Privacy policy for ABG Sundal Collier's employer branding and recruitment
Date of publication: 13-06-2025
ABG Sundal Collier ASA ("ABGSC") manages ABGSC’s employer branding and recruitment process through ABGSC’s career site (the “Career Site”), and by using a related applicant tracking system.
In this privacy policy, ABGSC explains how ABGSC processes your personal data if:
- You visit ABGSC’s Career Site (you being a “Visitor”)
- You connect with ABGSC via ABGSC’s Career Site, to create a profile with ABGSC and receive information about current or future vacancies with ABGSC (you being a “Connecting Candidate”)
- You apply for a position with ABGSC, via ABGSC’s Career Site or a third party service (you being an ”Applying Candidate”)
- ABGSC collects information about you from other parties, sites and services, since ABGSC believes your profile is of interest for ABGSC’s current or future vacancies (you being a “Sourced Candidate”)
- ABGSC receives information about you from ABGSC’s employees or partners, since they believe your profile is of interest for ABGSC’s current or future vacancies (you being a “Referred Candidate”)
- ABGSC receives information about you from a Candidate, who lists you as their reference (you being a “Reference”).
This privacy policy also describes what rights you have when ABGSC processes your personal data, and how you can exercise these rights.
When ABGSC use the term “Candidate” in this privacy policy, ABGSC is referring to each of Connecting Candidates; Applying Candidates; Sourced Candidates; and Referred Candidates, unless it is stated otherwise. These are defined as follows:
- Connecting Candidates: Individuals who have shown interest in ABGSC by connecting through the recruitment platform without applying for a specific position.
- Applying Candidates: Individuals who have submitted an application for a specific job opening at ABGSC through the recruitment platform or other channels.
- Sourced Candidates: Individuals whose profiles have been identified and collected by ABGSC through publicly available sources or professional networks (e.g., LinkedIn) as potential matches for current or future job openings.
- Referred Candidates: Individuals who have been recommended to ABGSC by current employees, partners, or other contacts, and whose information has been submitted for consideration in the recruitment process.
1. About processing of personal data
Personal data is all information that can be directly or indirectly linked to a living, physical person. Examples of personal data are name, e-mail address, telephone number, and IP address. Processing of personal data refers to automated use of personal data - such as collecting, creating, analyzing, sharing, and deleting personal data.
There are laws and regulations on how companies may process personal data, so-called data protection laws. Different data protection laws apply to different types of use of personal data, and in different parts of the world. An example of a data protection law that is relevant for ABGSC’s use of your personal data, as described in this privacy policy, is the EU Data Protection Regulation (2016/679, “GDPR”).
Most obligations under the GDPR apply to the so-called data controller. A data controller is the entity that decides for which purposes personal data will be processed, and how the processing will be executed. The data controller can use a so-called data processor. A data processor is an entity that is only allowed to process personal data as instructed by the data controller and may not use the personal data for its own purposes.
ABGSC is the data controller when ABGSC processes your personal data as described in this privacy policy.
2. What personal data does ABGSC process?
All individuals
- Device information - If you visit ABGSC’s Career Site, ABGSC will collect information about your device, such as IP address, browser type and version, session behaviour, traffic source, screen resolution, preferred language, geographic location, operating system and device settings/usage.
- Technical and statistical data - If you visit ABGSC’s Career Site, ABGSC will collect technical and statistical data about your use of the site, such as information about which URLs you visit, and your activity on the site.
- Communications data - ABGSC will collect and store your communication with ABGSC, including the information you provided in the communication. This may include the content of emails, video recordings, messages on social media, the information you add to your account with ABGSC, surveys, etc.
- Contact details - Such as your name, email address, telephone number and physical address.
Candidates
- Data from interviews, assessments and other information from the recruitment process, such as notes from interviews with you, assessments and tests made, salary requirements.
- Information in your application, such as your CV, cover letter, work samples, references, letters of recommendation and education.
- Information in your public profile, meaning the information ABGSC collect about you from public sources related to your professional experience, such as LinkedIn or the website of your current employer.
- Information provided by references, meaning the information ABGSC receive from ABGSC’s employees or partners who refer you to ABGSC, or by the persons you have listed as your references.
