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Job Applicant Privacy Notice

Last updated: 2025-11-04

As part of any recruitment process, Interogo  Long-Term Equity Advisors AB, Jakobsbergsgatan 24, 111 44 Stockholm, Sweden organisation number 559091‑9295 (“ILTE”, “we”, “our” or “us”) collects, handles and processes personal data relating to job applicants. We are committed to being transparent about how we collect and use that data and to meeting our data protection obligations. This notice applies to all applicants who apply for employment in our Swedish office only.

ILTE acts as the data “Controller” for the processing of your personal data. Personal data will be processed in compliance with EU General Data Protection Regulation (Regulation (EU) 2016/679 (“GDPR”), the Swedish Data Protection Act (Dataskyddslagen 2018:218) and any other applicable laws or regulations which implement or supplement the foregoing) (collectively, the “applicable data protection laws”). “Personal data”, “processor”, and “controller” have the meanings given in the applicable data protection laws.

Any questions about the contents of this privacy notice or how personal data will be used, stored, or transferred, should be sent to [email protected].

2. What personal data do we collect?

ILTE may collect and process a range of personal data about you. This includes, but is not limited to:

  • your name, address and contact details, including email address and telephone number;
  • gender, nationality, citizenship, date of birth, details of dependents and family members (where applicable);
  • education and employment information (e.g. remuneration, bonus, pension entitlements, insurance and other benefits information, employment dates such as dates of hiring/promotion/position change, performance evaluation, position information such as position title and reference number, attendance information including illness or leaves of absence, language skills, degree grade/title, certificates, licences, memberships of committees or other bodies);
  • records of interviews (including attendance details at our office) or interview notes. For certain roles, we will obtain the results from assessments we have conducted with you or from assessment agencies that have conducted an assessment with you;
  • any feedback or opinions you voluntarily provide to us during the recruitment process;
  • personal identity number (Sw. Personummer);
  • evidence of your right to work in the place of your prospective employment; and
  • any other personal data which you choose to disclose to us during the course of the application process.

In principle, we do not collect or use any special categories of personal data of applicants, such as health data or other sensitive types of data, unless you provide this to us voluntarily as part of your application documentation or during an interview.

ILTE may collect this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment. ILTE may also collect personal data indirectly from recruiters, external assessors, academic institutions, certification providers and industry bodies, from other administration, or from publicly available sources (including via social media, to the extent that you choose to make your profile publicly available).

ILTE may carry out background checks as part of the application process and may use a third party for the purpose. Those checks may include criminal record checks, credit reference checks and similar background verification activities.

We may also, with your permission, collect personal data from any person who you have nominated as an employment referee.

For further details about the purposes for processing your personal data and the corresponding lawful basis, please see below:

Purpose: Lawful Basis:
For legal and regulatory purposes: (a) complying with applicable laws and statutory requirements such as income tax, national insurance deductions, and employment and immigration laws; and (b) responding to and complying with requests and legal demands from regulators or other authorities. Article 6(1)(c) GDPR – Legal obligation (Necessary for compliance with legal obligations under Swedish labour, immigration, tax, and social-security law.)
Where we have your consent: In principle, we do not rely on your consent to process your personal data. We will only do so in limited circumstances. If we do so, we will provide you with full details of the data that we would like and the reason we need it, so that you can carefully consider whether you wish to freely consent. Where we rely on consent as a lawful basis, you have the right to withdraw your consent for use of your personal data at any time using the contact details provided in the section below headed “Your Rights”. Article 6(1)(a) GDPR – Consent (Used only when you explicitly agree, e.g. for keeping your CV in a talent pool or for optional equal-opportunity data.)
*To pursue our legitimate interests of hiring qualified people, to find the right candidates for future vacancies and to secure, defend and develop our business. We only use this legal basis if your interests and fundamental rights do not override our legitimate interests. Article 6(1)(f) GDPR – Legitimate interests (Necessary for ILTE’s legitimate interests in recruiting and assessing candidates, provided the applicant’s rights and freedoms are not overridden.) *
To enter into contracts, such as confidentiality agreement, employment agreement, consultancy agreement or related. Article 6(1)(b) GDPR – Performance of a contract or steps prior to entering into one,

 

3. Why does ILTE process personal data?

We need to process personal data to manage your application through the entire application process and to take steps at your request prior to entering into a contract with you. We may also need to process your data to enter into a contract with you. In some cases, we need to process data to ensure that we are complying with our legal obligations.

ILTE has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows us to manage the recruitment process, assess and confirm a candidate's suitability for employment and decide to whom to offer a job. We may also need to process data from job applicants to respond to and defend against legal claims.

