”, “us” and “our” refer to Unique Human Capital
2. Definitions
The following terms mean the following in this policy:
“Personal data/candidate personal data” means any personal data/information that either personally identifies a person or relates to an identifiable person and is either provided to us or collected by us to then be stored and/or processed by us. This kind of personal data is also called common personal data and will typically be the name, email address, telephone number and information about education, experience, skills, etc.
“The data subject” means the person(s) whose personal data we process.
“Processing” (and variations such as “handle”) means any process carried out with personal data/sets of personal data such as the collection, registration, structuring, storing, adaptation or modification, retrieval, use, disclosure, dissemination or other form of accessibility, coordination or composition, blocking, restriction, deletion or destruction of personal data.
“Sensitive personal data” means personal information that reveals racial or ethnic origins, political views, religious or philosophical beliefs or trade union membership and the processing of genetic data as well as biometric data for the purpose of uniquely identifying a natural person, health information or information relating to a person’s sexual life or sexual orientation.
Unique Human Capital considers CPR numbers as sensitive personal data.
“Articles” refers to the articles in Regulation (EU) 2016/679 of the European Parliament and of the Council of Europe dated 27 April 2016 (GDPR Regulation), which can be read in detail here.The regulation, together with the Danish Data Protection Act[2], are the two laws that primarily govern the protection of personal data in the EU/EEA.
3. Collection and processing of personal data
3.1. Why and how does Unique Human Capital process personal data?
Unique Human Capital’s core business is recruitment: Finding the best suited candidates for our clients’ vacant positions including board members. In addition to recruitment, we can help our clients with management assessments and advice on the composition of boards. In addition, we make outplacement courses for the employees of our clients who are going forward in their working lives. Lastly, we also process our clients’ personal data when we enter into a contractual relationship with the client and during a sales process.
- To solve recruitment tasks, we search the market for potential candidates, thereby collecting and processing candidates’ personal data. We find this personal data, for example, on LinkedIn or have it provided by the candidates themselves. This also applies to positions at our own company
- To make management assessments, we process personal data on management members. We receive this personal data from the client and the members who are to be assessed
- In order to make outplacement programmes, we process the personal data provided to us by the person who is part of the outplacement process. We may also obtain information from the client where the person has been employed
- We process our clients’ personal data when we enter into a contractual relationship with the client or when we are engaged in a sales programme.
When we collect and process personal data as described above, we use three different forms of legal basis or basis for processing:
- Balancing of interests Article 6 (1) (f)
- Consent Article 6 (1) (a)
- Contract Article 6 (1) (b), Article 6 (2) (c) and
.
Article 6 (1) (f)
Each of these legal bases and the disclosure obligations[3] is the basis for how we communicate with our candidates and clients about their personal data and, at the same time, is the basis for how we process and store your personal data.
You can read more about which legal bases we use in different contexts below.
3.2. When you are a candidate
3.2.1. The initial stage — your profile is interesting
3.2.1.1. Legal basis and purpose.
Our legal basis for processing:
Article 6 (1) (f) (balancing of interests): It is expected that we process the information that is made publicly available by the candidate themselves.
Purpose:
When we are tasked with finding the right candidate for a vacant position with one of our clients, we must search a large field of candidates — both in Denmark and internationally. To do this, we search various databases for example LinkedIn, where candidates themselves have posted information about, for example, current position, title, education. From here we will determine what a field of candidates should look like and whether it is in the client’s/our interest to consider your profile for a vacant position.
So we weigh whether your profile, as we see it on, for example LinkedIn, fits the client’s requirements for competence in the position. At this point in the recruitment, we process a minimum of ordinary personal data and only information that we can find on freely accessible social media or websites.
3.2.1.2. What personal data do we collect at the initial stage and from where?
- Information about your current title and company that is publicly available through social media and websites
- Information about past employment that is publicly available through social media and websites.
- Contact information (name, region, telephone number, email address, etc.) if this is easily available on social media
3.2.1.3. How do you know that we have looked at your profile and have saved your personal data?
In the event that your information has been collected and processed by us via the “balancing of interests”, you will be made aware of this through an email from us. In the email you are informed that we have looked at your profile as a potential candidate for a vacancy with a non-specific client. Of course, this assumes that we know your email address. If you have not made your email address available, you will not receive notification from us that we have looked at your profile.
