At DigitalRoute (“DigitalRoute”, “we”, “our”, “us”), we are committed to safeguarding your privacy. This Recruitment Privacy Notice (“Notice”) explains how we process and protect your personal data during our recruitment process. This applies to anyone interacting with our recruitment platform (the “Platform”), which is powered by Jobylon, and covers all stages of the recruitment process. This Notice also describes what rights you have when we process your personal data, and how you can exercise these rights.
In this Notice the term "processing" covers all activities involving your personal data, including collecting, handling, storing, sharing, accessing, using, transferring and disposing of your personal data. The term "personal data" refers to any information relating to an identified or identifiable natural person.
1.
Who This Notice Applies ToThis Notice applies to:
- Visitors: Anyone browsing our Careers Platform.
- Job Applicants: Individuals who apply for a job via the Platform or through third-party services.
- Interested Talent: Individuals who create a profile to receive updates about job openings.
- Sourced Talent: Individuals whose profiles we find on public platforms and consider for current or future roles.
- Referred Talent: Individuals recommended to us by our employees or partners.
- References: Individuals listed as a reference by a prospective candidate during the recruitment process.
When we refer to “Candidate” or “you”, we mean all Job Applicants, Interested Talent, Sourced Talent, and Referred Talent, unless stated otherwise.
2. Data ControllerDigitalRoute is the data controller for the processing of your personal data as described in this Notice. This means we determine the purposes and means of processing your personal data. In some cases, we may use third-party service providers as data processors, who process your data on our behalf and according to our instructions.
3. Types of Personal Data We ProcessThe personal data we process depends on how you interact with us. We may process the following categories of data:
For all users:
- Device and Usage Data: Your device, including IP address, browser type and version, session activity, traffic source, screen resolution, preferred language, geographic location, operating system and device settings.
- Communication Data: Any correspondence with us, including emails, messages, and survey responses.
- Contact Details: Name, email, phone number, and address.
For Candidates:
- Application Materials: CV, cover letter, work samples, education, references, and recommendations.
- Interview and Assessment Records: Notes from interviews, test results, and salary expectations.
- Public Profile Information: Information from professional sites (e.g. LinkedIn).
- Background Check Information: Where permitted by applicable law and relevant to the role (e.g. senior leadership or decision-making positions), we may process information obtained through background and integrity checks. This may include information relating to criminal records, financial integrity, sanctions or compliance checks, conflicts of interest, or similar suitability assessments.
- Reference Feedback: Feedback from references or those who referred you.
- Application Evaluation Data: Information derived from your application (including skills, experience, and indicators used to assess alignment between your profile and the role requirements). This is generated through an AI-assisted matching tool.
For References:
- Reference Contact Information: Name, contact details, and information provided by the candidate or by you in the context of a reference check.
We may also create data during the recruitment process, such as interview notes or assessment results, either independently or in cooperation with you.
4. How We Collect Your Data
We may collect your data in the following ways:
- Directly from you: When you apply, create a profile, participate in interviews or assessments, or communicate with us. You can always choose not to provide us with certain information, but some personal data is required in order for us to process your application or provide you with information you request from us.
- From your device: When you visit or interact with the Platform, including through cookies and similar technologies (see our Cookie Policy for details).
- From public sources: Such as professional networking sites (e.g. LinkedIn) or company websites.
- From our employees, partners (e.g. recruitment service providers), or References: When they refer you, provide feedback or act as a reference.
- From Candidates: If you are listed as a reference by a Candidate, we will collect your contact details from the candidate to be able to contact you.
- From background screening providers or authorities: Where applicable and permitted by law, from background screening providers, public authorities, or directly from you (for example, where you provide an official extract yourself).
5. Purposes for Processing Your Data
We process your personal data for the following purposes:
- Managing Recruitment: Reviewing applications, communicating with you, and making job offers.
Legal basis: Legitimate interest ((our interest in recruiting suitable talent).
- Application Matching: Using an AI tool to assess how well your application matches a specific role, to help us review applications consistently and efficiently. The tool does assist us but does not replace human decision-making. You can opt-out of this assessment and your application will still be reviewed, without disadvantage.
Legal basis: Legitimate interest.
- Assessment and Testing: Conducting interviews and tests to evaluate your suitability.
Legal basis: Consent (where required for recording interviews or specific assessments)
- Protecting Our Rights: Handling legal claims, disputes or regulatory obligations
Legal basis: Legitimate interest or legal obligation
- Background and Integrity Checks (for certain roles): Assessing suitability for positions involving leadership, decision-making authority or fiduciary responsibility.
Legal basis: Legitimate interest.
- Platform Analytics and Security: Monitoring usage, maintaining security, and improving the Platform.
