Privacy Policy

We are the data controller – how to contact us

Dansk Avis Omdeling A/S is the data controller for the processing of the personal data we have received about you. Our contact details are:

Dansk Avis Omdeling A/S (hereinafter dao) Islandsvej 1 7100 Vejle CVR (Company Reg. No.): 26063892 Email: hr@dao.as

Contact details of the Data Protection Officer

If you have questions about our processing of your data, you are always welcome to contact our Data Protection Officer.

You can contact our Data Protection Officer in the following ways:

  • By email: dpo@dao.as
  • By post: dao, Islandsvej 1, 7100 Vejle, attn. "Data Protection Officer"

Purposes of processing, the types/categories of data, and the legal basis

As an applicant at dao, we collect the following personal data in connection with the recruitment process:


Purposes

  • To assess whether you are the right candidate for a position at dao.
  • To determine whether dao has a vacant position that matches your qualifications and experience.
  • If our recruitment process has progressed and we have held a first interview, we may:
    1. in some cases contact one or more of your former employers in order to collect references about you; and
    2. if relevant for the specific position, ask you to send a criminal record certificate or driving licence. This will depend on a concrete assessment of relevance.
  • If you have subscribed to one of our job alerts, we will process your personal data for the purpose of notifying you when we post a vacancy that matches your preferences.

Types of personal data we process

  • Name, address, phone number, email.
  • Information included in the job application, position and place of work, CV information, education and exam results, professional qualifications and salary conditions and the justification for these.
  • References from previous/current employers/colleagues about you.
  • Health data, data on criminal matters.
  • Notes and comments from interviews and other dialogue.
  • Competency profile/personality test.
  • CPR number (Danish national ID), passport, residence permit, ID card, driving licence.
  • Photo/video, if you upload it together with your application.
  • Other information contained in your CV and application or in links to your profile on social media, e.g. LinkedIn.

Legal bases for our processing

  • GDPR Article 6(1)(a) (consent) for obtaining references and for storing your data for up to six months after the recruitment process in order to contact you about new job postings, if you have provided consent.
  • GDPR Article 6(1)(f) (legitimate interests). Our legitimate interest is to select candidates who best match the competencies and attributes required for the position, to inform candidates of the outcome of the recruitment process, and to document the recruitment process in order to defend against and address any claims.
  • Processing of personal data in relation to employment is carried out pursuant to Section 12 of the Danish Data Protection Act.
  • If the criminal record certificate contains information about criminal offences, the data are processed pursuant to Section 8(3) of the Danish Data Protection Act. If the certificate does not contain such information, the data are processed based on our legitimate interest in ensuring that candidates for certain positions are reliable and do not pose a security risk to dao.

Where your personal data come from

  • Directly from you when you apply for a position at dao.
  • Participation in a development programme with a view to employment at dao.
  • Completing a personal profile via dao's online recruitment channels Bud-opret, MEDI, omdeler.dk or Emply.
  • Providing personal data to dao in another way.
  • External recruitment consultants may handle information via their system.
  • A former employer.
  • Online sources that are publicly available, if you have provided links to your social media profile, e.g. LinkedIn.

Recipients or categories of recipients

We disclose your personal data to the following recipients:

  • dao's external recruitment consultants.
  • Our IT providers Embrace, Microsoft.
  • Our data processor Emply A/S, which provides our recruitment platform.
  • Talents Unlimited Denmark ApS, if it is relevant for the position to carry out a personality test.

Transfers to recipients in third countries, including international organisations

  • We will transfer your personal data to recipients outside the EU/EEA in connection with hosting or support services from one of our data processors. We can inform you that the European Commission has adopted adequacy decisions, or—in the case of transfers pursuant to GDPR Articles 46, 47 or Article 49(1) second subparagraph—we rely on appropriate safeguards and will inform you how to obtain a copy of such safeguards, or where they have been made available.
  • Such a transfer will only take place if an adequate level of protection for your data is ensured. This may, for example, be the case where:
    • the European Commission has decided that the country or international organisation in question ensures an adequate level of protection;
    • Standard Contractual Clauses (SCCs) have been concluded with the recipient, ensuring a level of data protection essentially equivalent to the EU rules;
    • the recipient is certified under GDPR Article 42;
    • the recipient has implemented approved Binding Corporate Rules (BCRs).

In special cases, we may also transfer your personal data to third countries based on your explicit consent. In addition, transfers may take place if necessary to perform a contract with you or to implement measures taken at your request prior to entering into a contract. These exceptions are described in GDPR Article 49.

You are entitled at any time to request further information about the safeguards for the transfer, including the possibility of obtaining a copy of any relevant transfer mechanism.

Storage (retention)

We store the personal data you provide in connection with your application.

  • At present, we cannot state how long we will retain your personal data. However, we can inform you that in determining the retention period, we will take into account the position you

have applied for, whether certain positions are frequently re-recruited, and whether specific competency requirements are decisive.

  • Information in our database may be used for statistics, for example on the number of applicants. The legal basis is our legitimate interest in gaining insight into application patterns at an overall level, which we have assessed to be a sufficiently compelling interest to justify the processing as described, cf. GDPR Article 6(1)(f). Only data necessary for such analysis are used, and the data are not used for purposes other than statistics.
  • If you are employed by us, you can read more about our processing of your personal data in our internal privacy notice.
  • Video surveillance at all external façades, along perimeter fencing at terminals, in parking areas, at main entrances, and at entrances to headquarters and the open-plan office. The legal basis for this processing is GDPR Article 6(1)(f). It is dao's assessment that our interests are sufficiently compelling and proportionate to any inconvenience an employee may experience from being recorded.

Your rights

Under the GDPR, you have a number of rights in relation to our processing of information about you. If you wish to exercise your rights, please contact us.

  • Right of access You have the right to access the data we process about you, as well as a range of additional information.
  • Right to rectification You have the right to have inaccurate information about yourself corrected.
  • Right to erasure In certain cases, you have the right to have information about you deleted before the time of our general routine deletion occurs.
  • 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 restriction, we may in future only process the data—apart from storage—with your consent, or for the establishment, exercise or defence of legal claims, or to protect a person or important public interests.

Right to object

Legitimate interests:

You have the right, on grounds relating to your particular situation, to object to the processing of personal data where the legal basis is our legitimate interests under GDPR Article 6(1)(f) as stated above. We may then no longer process the data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is necessary for the establishment, exercise or defence of legal claims.

Direct marketing:

If your personal data are processed for direct marketing purposes, you have the right at any time to

object to such processing, including profiling to the extent that it relates to direct marketing. If you object to processing for direct marketing, the personal data may no longer be processed for this purpose.


Right to data portability

In certain cases, you have the right to receive your personal data in a structured, commonly used and machine-readable format and to have those data transmitted from one controller to another without hindrance.

Withdrawal of consent

If the processing of your personal data is based on your consent, you have the right to withdraw your consent at any time.

You can write to dpo@dao.as to exercise your rights. Please note that there may be conditions or limitations associated with these rights. For example, you may not always have the right to data portability; this depends on the circumstances of the specific processing activity.

You can read more about your rights in the Danish Data Protection Agency's guidance on data subjects' rights at www.datatilsynet.dk.

Complaint to the Danish Data Protection Agency

You have the right to lodge a complaint with the Danish Data Protection Agency if you are dissatisfied with the way we process your personal data. You can find the Agency's contact details at www.datatilsynet.dk.