The email informing you that we have looked at your profile will come from our GDPR management system, GatedTalent.
3.2.1.4. Storing and deleting personal data v. balancing of interests
Unique Human Capital will store your personal data for the period of time we assess that your profile may be relevant to current or future clients.
If we have had the possibility to contact you via your email, you are always welcome to write to us at gdpr@uhc.dk to have your personal data that we have stored deleted. We will then ensure that your data is deleted from our system within 30 days [4].
Once we have deleted your data, it means that we have deleted all data we have on you including contact details and history of any dialogue made with you. This means that we may inadvertently get to contact you again as we cannot see that we have had contact with you in the past.
3.2.2. Contact phase — we would like to know more about you
3.2.2.1. Legal basis and purpose
Our legal basis for processing:
Consent, see article 6 (1) (a): You give us your explicit consent that we may process and store your personal data.
Purpose:
When a recruitment reaches the contact phase, we will start collecting more personal data on relevant candidates. In this part of the recruitment process, we call and write to candidates via, e.g. LinkedIn, private mail and telephone, we receive applications, resumes, diplomas, certifications and other information that is necessary to identify whether a candidate is the right person for one of our clients’ vacant positions.
During this part of the process, we have an active dialogue with our client(s) about specific candidates for a vacant position, but before we can process your information and possibly share your personal data with our client(s), it is necessary that we obtain your explicit consent to process your personal data.
3.2.2.2. What personal data do we collect during the contact phase and from where?
- Contact information (name, address, phone number, email address, etc.)
- CV and, if applicable, application
- Information on education, diplomas and certificates
- Employment and salary History
- Information about your current title and company that is publicly available through social media and websites or through other information on the Internet which may be important for a candidate’s suitability for a particular position
- Information about past employment that is publicly available through social media (e.g. Facebook, Google, LinkedIn, Twitter etc.)
- Test results from, for example, personality test/proficiency test conducted by Unique Human Capital
- Any personal data you may choose to disclose to us
In addition, if we get so far in the recruitment process that you will meet the client, Unique Human Capital will prepare documents for sharing with the client:
- Presentation material:
- Includes work experience, summary of test results, assessment of your competencies compared with the competency requirement for the position, and your contact information and motivation for the position
- References:
- When we are so far in the recruitment that the client asks for references on you, we will obtain references to get opinions about your professional competencies from former managers, colleagues, etc.
- We only contact the references for which you give permission
3.2.2.3. How do you know that we process your personal data and use consent?
In the event that your data has been collected and processed by us via “consent”, an email will be sent to you asking for your permission to process your personal data and keep it for a period of two years.
You will receive this email even if you have sent us your information, e.g. application and CV. Unique Human Capital will not share your personal data with clients or others until you have consented to the storing and processing of the data.
The consent email will come from our GDPR management system, GatedTalent.
3.2.2.4. Storage and deletion of personal data?
Unique Human Capital will store your personal data for two years. After two years, you will receive an email asking for permission to store your data for another two years, except any test results, which are stored exclusively for eight months.
If you do not want us to process your personal data, you can either choose to say no to further storage, or you can write an email to gdpr@uhc.dk asking that we delete the personal data we have stored on you. We will then ensure that your data is deleted from our system within 30 days [5].
Once we have deleted your data, this means that we have deleted all data we have on you, including contact information and history of any dialogue we have had with you. This means that we may inadvertently get to contact you again as we cannot see that we have had contact with you in the past.
3.2.2.5. What if I am a candidate in the process for a position and will not consent to the processing of my personal data?
It is every person’s right to ask to have their personal data deleted from the controller — in this case Unique Human Capital. If you write to us that you withdraw your consent, we will delete your personal data within 30 days [6].
However, while we are in dialogue with the client about you for a specific position and you choose to withdraw your consent, we will no longer be able to process your data. As a basis, this means that you can no longer engage in an active recruitment through Unique Human Capital.
However, before deletion, we will contact you to ensure that your request for deletion is not due to a misunderstanding. If so, it will always be possible for you to change your mind and be considered again for the position in question.
3.2.3. Conclusion — you’ve been hired
If you are the right match for the position with our client, you will negotiate directly with our client about your new responsibilities and benefits, and then you will go from being a candidate in our system to being a client. Below you will find a description of our legal basis for the processing of your personal data and the purpose.
