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Personal data recruitment process

Processing of personal data

Information to you as a data subject (as applicant for a position or as reference person in a recruitment process)

Pandox AB (publ), reg. no. 556030-7885, (“Pandox”) is the controller for the processing of personal data that you as an applicant or a recruiting firm (retained by Pandox) provide to Pandox in connection with your application for a position and that might be collected about you during the recruitment process (note that recruiting firm can be separate controller for the processing such firm conducts)Pandox may also process personal data of reference persons that an applicant provides in connection with an application and information that the reference persons provide regarding the applicant. Pandox may also collect personal data from publicly available sources.


Application - advertised positions 

1.1 Pandox processes your personal data within the scope of the recruitment process in order to, among other things, handle, administer and document the recruitment process. This takes place after a weighing of interests, where Pandox’s interest in processing your application overrides the applicant’s interest in protecting its privacy.  

Spontaneous application 

1.2 In connection with an open statement of interest/spontaneous application, Pandox will process your application for the purpose of seeing which positions fit your profile and whether your profile matches any needs that Pandox has. This takes place after a weighing of interests, where Pandox’s interest in processing your application overrides the applicant’s interest in protecting its privacy. 


1.3 Pandox may process the responses you provide and test results from proficiency and/or personality tests as a step in the recruitment process in order to have a better and more secure basis for decision making decisions before any hiring of new co-workers. Responses which are given in connection with tests, and test results, are used as a supplementary assessment basis in the recruitment process. The applicant’s participation in proficiency and/or personality tests is voluntary. Any such processing takes place after a weighing of interests, where Pandox’s interest in processing the responses you have provided in completed proficiency and/or personality tests, as well as test results, overrides the applicant’s interest in protecting its privacy. In exceptional cases, sensitive personal data may be processed and, in such case, Pandox will obtain written consent from the applicant before the test begins. Personal data from proficiency and personality tests may become the subject of profiling in order to enable Pandox to generate test results and/or personality profiles, if any.  

Reference persons 

1.4 In connection with a recruitment process, Pandox may process personal data relating to reference persons. Such processing takes place with the aim of obtaining information about the applicant’s previous work and other information that may be relevant to the recruitment process. The processing takes place after weighing of interests where Pandox’s interest in processing personal data of the reference persons overrides the reference persons’ interests in protecting their personal privacy. 


2.1 Pandox processes the following personal data about the applicant: name, address, telephone number, email address, completed education, skills and previous experience via your CV, photographs, certificates, transcripts and other information which you provide to us from a former or current employer, data which is provided by the persons who you offer as references, any salary demands, notes from interviews, any responses that you have given and test results from proficiency and/or personality tests that you took as part of the recruitment process. In addition, other personal data that you chose to provide in your CV, cover letter, or other documents will be processed.  

2.2 Pandox may process the following personal data regarding reference persons: name, contact details, employer and professional title. 

2.3 To the extent possible, Pandox will avoid processing sensitive personal data about you. In the event sensitive personal data will be processed, consent is obtained from the data subject before such processing begins.


3.1 Possible recipients of your personal data are Pandox’s processors of personal data, such as: (i) IT system suppliers; (ii) Pandox’s suppliers of proficiency and/or personality tests; and (iii) recruiting firms that assist Pandox in the recruitment process. 

3.2 When collecting input from reference persons, such persons will be informed that you have applied for a position with Pandox. 


4.1 Pandox or processors who are processing personal data on behalf of Pandox may transfer personal data to a third country outside of the EU/EEA. Where a transfer to a third country takes place, Pandox will ensure that appropriate safeguards have been taken. Such appropriate measures can for example be: 

i. to ensure that the parties (for example data exporter and data importer) enter into the EU Commission’s Standard Contract Clauses; or

ii. if transfer takes place within a group of companies, that the group has adopted so called Binding Corporate Rules approved by the relevant supervisory authority. 

4.2 Pandox ensures that all transfers to third parties and third countries take place in accordance with the applicable data protection legislation. 


5.1 Personal data which is collected during the recruitment process is erased (unless otherwise provided under domestic law) in the following cases: 

a. when it is clear that the applicant will not be offered employment; 

b. if an applicant declines an offer of employment; or 

c. when the recruitment process is concluded. 

5.2 However, Pandox may save application documents for up to two years after completion of recruitment in accordance with the Discrimination Act. Application documents that lead to employment are maintained throughout the employment relationship. 

5.3 In certain cases, Pandox may ask for permission to save your application, including results from completed tests, for future recruitment for similar positions. In the event of such enquiry, Pandox will obtain written consent from the applicant whose personal data Pandox wishes to save. 


Application documents are not subject to automated decision making. All applications are reviewed and assessed by an HR manager or another responsible person at Pandox.


7.1 As a data subject, you are, without cost, entitled to request information from Pandox about the processing of your personal data. Upon your request, or on our own initiative, Pandox will correct or delete incorrect personal data, and/or limit the processing of these. In addition, you have the right in certain cases to object to the processing and demand that personal data is provided to you on an IT medium (data portability). To exercise your rights, you can send a request to Pandox by mail or email (see contact details below). 

7.2 If the processing is based on consent, you have a right to withdraw your consent at any time whatsoever. Note that a withdrawal does not affect the lawfulness of the processing carried out on the basis of the consent before the consent was withdrawn. 

7.3 If you are dissatisfied with how we process your personal data, you can contact us or submit a complaint to the supervisory authority (Integritetsskyddsmyndigheten,

For further details about Pandox' processing of personal data, please see

If you as a data subject have questions about how Pandox process your personal information, please feel free to contact us at

Pandox AB (publ), org. nr. 556030-7885, Vasagatan 11, 101 20 Stockholm, Sweden,, is the controller of the personal data.