ABW Consulting Privacy Policy

ABW Consulting's Privacy Policy pertains to the nature and extent of our processing of your personal data in our business operations, in accordance with the provisions of the General Data Protection Regulation (EU) 2016/679 ("GDPR").

1 Privacy Policy

This Privacy Policy explains how ABW Consulting processes your personal data and outlines your rights in connection with ABW Consulting's collection, processing, and retention of your personal data. This Privacy Policy applies to you as an applicant, customer, supplier, business partner, collaborator, consultant, advisor, or any other party for whom we process personal data.

2 Data Controller

When processing your personal data for ABW Consulting's purposes, ABW Consulting acts as a data controller. ABW Consulting is an international organization with legal entities in multiple countries. The entity responsible for processing your personal data (the data controller) depends on the entity with which you are collaborating.

Location Company Address

ABW Consulting Denmark A/S
Pladehals Alle 27
DK-2450 Copenhagen

3 Purposes for Processing of Personal Data

ABW Consulting processes personal data only when there is a specific and legitimate purpose. Below, we have outlined the most relevant purposes for the processing of personal data by ABW Consulting and provided some insight into the associated activities:
  • Applications and Recruitment: This includes processing data related to job applicants, candidates participating in various events, candidates contacting ABW Consulting for the purpose of employment, and individuals participating in our recruitment process, job interviews, and personality tests.
  • Business Operations: This category encompasses activities related to managing IT and communications systems, product and service development, procurement from suppliers, product and service improvement, asset management, allocation of company resources, strategic planning, project management, business continuity, audit trails, and other reporting tools, record-keeping related to manufacturing and business activities, security of premises, budgeting, financial management and reporting, communications, management of mergers, acquisitions, and reorganization or disposals.
  • Communication: Communication-related processing activities include facilitating communication with employees, using photographs in newsletters and other materials distributed within ABW Consulting and to partner entities and subsidiaries, providing references, ensuring business continuity, protecting the health and safety of employees and others, safeguarding IT infrastructure, office equipment, and other property, facilitating communication in emergencies, and publishing contact information and pictures on our website.
  • Compliance: Compliance activities include monitoring compliance with internal policies and applicable laws, adhering to legal and other requirements, such as income tax and national insurance deductions, record-keeping, conducting audits, responding to government inspections and other requests from government or other public or regulatory authorities, addressing legal processes such as subpoenas, pursuing legal rights and remedies, defending against litigation, managing internal complaints or claims, and complying with internal policies and procedures.
  • Website: When you use our website, we collect personal data through the use of cookies. For more information, please refer to ABW Consulting's cookie policy.

4 Categories of Personal Data

4.1 Personal Data

ABW Consulting processes personal data provided by individuals, business partners, or customers. This typically includes the processing of the following categories of personal data:
  • Name
  • Email
  • 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

4.2 Sensitive Personal Data

Sensitive personal data refers to information that is of a sensitive nature, including:
  • 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 offenses
Generally, ABW Consulting does not process sensitive personal data. However, in the context of an application, we may request a criminal record to be provided.

5 Collection of Personal Data

ABW Consulting may collect personal data from various sources, including but not limited to:
  1. Directly from you: This includes data obtained through application processes or other forms, as well as information provided to ABW Consulting in connection with applications, partnerships, consultancy work, or advisory services.
  2. From group entities or subsidiaries: Data may be collected through application processes or other forms or information you provide to the group entity or subsidiary in connection with your employment, partnership, or consultancy work.
  3. During your activities: Personal data may be collected as part of your activities during the application, partnership, or consultancy work, including your interactions with other employees, customers, or other individuals.
  4. From third parties: This may include, but is not limited to, data obtained from references, former employers, public authorities (especially concerning security checks and the obtaining of security licenses), other third parties like background check agencies, and external recruiters. Additionally, data from websites, LinkedIn, or similar public media sources may also be collected.

6 Special Notices

ABW Consulting hereby notifies all individuals that there is video surveillance at the entrances to our premises.

