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

Data protection information for applicants in accordance with the EU General Data Protection Regulation (GDPR)
Dear Applicant
Thank you for your interest in our company.
We take the protection of your personal data very seriously and comply with data protection provisions, particularly the EU General Data Protection Regulation ("GDPR"), and the German Data Protection Act ("BDSG"). In particular, this means that we will process your personal data only if this is permitted by statutory law, a collective bargaining agreement or a works agreement, or if you have declared your consent.
To ensure that you are fully informed about the processing of your personal data as part of the application process, please take note of the in-formation below.

I. Controller
(1) The responsible person pursuant to Art. 4 (7) GDPR is
ctrl QS GmbH 
Schuetzenstrasse 6a
10117 Berlin, Germany
Phone: +49 (0)30 440 325 20
E-Mail: contact@ctrl-qs.com
Website: https://ctrl-qs.com/
(hereinafter „ctrl QS“)
You will find further information in our imprint.
Wherever this data protection information refers to "we" or "us", this refers in each case to the aforementioned company.
(2) You can reach our data protection officer at dataprotection@ctrl-qs.com or our postal address with the addition of "the data protection officer".

II. Data processing description and categories of personal data
The execution of the application process requires the processing of personal data. We only process data that is related to your application. These can be:

  1. Contact details in your application profile (e.g. first and last name, place of residence, e-mail, telephone number);
  2. Information regarding your professional qualifications and schooling (e.g. curriculum vitae, cover letter, career development data, qualifications and language skills);
  3. Results of online procedures (e.g. personality tests, cognitive performance tests) and, if applicable, video interviews;
  4. if applicable, other data that you provide to us in connection with your application.
III. Purposes and legal bases of data processing
(1) We process your personal data in accordance with the provisions of the European Data Protection Regulation (GDPR) and the German Federal Data Protection Act (BDSG), insofar as this is necessary for the decision on the establishment of an employment relationship with us. The legal basis for this is Art. 88 GDPR in conjunction with. § 26 BDSG-neu as well as, if applicable, Art. 6 para. 1 lit. b GDPR for the initiation or implementation of contractual relationships.
(2) Furthermore, we may process personal data from you if this is necessary for the fulfilment of legal obligations (Art. 6 para. 1 lit. c GDPR) or for the defence of asserted legal claims against us. The legal basis for this is Art. 6 (1) lit. f GDPR. The legitimate interest is, for example, a duty to provide evidence in proceedings under the General Equal Treatment Act (AGG). If you give us explicit consent to process personal data for certain purposes, the lawfulness of this processing is given on the basis of your consent according to Art. 6 para. 1 lit. a GDPR. Consent given can be revoked at any time with effect for the future (see section [VIII] of this data protection information).
(3) If an employment relationship arises between you and us, we may, in accordance with Art. 88 GDPR in conjunction with § 26 BDSG-neu, further process the personal data already received from you for the purposes of the employment relationship, insofar as this is necessary for the implementation or termination of the employment relationship or for the exercise or fulfilment of the rights and obligations of the employee representation resulting from a law or a collective agreement, a company or service agreement (collective agreement).

IV. Data Sources
(1) We process personal data that we receive from you by post or e-mail during the course of contacting you or your application, or that you send to us via our contact form.
(2) We may also obtain the above information about you from other sources, including external business partners such as recruitment companies. We may also receive data that you have made public on work-related social networking sites, such as LinkedIn, or that you submit to us via other websites, such as Monster Job Board, or from other publicly available sources (only if the data is relevant to your professional life). The purpose is to contact you about job offers or to verify the accuracy of the information you provide in your application.

V. Recipients of personal data
(1) Your personal data is generally processed within our company. Depending on the type of personal data, only certain departments/organizational units have access to your personal data. This includes, in particular, the HR department and – in the event of data generated by the IT infrastructure – the IT department, to a certain ex-tent. A role and authorization concept restricts access within our company to such functions and to such extent that is required for the respective purpose of the processing.
(2) To the extent permitted by statute, we may also transmit your personal data to third par-ties outside our company. These external recipients may include, in particular:
  • service providers (processors) engaged by us who on the basis of a separate contract provide services to us that may also include the processing of personal data, and any subcontractors engaged by our service providers with our permission;
  • non-public and public bodies, to the extent we are obliged to transmit your personal data on the basis of statutory obligations,
  • business partners, to the extent that the transfer of personal data (e.g. your publicly available company contact data) is necessary for establishing, executing or terminating the employment relationship,
(3) Our website contains an application form that can be used for electronic applications. For the provision of the application form, we use the recruiting page of the personnel and applicant management software Personio of the service provider 

Personio GmbH, Rundfunkplatz 4, 80335, Munich, Germany.

