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Applicant Privacy Notice Template for Germany

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Key Requirements PROMPT example:

Applicant Privacy Notice

"I need an Applicant Privacy Notice for our Berlin-based tech company that covers AI-powered recruitment tools, international data transfers to our offices in the US and Asia, and includes provisions for our talent pool database that we're launching in March 2025."

Document background
The Applicant Privacy Notice is a fundamental data protection document required for any organization recruiting in Germany. It must be provided to job applicants at the time their personal data is collected, typically at the start of the application process. The notice ensures compliance with Article 13/14 of the GDPR and Section 26 of the German Federal Data Protection Act (BDSG), which contains specific provisions for employee data protection. The document should be written in clear, plain language and must cover all aspects of personal data processing during recruitment, including any automated decision-making, international transfers, and special categories of data. It serves both as a legal compliance tool and as a transparency measure to build trust with potential employees.
Suggested Sections

1. Introduction: Overview of the notice's purpose and scope, identifying the data controller

2. Types of Personal Data We Collect: Comprehensive list of personal data categories collected during the application process

3. How We Collect Your Personal Data: Sources of personal data, including direct collection, third-party sources, and public sources

4. Purposes of Processing: Detailed explanation of how and why personal data is processed during recruitment

5. Legal Bases for Processing: Explanation of GDPR Article 6 and BDSG Section 26 legal bases for processing application data

6. Recipients of Your Personal Data: Information about who has access to the data, including internal departments and external service providers

7. Data Retention: How long application data is kept and criteria for determining retention periods

8. International Data Transfers: Information about any transfers outside the EU/EEA and safeguards in place

9. Your Privacy Rights: Explanation of GDPR rights and how to exercise them, including local DPA contact details

10. Security Measures: Overview of technical and organizational measures to protect personal data

11. Updates to This Notice: Information about how changes to the notice will be communicated

12. Contact Information: Details of data controller and Data Protection Officer contact information

Optional Sections

1. Automated Decision-Making: Required if automated decision-making or profiling is used in the recruitment process

2. Background Checks: Include if the organization conducts background checks or obtains references

3. Video Interview Processing: Required if video interviews are part of the recruitment process

4. Assessment Tests: Include if personality, skills, or other assessment tests are used

5. Talent Pool: Include if candidates can opt into staying in a talent pool for future opportunities

6. Works Council Involvement: Required if works council is involved in recruitment decisions

7. Special Categories of Data: Include if processing special categories of personal data (e.g., health information, diversity monitoring)

Suggested Schedules

1. List of Data Processors: Detailed list of third-party service providers processing application data

2. International Transfer Mechanisms: Details of adequacy decisions, SCCs, or other transfer mechanisms used

3. Retention Schedule: Detailed retention periods for different categories of application data

Authors

Alex Denne

Head of Growth (Open Source Law) @ tiktok³ÉÈ˰æ | 3 x UCL-Certified in Contract Law & Drafting | 4+ Years Managing 1M+ Legal Documents | Serial Founder & Legal AI Author

Relevant legal definitions

























Clauses
























Relevant Industries

Technology

Manufacturing

Financial Services

Healthcare

Retail

Professional Services

Education

Non-profit

Public Sector

Telecommunications

Energy

Transportation

Construction

Media and Entertainment

Hospitality

Real Estate

Agriculture

Mining

Pharmaceuticals

Insurance

Relevant Teams

Human Resources

Legal

Compliance

Data Protection

Recruitment

Talent Acquisition

Privacy

Information Security

Works Council

Executive Leadership

Relevant Roles

HR Director

Data Protection Officer

Privacy Counsel

Legal Counsel

HR Manager

Recruitment Manager

Compliance Officer

HR Business Partner

Chief Privacy Officer

General Counsel

Chief Legal Officer

HR Operations Manager

Talent Acquisition Manager

Chief Human Resources Officer

Privacy Manager

Industries







Teams

Employer, Employee, Start Date, Job Title, Department, Location, Probationary Period, Notice Period, Salary, Overtime, Vacation Pay, Statutory Holidays, Benefits, Bonus, Expenses, Working Hours, Rest Breaks,  Leaves of Absence, Confidentiality, Intellectual Property, Non-Solicitation, Non-Competition, Code of Conduct, Termination,  Severance Pay, Governing Law, Entire Agreemen

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