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

Contents
1. Name and contact details of the controller    
2. Contact details of the Data Protection Officer    
3. Information on relevant processing activities    
3.1 Applications via the online application portal, by email or letter or via headhunters    
3.1.1. Purpose of data processing
3.1.2. Legal bases of data processing    
3.1.3. Recipients    
3.1.4. Intended third-country transfer    
3.1.5. Storage duration    
3.1.6. Obligation to provide data and consequences of not providing data    
3.1.7. Categories of personal data    
3.1.8. Sources of personal data    
3.2 Provision of our online application portal    
3.2.1. Purpose of data processing
3.2.2. Legal bases of data processing
3.2.3. Recipients
3.2.4. Intended third-country transfer
3.2.5. Storage duration
3.2.6. Obligation to provide data and consequences of not providing data
3.2.7. Categories of personal data
4. Automated decision-making (Article 22 UK-GDPR)    
5. Rights as data subject    

Data protection information for applicants
We, kloeckner.i GmbH (also referred to in the following as “kloeckner.i”, “we” or “us”) inform you in this document about the processing of your personal data and your rights in connection with your application. 

1. Name and contact details of the controller
kloeckner.i GmbH
Ackerstr. 14-15
10115 Berlin
Deutschland
+49 30 56837077 
info-kci@kloeckner.com


2. Contact details of the Data Protection Officer
Datenschutzbeauftragter der kloeckner.i GmbH 
Am Silberpalais 1
D-47057 Duisburg
Telefon: +49 (0) 203-307-0
E-Mail: datenschutzbeauftragter@kloeckner.com

Our Data Protection Officer is available to answer all of your questions relating to the processing of your personal data and your rights under the EU General Data Protection Regulation (UK-GDPR), the German Federal Data Protection Act (BDSG) as well as any other data protection laws.

3. Information on relevant processing activities

3.1 Applications via the online application portal, by email or letter or via headhunters

3.1.1. Purpose of data processing:
We process your personal data for decision-making on the establishment of an employment relationship (processing of your application) and, as the case may be, for defense purposes in the event of a legal dispute.
We also process your personal data in order to comply with our legal obligations.


3.1.2. Legal bases of data processing:
Data processing for the processing of applications takes place on the basis of Article 6(1)(b) of the UK-GDPR. We process special categories of personal data on the basis of Article 9(2)(b) UK-GDPR.
In the case of data processing for which you have given your consent, data processing takes place on the basis of Article 6(1)(a) UK-GDPR. If we also process special categories of personal data on the basis of your consent, the data processing takes place on the basis of Article 9(2)(a) UK-GDPR.
Any data processing for the purpose of defense in the context of legal disputes takes place on the basis of Article 6(1)(f) UK-GDPR (balancing of interests). The legitimate interests here consist in being able to prove the lawful conduct of the application process in any proceedings. We process special categories of personal data on the basis of Article 9(2)(f) UK-GDPR.
You have the right to withdraw your consent at any time. We will then no longer process your personal data on the basis of your consent. However, withdrawing consent does not affect the lawfulness of any processing done on the basis of your consent before it was withdrawn. Such processing therefore remains lawful even after the withdrawal of consent. You can withdraw your consent by email to hr-solution@kloeckner.com.
Data processing for compliance with legal obligations takes place on the basis of Article 6(1)(c) UK-GDPR.


3.1.3. Recipients:
The following recipients/categories of recipients have access to your data: 
•    Internal departments;
•    In some cases, other Klöckner companies;
•    External service providers whom we use for the provision of services, such as IT infrastructure operators;
•    Headhunters;
•    Public-sector entities: public authorities and government institutions, such as prosecutors or courts to which we may be required to submit personal data in individual cases;
•    Private-sector entities: counsel such as external lawyers and other professional consulting providers or other private-sector entities to which or to whom we transfer your personal data on the basis of a legal requirement or your consent.
Supplementary information for applicants using the online application portal 
•    External service provider for provision of the application portal.


3.1.4. Intended third-country transfer:
In the context of your application, your personal data may be transferred to bodies whose registered office or place of data processing is not located in a member state of the European Union or other signatory state to the Agreement on the European Economic Area. For this purpose – other than in exceptional cases allowed by law – we ensure that there is an adequate level of data protection at the recipient (for instance, on the basis of an adequacy decision by the European Commission or suitable guarantees such as agreement with the recipient of EU standard data protection clauses as published by the European Commission) or that you have given your express consent. 
If you would like a copy of the specific arrangements agreed to ensure an adequate level of data protection, please request one using our contact details under heading 1.


3.1.5. Storage duration:
We will generally store your data for a period of 6 months from the time of completion of the application process. If you have consented to receiving additional job offers from us, the retention period is 24 months from the time of completion of the application process. In specific cases, we retain your Application Data beyond the aforementioned periods insofar as permitted or required by statutory provisions other than the aforementioned. 
If an employment relationship is established between you and us, we will not delete your Application Data in its entirety, but will incorporate it to the extent necessary in your personnel file. We will then process that data for performance of the employment relationship. You will then be provided with more detailed information on this separately.