If an applicant uses this option, the data entered in the input mask will be transmitted to Personio and stored.
Further information can be found in Personio's data protection declaration:
https://www.personio.de/datenschutzerklaerung/

VI. Processing in third countries
(1) We intend to also transfer your personal data to recipients in "third countries". "Third countries" are countries outside the European Union or the European Economic Area with regard to which it cannot be readily assumed that the level of data protection is comparable to that of the European Union.
(2) Before any such data transfer we ensure that the required level of data protection is ensured in the third country concerned or at the recipient in the third country. In particular, this may take the form of an "adequacy decision" of the European Commission which ensures that an adequate level of data protection has been ascertained overall for a certain third country. Alternatively, we can also transfer data on the basis of "EU standard contractual clauses" agreed with a recipient".
(3) We are happy to provide you with additional information regarding the suitable and appropriate guaranties for observance of an appropriate data protection level, if you so request; for the relevant contact data please refer to the beginning of this data protection information.

VII. Storage period
(1) We store your personal data as long as this is necessary for the decision on your application. Your personal data or application documents will be deleted a maximum of six months after the end of the application process (e.g. notification of the rejection decision), unless longer storage is legally required or permitted.
(2) We store your personal data beyond this only insofar as this is required by law or in the specific case for the assertion, exercise or defence of legal claims for the duration of a legal dispute.
(3) In the event that you have consented to a longer storage of your personal data, we will store it in accordance with your declaration of consent.
(4) If an employment relationship, apprenticeship or trainee relationship is established following the application process, your data will, insofar as necessary and permissible, initially continue to be stored and then transferred to the personnel file.
(5) If applicable, you will receive an invitation to join our talent pool following the application process. This will allow us to continue to consider you in our selection of applicants for suitable vacancies in the future. If we have your consent to do so, we will store your application data in our talent pool in accordance with your consent or any future consent

VIII. Your rights
(1) Every data subject has the right to information under Article 15 of the GDPR, the right to rectifi-cation under Article 16 of the GDPR, the right to erasure under Article 17 of the GDPR, the right to restriction of processing under Article 18 of the GDPR, the right to notification under Article 19 of the GDPR and the right to data portability under Article 20 of the GDPR.
(2) In addition, you have the right to lodge a complaint with a data protection supervisory authority pursuant to Art. 77 GDPR if you are of the opinion that the processing of your personal data is not lawful. The right of appeal is without prejudice to any other administrative or judicial remedy.
(3) If the processing of data is based on your consent, you are entitled to revoke your consent to the use of your personal data at any time in accordance with Art. 7 GDPR. Please note that the revocation only takes effect for the future. Processing that took place before the revocation is not affected. Please also note that we may need to retain certain data for a certain period of time in order to comply with legal requirements (see section [VII] of this data protection information).(3) If the processing of data is based on your consent, you are entitled to revoke your consent to the use of your personal data at any time in accordance with Art. 7 GDPR. Please note that the revocation only takes effect for the future. Processing that took place before the revocation is not affected. Please also note that we may need to retain certain data for a certain period of time in order to comply with legal requirements (see section [VII] of this data protection information).

Right to object 
Insofar as the processing of your personal data is carried out for the protection of legitimate interests pursuant to Art. 6 (1) (f) GDPR, you have the right pursuant to Art. 21 GDPR to object to the processing of this data at any time for reasons arising from your particular situation. We will then no longer process this personal data unless we can demonstrate compelling legitimate grounds for the processing. These must outweigh your interests, rights and freedoms, or the processing must serve the assertion, exercise or defence of legal claims.
(4) If you have any questions regarding the processing of your data, please feel free to con-tact our data protection officer using the contact details stated above.

