Data Privacy for Recruiting

This data privacy statement (“Privacy Statement”) is effective from 7th of January 2022 and updates the previous data privacy statement dated 24th of May 2019 and explains how XCI A/S, Niels Jernes 6A, 9220 Aalborg Øst, Denmark, company registration no. 39135647 (“XCI”, “we” or “us”) collect and use the personal data and associated information received and collected from our internal and external job candidates and applicants. XCI is the legal entity responsible for the processing of your personal data. 

This privacy statement may be updated regularly, and changes will be reflected in this web page. Users and applicants are recommended to check regularly for any changes and updates in the purposes of the processing.

We recognize and respect the privacy of our applicants, current employees and former employees. This Privacy Statement concerns personal data submitted by you during your application process, personal data collected by XCI as part of the recruitment process, personal data collected by XCI as part of a previous employment process and personal data submitted in the candidate log. 

By applying and submitting your application, you accept this Privacy Statement. Furthermore, you consent to XCI using, storing and otherwise processing your personal data (including any sensitive personal data) in accordance with the description below.

Information XCI collect and how XCI will use the information

To apply for a position at XCI, you have to submit an application, which should preferably include your application stating reasons for applying along with your CV regardless of the application being an unsolicited application or submitted due to an advertised job opening. 

When applying for a position within XCI, you will be requested to submit personal data such as your name, e-mail address, mobile phone number, your primary language and an attachment of your resume/CV. You may also be requested to provide additional data and information, such as your address, relevant education and any other relevant information reasonably required to evaluate your application. You may be requested to respond to various assessment tests, including assessment tests on logical reasoning and personality profiling. You will be informed prior to any collection of your personal data, including in case of references being collected during the recruitment process if required according to applicable local law. Furthermore, we will obtain consent for collecting references if required according to applicable local law.

If you are applying for a position where a criminal history record, credit report or visa/work permit etc. is required by law, you may be required to provide these as well, in compliance with local law.

If your application is successful, the job offer may be conditional on pre-employment checks and external security clearance being carried out to XCI’s satisfaction.

XCI is collecting information that makes it possible for us to assess your candidacy for our available positions. XCI is an equal opportunity employer (in accordance with applicable federal, state and local law) and makes all employment-related decisions entirely on merit and qualifications. Consequently, you should only include information relevant for the review of your application, and disregard information such as your race or ethnic origin, your political or philosophical orientation, your religious beliefs, your union memberships or your sexual orientation. The assessment of your application will not be affected in any way should you choose not to provide the listed information.

Legal grounds for processing of your personal data 

XCI will process your personal data in accordance with the relevant data protection regulation. Our processing of personal will be subject to one or more of the following:

  • consent in accordance with Directive 95/46/EC General Data Protection Regulation (“GDPR”) cf. article 6 (1)(a). 
  • processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering a contract GDPR cf. GDPR article 6 (1)(b);
  • processing is necessary for compliance with a legal obligation to which the controller is subject cf. GDPR article 6 (1)(c)
  • processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party cf. GDPR article 6 (1)(f)
Purposes for processing your personal information

XCI processes personal data submitted by you or collected from other parties for the purpose of assessing your candidacy for our available positions, as well as for HR and personnel administration purposes and for compliance with any laws to which XCI is subject to.

We may further process your personal data for the following purposes:

  • Facilitating communication with you for the purpose of recruiting, providing information, references and recommendations
  • To accommodate your requests and inquiries for information

By accepting this Privacy Statement, you explicitly consent to and authorize XCI to gain access to any and all of the personal data included in your application. 

Part of the support in connection with the recruitment process is outsourced to external suppliers and they will also gain access to relevant personal data submitted by you or collected by XCI during the recruitment process. However, any such suppliers providing services on behalf of XCI have to meet high data security standards to protect your personal data (including any sensitive data).

The personal data submitted by you or collected by XCI during the recruitment process may also be shared with any third party, courts, government body, regulator, law enforcement office or any other applicable authority, if mandated due to legal or regulatory requirements.

Transfer of personal data outside the EU/EEA 

If the recruitment process concerns a position within the EU/EEA we will generally not transfer your personal data to countries outside the EU/EEA. 

In case of any transfer of your personal data to countries outside the EU/EEA it will be based on the European Commission’s standard contractual clauses and GDPR requirements. 

How long will we keep your information

We will keep the personal data submitted by you as part of your job application process and other collected and submitted personal information as part of such application process, including potential assessment tests results, interview conclusions, etc., for a period of 6 months unless local legal requirements would set out a longer or shorter mandatory retention period. The starting point for calculating the retention periods will be from the moment the latest of the following: (a) when you apply for a job, (b) the moment the rejection of your job application; (c) the moment when you withdrawn your application candidacy for the job, etc.

XCI retains your personal data to simplify the application process in the event you should choose to apply for another job at XCI during this period. You give your explicit consent to XCI to retain your personal data in accordance with this section.

If you are hired by XCI, your personal data submitted and all personal data collected through the recruitment process will be stored and processed throughout your employment along with your personal data collected throughout the employment process in accordance with the employment contract. The personal data will be deleted after the end of your employment in accordance with the internal policies in this respect and applicable local legislation.

What are your rights
  • Request access to the personal data we process about you: this right entitles you to know whether we hold personal data of you and, if so, obtain information on and a copy of those personal data.
  • Request rectification of your personal data: this right entitles you to have your personal data be corrected if it is inaccurate or incomplete.
  • Object to the processing of your personal data: this right entitles you to request that we no longer process your personal data.
  • Request the erasure of your personal data: this right entitles you to request the erasure of your personal data, including where such personal data would no longer be necessary to achieve the purposes.
  • Request the restriction of the processing of your personal data: this right entitles you to request that we only process your personal data in limited circumstances, including with your consent.
  • Request portability of your personal data: this right entitles you to receive a copy (in a structured, commonly used and machine-readable format) of personal data that you have provided to us, or request us to transmit such personal data to another data controller

Note that most of the personal data that we hold about you comes from information you completed, therefore, please ensure that you keep your information correct and up to date and in the event that your information is incomplete, please contact HR. Please note, however, that certain personal data may be exempt from the above-mentioned rights pursuant to applicable data privacy or other laws and regulations.

To the extent that the processing of your personal data is based on your consent, you have the right to withdraw such consent at any time by contacting Please note that this will not affect our right to process personal data obtained prior to the withdrawal of your consent, or its right to continue parts of the processing based on other legal bases than your consent.

If you wish to exercise your right to access your personal data, to object to it being processed or to rectify processed data, please contact or send a letter to XCI A/S, Niels Jernes Vej 6A, 9220 Aalborg Øst, Denmark, Att.: Legal.

As the privacy of our applicants and our employees is of utmost importance to XCI, this Privacy Statement will be updated on an ongoing basis to make sure that we comply with legal requirements.

You can read more about your right on the Danish Data Protection Agency’s website