1. INTRODUCTION

When you apply for a vacancy at the ln Commodities Group (hereinafter referred to as "lnC"), lnC will collect and process your personal data as a job applicant, including storing your job application, CV and other relevant material.

lnC is the data controller for the processing of your personal data relating to your job application. We understand the importance of correctly processing your personal data. We are therefore committed to being compliant with the applicable law and have created this Job Applicant Privacy Policy (hereinafter referred to as "Privacy Policy") in accordance with the General Data Protection Regulation (hereinafter referred to as "GDPR").

lnC kindly requests that you only submit your own personal data in your job application, CV or other relevant material you choose to provide to us, to the extent such information is relevant to the specific position you are applying for. For this reason, please do not include information such as your CPR-number in the initially submitted documents and consider whether there is any other personal information, such as health information, information on family relations or similar, that is not necessary for lnC's recruitment process.

2. PURPOSE, SOURCE AND PERSONAL DATA PROCESSED BY INC 

lnC gathers, collects and processes your personal data to run an efficient recruitment process, where you as a candidate can be evaluated fairly and thoroughly.

lnC processes your personal data contained in the materials that you have provided by submitting your job application, such as your application, CV, diplomas, references, etc. This includes your name, address, e-mail address, telephone number, your work experience, qualifications, education, preferred leisure activities, etc.

We collect your personal data through our Recruitment system "HR-ON Recruit" which is an integrated part of our website. Furthermore, lnC may process your personal data collected from third parties; for example, from public databases, via Linkedln or other public social media platforms, an online search or a search and selection/recruitment agency. lf you have given your consent, lnC may also obtain and process statements from your former employers, cf. Article 6 (1) (a) of the GDPR.

lnC does not process or otherwise use your CPR number during the recruitment process. Although lnC does not ordinarily process sensitive personal data, personal data relating to (potential) criminal convictions or offences may be processed based on section 8(3)-(5) of the Danish Data Protection Act. This will only be done where processing is necessary for the purpose of pursuing a legitimate interest, that clearly overrides the interest of the data subject, e.g the protection of business-related data, trade secrets and prevention of fraud or any kind of deception

3. LEGAL BASIS FOR PROCESSING

lnC processes the personal data you have provided for recruitment purposes to pursue lnC's legitimate interests such as the administration of the recruitment process and the evaluation of job applicants before hiring, and this interest is considered to override your interests or fundamental rights and freedoms, cf. Article 6 (1) (f) of the GDPR. lf you are chosen for one of our vacancies, such processing will also be necessary in order to take any necessary steps prior to entering into an employment contract, cf. Article 6 (1) (b) of the GDPR.

lnC will only process references obtained from external parties, such as previous employers, with your explicit consent, cf. Article 6 (1) (a) of the GDPR. Additionally, lnC will store your personal data for relevant future recruitment only if you have granted consent, cf. Article 6 (1) (a) of the GDPR.

4. RECIPIENTS OF YOUR PERSONAL DATA

Where it is necessary, lnC may disclose or transfer your personal data to certain third-party recipients, such as lnC Group companies or service providers, such as HR-ON Recruit, in relation to the recruitment process (including search and selection/recruitment agencies).

ln certain specific cases, e.g., in connection with disputes, including when the disclosure of your personal data is necessary for the establishment, exercise or defence of lnC's legal claims, lnC may disclose your personal data to its advisers or other relevant third parties provided it is deemed necessary and lawful.

These parties act generally as data processors and may only process your personal data on behalf of lnC and in accordance with lnC's instructions. They are not permitted to process your personal data for their own purposes.

5. TRANSFER OF YOUR PERSONAL DATA TO A THIRD COUNTRY (OUTSIDE OF EU/EEA)

Your personal data may be transferred to countries outside of the EU/EEA if necessary for the performance of a service or contractual obligation. lnC ensures that any transfer of your personal data to a third country will be carried out in accordance with the GDPR, i.e. the recipient will ensure an adequate level of data protection, by either entering into the EU standard contractual clauses or adopting supplementary measures.

6. STORAGE OF YOUR PERSONAL DATA

If you are not chosen for the vacancy you applied for, InC will store your job application, CV and other relevant material for 6 months if you have consented to such storage. Hereafter, your personal data will be deleted.

If you have not consented, these will be deleted as soon as possible after the position you have applied for has been filled by another applicant.

7. YOUR RIGHTS AS A DATA SUBJECT

As a data subject, you have a number of rights. lnC has taken all necessary and adequate steps to protect your personal data and ensure your rights as a data subject. Your rights are: 

• The right of access to the personal data stored by InC.
• The right to rectify your personal data if it is incomplete or inaccurate.
• The right to restrict or object at any time to InC's processing your personal data.
• Under specific circumstances, the right to erasure of your personal data stored by InC.
• Under specific circumstances, the right to data portability. 

If processing your personal data is based solely on your consent, you have the right to withdraw your consent at any time. The withdrawal of your consent will not affect the lawfulness of InC's processing of your personal data that occurred prior to the withdrawal of your consent.

If you wish to exercise any of your rights as a data subject, please contact us at legal@in-commodities.com.

9. QUESTIONS AND COMPLAINTS

If you have any question about the processing of your personal data or you wish to file a complaint in this regard, you can contact InC at legal@in-commodities.com.

If your complaint is not resolved by InC., you may choose to submit a compliant to the Danish Data Protection Agency. 

Danish Data Protection Agency (Datatilsynet)

Borgergade 28, 5.

1300 Copenhagen K.

Telephone number: +45 33 19 32 00

E-mail address: dt@datatilsynet.dk

Website: www.datatilsynet.dk

11. CHANGE TO THE PRIVACY POLICY

This Privacy Policy will be updated on a regular basis and when necessary due to changes in applicable law and practic. We therefor recommended that you consult this Privacy Policy regularly.

Revision History	Responsible	Summary of change
06/01/2022	Ida Hedam Pedersen, HR Partner	First publication of the Policy
30/01/2024	Nana Mägi, Legal Counsel	Policy updated