IX. Necessity of the provision of personal data
The provision of personal data in the context of application processes is neither legally nor contractually required. You are therefore not obliged to provide any personal data. Please note, however, that these are necessary for the decision on an application or the conclusion of a contract in relation to an employment relationship with us. If you do not provide us with any personal data, we will not be able to make a decision regarding the establishment of an employment relationship. We recommend that you only provide personal data in your application that is required to complete the application.
X. Final provisions
(1) We use technical and organisational security measures to protect your data, in particular against accidental or intentional manipulation, loss, destruction or against attack by unauthorised persons. Our security measures are continuously improved in line with technological developments.
(2) We will update the data protection declaration from time to time due to the technical progress of our offers. Insofar as the change to the data protection declaration does not affect the use of existing data, the new data protection declaration will apply from the date of its update on our website. A change to the data protection declaration that relates to the use of data already collected will only be made if it is reasonable for you. In such a case, we will notify you in good time by e-mail, on our website, in our application or in another form. You have the right to object to the validity of the new data protection declaration within four weeks of receipt of the notification. In the event of an objection, we reserve the right to terminate the contractual relationship. If no objection is made within the aforementioned period, you will be deemed to have accepted the amended data protection declaration. We will inform you of your right of objection and the significance of the objection period in the notification.

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Processing of (personal) data by the operator of the recruitment website

General information

This recruitment website is operated by Personio SE & Co. KG, which offers a human resource and candidate management software solution (https://www.personio.com/legal-notice/). Data transmitted as part of your application will be transferred using TLS encryption and stored in a database. The sole controller of this data within the meaning of article 24 of the GDPR is the enterprise carrying out this online application process. Personio’s role is limited to operating the software and this recruitment website and, in this context, being a processor under article 28 of the GDPR. In this case, the processing by Personio is based on an agreement for the processing of orders between the controller and Personio. In addition, Personio SE & Co. KG processes further data, some of which may be personal data, to provide its services, in particular for operating this recruitment website. We will refer to this in more detail below.

The controller

The controller under data protection law is:
Personio SE & Co. KG
Seidlstraße 3
80335 München
Tel.: +49 (89) 1250 1004
Entry in the commercial register
Commercial register entry number: HRA 115934
Registration Court: Amtsgericht München
Data Protection Officer contact: privacy@personio.com

Access logs (“server logs”)

Each access to this recruitment website automatically causes general protocol data, so-called server logs, to be collected. As a rule, this data is a pseudonym and thus does not allow for inferences about the identity of an individual. Without this data, it would, in some cases, be technically impossible to deliver or display the contents of the software. In addition, processing this data is absolutely necessary under security aspects, in particular for access, input, transfer, and storage control. Furthermore, this anonymous information can be used for statistical purposes and for optimizing services and technology. In addition, the log files can be checked and analyzed retrospectively when unlawful use of the software is suspected. The legal basis for this is §25 subsection 2 Sentence 2 TDDDG. Generally, data such as the domain name of the website, the web browser and web-browser version, the operating system, the IP address, as well as the timestamp of the access to the software is collected. The scope of this log process does not exceed the common log scope of any other site on the web. These access logs are stored for a period of up to 7 days. There is no right to object to this.

Error logs

So-called error logs are generated for the purpose of identifying and fixing bugs. This is absolutely necessary to ensure we can react as quickly as possible to possible problems with displaying and implementing content (legitimate interest). As a rule, this data is a pseudonym and thus does not allow for inferences about the identity of an individual. The legal basis for this is §25 subsection 2 Sentence 2 TDDDG. When an error message occurs, general data such as the domain name of the website, the web browser and web-browser version, the operating system, the IP address, as well as the timestamp upon occurrence of the respective error message and/or specification is collected. These error logs are stored for a period of up to 7 days. There is no right to object to this.

Use of cookies

So-called cookies are used on parts of this recruitment website. They are small text files which are stored on the device with which you access this recruitment website. As a general rule, cookies serve the purpose of ensuring secure access to a website (“absolutely necessary”), implementing certain functionalities such as standard-language settings (“functional”), improving the user experience or the performance of the website (“performance”), or placing targeted advertisements (“marketing”). On this recruitment website, we generally use only cookies that are absolutely necessary, functional or performance-related, in particular for implementing certain default settings such as language, for identifying the job advertising channel, or for analyzing the performance of a job advert via which a user accessed this recruitment website. The use of cookies is absolutely necessary for providing our services and thus for the performance of the contract (article 6 (1) b) of the GDPR). Period of storage: up to 1 month or until the end of the browser session Right to object: You can determine via your browser settings whether you allow or object to the use of cookies. Please note that deactivating cookies may result in limited or completely blocked functionalities of this recruitment website.

Rights of data subjects

If Personio SE & Co. KG as the controller processes 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 for the purpose of operating this recruitment website, please refer to Personio SE & Co. KG’s Data Protection Officer (see item B).

Concluding provisions

Personio reserves 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 services offered, for example when new services are introduced. In this case, the new data privacy statement applies to any later visit of this recruitment website or any later job application.