3. Where does ABGSC receive your personal data from?
All individuals
- From the Career Site. If you visit ABGSC’s Career Site, ABGSC collects technical and statistical information about how you use the Career Site, and information from your device.
- Directly from you. Most of the information ABGSC processes about you, ABGSC receives directly from you, for example when you apply for a position with ABGSC or connect with ABGSC. You can always choose not to provide ABGSC with certain information. However, some personal data is necessary in order for ABGSC to process your application or provide you with the information you request to get from ABGSC.
References
- From the person for whom you are a reference. If a Candidate lists you as their reference, ABGSC will collect your contact details from the Candidate to be able to contact you.
Candidates
- From public sources. ABGSC may collect personal data about you from public sources, such as LinkedIn or the website of your current employer.
- From ABGSC’s references. ABGSC may receive information about you from ABGSC’s employees or partners (such as recruitment service providers), when they believe your profile is of interest for ABGSC’s current or future vacancies.
- From your references. If you provide ABGSC with references, ABGSC may collect information about you from them.
- Data ABGSC creates itself or in cooperation with you. Information about your application and profile is usually created by ABGSC, or by ABGSC in cooperation with you, during the recruitment process. This may for example, include notes from interviews with you, assessments and tests made.
4. For what purposes does ABGSC process your personal data?
Protect and enforce ABGSC’s rights, interests and the interests of others, for example in connection with legal claims.
Affected individuals: The individual(s) affected by the legal issue - this may include persons from all categories of individuals listed above.
Categories of personal data used: All the categories of personal data listed above can be used for this purpose.
Share your personal data with other recipients, for the purposes mentioned in Section 5 below.
Affected individuals: Varies depending on the purpose of the sharing, see Section 5 below.
Categories of personal data used: All the categories of personal data listed above may be used for this purpose.
Collect information about your use of the Career Site, using cookies and other tracking technologies, as described in ABGSC’s Cookie Policy.
Affected individuals: Visitors.
Categories of personal data used: Device information.
Maintain, develop, test, and otherwise ensure the security of the Career Site.
Affected individuals: Visitors.
Categories of personal data used: Device information; Technical and statistical data.
Analyse how the Career Site and its content is being used and is performing, to get statistics and to improve operational performance.
Affected individuals: Visitors.
Categories of personal data used: Device information; Technical and statistical data.
Provide you with updates about vacancies with ABGSC.
Affected individuals: Connecting Candidates.
Categories of personal data used: Contact details; Communications data.
Review profiles and applications sent to ABGSC. This also includes communicating with you about your application and profile.
Affected individuals: Connecting Candidates; Applying Candidates.
Categories of personal data used: All the categories of personal data listed above may be used for this purpose.
Support within the recruitment process in the assessment of applications by using AI to identify relevant qualifications and experience, to suggest potential matches between candidates and roles and help reduce bias by ensuring a more objective and consistent evaluation.
Affected individuals: Applying Candidates.
Categories of personal data used: All the categories of personal data listed above may be used for this purpose.
Collect and evaluate your professional profile on ABGSC’s own initiative. This also includes communicating with you regarding your profile.
Affected individuals: Sourced Candidates; Referred Candidates.
Categories of personal data used: All the categories of personal data listed above may be used for this purpose.
Contact you directly about specific, future vacancies with ABGSC.
Affected individuals: Candidates.
Categories of personal data used: All the categories of personal data listed above may be used for this purpose.
Record the interview(s) with you.
Affected individuals: Candidates.
Categories of personal data used: Communications data.
Contact you to ask for your participation in surveys
Affected individuals: Candidates.
Categories of personal data used: All the categories of personal data listed above may be used for this purpose.
Contact you ask for information about a Candidate and evaluate the information you provide.
Affected individuals: References.
Categories of personal data used: Contact details; Communications data.
5. With whom does ABGSC share your personal data?
ABGSC’s service providers. ABGSC shares your personal data with ABGSC’s suppliers who provide services and functionality in ABGSC’s employer branding- and recruitment process. For example, this includes recruitment service providers and the supplier of ABGSC’s Career Site and related applicant tracking system.
