Privacy Notice for candidates at Klarna Group.
Klarna cares about your privacy. We always collect and process personal data responsibly and with your privacy in mind.
This Privacy Notice describes how we collect and use your personal data as an applicant, sourced or referred candidate, before, during and after the recruitment process. It also describes your rights and how to exercise them.
Purpose of the processing
The purpose of the processing is to find, hire and pre-board suitable candidates to the Klarna Group. The data may also be used by the Klarna Group for statistical and diversity analysis and business reporting purposes.
The personal data we process
The data we process is contact details, education, work experience, skills, CV, publicly available profiles (such as LinkedIn, Xing, etc.), as well as any additional information provided by the applicants. For referred candidates, we may also process other information given by the Klarna employee who has referred you.
Klarna conducts background checks as a final step in the recruitment process. This background check includes processing additional information that is deemed relevant to the role that you have been offered. Your contact person at Klarna will inform you about the specific contents of your background check.
Klarna conducts a demographic survey as part of the application. This survey is voluntary and your response is anonymized and stored separately from your application.
The information contained in your application will be available for Human Resources (HR) and the recruiting manager within the Klarna Group on a need-to-know basis.
The legal basis for the processing
When you submit an application for a role at Klarna, our legal basis for collecting, storing and processing your information is Article 6(1)(b) – steps necessary to enter into a contract. We will store your information for a maximum of 2 years.
If you sign an employment contract at the end of the recruitment process, Klarna will start the pre-boarding process between the date of signing the employment contract and your first day at Klarna (e.g. informing you about your office location, Klarna’s ways of working, etc.). Our legal basis for collecting, storing and processing your information for the pre-boarding process is also Article 6(1)(b) – necessary for the performance of a contract.
In the case where candidates who have been approached by Klarna with an invitation to apply for a role (“referred candidates” or “sourced candidates”), our legal basis for collecting, storing and processing your information is Article 6(1)(f) – legitimate business interest. We have conducted a legitimate interest assessment and balanced our legitimate interest (finding suitable candidates) against the candidates interests, and concluded that our interest outweighs the candidates’. We will only process information which you have made publicly available yourself.
For the voluntary demographic survey, the legal basis for processing is Article 6(1)(a) – consent.
The time we will keep your personal data
Personal data about applicants, “referred candidates” or “sourced candidates” who choose to enter our application process will be retained for a period of up to two years. The retention period is based on the time under which a candidate can initiate proceedings against Klarna, e.g. discrimination claims.
Personal data about “referred candidates” or “sourced candidates” who choose not to enter our application process, will be stored for a maximum of 30 days.
You have upon written request the right of access to the data relating to you. You also have the right to get data rectified, and under some circumstances the right to have your data deleted before the retention period expires (2 years). Further information may be obtained by contacting Klarna Bank AB’s Data Protection Officer at firstname.lastname@example.org.
You also have the right to file a complaint to the Data Protection Authority. Contact details can be found here.
Where your personal data is processed
To the extent necessary, the personal data may be transferred and/or disclosed to a company within the Klarna Group as well as to third parties acting on behalf of Klarna used for parts of the processing (data processors). The data may be transferred outside the EU/EEA. If this is done, Klarna will put in place adequate safeguards in order to protect the data in accordance with applicable data protection legislation, e.g. EU Standard Contractual Clauses or an adequacy decision of the European Commission.
Contact details to Klarna
The Klarna Group consists of Klarna Bank AB (reg.no. 556737-0431) and its affiliates (the Klarna Group). Klarna Bank AB is the data controller. If you would like further information this may be obtained by contacting Klarna Bank AB’s Data Protection Officer at email@example.com, or the person that reached out to you.
Privacy Notice for candidates and employees at Klarna Group that are California Residents.
This section of the notice applies only to residents of the state of California. It describes the categories of personal information Klarna collects and the purposes for which Klarna processes that information in accordance with section 1798.100 (b) of the California Consumer Privacy Act (CCPA). The CCPA requires us to disclose certain information about our data collection and sharing practices to California residents, and to align this information to certain categories of personal information as enumerated in the law:
- The specific pieces of personal information and the categories of personal information we have collected about consumers in the past 12 months.
- The business or commercial purpose for collecting that personal information.
- Whether we “sell” that category of information to third parties. To “sell” data means to sell, rent, release, disclose, disseminate, make available, transfer, or otherwise communicate orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration.
- Whether we disclose that category of information to “service providers,” which are external parties that we engage for business purposes and are restricted from using personal information for any purpose that is not related to our engagement.
Klarna does not engage in the practice of providing data to third parties in return for a financial benefit to us.
This Privacy Notice may be subject to update and change from time to time. Any changes will be published on our website. We recommend that you check this Privacy Notice regularly.