3.2.3.1. Legal basis and purpose
Our legal basis for processing:
Article 6 (1) (b): Processing is necessary for the sake of fulfilment of a contract.
Article 6 (1) (c): Processing is necessary in order to comply with a legal obligation that is incumbent on the data controller
Article 6 (1) (f): Balancing of interests. It is reasonable that, due to their position, the data subject is included in the client relationship.
Purpose:
The purpose of this processing is so that we can communicate with our clients and we can fulfil the terms of our contract with the client. In addition, we use your employment date for internal statistics — here, however, your data is anonymized.
3.2.3.2. Storage and deletion of personal data
Once you have been employed by the client, we will keep the personal data we have collected on you during the recruitment process for a warranty period of 6 months, after which we will delete all your personal data except:
- Your name
- Your work emailorpersonal email if we do not receive your work email
- Your work phone numberorpersonal phone number if we do not receive your work number
- Current title
- Start date of your employment
We will not use this data to contact you about vacant positions or anything else that is irrelevant to your relationship with us as a client.
We keep your client contact data for as long as you are part of a client relationship with us and as long as our relationship with the client continues – both when the client is active (active recruitment is in progress) and when the client is passive, (we have sales work in progress).
3.2.3.3. What if I have been employed for a position with your client and would now like to have my personal data deleted?
In this case, we cannot delete all your personal data. However, we will delete all the data that is no longer necessary for us to store. In this case, we will keep your name and email, as well as your new title and employer so that, as part of qualitative client relationships, we can follow up on your employment and warranty obligation. We will not use this data to contact you about vacant positions or anything else that is irrelevant to your relationship with us as a client.
3.2.4. Conclusion — you’ve received a rejection
If you have applied for a position and you were not the right match in this case, you will receive a rejection from us either by mail or with a phone call. We process your personal data both during the rejection and after. Below you will find a description of the legal basis for the processing as well as the purpose.
3.2.4.1. Legal basis and purpose
Our legal basis for processing:
Consent, see Article 6 (1) (a): You have given us your explicit consent that we may process and store your personal data for two years.
Purpose:
When you receive a rejection from Unique Human Capital, we still have an interest in keeping your data in our Candidate Management System so that we can contact you again if a vacancy occurs with one of our other clients for which your profile could be a match.
3.2.4.2. What personal data do we retain?
- Contact information (name, address, phone number, email address, etc.)
- CV and, if applicable, application
- Information on education, diplomas and certificates
- Employment and salary History
- Information about your current title and company that is publicly available via social media
(e.g. Facebook, Google, LinkedIn, Twitter, etc.) or through other information on the Internet which may be important for a candidate’s suitability for a particular position
- Information about past employment that is publicly available via social media (e.g. Facebook, Google, LinkedIn, Twitter etc.)
- Test results from, for example, personality test/proficiency test conducted by Unique Human Capital
- Any personal data you may choose to disclose to us
In addition, if you have been presented to a client, we store:
- Presentation material which includes work experience, summary of test results, assessment of
your competencies compared with the competence requirement for the position, as well as your contact information and motivation for the position
3.2.4.3 How do you know that we process your personal data and use consent?
At the start of the recruitment process, you received an email asking for your consent to keep your personal data for two years — this consent still applies even if you have received a rejection for a position.
3.2.4.4. Storage and deletion of personal data
We keep your personal data for two years after consent is given. After two years, you will receive an email asking for permission to keep your data for another two years, with the exception of any test results, which are stored exclusively for eight months.
If you do not want us to process your personal data, you can either choose to say no to further storage, or you can write an email to gdpr@uhc.dk asking that we delete your personal data we have stored. We will then ensure that your data is deleted from our system within 30 days [7].
Once we have deleted your data, this means that we have deleted all data we have on you, including contact information and history of any dialogue we have had with you. This means that we may inadvertently get to contact you again as we cannot see that we have had contact with you in the past.
3.2.5. If you are applying for a job at Unique Human Capital
If you apply for a position with Unique Human Capital, we will process your data as described in sections 3.2.2. — 3.2.4.
3.2.6. Sensitive personal data
Sensitive personal data means personal data revealing racial or ethnic origins, political attitudes, religious or philosophical beliefs or trade union membership and the processing of genetic data as well as biometric data for the purpose of uniquely identifying a natural person, health information or information relating to a person’s sexual life or sexual orientation. In addition, Unique Human Capital has chosen to consider a social security number as sensitive personal data.