ABGSC’s group companies. ABGSC shares your personal data with ABGSC’s group companies, when they provide ABGSC services and functionality to ABGSC’s employer branding- and recruitment processes, such as access to particular systems and software.
Companies providing cookies on the Career Site. If you consent to it, cookies are set by other companies than ABGSC, who will use the data collected by these cookies in accordance with their own privacy policy. You can find information about which cookies this applies to in ABGSC’s Cookie Policy.
With authorities and other public actors - when ABGSC is ordered to do so. ABGSC will share your personal data with authorities and other public actors when ABGSC has a legal obligation to do so.
With parties involved in legal proceedings. If needed to protect or defend ABGSC’s rights, ABGSC shares your personal data with public authorities or with other parties involved in a potential or existing legal proceeding. This can, for example, be in cases of discrimination claims.
Mergers and acquisitions etc. In connection with a potential merger, sale of company assets, financing, or acquisition of all or part of ABGSC’s business with another company, ABGSC may share your personal data to other parties involved in the process.
6. On what legal basis does ABGSC process your personal data?
To be able to process your personal data, ABGSC needs to have a so-called legal basis. A legal basis is a reason for processing personal data that is justified under the GDPR.
When ABGSC processes your personal data for the purposes described in this privacy policy, the legal basis ABGSC relies on is normally that the processing is necessary for ABGSC’s legitimate interest in being able to recruit talent with the relevant competence for ABGSC. ABGSC has concluded that ABGSC has a legitimate interest in being able to perform the personal data processing for this purpose; that the processing is necessary to achieve that purpose; and that ABGSC’s interest outweighs your right not to have your data processed for this purpose.
You can contact ABGSC for more information about how this assessment was made. See Section 9 and 10 below for ABGSC’s contact information.
There may be specific circumstances when the processing is only performed if and when you provide your consent to the processing. This is for example the case if ABGSC proposes to record an interview with you. Please see Section 9 below for more information about your right to withdraw your consent.
7. When does ABGSC transfer your personal data outside of the EU/EEA, and how does ABGSC protect it?
ABGSC always strives to process your personal data within the EU/EEA area.
However, some of ABGSC’s service providers process your personal data outside of the EU/EEA. ABGSC also uses suppliers whose parent company, or whose subcontractor’s parent company, is based outside the EU/EEA. In these cases, ABGSC has considered the risk that the personal data may be disclosed to countries outside the EU/EEA, for example because of an authority request.
In cases where another recipient of your personal data (as described in Section 5 above) is based outside the EU/EEA, this will also mean that your personal data is transferred outside the EU/EEA.
When, ABGSC , or one of ABGSC’s suppliers, transfers your personal data outside the EU/EEA, ABGSC will ensure that a safeguard recognized by the GDPR is used to enable the transfer. ABGSC uses the following safeguards:
When your personal data is transferred outside the EU/EEA, ABGSC also implements appropriate technical and organizational safeguards, to protect the personal data in case of a disclosure. Exactly which protective measures ABGSC implements depends on what is technically feasible, and sufficiently effective, for the particular transfer.
If you want more information about the cases in which your personal data is transferred outside the EU/EEA you can contact ABGSC using the contact details in Section 9 and 10 below.
8. For how long does ABGSC keep your personal data?
All individuals
If ABGSC processes your personal data for the purpose of being able to protect and enforce ABGSC’s rights, ABGSC will keep your personal data until the relevant legal issue has been fully and finally resolved.
Visitors
ABGSC keeps your personal data for one (1) year for security purposes. The retention periods for cookies are set out in ABGSC’s Cookie Policy. ABGSC keeps your personal data to analyse the performance of the Career Site for as long as ABGSC keeps personal data about you for other purposes.
Candidates
If you are a Connecting Candidate (only), ABGSC keeps your personal data for as long as you remain connected with ABGSC.
For other types of Candidates, ABGSC keeps your personal data to decide if you are a suitable candidate for the relevant vacancy(ies) with ABGSC.
If you do not succeed in the initial recruitment process, ABGSC keeps your personal data for as long as needed to consider, and potentially contact you, for relevant future job openings. The maximum time a Candidate's personal data may be saved, with the Candidate,s consent, is a total of 4 years.