We also process data as necessary to comply with our legal obligations under Swedish labour, immigration, and tax laws

4. How does ILTE protect personal data?

We take the security of your data seriously. We have implemented adequate technical and organisational measures in accordance with Article 32 GPDR to protect personal data against unauthorised, accidental or unlawful destruction, loss, alteration, misuse, disclosure or access and against all other unlawful forms of processing. All personnel accessing your personal data must comply with the internal rules and processes in relation to the processing of personal data to protect them and ensure their confidentiality. They are also required to follow all technical and organisational security measures put in place to protect the personal data.

ILTE regularly reviews and updates its security controls to ensure an appropriate level of protection in light of the risks involved.

5. Who has access to personal data and with whom are they shared?

We may transfer personal data internally at ILTE on a need-to-know basis and to other companies of the group to which we belong (the “Interogo Holding Group”). Such other companies of Interogo Holding Group will either act as another controller under this notice or will only process personal data on behalf and upon request of ILTE.

We may also transfer personal data to third parties outside Interogo Holding Group to complete the purposes listed in the table above, to the extent they need it to carry out the instructions we have given to them. Such third parties may include: 

  • third parties who process personal data, such as our (IT) systems providers, our payroll provider, transport companies or travel agency, cloud service providers, database providers, consultants and third parties who carry out pre-employment checks and tests on prospective Co-workers. Where relevant, these third parties have entered into an agreement with ILTE (or another Interogo Holding Group member) to keep personal data secure and must implement appropriate technical and organisational measures to do so in accordance with Article 28 GDPR;
  • successors in title of our business in case of a corporate transaction;
  • any national and/or international regulatory, enforcement or exchange body or court where we are required to do so by applicable law or regulation or at their request; and
  • any central or local government department and other statutory or public bodies.

The Personal Data transferred within or outside Interogo Holding Group above, may also be processed in a country outside the United Kingdom, Switzerland and the European Economic Area (collectively, the “equivalent standard jurisdictions"). Countries other than the equivalent standard jurisdictions may not offer the same level of personal data protection as the equivalent standard jurisdictions.

If your personal data is transferred outside the equivalent standard jurisdictions, we will put suitable safeguards in place to ensure that such transfers is carried out in compliance with  Articles 46–49 GDPR, such as the European Commission’s Standard Contractual Clauses (SCCs). You may request additional information in this respect and obtain a copy of the relevant safeguard by exercising your rights as set out below.

6. For how long does ILTE keep data?

We will keep your personal data for long as necessarily to fulfil the purpose for which it was collected.

If your application for employment is unsuccessful, we will keep your personal data on file for three months (from the date that we communicate this) in case of any potential legal claim. 

We may ask your consent to contact you about future employment opportunities. If you agree, we will keep your personal data on file for up to 12 months for this purpose.

If your application for employment is successful, your personal data will be processed in accordance with our Privacy Notice available on our website.

7. Your rights

Individuals whose personal data is processed by ILTE have certain legal rights in respect of the information. These include:

  • Access the personal data we hold about you and receive a copy (Art. 15 GDPR);
  • Rectify inaccurate or incomplete personal data (Art. 16 GDPR);
  • Erase personal data (“right to be forgotten”) where certain grounds apply (Art. 17 GDPR);
  • Restrict processing in specified circumstances (Art. 18 GDPR);
  • Data portability – receive the data you have provided to us in a structured, commonly-used and machine-readable format, and transmit it to another controller where technically feasible (Art. 20 GDPR);
  • Object to processing carried out on the basis of our legitimate interests (Art. 21 GDPR); and
  • Withdraw your consent at any time, where processing relies on consent (Art. 7(3) GDPR). Withdrawal does not affect the lawfulness of processing before withdrawal.

If you wish to exercise any of these rights, please contact us at contact [email protected]  or write to Interogo  Long-Term Equity Advisors AB, Jakobsbergsgatan 24, 111 44 Stockholm, marking the envelope “Data Protection – Recruitment”.

We will respond to your request within one month of receipt (extendable by up to two months for complex or numerous requests). If we cannot fulfil your request, we will explain why.

If you believe that our processing of your personal data infringes data-protection law, you have the right to lodge a complaint with the Swedish Authority for Privacy Protection (Integritetsskyddsmyndigheten – IMY) at www.imy.se or with another supervisory authority in the EEA.

Exercising your rights is free of charge, unless requests are manifestly unfounded or excessive.

8. Updates

This notice may be updated from time to time to reflect changes in Interogo Long-Term Equity Advisors AB’s processing activities or to comply with legal or regulatory developments, including amendments to the EU General Data Protection Regulation (2016/679) or the Swedish Data Protection Act (2018:218).

Any material changes affecting how your personal data is processed will be communicated through our recruitment channels or on our website. The most recent version will always indicate the date of last update at the top of the notice.

ILTE will ensure that any such updates remain consistent with applicable data-protection law and do not diminish your rights under the GDPR.