How Klarna Collects, Shares, and Retains Your Data
The following table summarizes the personal information we collect or create and how we share with external parties throughout your recruitment and employment relationship with Klarna. This table describes our practices generally; not all individual pieces of your personal information may be shared.
|Category of Personal Information||Examples of the types of data||How we have collected your data||Who we have shared your data with|
|Personal Identifiers||e.g. Name, alias, postal address, prior addresses, unique personal identifiers, online identifiers, IP address, email address, account name, social security number, passport number, or other similar identifiers.||- Directly from you, e.g., from forms you completed. - Indirectly from you, e.g., information you authorized a third-party or service provider to provide to us. - From service providers acting on Klarna’s behalf (e.g., background screening and verification including education, past employment, criminal background, references). - From references you have authorized us to contact. - From a public source (i.e., the internet or public records). - Information we have created or assigned to you throughout your candidacy and the course of employment (e.g. email address and phone number).||- External recruitment firms - Public entities and institutions (e.g., regulatory, quasi-regulatory, tax or other authorities, law enforcement agencies, courts, arbitrational bodies, fraud prevention agencies) - Professional advisors including law firms, accountants, auditors, insurers, and tax advisors.|
|Characteristics of protected classifications under California or federal law||e.g. Sex (including gender, gender identity, gender expression, pregnancy or childbirth, and related medical conditions), age, race, religion, national origin, disability, medical conditions and information, citizenship, immigration status and marital status; veteran or military status.|
|Professional or employment-related information:||Job applications, resumes, background check forms and results, interview notes, candidate evaluation records (including results from any required pre employment testing), work history, notes from reference checks and other similar pre-employment documents. After an offer of employment has been extended, these could also include work contact details (corporate email address and telephone numbers), staff number, photograph, job title, job description, reporting lines, primary work location and your terms and conditions of employment; Remuneration and benefits data, e.g. details of your pay and benefits package, bank account details, tax information, third party benefit recipient information; Leave data, for example your holiday, sickness and family related leave records, any personal data contained in your absence records, medical forms, reports or certificates and records relating to accommodations or adjustments of your workplace, or in relation to a company integration management; Health and workplace safety data, e.g. from audits, risk assessments and accident reports; Training and development data; Monitoring data, e.g. identifiable images contained in CCTV footage, system and building login, device and application usage and access records and other human resources data including performance evaluations and data necessary to provide employee benefits and related administrative services.|
|Education information, defined as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99):||e.g., student records, transcripts or degrees|
|Inferences drawn from any of the information identified in this notice to create a profile reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.|
|Audio, electronic, visual, thermal, olfactory, or similar information||e.g. identifiable images contained in CCTV footage, identification badge photographs, your temperature when entering a Klarna office|
|Internet or network activity information||e.g., interactions with our website, applications, or systems.||Please see our California Consumer Privacy Act Notice for California Residents, including website users, located at https://cdn.klarna.com/1.0/shared/content/legal/terms/0/en_us/privacy for more information.|
|Geolocation data:||e.g., IP address|
We Also May Share Any of the Personal Information We Collect as Follows:
Sharing for Legal Purposes: We may share personal information with third parties in order to comply with a legal process or a regulatory investigations; enforce our rights under our contracts with consumers and our business partners, including investigations of potential violations; and/or to protect the rights, property or personal safety of us, our technology, our business partners, our employees, agents and affiliates, our users and/or the public. We likewise may provide information to other companies and organizations (including law enforcement) for fraud protection, and spam/malware prevention, and similar purposes.
Sharing In the Event of a Corporate Transaction: We may also share personal information in the event of a corporate transaction, including for example a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of our assets, for purposes of due diligence connected with any such transaction or transition of service to another provider. In such cases, your personal information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
Sharing With Service Providers: We share any personal information we collect with our service providers, which may include (for instance) providers involved in technical or customer support, operations including payroll, benefits and/or pension, insurance, travel, background screening, search firms who submit candidate information to us, recruiting, web or data hosting, billing, accounting, auditing, legal consultancy, security, marketing, or otherwise assisting us to provide, develop, maintain, and improve our company and our services.
Sharing at your direction: There may be circumstances where we will share your information with third parties at your direction.
Sharing of Aggregate Information: We may aggregate and/or de-identify any information collected so that such information can no longer be linked to a single person (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors, in our discretion.
For Which Business Purposes Klarna Collects, Uses, Discloses, and Retains Your Data
We may collect, use, disclose and retain your personal information for one or more of the following business or commercial purposes (each, a “Business Purpose”):
- To evaluate applications for employment or internal promotion.
- To attract, maintain, motivate, and administer the employment relationship of Klarna employees, including, but not limited to the following: recruitment and staffing, creating and maintaining an employee contact directory, compensation and payroll, succession planning and management, reorganization, performance assessment, promotion and career management, administering bonus, award and recognition programs, administering employee enrollment and participation in activities and programs offered to eligible employees, training and development, employee benefits administration, pension plan administration, 401k and/or retirement plans, health insurance benefits, business travel and expenses, relocating and transferring employees, compliance with applicable legal and regulatory requirements, and communication with applicants and employees.
- To comply with regulatory and legal obligations such as (i) fulfilling control and reporting obligations under applicable financial regulations, including securities regulations; (ii) complying with investor protection or conduct of business regulation (such as carrying out suitability or appropriateness assessments; (iii) comply with state and federal law requiring employers to maintain certain records.
- Other internal purposes, for example authorizing, granting, administering, monitoring, and terminating access to or use of company systems, software, facilities, records, property, and infrastructure.
- To protect the company, its employees, and the public against injury, theft, legal liability, fraud or abuse, internal research, internal operations, auditing, detecting security incidents, debugging, short-term and transient use, quality control, and legal compliance.
- To provide you with information, products, or services that you request from us.
- As necessary or appropriate to protect the rights, property, or safety of us, our clients, or others.
Disclosure of Personal Information, No Sale
Over the preceding twelve (12) months, we disclosed certain categories of California residents’ personal information to the categories of third parties as shown in the table above. We do not sell California residents’ personal information.
Version 1.1, 17 February 2021