If you are hired, ABGSC will keep your personal data during your employment, for other purposes than those stated above, which you will be informed of.
References
ABGSC keeps your personal data for as long as ABGSC keeps the personal data of the Candidate for whom you acted as a reference.
9. What rights do you have, and how can you exercise them?
In this section, you will find information about the rights you have when ABGSC processes your personal data. As described below, some of the rights only come into play when ABGSC processes your personal data on a particular legal basis.
If you want to exercise any of the rights listed here, ABGSC suggests that you:
- Visit the Data & Privacy page on ABGSC’s Career Site, where ABGSC offers features to let you exercise your rights;
- Log in to your account with ABGSC, where you can use the settings in the account to exercise your rights; or
- Contact ABGSC directly at thea.klausen@abgsc.no.
Right to be informed
You have the right to be informed about how ABGSC processes your personal data. You also have the right to be informed if ABGSC plans to process your personal data for any purpose other than that for which it was originally collected.
ABGSC provides you with such information through this privacy policy, through updates on ABGSC’s Career Site (see also Section 11 below), and by answering any questions you may have.
Right to access your personal data
You have the right to know if ABGSC processes personal data about you, and to receive a copy of the data processed. In connection with receiving the copy of your data, you will also receive information about how ABGSC processes your personal data.
Right to access and request a transfer of your personal data to another recipient (“data portability”)
When the legal basis for ABGSC’s data processing is performance of a contract with you or your consent, and such processing is carried out by automated means, you can request a copy of the personal data relating to you in a structured, commonly used, machine-readable format. This will allow you to use this data somewhere else, for example to transfer it to another recipient. If technically feasible, you also have the right to request that ABGSC transfers your data directly to another recipient.
Right to have your personal data deleted (“right to be forgotten”)
In some cases, you have the right to have ABGSC delete personal data about you. This is for example the case if it is no longer necessary for ABGSC to process the data for the purpose for which ABGSC collected it; if you withdraw your consent; if you have objected to the processing and there are no legitimate, overriding justifications for the processing. (For the separate right to object, see below.)
Right to object against ABGSC’s processing of your personal data
You have the right to object to processing of your personal data, which is based on ABGSC’s legitimate interest, by referencing your personal circumstances.
Right to restrict processing
If you believe that the personal data ABGSC processes about you is inaccurate, that ABGSC’s processing is unlawful, or that ABGSC does not need the information for a specific purpose, you have the right to request that ABGSC restricts the processing of such personal data. If you object to ABGSC’s processing, as described just above, you can also request ABGSC to restrict processing of that personal data while ABGSC make its assessment of your request.
When ABGSC’s processing of your personal data is restricted, ABGSC will (with the exception of storage) only process the data with your consent or for the establishment, exercise or defense of legal claims, to protect the rights of another natural or legal person, or for reasons relating to an important public interest.
Right to rectification
You have the right to request that ABGSC rectifies inaccurate information and completes information about you that you consider incomplete.
Right to withdraw your consent
When ABGSC processes your personal data based on your consent, you have the right to withdraw your given consent at any time. If you do so, ABGSC will stop processing your data for the purposes you have withdrawn your consent to. However, it does not affect the lawfulness of processing that was based on your consent before it was withdrawn.
Right to raise a complaint
If you have complaints about ABGSC’s processing of your personal data, you can raise a complaint with the data protection authority in Norway. You can find their contact details here.
You can also lodge a complaint with your national data protection authority, which you can find listed here if you are based in the EU. If you are based in the UK, you can lodge a complaint with the Information Commissioner’s Office, here.
10. How to get in contact with ABGSC
If you want to get in contact with ABGSC to exercise your rights, or if you have any questions, comments or concerns about how ABGSC handles your personal data, you can reach ABGSC by sending an email to thea.klausen@abgsc.no.
11. Updates to this privacy policy
ABGSC updates this privacy policy when necessary - for example, because ABGSC starts processing your personal data in a new way, because ABGSC wants to make the information even clearer to you, or if it is necessary to do so to comply with applicable data protection laws.
ABGSC encourages you to regularly check this page for any changes. At the top of this page, you will find the date this privacy policy was last updated.
