Data Protection Information for Applicants

Dear applicant,

Information on data protection regarding our processing of applicant data in accordance with Art. 13, 14 and 21 of the Data Protection Basic Regulation (DSGVO).

Thank you for your interest. In accordance with the provisions of Art. 13, 14 and 21 of the Data Protection Basic Regulation (DSGVO), this information sheet informs you about the use of the personal data you provide as part of the application process and your rights in this regard. In order to

ensure that you are fully informed about the processing of your personal data and that data are informed within the framework of the application process, please note the following Information.

1. Responsible body within the meaning of data protection law

atrain GmbH Unterer Kaulberg 3

96049 Bamberg (Germany)

Tel.: (+49) 0951 / 30 20 680

Mail: info@atrain.de

hereinafter also referred to as “we” or “atrain”.

2. Contact details of our data protection officer

The data protection officer of those responsible is Mr. Andreas Hein and can be contacted by e-mail at datasecurity@atrain.de as well as at the contact details mentioned in § 1 with the suffix

“Data Protection Officer”.

3. Purposes and legal basis of the processing

We process your personal data in accordance with the provisions of the European Data Protection Basic Regulation (DSGVO) and the Federal Data Protection Act (BDSG) for the purpose of your application for an employment relationship, insofar as this is necessary for the decision on the establishment of an employment relationship with atrain GmbH. The legal basis for this is § 26 BDSG (new) and, if applicable, Art. 6 Para. 1 lit. b DSGVO for the initiation or execution of contractual relationships.

Furthermore, we may process personal data about you to the extent necessary to defend ourselves against legal claims asserted against us in the application process. The legal basis is Art. 6 Para. 1 lit. f DSGVO; the legitimate interest is, for example, a burden of proof in proceedings under the General Equal Treatment Act (Allgemeines Gleichbehandlungsgesetz – AGG).

If there is already an employment relationship between you and us, we may further process the personal data already received from you for the purposes of the employment relationship in accordance with § 26 Para. 1 BDSG, insofar as this is necessary for the performance or termination of the employment relationship or for the exercise or fulfilment of the rights and obligations of the representation of the interests of the employees resulting from a law or a collective agreement, a works agreement or a service agreement (collective agreement).

4. Categories of personal data

We process data related to your application. Personal data includes in particular your contact data (such as first name, surname, name extensions, private address, telephone number, e-mail address) as well as other data relating to your career (e.g. curriculum vitae, qualifications and degrees, work experience) and your person (e.g. cover letter, personal interests). This may also include special categories of personal data e.g. information about a severe disability, interview questionnaires, assessment center results and reports.

As a rule, your personal data is collected directly from you as part of the application process and encrypted during electronic transmission. The data comes from the online application form, from the uploaded files or from the documents sent to us by e-mail or written information’s captured during interviews and assessment center.

In addition, we may process personal data that we have permissibly obtained from publicly accessible sources (e.g. professional networks).

Pursuant to Art. 13 Para. 2 lit. e) DSGVO, we are obliged to inform you that you are not obliged to make your data available to us. Without your data, however, we will not be able to include you in the application process.

5. Passing on the data to third parties

We pass on your personal data within our company exclusively to those areas which need this data to fulfil their contractual and legal obligations or to implement our legitimate interest.

Application and Assessment Management Systems

Your personal data will be processed on our behalf on the basis of order processing contracts in accordance with Art. 28 DSGVO. In these cases, we ensure that the processing of personal data is carried out in accordance with the Basic Data Protection Ordinance. The categories of recipients in this case are hosting providers and providers of applicant management systems and software used within atrain.

Governmental or law enforcement agencies

To governmental or law enforcement agencies if, after our legal review, we determine that we are required by law to disclose your personal information to them.

6. Transfer to a third country

A transfer to a third country is not intended.

7. Duration of data storage

Your personal data, application documents and reports created within interviews, tests or assessment center will be stored for as long as this is necessary for the decision on your application. If you have consented to the inclusion of your application in our applicant pool, your application will be stored for a maximum of 12 months, after which we will automatically delete your data there as well. Even before these 12 months have expired, you can contact our data protection officer at any time using the contact details below (see point 2) and request that your data be deleted from the applicant pool. The data will then be deleted immediately.

If your application is followed by the conclusion of a contract, your data will continue to be stored and used for the purpose of the usual organizational and administrative process and the performance of the

employment relationship in compliance with the relevant legal regulations.

You have the following rights under applicable data protection laws

The right to access and receive a copy of your personal data

You have the right to request confirmation as to whether and how we process your personal data. In some cases, you may ask us to send you an electronic copy of your personal data.

The right to correct your personal data

If you can prove that your personal information has not been properly collected by us, you may request that this information be updated or otherwise corrected.

The right to be forgotten/to have the data deleted

In certain circumstances, you have the right to have your personal data deleted. You can request this at any time. We will check to see if your request can be met, as this right conflicts with other legal rights and obligations and we may be required to retain information. In cases where retention periods do not prevent deletion, we will comply with your request without delay.

To exercise your rights, you can contact us at the following address: datasecurity@atrain.de

In some cases, we might will obtain your consent to process your personal data to a point that exceeds the content described in this information sheet. You can revoke this consent at any time. Your revocation will cause us to stop processing your data for the future. You also have the right to file a complaint with your local data protection authority about the way we process your personal data.

Contact

Questions and comments regarding this policy are always welcome and should be addressed to the data protection officer: Andreas Hein, datasecurity@atrain.de.