10.1 Disclosure of application data within the corporate group

The companies within our corporate group work closely together when filling open positions. If, in our assessment, your qualifications are a better match for a position at another company within the group, or if several group companies are considered as potential employers for your application, your application documents may be forwarded within the corporate group to the respective responsible company.

The disclosure takes place exclusively for the purpose of conducting recruitment procedures and filling open positions within the corporate group. Only those personal data will be transferred that are necessary for assessing your suitability and for carrying out the recruitment process.

The legal basis for this processing is our legitimate interest, as well as the legitimate interest of the respective companies within the corporate group, in the efficient and needs-based filling of open positions and in the consideration of suitable applicants within the corporate group.

Applicants may object to the disclosure of their application documents within the corporate group at any time with effect for the future. An informal notice to the contact details specified above is sufficient for this purpose. In such a case, the application will be considered exclusively for the position and/or company to which it was originally submitted.

10.2 Active Sourcing

We carry out so-called active sourcing measures to identify promising potential employees on the external labor market and actively contact potential applicants and employees. The purpose of data processing is recruitment, e.g. by individually drawing the attention of promising candidates to job vacancies in our company.

We collect the following categories of data for active sourcing: Surname, first name, gender, contact details, education, professional experience, qualifications, salary data, application data, non-professional experience and interests and other information resulting from public profiles on social networks, in particular LinkedIn and Xing, and/or from other publicly accessible sources on the internet.

All personal data processed in the context of active sourcing is collected from generally/publicly accessible sources on the Internet, in particular from social networks such as LinkedIn and Xing.

The legal basis for the collection and processing of publicly accessible data in the context of active sourcing is the Controller’s legitimate interest in identifying, approaching and recruiting the best possible employees for the company.

10.3 Application Process

We collect and process personal data from applicants for the purpose of carrying out the application process.

When we conclude an employment contract with an applicant, the data provided will be processed for the purpose of implementing the employment relationship in accordance with the statutory provisions. If no employment contract is concluded, the application documents will be deleted immediately, at the latest 6 months after the end of the application process, provided that there is no overriding legitimate interest, such as the defense against claims or a function of preserving evidence in accordance with equal treatment and anti-discrimination laws.

The legal basis for this storage and processing is the implementation of pre-contractual measures (decision on the establishment of an employment relationship). If the data is required for legal defense or prosecution after the application process has been completed, data processing may be carried out to protect legitimate interests. In this case, our legitimate interests consist of defending against legal claims or asserting legal claims.

10.4 Internet Research as Part of the Application Process

As part of the application process, publicly available information about applicants may be viewed on the Internet. This includes, in particular, professional profiles on social networks (e.g., LinkedIn), publicly accessible profiles on other social media, and information from generally accessible sources (e.g., press articles, blogs, websites, search engine results).

Only publicly available information about the applicant will be processed. There is no systematic or automated decision-making or profiling.

The Internet search serves to supplement the application documents in order to better assess the professional suitability, career history, qualifications, and public professional presence of the applicants. This provides a sound basis for selecting suitable candidates.

The legal basis for this processing is the legitimate interest of the potential future employer in a comprehensive and well-founded assessment of the suitability of applicants for the advertised position.

10.5 Background Checks

As part of the application process, it may be necessary to carry out additional checks (“background checks”), particularly for security-related positions, management roles, activities involving financial responsibility, or access to confidential company information. These checks serve to verify the information provided in the application process and to assess the professional integrity, reliability, and suitability of the applicant for the respective position.

Depending on the type of position advertised and the requirements, information on education, professional career, qualifications, references, and, if applicable, creditworthiness information or information from public registers may be collected and processed in the course of such background checks. If the advertised position requires it or if legal requirements demand it (e.g., for activities in sensitive compliance, finance, or IT areas), the submission of an official certificate of good conduct may also be required in individual cases. In this case, processing is carried out exclusively on the basis of the documents voluntarily submitted by the applicant; we do not carry out any automated queries.

To carry out background checks, external service providers may be commissioned as processors to assist us in verifying qualifications or obtaining references, if necessary. In addition, in individual cases, previous employers, references, or educational institutions may be contacted, provided that the applicant has given their express prior consent.

The legal basis for the processing of personal data in the context of background checks is primarily the implementation of pre-contractual measures (decision on the establishment of an employment relationship), insofar as the check is necessary for the decision on the establishment of an employment relationship. The legal basis for these checks is their necessity for the employment relationship in conjunction with any applicable legal requirements. To the extent that checks go beyond this (e.g. reference checks with former employers), they are carried out exclusively on the basis of your express consent.

Before a background check is carried out, the applicant is always informed transparently about the nature, scope, and purpose of the planned check. If consent is required for certain checks, this is obtained separately in advance. Personal data will not be processed or passed on beyond the stated purpose.

10.6 Use of Automated (AI) Processes

As part of our application process, we use partially automated processes to preselect applications. The application documents submitted (e.g., resume, qualifications, professional experience) are analyzed using an AI-supported system according to specific, predefined criteria. The aim is to identify applications that are particularly well suited to the requirements of the advertised position.

The automated evaluation is used exclusively to support our HR managers. The final decision on the continuation of the application process is not made automatically, but always by a natural person.

The system used evaluates application documents based on predefined criteria (e.g., education, professional experience, language skills, qualifications). On this basis, a preliminary classification or weighting is carried out, which serves as a guide for the subsequent manual review.

This evaluation has no legal effect and does not have any comparable significant impairment.

Every applicant has the right to request a human review of the automated pre-selection, to present their point of view, and to challenge the decision.

10.7 Compliance/Sanctions Screening

Applicants who are shortlisted as part of the application process may be subject to an initial compliance check. The compliance check involves a comparison of the applicant’s name and address with relevant sanctions lists, in particular on the basis of the EU anti-terrorism regulations.

To carry out the compliance/sanctions list screening, we use an external service provider as a data processor on the basis of a data processing agreement.

The legal basis for this storage and processing is, if there is a legal obligation to carry out a compliance/sanctions list screening, the fulfillment of the legal obligation. In individual cases, depending on a balancing of interests, compliance/sanctions list screening can also take place if there is no mandatory legal obligation. In this case, the legal basis is our legitimate interest in avoiding potential sanctions by foreign authorities.

10.8 Talent Pool

If an applicant submits an unsolicited/speculative application without reference to a specific job posting, expressing general interest in potential future employment opportunities, or if an applicant has consented to the longer retention of their data in our talent pool in the context of an application process for a specific position, we will store the data submitted as part of the application in our talent pool for a period of 2 years after receipt of the unsolicited/speculative application or after the conclusion of the application process. This storage serves the purpose of identifying potentially suitable future positions for the applicant and contacting them if applicable. After this period, the data will be deleted.

Such consent to the storage of application data in our talent pool can be withdrawn at any time for the future. To do so, please send us an email to the contact details provided above.

The legal basis for the storage of application documents in our Talent Pool is, where applicable, the explicit consent of the applicant, which can be revoked at any time.

10.9 Statistical evaluations

We process anonymized or aggregated application data in order to analyze and improve our recruiting process (e.g., to evaluate application numbers, sources, or success rates). These evaluations are carried out using anonymized/aggregated data without personal references.