This policy applies to the North-East Family Office Group, which includes North-East Family Office Holding ApS (Danish business registration (CVR) no. 35 24 43 28), North-East Family Office Holding 2 ApS (Danish business registration (CVR) no. 37 25 68 70) and each of their respective subsidiaries, (”North-East”, ”we”, ”our” or ”us”).

At North-East, confidentiality and data protection are high priorities. This privacy policy (“Privacy Policy”) explains how we process (“Process/Processing/Processed”) your personal data (“Personal Data”) as a job applicant of North-East (an “Applicant”).

In this Privacy Policy, the defined term “North-East” shall both refer to North-East Family Office Group taken together as well as any member of the North-East Family Office Group individually, including, but not limited to, North-East Family Office ApS (“North-East ApS”) and North-East Family Office Asset Management (full legal name: North-East Family Office Fondsmæglerselskab A/S) (“North-East AM”).

As part of our recruitment process, we will Process your Personal Data as further described in this Privacy Policy.

Changes may occur to this Privacy Policy form time to time and will be made available here. 

1. Processing of non-sensitive Personal Data

In order to evaluate your application (including your formal, written job application and exhibits, your “Application”), we will:

1. Process the Personal Data, which you have disclosed in your Application; and
   
   
2. evaluate your performance and competencies during interviews; and
   
   
3. Process relevant and available Personal Data about you that we find on the Internet, including content from social media (we will typically search for information regarding your previous jobs, activities, competencies, performance, etc).
   
   

The legal basis for our Processing of your Personal Data is your submission of your Application, cf.  Article 6(1)(b) of the General Data Protection Regulation (“GDPR”).

If the job position requires you to complete one or more personality tests, you will be informed hereof when we have processed your Application. The results of such tests will be treated confidentially but will be included in our evaluation of your Application. Our legal basis for such Processing is Article 6(1)(b) of the GDPR.

We may also request that you provide us with a copy of your criminal record (in Danish: straffeattest) if this is necessary for evaluating your suitability for the position in question. Your criminal record (and the Personal Data included therein) will be treated confidentially and will be deleted immediately after presentation. You will be asked to obtain the criminal record yourself, and your submission of your criminal record will thus constitute our legal basis for the Processing of the Personal Data identified therein, cf. Section 8(3) of the Danish Data Protection Act (in Danish: persondataloven) (the “Data Protection Act”).

As part of our evaluation of you as an Applicant (including the evaluation of your Application), we may wish to speak to your previous and/or current employers. We will, however, only reach out to the persons you have explicitly stated as references in your Application. Our legal basis for the Processing of Personal Data about you as part of reaching out to such references is Article 6(1)(f) of the GDPR (and/ or if you have provided your explicit consent, such consent in accordance with Article 6(1)(a) of the GDPR).

2. Processing of sensitive Personal Data

We recommend that you do not disclose sensitive Personal Data, such as information revealing racial or ethnic origin, religion, trade union membership, sexual orientation, health, etc. in your Application. In the unlikely event that a certain health condition is required for the ability to perform the duties related to the position in question, we might – based on an individual assessment – request health information from you. In such case, we will ask for your consent for the Processing of such Personal Data, which will form the legal basis for such Processing, cf. Article 9(2)(a) of the GDPR.

3. Retention of Personal Data

If you are offered a position at North-East, your Application and other relevant Personal Data obtained during the recruitment procedure will be stored in your employee file.

If you are not offered a position, we will store your Application and any additional Personal Data obtained during the recruitment procedure for a period of six months following our rejection of your Application, unless you have provided your consent to storing such Personal Data for a longer period than six months.

4. Video surveillance

To the extent you are invited to one or more interviews at our offices in Denmark, please note that North-East has installed video surveillance in certain targeted areas at the offices at Vestagervej 17, 2900 Hellerup, and Svanemøllevej 16, 2100 Copenhagen Ø, including garden, parking and entrances areas. The purpose of the video surveillance is to ensure safety and prevent crimes in accordance with Article 6(1)(f) of the GDPR and Section 8(3) of the Data Protection Act.

With the exception of video surveillances at the entrance and the parking areas that are accessed live by a small number of selected employees within North-East, the video recordings may only be accessed and reviewed in the event of the suspicion of criminal behaviour, violation of North-East’s internal guidelines or through internal/external auditing. The recordings may be disclosed to the police for criminal investigations, if the recordings are disclosed for the purpose of safeguarding public or private interests which clearly override the interests of secrecy in accordance with Section 8(4) of the Data Protection Act or if the disclosure is otherwise required by law. Should it be necessary to disclose the recordings for other purposes than mentioned, the prior consent of the subjects of such recordings will be obtained before disclosing the recording.

The video recordings are stored on a server that only a limited number of employees within North-East have access to and can only be accessed with a password.

Video recordings which have been recorded for the purposes of preventing crime will be deleted or anonymized no later than 30 days after the recording has taken place, unless it is necessary for North-East to keep the recordings for the purpose of solving a breach of law. Recordings from video surveillance which has been conducted for other purposes will be deleted when it no longer serves a purpose to store the information.

Any consent that you may have provided during the Application procedure can be withdrawn by you at any time.

5. Transfers to third parties, transfers to third countries 

Your Personal Data may be shared with other entities within the North-East Group and other third parties.

To the extent your Personal Data is transferred to data controllers or data processors in countries outside the EU/EEA, including group entities, that do not ensure an adequate level of data protection, such transfer will be based on the EU Commission’s standard contractual clauses.

6. Your rights

Subject to certain statutory exceptions you have the right to access the Personal Data Processed about you. Furthermore, you have the right to object to the Processing and request restriction of the Processing of your Personal Data. In addition, you also have the right to request rectification, including completion, or request deletion of your Personal Data to the extent it is incomplete or incorrect, subject to certain exceptions.

In certain situations, you can also request that we provide you with a copy of your Personal Data in a structured, commonly used and machine-readable format and request us to transfer such Personal Data to another Data Controller.

If you want to exercise any of your rights, if you have any questions regarding this Privacy Policy or the Processing of your Personal Data, please contact us at legal(at)nefo.com.

7. Data controller, contact and complaints

If you apply for a job at North-East ApS, North-East ApS is data controller and responsible for the Processing of your Personal Data as part of the recruitment/Application procedure.

The contact information of North-East ApS is stated below:

North-East Family Office ApS
Danish business registration (CVR) no. 36 98 90 41
Vestagervej 17
2900 Hellerup
Denmark

If you apply for a job at North-East AM, North-East AM is data controller and responsible for the Processing of your Personal Data as part of our recruitment procedure.

The contact information of North-East AM is stated below:

North-East Family Office Fondsmæglerselskab A/S
Danish business registration (CVR) no. 36 44 93 81
Vestagervej 17
2900 Hellerup
Denmark

If you have any complaints regarding the Processing of your Personal Data, please contact us at legal(at)nefo.com. You are also entitled to file a complaint with the Danish Data Protection Agency (in Danish: Datatilsynet), Carl Jacobsens Vej 35, 2500 Valby, e-mail dt(at)datatilsynet.dk.