Unique Human Capital does NOT, in some circumstances, want to receive sensitive personal data from candidates/clients, and consequently we strongly urge that candidates/clients avoid sharing some kinds of sensitive personal data with us.
If, against expectations, we receive sensitive personal data, e.g. in an attachment from the candidate in regard to a recruitment process, a CPR number could be included in the CV or on a diploma or information on, e.g. diseases, etc., the recipient at Unique Human Capital will delete the attachments and the candidate will be notified of this as well as a message to resend the attachments without the sensitive personal data.
Sensitive personal data is not disclosed to our clients unless we have explicit written consent from the candidate that we may pass on the information. In these cases, the information will only be provided verbally and the information will not be stored and/or processed in our data processing systems. However, we will store the consent statement in our system for two years or until your personal data is deleted.
3.3. When you are a client
As a client of Unique Human Capital, we process personal data about you. Below you will find a description of the legal basis for the processing as well as the purpose.
3.3.1. Legal basis and purpose
Our legal basis for processing:
Article 6 (1) (b): The data subject is a signatory of the contract
Article 6 (1) (c): The data subject is the contact person in regard to purchase and payment in accordance with the Danish Bookkeeping Act
Article 6 (1) (f): It is reasonable that the data subject, on the basis of their position, is included in the client relationship
Purpose:
The purpose of this treatment is so that we can communicate with our clients and that we can fulfil our contractual obligations.
3.3.2. Clients’ personal data
When you are a client at Unique Human Capital, we store the following personal data about you:
- Your name
- Work email
- Work phone number
- Current title
- Possible department
- The start date of your employment (if you have been a candidate for your current position through Unique Human Capital)
In connection with the start-up of the collaboration, information on the relevant persons who are involved in the collaboration on the part of the client is received. Personal data can be sent by employees of the client company.
3.3.3. Storage and deletion of clients’ personal data
We keep your personal data for the entire duration of the collaboration — and as long as Unique Human Capital considers it necessary.
4. Sharing personal data with third parties and security
4.1. Sharing of personal data with clients
Unique Human Capital shares personal data with our clients in order to perform the task: To find the best possible candidate for a vacant position at the client. We may share the following personal data with our clients:
- Contact information (name, address, phone number, email address, etc.)
- CV and application
- Information on education, diplomas and certificates
- Employment and salary History
- Information about your current title and company that is publicly available via social media
(e.g. Facebook, Google, LinkedIn, Twitter, etc.) or through other information on the Internet which may be important for a candidate’s suitability for a particular position
- Information about past employment that is publicly available via social media (e.g. Facebook, Google, LinkedIn, Twitter, etc.
- Test results from, for example, personality test/proficiency test conducted by Unique Human Capital
- Any personal data you may choose to disclose to us
If a candidate is to meet the client, Unique Human Capital will prepare the following documentation:
- Presentation material relating to the candidate, which includes work experience, summary of test results, assessment of competencies compared with the competency requirement for the position, as well as contact information and motivation for the position.
- At the end of the recruitment process, we will obtain references on the top candidate(s), and this will be in the form of opinions about your professional competencies, etc. from former managers, colleagues, etc.
- We only contact the references for which you give permission
4.2. Where is my personal data stored?
Your personal data is stored in a database and the server that is used for this purpose is located in a secure third country (UK) — see section 4.3. The database is operated and accessible by employees of Unique Human Capital and the third party vendor, which acts on behalf of Unique Human Capital and in accordance with our server operation instructions.
In addition, Unique Human Capital uses the Microsoft Office 365 suite for our work incl. SharePoint and Outlook. Therefore, your personal data will be able to be stored and processed here.
4.3. Disclosure to non-secure third countries and the UK
We use a few data processors/vendors in non-secure third countries. When the legislation of the third countries does not offer the same security as the EU, we have increased the obligations for the protection of your personal data.
- When you contact us by mail, your information may be passed to Microsoft in the United States given that we use Outlook as our mail client
- We have entered into a Standard Contractual Clause [8]with Microsoft which ensures that we have a transfer basis for your data. However, we are aware of the Schrems II decision and await news from the Danish Data Protection Agency regarding legal transfers to non-secure third countries
- The servers for Unique Human Capital’s candidate and client management system are located in the UK which, after Brexit, means the UK will no longer have to comply with GDPR legislation.