7 Legal Basis for Processing of Personal Data

ABW Consulting processes personal data based on various legal grounds in accordance with the General Data Protection Regulation (GDPR). These legal grounds include:
  1. Consent (article 6.1.a): Personal data may be processed when you provide it directly to ABW Consulting or when you provide explicit consent for ABW Consulting to obtain such personal data.
  2. Necessary for the performance of the contract between you and ABW Consulting (article 6.1.b): Processing may be necessary to fulfill contractual obligations between you and ABW Consulting.
  3. Necessary for ABW Consulting to comply with a legal obligation (article 6.1.c): Processing may be required to meet legal obligations, such as those related to bookkeeping and financial reporting.
  4. Necessary for the pursuit of legitimate purposes of ABW Consulting (article 6.1.f): This includes situations where personal data is stored to facilitate client relations within our CRM system.
  5. Necessary for the purpose of carrying out obligations in the field of employment, social security, and social protection (article 9.2.b): Processing may be required to comply with employment-related laws and obligations.
  6. Necessary for the establishment, exercise, or defense of legal claims (article 9.2.f): Processing may be necessary when ABW Consulting needs to establish, exercise, or defend legal claims.

8 Recipients of Personal Data

ABW Consulting shares your personal data only to the extent necessary to fulfill the purposes of processing or as required by applicable law. In such cases, we may share your personal data with the following entities:
  • Suppliers, business partners, and clients: This includes service providers and financial institutions with whom we work.
  • Group entities: Data may be shared with other entities within the ABW Consulting Group.
  • Public authorities: Personal data may be shared with governmental or regulatory authorities as required by law.
Certain recipients may process personal data on behalf of ABW Consulting (data processors) and may only do so in accordance with the instructions provided by ABW Consulting. These third parties are not authorized to process your personal data for their own purposes. To the extent that ABW Consulting discloses or transfers personal data to third parties who may use your data for their own purposes (joint data controllers), such disclosure or transfer will only take place in accordance with applicable law or with your prior consent.

9 Transfer to Countries Outside the EU/EEA

ABW Consulting generally refrains from transferring personal data to countries outside the European Union (EU) or the European Economic Area (EEA). However, in cases where such transfers are necessary, they will be conducted in compliance with applicable data protection laws. These transfers may occur under the following conditions:
  • If the country has been deemed by the European Union Commission to have an adequate level of protection for personal data.
  • If the country has not been deemed to have an adequate level of protection, appropriate safeguards will be employed, which may include the use of "Model Contracts for the Transfer of Personal Data to Third Countries" as published by the European Union Commission, or any other contractual agreements approved by competent authorities.

10 Storage

ABW Consulting retains personal data only for as long as necessary to fulfill the purposes of processing, unless specific legal requirements or obligations dictate a longer retention period. As a general rule, personal data collected in connection with applications and recruitment will be deleted after 12 months from the date of receiving the candidate's application. Personal data collected in connection with business operations will typically be deleted according to ABW Consulting's Internal Privacy Policy or as agreed upon in terms with our suppliers or other business partners. Personal data obtained in connection with communications will also be deleted in accordance with ABW Consulting's Internal Privacy Policy.

11 Your Rights as a Data Subject

As a data subject, you have specific rights regarding your personal data, including:
  • Requesting access to your personal data
  • Requesting rectification of your personal data
  • Requesting erasure of your personal data
  • Objecting to the processing of your personal data and requesting processing restrictions
  • Receiving your personal data in a structured, commonly used, and machine-readable format (data portability)
  • Filing a complaint with a data protection supervisory authority
To exercise your rights, please contact ABW Consulting's appointed Data Protection Officer (DPO). Contact information for the DPO can be found in Section 15. Please be aware that there may be additional conditions or limitations on your rights as a data subject, depending on the specific circumstances.

12 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 by contacting ABW Consulting's DPO. However, please note that this withdrawal of consent does not affect the legal basis for ABW Consulting's processing of your personal data that occurred prior to the withdrawal.

13 Filing a Complaint

If you wish to file a complaint regarding ABW Consulting's processing of your personal data, you can contact ABW Consulting's DPO. All complaints submitted to the DPO should be resolved. However, if resolution is not achieved, you may file a complaint with your local data protection supervisory authority.

14 Data Protection Officer (DPO)

The contact information for ABW Consulting's Data Protection Officer (DPO) is as follows:
  • Telephone number: +45 61 27 61 61
  • Email address: contact at anrs.dk

15 Changes to the Privacy Policy

This Privacy Policy will be periodically updated and whenever necessary due to changes in applicable law. The Privacy Policy will always include information about the effective date of the latest version. The latest version was approved and adopted on February 3, 2020.