Netcompany privacy policy

When processing your personal data for Netcompany’s purposes, Netcompany acts as a data controller.

Netcompany is an international organisation with legal entities in several countries. The entity responsible for the processing of your personal data (the data controller) thus depends on which entity you are working with.

Some of your personal data may be shared internally within the Netcompany Group, but only if it is necessary in order to fulfil the purpose of which we are processing your personal data. All entities in the Netcompany Group have entered into an Intra Group Agreement that ensures that everyone follows the same procedures when processing personal data so the same level of security is maintained throughout.

Netcompany processes personal data that is provided to us by either you, our business partners or customers etc. Usually, that amounts to the processing of some of the following categories of personal data e.g.:

• Name, e-mail, telephone number, address, date of birth, gender, photographs, bank and salary details, description of current position and title, employment status, details contained in letters of application and resume/CV, previous employment background and references, education history, professional qualifications and academic credentials, other relevant skills and personality test results.
   

Sensitive personal data is defined as:

• Personal data regarding racial or ethnic origin
• Political opinions
• Religious or philosophical beliefs
• Trade-union membership
• Genetic and biometric data for the purpose of uniquely identifying a natural person
• Data concerning health or data concerning a natural person's sex life or sexual orientation
• Criminal offences

We may collect personal data from the following source(s):
 
(1) Directly from you, such as through an application process or other forms or information you provide to Netcompany in connection with your application, partnership, consultancy work, advisory work etc.

(2) From group entities or subsidiaries such as through an application process or other forms or information you provide to the group entity or subsidiary in connection with your employment, partnership, consultancy work etc.

(3) During your activities in the course of your application, partnership, consultancy work, such as through your performance and interaction with other employees, customers, or other individuals

(4) From third parties which may include (the list is not exhaustive):

(i) References

(ii) Former employers

(iii) Public authorities (in particular regarding security checks and the obtaining of security licenses)

(iiiv) Other third parties, including background checks, agencies and external recruiters

(v) Websites, LinkedIn or similar public medias

We process personal data on the following legal grounds pursuant to the GDPR:

Consent (article 6.1.a):
E.g. when you provide Netcompany with the relevant personal data directly or you provide Netcompany with your explicit consent to obtain such personal data.
 
Necessary for the performance of the contract between you and Netcompany (article 6.1.b):
E.g. when it is necessary for Netcompany to comply with a contractual obligation.
 
Necessary for Netcompany to comply with a legal obligation (article 6.1.c):
E.g. when Netcompany must comply with laws on bookkeeping and financial reporting etc.
 
Necessary for the pursuit of legitimate purposes of Netcompany (article 6.1.f):
E.g. when Netcompany stores contact information in our CRM system to handle client relations.
 
Necessary for the purpose of carrying out obligations in the field of employment, social security and social protection (article 9.2.b):
E.g. when Netcompany must comply with employment laws etc.
 
Necessary for the establishment, exercise or defence of legal claims (article 9.2.f):
E.g. in cases where it is necessary for Netcompany to either establish, exercise or defence legal claims.

Netcompany only shares your personal data to the extent that it is necessary in order to fulfil the purposes with the processing or if required by law. In such cases, we might share your personal data with:

• Suppliers, business partners and clients that we work with e.g. service providers and financial institutions
• Group entities
• Public authorities

(1) If the country has been deemed to have an adequate level of protection of personal data by the Commission of the European Union, and

(2) If the country has not been deemed to have an adequate level of protection of personal data by the Commission of the European Union, where the appropriate safeguards can be guaranteed through either:

(a) The use of "Model Contracts for the Transfer of Personal Data to Third Countries", as published by the Commission of the European Union, or any other contractual agreement approved by the competent authorities, or

(b) The use of an approved code of conduct pursuant to article 40, an approved certification mechanism pursuant to article 42

Your rights as a data subject includes the right to:

• Request access to your personal data
• Request rectification of your personal data
• Request erasure of your personal data
• Object to the processing of your personal data and have the processing restricted
• Receive your personal data in a structured, commonly used and machine-readable format (data portability)
• Complain to a data protection supervisory authority
   

You may take steps to exercise your rights by contacting Netcompany’s appointed DPO. You can find the contact information under section 15.
 

If you wish to file a complaint regarding Netcompany’s processing of your personal data, you can always contact Netcompany’s DPO. All complaints filed to the DPO should be resolved, if, however, this is not the case, you can file a complaint to the local data protection supervisory authority.

The contact information of Netcompany’s Data Protection Officer (DPO) are as follows:
Telephone number: +45 70 13 14 40
Email address: gdpr@netcompany.com