Version October 2022
ProQR Therapeutics N.V. processes personal data for recruitment purposes. With this privacy statement, we want to assure you that your personal data is collected in a transparent manner and in accordance with applicable data protections laws.
To that end, this privacy notice provides you with all the details about your personal data, including which personal data we process, for what purposes and for how long we keep them. It also explains your rights in respect to your personal data. If you are offered a job, we will provide you with a draft employment agreement together with our employee manual, which contains our privacy statement for employees. The privacy statement for employees explains how we will (further) process your personal data when you become an employee.
What we collect
(a) Contact information: your name, address, email address and telephone number;
(b) Information regarding your qualifications: details of your qualifications, skills, experience and employment history;
(c) Data concerning health: special categories of personal data concerning your health, for example in relation to a disability or pregnancy, will only be processed by ProQR if you disclose this information to us, so that we are able to make proper arrangements to support you during an interview. We will not ask for this information during or after the job application procedure. In no way will any disclosed information be used at your disadvantage, except in cases where a disability makes it technically impossible to perform the job you apply for (in which case you are legally required to disclose this information).
Ways we Collect your personal data
- We mainly process information you directly provide to us. During the job application process, you send us your contact details, resume, *references (*optional) by mail or online submission form;
- We also process personal data provided by you during interviews;
- We may collect personal data relating to you through third parties, namely a) your current and former employers; b) any references you have optionally provided; c) third parties who recruit on our behalf, such as any recruitment agency which introduced you to us.
Purposes and legitimate basis for processing your personal data
- We require (a) Contact information to be able to respond to any questions related to job applicants and vacancies, and to establish appointments and to update you on the status of your job application when you apply for a job. Prior to your job application, we process Contact information based on our legitimate interest, to be able to respond to your questions and, after your job application, in preparation of a potential employment contract as well;
- ProQR requires to process (b) Information regarding your qualifications, in order to assess your potential fit for our vacancy. We process above-mentioned personal data for the preparation of a potential employment contract;
- We may require you to provide references based on our legitimate interest, to be able to better assess your application and reach a decision.
- In order to evaluate and improve our vacancies, inter alia identifying improvements of vacancy text and ways to target the correct audience, we process (a) Contact Information (only location) and (b) Information regarding your qualifications to generate aggregated overviews, which can no longer identify an individual person, in order to discover trends in demographics and skill sets of candidates. We process above-mentioned personal data to generate these overviews based on our legitimate interests, which is being able to improve our recruitment procedures, which has limited impact to your privacy as we will only analyze aggregated data;
- We may process (c) Data concerning health to support you, for example, in case of disability in order to make proper arrangements during the interview and during employment. We only process aforementioned personal data to be able to make the arrangements we are legally (and ethically) required to take to support you in the work environment, and we will not record this information for any other purposes.
Who receives your personal data?
- Within ProQR, your personal data is processed by the HR team as well as by the interviewers from different departments involved in the interview process;
- The provider of our job application software, which we use to enable online job applications and tracking the job application procedure;
- Your former employer(s) or others to verify your references (the only information that will be disclosed to these parties is that you have applied for a job at ProQR, no further information regarding your application will be shared with these parties);
- Governmental and law enforcement bodies might require us to provide your personal data; we will only do so if we are obligated by law to release above-mentioned personal data.
How long do we keep your data?
- Any personal data related to your application will be stored for a maximum of four weeks after the completion of the job application procedure, or up to a year with your permission, which permission you can retract at any time;
- Health data will only be retained for as long as required to make proper arrangements during the interview.
Data subject rights
You have various rights related to your personal data. You can use your rights as a data subject, we will never charge you any costs related to the data subject rights provided to you under the applicable data protection laws, except for exceptional situations (where excessive or manifestly unfounded requests are filed).
To make use of your data subject rights, you may contact our Data Protection Officer at firstname.lastname@example.org.
Please note that the Data Protection Officer might need to request additional documents from you, for example, identification documents, to verify that you are the data subject involved.
The following data subject rights are available, and will be provided to you in accordance with the General Data Protection Regulation (GDPR):
- Right to access: You may request information on the content of your personal data that is processed by ProQR, including a confirmation whether or not personal data is collected concerning you, and the following information regarding the personal data processed: the purposes for which they are processed, the categories of aforementioned personal data, the categories of recipients to which the personal data has been or will be disclosed, the envisioned storage period of aforementioned personal data; the source of the personal data (if the personal data was not collected directly from you), the existence of automated decision making and the basic logic behind such (if any such decision making exists). In many cases, we will refer you to this Privacy Statement for some of this information, as a large amount of this information is included here within;
- Right to rectification: in case of inaccurate or incomplete personal data, you may ask these data to be corrected, amended or supplemented.
- Right to restriction of processing: you may request the restriction of processing of your personal data in the following cases: 1) for a period to enable us to verify your personal data where you have contested the accuracy of your data, or 2) where your personal data is unlawfully processed and you have asked for restriction of processing instead of deletion, or 3) where the personal data are no longer necessary in relation to the purposes for which they were collected and processed, but they are required by you to establish, exercise or defend legal claims, or 4) for a period enabling us to verify whether our legitimate interests override your interests where you have objected to processing based on being necessary for pursuing a legitimate interest that is identified by us.
- Right to be forgotten: you have the right to ask for erasure of your personal data: 1) where personal data is no longer needed for the purposes it was processed, or 2) the personal data was processed based on consent and you have retracted your consent, and there are no other legal grounds that (also) apply to these personal data, or 3) where you have objected on the processing of your personal data, and there are no other legal grounds that override the right to object, or 4) the personal data were unlawfully processed, or 5) there is an obligation for the controller to comply to national laws and erase the personal data.
- Right to data portability: you have the right to receive your personal data in a structured, commonly used and machine-readable format and you can transfer it to another controller provided that the processing: 1) is based on consent or on a contract, or 2) it is carried out by automated means. Should you wish to transfer your personal data to another controller, you may request ProQR, when technically feasible, to transmit personal data to that controller.
- Right to object: if ProQR processed your personal data to 1) carry out a task out a task in the public interest, or 2) for the legitimate interests of ProQR or a third party, you may still object to the processing on grounds relating to your particular situation.
- Right to lodge a complaint: If, for any reason, you think we have not treated your personal data in accordance with the GDPR, or we unjustifiably did not satisfy one of your above rights, you have the right to lodge a complaint to the data supervisory authority which is located in the country of your residence.
Please click here to find information on all data supervisory authorities in Europe.
Automated decision-making including profiling
ProQR does not make use of fully automated decision-making technologies.
Your personal data as mentioned in this privacy statement is not transferred outside of the European Economic Area.