3.1.6. Obligation to provide data and consequences of not providing data:
You are not required to provide us with personal data either by contract or by law. However, the provision of certain items of personal data is required for processing your application and for deciding whether to enter into a contract of employment.
Supplementary information for applicants using the online application portal
The items of personal data required for processing your application and deciding whether to enter into a contract of employment are marked as such in the online application portal. You may decline to provide any Application Data not designated as “required” without incurring any disadvantages in connection with the application process.


3.1.7. Categories of personal data:
We process the following categories of personal data concerning you:
•    Title, first and last name;
•    Email address;
•    Language preference;
•    Personal application documents (CV, cover letter and any other documents you provide);
•    Information on how you heard about Klöckner;
•    Any preferences regarding division of the company and place of work, if applicable;
•    Salary expectations, if applicable.
(jointly referred to as “Application Data”).


3.1.8. Sources of personal data:
In cases where we obtain your personal data from third parties, it originates from the following sources:
•    Headhunters from whom we receive your application data for the purpose of an application;
•    Your publicly viewable profile in professional social media networks (such as StepStone, Monster, LinkedIn and Xing).


3.2 Provision of our online application portal


3.2.1. Purpose of data processing:
We process your personal data for the purpose of providing our online application portal, including, but not limited to, technically enabling you to access it using your web browser.


3.2.2. Legal bases of data processing:
The data processing takes place on the basis of Article 6(1)(f) UK-GDPR (balancing of interests).
It takes place if, on the balance of interests, we come to the conclusion that your interests or fundamental rights or freedoms do not override our interests (and/or those of third parties). Our legitimate interest in this connection is as follows:
•    Provision of our online application portal.


3.2.3. Recipients:
The following recipients/categories of recipients have access to your data: 
•    Hosting providers;
•    Internal departments;
•    External service providers whom we use for the provision of services such as technical support, IT infrastructure operation or provision of the online application portal;
•    Public-sector entities: public authorities and government institutions, such as prosecutors or courts to which we may be required to submit personal data in individual cases;
•    Private-sector entities: counsel such as external lawyers and other professional consulting providers or other private-sector entities to which or to whom we transfer your personal data on the basis of a legal requirement or your consent.


3.2.4. Intended third-country transfer:
In the context of your application, your personal data may be transferred to bodies whose registered office or place of data processing is not located in a member state of the European Union or other signatory state to the Agreement on the European Economic Area. For this purpose – other than in exceptional cases allowed by law – we ensure that there is an adequate level of data protection at the recipient (for instance, on the basis of an adequacy decision by the European Commission or suitable guarantees such as agreement with the recipient of EU standard data protection clauses as published by the European Commission) or that you have given your express consent. 
If you would like a copy of the specific arrangements agreed to ensure an adequate level of data protection, please request one using our contact details under heading 1.


3.2.5. Storage duration:
Once your Usage Data has been obtained, it will be stored for the duration of your visit to our site.


3.2.6. Obligation to provide data and consequences of not providing data:
There is no legal or contractual obligation to provide your Usage Data. However, we require your Usage Data to enable you to access our online application portal and utilize the features and services made available there.

3.2.7. Categories of personal data:
We process the following categories of personal data concerning you:
•    Your IP address;
•    The date and time of access;
•    The time zone difference to Greenwich Mean Time (GMT);
•    Which pages on the site you view;
•    Your access status/HTTP status code;
•    The volume of data transferred;
•    The website from which you access our site;
•    Which browser you are using (including language and version);
•    Your operating system and interface;
(jointly referred to as “Usage Data”).

4. Automated decision-making (Article 22 UK-GDPR)
No use is made of automated decision-making, including profiling.


5. Rights as data subject
Subject to meeting the legal requirements, you have the following rights:
•    To obtain confirmation of whether we process personal data concerning you; if so, you have the right of access to the data and information on the processing (Article 15 UK-GDPR).
•    To obtain rectification of inaccurate personal data concerning you and to have incomplete personal data concerning you completed (Article 16 UK-GDPR).
•    To obtain erasure of personal data concerning you, including if the processing was carried out unlawfully or is no longer necessary (Article 17 UK-GDPR).
•    To obtain restriction of processing of personal data concerning you, including in lieu of erasure of the data (Article 18 UK-GDPR).
•    To receive personal data concerning you, which you have provided, in a structured, commonly used and machine-readable format, and to transmit that data to another controller where the processing is carried out by automated means and is based on your consent or a contract with you (data portability, Article 20 UK-GDPR).
•    At any time, and with effect for the future, to withdraw any consent you have given us to process your personal data (withdrawal of consent, Article 7 UK-GDPR). This does not affect the lawfulness of the processing of your data prior to withdrawing consent.

Right to object on grounds relating to your particular situation:
You have the right to object at any time, on grounds relating to your particular situation, to processing of personal data concerning you which is based on Article 6(1)(e) UK-GDPR (performance of a task carried out in the public interest or in the exercise of official authority) or Article 6(1)(f) UK-GDPR (balancing of interests); this also applies to any profiling based on these provisions.
If you exercise your right to object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for processing that override your interests, rights and freedoms, or the processing is for the purpose of establishing, exercising or defending legal claims.

In order to assert your rights as a data subject, you may contact us at any time using the contact details for the Data Protection Officer provided above under heading 1.

If you consider that the processing of your personal data violates data protection law, you may also lodge a complaint with a supervisory authority, in particular in the EU member state or, in Germany, Bundesland of your habitual residence, place of work or place of the alleged infringement.

As of November 2022


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.