- The European Commission adopted a sufficiency decision on 28 June 2021, which means that the UK is considered a secure third country
4.4. Is my information secure with you?
Yes, your information is secure with us. At Unique Human Capital, we make use of extended enterprise validated protection, also known as Extended SSL Validation (EV). We take responsibility for the information you share with us. We would like to return the trust that you give to us. Therefore, all data transactions are automatically encrypted and thus secured against malicious third parties (e.g. a data transaction is when you upload your CV or application to us).
Moreover, we make use of the highest level of SSL encryption, we use multi-factor authentication for a wide range of systems, and we generally have a high level of IT security that ensures that we have and use some of the best technical and organisational tools designed to counteract unauthorised access, unlawful processing and unauthorised or accidental loss of your personal data.
5. Social media use
5.1. LinkedIn
When you use LinkedIn as a private individual, you should be aware of LinkedIn’s privacy policy, which describes how LinkedIn processes and stores your personal data. You can find LinkedIn’s privacy policy here: https://www.linkedin.com/legal/privacy-policy.
LinkedIn is an American company, which is why the information LinkedIn has about you may be outside the EU/EEA. However, the data controller is LinkedIn Ireland according to their own information.
5.1.1. Company Page — when you like/share listings from Unique Human Capital’s LinkedIn page
5.1.1.1. Joint data responsibility
Unique Human Capital, together with LinkedIn, is the joint data controller for collecting personal data about you when you visit Unique Human Capital’s LinkedIn page, also called Company Page and, for example, you like or share a listing from us with your network.
Consequently, LinkedIn and Unique Human Capital have a so-called joint data responsibility for processing information about you. This means that LinkedIn and Unique Human Capital must allocate and determine the responsibility for complying with the laws surrounding the processing of your personal data in this regard. For this reason, we have entered into a joint data processor agreement.
5.1.1.2. Legal basis and purpose
Our legal basis for processing:
Article 6 (1) (f) (balancing of interests): The processing of this information is necessary in order to pursue a legitimate interest — the possibility to communicate with you directly and respond to any enquiries and comments that you have sent directly to us.
Purpose:
Purpose of personal data processing via our Company Page:
- To make Unique Human Capital’s vacant positions visible to our clients, to make Unique Human Capital visible as a workplace and to market the company to potential and existing partners
- Unique Human Capital processes the information about you that you send to us in connection with a comment or direct message from you to us via our LinkedIn Company Page for the purpose of responding to your question or enquiry. This applies ONLY to enquiries from you to us on our Company Page and not to inquiries directly to you from us or from you to us via InMail (see section 5.3.)
5.1.1.3. What personal data is collected on the Company Page?
- Your name
- Your picture
- Your question and/or comment
The information that Unique Human Capital otherwise has available through the Company Page is not directly attributable to you, but contains an overview of visitor statistics that may be used to improve our use of our Company Page by knowing the interests, demographics and geography of users.
The information is available to Unique Human Capital through a feature called LinkedIn Page Analytics. This feature is a standard feature if you have a LinkedIn Company page. When you visit the Unique Human Capital’s Company Page, LinkedIn places cookies on your equipment, for example, your PC, tablet or mobile phone. By placing cookies, LinkedIn collects and processes information about you, including information you have given permission in order to create your profile such as reactions, comments and sharing that you and others make.
This data is stored for one year in LinkedIn Page Analytics, after which it is deleted.
5.1.2. LinkedIn Talent Solutions – when we contact you
5.1.2.1. Legal basis and purpose
Our legal basis for processing:
Article 6 (1) (f) (balancing of interests): The processing of this information is necessary to pursue a legitimate interest — the ability to communicate with you directly about vacancies with our clients.
Purpose:
LinkedIn is primarily used by private individuals in order to make themselves visible to others in their industry, and/or because they want to make themselves visible in relation to a possible change of job. When Unique Human Capital employees work on LinkedIn, they use LinkedIn Talent Solutions (LTS) because it provides some more interaction opportunities with private individuals such as LinkedIn users.