Legal basis: Legitimate interest or consent (for certain cookies and analytics)
- Future Opportunities: Contacting you about future job openings that may match your profile.
Legal basis: Consent
- Surveys: Inviting you to participate in surveys to improve our recruitment process.
Legal basis: Legitimate interest
- Compliance with Legal Obligations: Fulfilling obligations under applicable data protection and employment laws.
Legal basis: Legal obligation.
6. Who We Share Your Data With
- Service Providers: Companies that help us with recruitment, Platform management, assessments, and analytics (for example, Jobylon and other recruitment technology providers and background check providers).
- Group Companies: Other companies within the DigitalRoute Group, when necessary for recruitment or administrative purposes.
- Cookie Providers: Third parties that set cookies if you consent (see our Cookie Policy).
- Authorities and Public Bodies: When required by law or in response to valid requests from regulatory authorities, courts or law enforcement.
- Legal Proceedings: If necessary to protect our rights or in connection with legal claims or disputes.
- Business Transfers: In case of mergers, acquisitions, or similar events, your data may be shared with the relevant parties.
We require all recipients to protect your data in accordance with applicable laws and with appropriate contractual safeguards in place.
7. International Data Transfers
We always aim to process your data within the EU/EEA, however if your data is transferred outside the EU/EEA (for example, to a service provider located elsewhere), we ensure that appropriate safeguards recognized by is the EU Data Protection Regulation 2016/679 (“GDPR”) are in place such as:
- Adequacy Decisions: A decision by the EU Commission that the country outside of the EU/EEA to which your personal data is transferred has an adequate level of protection, which corresponds to the level of protection afforded by the GDPR. (for example, for the UK)
- Standard Contractual Clauses: Entering into the EU Commission's Standard Contractual Clauses with the recipient of the personal data to ensure your data is protected to EU standards
- Additional Safeguards: Technical and organizational measures to protect your data in case of disclosure or unauthorized access.
8. Data Retention
We keep your personal data only as long as necessary for the purposes described in this Notice, or as required by law. Specifically:
- All Individuals: If we process your personal data for the purpose of being able to protect and enforce our rights, we will keep your personal data until the relevant legal issue has been fully and finally resolved.
- Visitors: Data is kept for one year for security purposes. Cookie retention is specified in our Cookie Policy).We keep your personal data to analyse the performance of the Platform for as long as we keep personal data about you for other purposes.
- Candidates: If you are only an Interested Candidate, we keep your personal data for as long as you remain connected with us. For other types of Candidates, we keep your personal data to decide if you are a suitable candidate for any relevant future vacancies.
- Background check: Information is retained only for as long as necessary to complete the recruitment process for the relevant role, unless a longer retention period is required by law.
- References: Personal data is stored for up to one year unless you object in writing or request deletion sooner / We keep your personal data for as long as we keep the personal data of the Candidate for whom you acted as a reference.
- Hired Candidates: If you are hired, your data will be retained in accordance with our employee privacy policy.
We may retain anonymized or aggregated data for analytics or statistical purposes.
9. Your Rights
You have the following rights regarding your personal data:
The right to know how your data is processed. We provide you this information via this Privacy Notice, through our website (see section 11), and by responding to your queries.
The right to know what personal data we process see and get a copy of the data we process.
- Right to Data Portability
The right to receive a copy of your personal your data in a structured, commonly used, machine-readable format. This will allow you to use this data somewhere else, for example to transfer it to another recipient. If technically feasible, you also have the right to request that we transfer your data directly to another recipient.
The right to have your data deleted in certain cases, e.g. if it’s no longer necessary for us to process the data for the purpose for which we collected it or if you withdraw your consent for us to process that data.
The right to object to us processing based on legitimate interests, by referencing your personal circumstances.
- Right to Restrict Processing
The right to limit how your data is used, e.g. if you believe that the personal data we process about you is inaccurate, or that we don’t need the data for a specific purpose, you have the right to request that we restrict the processing of such personal data.
The right to request us to correct inaccurate data or to complete information that you consider incomplete.
- Right to Withdraw Consent:
The right to withdraw your consent to us processing your personal data at any time. If you do so, we will stop processing your data for the purposes you’ve withdrawn your consent for.
The right to lodge a complaint with a data protection authority.
You can find the details of the Swedish data protection authority (Integritetsskyddsmyndigheten) here. If you are based elsewhere in the EU, you can find a list of all national data protection authorities here. If you are based in the UK, you can lodge a complaint with the Information Commissioner’s Office, here.
10. Contact Us
If you wish to contact us to exercise your rights or if you have any other questions or concerns, you can contact us directly by sending us an email at dpo@digitalroute.com. We will respond to your request as soon as possible.
11. Updates to This Notice
We may update this Notice as needed. Please check this page regularly for changes. The top of this page will always specify when the policy was last updated.