When Unique Human Capital needs to find the right candidates for positions with our clients, we create projects in LTS to “gather” the candidates we think might be interesting to move forward with in a recruitment process. At this point, we only collect and process personal data of the affected persons in LTS and only have the information about users which the users have made available themselves.
Then, we may choose to communicate with potential candidates through InMail — LinkedIn’s own email system — to hear if they might be interested in further dialogue. Here, candidates can choose to provide a Unique Human Capital employee with their email and/or phone number for an in-depth dialogue.
5.1.2.2. What personal data do we collect in LTS?
As a starting point, we only collect the data from LinkedIn that you have made available yourself. This could be:
- Work experience
- Contact information, if available, e.g. email or phone number
5.1.2.3. Storage and deletion in LITS
Attachments and dialogues that Unique Human Capital has with potential candidates about positions with our clients are automatically deleted by LinkedIn after 5 years.
Currently, it is not possible for Unique Human Capital’s own employees to delete attachments, conversations, etc. in projects in LTS, as this feature has not been made available by LinkedIn.
If you want to delete the dialogue you have had with Unique Human Capital about a position via LinkedIn, you will need to contact gdpr@uhc.dk and ask to have your dialogues/attachments deleted on LinkedIn. Unique Human Capital will then pass on your request to LinkedIn within 30 days.
You can also ask LinkedIn to delete your data — you can find more information about deleting data on LinkedIn here: https://www.linkedin.com/help/linkedin/answers/deleting%20data?query=deleting+data.
5.1.2.4. What happens if I become part of the process for a position?
At this point, when an actual recruitment process (the contact phase) is underway, the candidate will have their personal data transferred to our candidate management database, after which the consent procedure and further process as described in section 3.2.2 is followed.
6. Google Analytics and Cookies
Unique Human Capital uses Google Analytics for the purpose of improving our website.
6.1. What information do you collect through Google Analytics?
For example, we may collect information about which pages you visit, whether you are visiting uhc.dk for the first time or have been on the site before, as well as other interactions that help to give us a picture of the activity level of a posted advertisement. To learn more about how Google collects information, read more in Google’s privacy policy here: https://policies.google.com/privacy?hl=da
We use Google Analytics, Google Search Console and Google my Business to better understand our candidates when we post job postings on www.uhc.dk.
We collect this information on the Site Kit programme, which gives us a comprehensive overview of the information collected. With this programme, we get a complete calculation of clicks on advertisements, visit duration, demographic overview, etc. If you want to learn more about what information each programme/plugin collects about you, then we suggest you read more on their respective websites for the full overview. Click on the program/plugin you would like to read more about below:
- Google Analytics, Google Search Console, Google my Business: https://policies.google.com/privacy?hl=dk-DK
- Site Kit: https://getsitekit.com/privacy-policy
6.2. What is a cookie?
A cookie is a small data file that is stored on your computer, tablet or mobile phone. A cookie is not a programme that may contain malicious programs or viruses. You can read all about Unique Human Capital’s cookie policy here: https://en.uhc.dk/p/cookie-policy. The website www.uhc.dk and www.en.uhc.dk uses cookies. Some are used for statistics and others are placed by third-party services. By clicking ‘OK’ you agree to the use of cookies. By saying no to cookies, you will find that the functionality of the website will deteriorate.
6.2.1. The website’s use of cookies
Cookies are necessary to make the website work. Cookies also help us to get an overview of your visit to the website so that we can continuously optimize and target the website to your needs and interests. For example, cookies remember whether you have previously visited the site, whether you are logged in, and what language and currency you would like to have displayed on the website. We also use cookies to focus our advertisements on you on other websites. Generally, cookies are used as part of our service to display content that is as relevant as possible to you. You can read more about what cookies we collect here: https://en.uhc.dk/p/cookie-policy
6.2.2. How long are cookies kept?
How long cookies are stored on your equipment varies. The time is counted from the last time you were on the website. After expiry, cookies will automatically be deleted from your equipment. You can see a complete list in section 6.6.
Cookies are kept for one year by Unique Human Capital, after which they are automatically deleted.
Our cookie declaration is updated continuously and every month.
6.2.3. How to refuse cookies
You can always refuse to have cookies on your computer, tablet or phone by changing the settings in your browser. Where the settings are depends on which browser you use. However, you should be aware that if you do refuse to have cookies, there are many features and services you cannot use because they require that the website can remember the choices you make. You can opt out of cookies from Google Analytics here.
6.2.4. How to delete your cookies
Cookies that you have previously accepted can subsequently be easily deleted. If you use a PC with a newer browser, you can delete your cookies by using the hotkeys: CTRL + SHIFT + Delete.
If the shortcut keys do not work and/or you use MAC, you will need to start by finding out which browser you are using and then click on the appropriate link:
| Internet Explorer | Flash cookies | Opera |
| Mozilla Firefox | Apple | Safari |
| Google Chrome | Android | Windows 7 |
Remember: If you use multiple internet browsers, you should delete cookies in all of them.
7. Data minimization
We only process the information necessary to fulfil our stated purpose. In addition, it may be required by law that we must collect and store some information about you. We only keep personal data for as long as necessary or required by law. Personal data will be deleted when it is no longer necessary for us to process it.
8. We keep personal data up to date
Since our core business is dependent on your personal data being correct and up-to-date, we will ask you to please inform us of any relevant changes to your personal data. You can use the contact information at the bottom of this document to notify us of your changes and we will make sure to update your personal data.
9. Your rights
In accordance with the General Data Protection Regulation, you have a number of rights in relation to Unique Human Capital’s processing of your personal data. For more information about your rights, see the Danish Data Protection Agency’s guide on data subject rights, which can be found at www.datatilsynet.dk.
9.1. Right to access your information
You have the right to access the information we process about you, as well as some additional information.
9.2. Right to rectification
You have the right to have incorrect information about yourself rectified.
9.3. Right to deletion
In special cases, you have the right to have information about you deleted before the date for our regular general deletion.
9.4. Right to restriction of processing
In certain cases, you have the right to have the processing of your personal data restricted. If you have the right to restricted processing, in future we may only process the information with your consent, or for the purpose that legal claims can be determined, asserted or defended, or to protect a person or important societal interests.
9.5. Right of objection
In certain cases, you have the right to object to our otherwise lawful processing of your personal data.
9.6. Right to transmit information
In certain cases, you have the right to receive your personal data in a structured, commonly used and machine-readable format and to transfer that personal data from one data controller to another without hindrance.
9.7. Right to withdraw consent
If the processing is based on consent, you have the right to withdraw that consent.
9.8. Assessment questions
In many of the above cases, it will be an assessment question of whether and what personal data we can delete, correct and or give access to. In all instances, you will receive a written response to your requests about the rights in question and in the event that we are unable to provide access, delete or rectify your data, you will be informed of the basis of our assessment. In our assessments, our basis is always in the GDPR as well as other applicable laws and regulations.
9.9. Do you want to exercise your rights?
If you want to exercise your rights, please contact us at gdpr@uhc.dk.
10.Complaint to the Danish Data Protection Agency
You have the right to lodge a complaint with the Danish Data Protection Agency if you are unhappy with the way we process your personal data:
The Danish Data Protection Agency
Borgergade 28, 5th floor
DK-1300 Copenhagen K
Email: dt@datatilsynet.dk
Phone: +45 33 19 32 00
11.How to contact Unique Human Capital
We encourage you to send us any questions and comments regarding this policy and our privacy protection practices by contacting us here:
Unique Human Capital
Jægersborg Alle 4
DK-2920 Charlottenlund
Email: gdpr@uhc.dk
[1] REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND THE COUNCIL OF EUROPE dated 27 April 2016 https://eur-lex.europa.eu/legal-content/DA/TXT/PDF/?uri=CELEX:32016R0679&from=DA as well as the Danish Data Protection Act: Act No 502 of 23 May 2018 on additional provisions to the regulation on the protection of natural persons in connection with the processing of personal data and on the free exchange of such data (Danish Data Protection Act) https://www.retsinformation.dk/eli/lta/2018/502.
[2] The Danish Data Protection Act, Act No 502 of 23 May 2018 on the additional provisions to the protection of natural persons in connection with the processing of personal data and on the free movement of such data (Data Protection Act)
[3] Article 13 (1) to (4)
[4] See Article 17 (1) to (3) of the Regulation
[5] See Article 17 (1) to (3) of the Regulation
[6] See Article 17 (1) to (3) of the Regulation
[7] See Article 17 (1) to (3) of the Regulation
[8] See Article 46 (2) (c)