Candidate Privacy Notice

1. Scope and Overview

This candidate privacy notice describes how ABeam Consulting Ltd. ("ABeam", "we," or "us") collects, uses, discloses and process personal data about you (hereinafter referred to as ‘candidate’) during the application and recruitment process. This Privacy Notice applies to job EU/EEA and UK originated candidates ("Privacy Notice").

This Privacy Notice describes, who we are, how to contact us, the categories of personal data that we collect, how we use your personal data, when we may disclose your personal data to third parties, and when we may transfer your personal data outside of your home jurisdiction. This Privacy Notice also describes your rights regarding the personal data that we hold about you including how you can access, correct, and request erasure of your personal data.

Separate data protection information applies to employees employed in ABeam’s own business operations and related applicants, as well as to visitors to our websites and events.

2. What categories of personal data we collect

For the purposes of this Privacy Notice, personal data means any information about an identifiable individual collected in connection with the recruitment process. ABeam may collect personal data directly from you, as a job candidate, or may receive personal data from third parties, for example recruiters. We may collect, store, and process the following
categories of personal data, which we require in connection with our recruiting activities:

Personal contact details: Name, title, addresses, telephone numbers, and personal email addresses.
Personal details: Age.
Work experience: Information contained in a resume, CV, cover letter, or candidate profile for job matching and employer presentation.
Educational background: Including degrees awarded, transcripts, certifications, and other educational information provided to support job recruitment activities.
Job Preferences: Details regarding the type of employment sought, desired salary, willingness to relocate, job preferences, and other information related to compensation and benefits for effective job matching.
Reference information: Information received from reference checks and verification processes, where applicable, including information provided by third parties to support placement activities.
Work permit documentation: Copies of right to work documentation and documents relating to immigration status for compliance verification and employer requirements.

We collect most of this information from you directly. For example, data is collected through our application portal and CVs, from correspondence with you, or through interviews, meetings, or other assessments. Apart from that, we also collect some information about you from other sources such as referees or organisations (e.g. from LinkedIn if you choose to connect us with your LinkedIn profile).

3. Why we collect, use and store this personal data

Below you will find an overview of what kind of personal data we process about you for the purposes of matching you with suitable job opportunities and providing recruitment services, on which legal basis we do so, and where we collect this data.

a) Legal Basis

Consent: In certain limited cases, we ask for your consent to use your data. Whenever we ask with your consent we will explain the situations where we use your data and for what purposes.
Contractual necessity: We process your data as it is necessary for performance of a recruiting contract with you or to carry out steps at your request prior to entering into a recruiting contract.
Compliance with legal obligations: As an organisation we have obligations to comply with legal, regulatory and other requirements under applicable local laws. In certain cases, we will have to use your data to meet these obligations.
Legitimate interests: We can process your data when this is necessary for us to achieve a business purpose related to our recruitment services, or where this is necessary for our clients or other parties to achieve their recruitment purposes. We explain below what interests we, our clients, or others, are trying to achieve when we process your data in the context of job placement and recruitment activities. Where we process personal data on the basis of a legitimate interest, then – as required by data protection law – we have carried out a balancing test to document our interests, to consider what the impact of the processing will be on job candidates and to determine whether candidates’ interests outweigh our interests in the processing taking place. You can obtain more information about this balancing test by using the contact details at the end of the Privacy Notice.

b) Purposes

We have set out below why we process your data in connection with our recruitment services and candidate placement activities and explain what data we use in each case. We may also provide you with more specific notices for some of the recruitment and job matching processes described below, and on the rare occasions we need to ask for your consent we will only do this at the time we collect your personal data.

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Purpose	Data categories	Legal basis	Collection of your Data	Recipients of your Data
A. Professional recruitment for candidate applications and job placement services We process personal data from the adjacent data categories to assess your suitability for the vacant position and, if necessary, to offer you other employment positions tailored to your personal profile and qualifications.	In this context, we process the following categories of personal data described above in section 2: Personal contact details Personal details Work experience Educational background Job preferences Work permit documentation	The data processing is based on the following legal basis: Art. 6 (1) (b) GDPR processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract with you. Art. 6 (1) (f) GDPR legitimate interest in assessing your suitability for the contemplated role	We collect the data directly from you.	In order to provide our professional recruitment and job placement services, we share personal information about you with potential employers who offer job openings that match your profile and preferences. This sharing is essential for our core business function of connecting qualified candidates with suitable employment opportunities. In the context of the data processing described here, it is also possible that both internal and external service providers have access to your data. These include processors as well as our controllers from the following areas: Background check provider(s) Our contractors and service providers are contractually obligated by us to maintain confidentiality and to comply with data protection standards and regulations when handling candidate data.
B. Processing of profilelink from publicly accessible career platforms If you are a member of a professional networking site (e.g. LinkedIn), we will also store the link to your profile page published on the network. This enables us to better compare the data you have provided directly, allowing us to tailor our placement services even more specifically to your needs.	In this context, we process the following data: Link to profile	The data processing is based on the following legal basis: Art. 6 (1) (f) GDPR legitimate interest in continuously improving the quality and effectiveness of our recruitment services. Linking to publicly available career profiles allows us to obtain a more complete overview of candidates' qualifications and thus create more accurate job matches. This leads to a higher success rate in placement. Processing is limited to storing links to profiles that are already publicly accessible. No comprehensive data collection or copying takes place. The data subjects have deliberately made this information publicly accessible, which shapes their expectations regarding its use by third parties.	We collect the data from third parties, namely: LinkedIn	In the context of the data processing described here, it is possible that both internal and external service providers from the following areas have access to your data:
C. Answering your inquiries about our services We process the data we need to communicate with you in order to answer your specific questions about our professional recruitment and job placement services.	In this context, we process the following categories of personal data described above in section 2: Depending on the question: Personal contact details Personal details Work experience Educational background Job preferences Work permit documentation	The data processing is based on the following legal basis: Art. 6 (1) (b) GDPR processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract with you.	We collect the data directly from you.	In the context of the data processing described here, it is possible that both internal and external service providers from the following areas have access to your data:
D. Informing unsuccessful applicant about other job opportunities To proactively inform you about new job opportunities that may match your professional profile, qualifications and career goals, and to consider you for these positions.	In this context, we process the following categories of personal data described above in section 2: Personal contact details	The data processing is based on the following legal bases: Art. 6 (1) (a) GDPR for potential candidates of ABeam only on the basis of consent.	We collect the data directly from you.	In the context of the data processing described here, it is possible that both internal and external service providers from the following areas have access to your data:

4. Is there an obligation to provide personal data?

As part of the recruitment process, you only need to provide the personal data that is required for the recruitment activity or that we are legally obliged to collect. If you have to provide us with personal data due to a legal or contractual obligation, we will inform you of this when
collecting the data and refer you to the respective obligation. If you do not provide us with the relevant data, we may not be able to fulfil certain obligations. If you do not provide us with personal data that is necessary for the recruitment process, it may not be possible to carry out the recruitment.

5. How we share your personal data?

To deliver our recruitment services to you, your personal data will primarily be processed by staff in our consultancy, IT, and administrative department. This will include sharing your personal data with Human Resources in the UK and Japan.

Your personal data will be shared with our group companies, companies providing services, such as technology services including hosting, maintenance, administration and analysis, as well as other agencies, under contract to ABeam as part of the recruitment process.
Furthermore, your personal data will be shared with the hiring companies that have engaged our recruitment services to identify suitable candidates. When we share your data with these companies, we have explained this according to each purpose under section 3.

6. AUTOMATED DECISIONS AND PROFILING

No solely automated decision-making, including profiling, is used when processing your personal data.

7. Will data be transferred to a third country?

As a rule, we process your personal data in the country or region where we residing. However, in the context of providing our services, your data may be transferred to countries outside the EU/EEA/UK.

If we transfer your personal data outside the EU/EEA/UK, we ensure that appropriate safeguards are in place to protect your personal data. These transfers may occur to countries that are subject to adequacy decisions rendered by the European Commission or to countries subject to regulations from the UK government permitting data transfers to that country without further safeguards. For transfers to countries without such a decision/regulation, we rely on Standard Contractual Clauses (SCCs) approved by the European Commission or for transfers outside of the UK: on the international data transfer agreement (the “IDTA”) or the international data transfer addendum to the European Commission’s standard contractual clauses for international data transfers (the “UK Addendum”):

You can find more information here:

European Commission Adequacy Decisions:https://commission.europa.eu/law/lawtopic/data-protection/international-dimension-data-protection/adequacydecisions_en
Standard Contractual Clauses (SCCs):https://commission.europa.eu/publications/publications-standard-contractual-clauses-sccs_en
IDTA:https://ico.org.uk/media2/migrated/4019538/international-data-transfer-agreement.pdf
UK Addendum:https://ico.org.uk/media2/migrated/4019539/international-data-transfer-addendum.pdf

8. How long will your data be stored?

Insofar as necessary, we process and store your personal data for the duration of the recruitment process and after the end of the recruitment process without successful placement, in most cases your data will be deleted after a maximum of 6 months. In case you gave us your consent to retain your data and contact you about future job opportunities, we will retain this data for 12 months after the end of the end of the recruitment process.

In addition, in Germany, we are subject to various retention and documentation obligations,which result, i.a. from the German Commercial Code (Handelsgesetzbuch, HGB) and the German Fiscal Code (Abgabenordnung, AO). The retention and documentation periods
specified there are up to ten years.

Under certain circumstances, your data must also be retained for longer, e.g. if a so-called legal hold or litigation hold (i.e. a ban on data deletion for the duration of the proceedings) is ordered in connection with official or legal proceedings.

9. Your choices and rights

You have certain rights regarding your personal data. These rights are described in more detail below.

If you have given us your consent, you can withdraw it at any time (Art. 7 (3) GDPR). The withdrawal of your consent does not affect the lawfulness of the processing carried out on the basis of the consent prior to the withdrawal.

You also have the right to object to the processing of your personal data by us:

in certain circumstances, if we process your data based on the necessity of a task carried out in the public interest or the exercise of official authority vested in the controller or processing is necessary for the purposes of the legitimate interests pursued by us or a third party (Art. 21 (1) GDPR).

Generally, you also have the right to request us to:

access and obtain a copy of your personal data that we store (Art. 15 GDPR),
provide some of your personal data to you or another data controller in a commonly used, machine-readable format (Art. 20 GDPR),
update or correct your personal data if it is inaccurate (Art. 16 GDPR),
delete your personal data (including your account) from our systems under certain circumstances (Art. 17 GDPR),
restrict the processingof your personal data under certain circumstances (Art. 18 GDPR).

We will consider all the above requests and provide our response within a reasonable period (and in any event within any time required by applicable law). These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if
you ask us to delete information which we are required by law or have compelling legitimate interests to keep. If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before
responding to any request you make.

In the UK, if you have unresolved concerns, you have the right to complain to ABeam using the details set out in ‘Contact us’ below.

If you have unresolved concerns, you can contact our HR in the UK for consultation, and you have the right to complain (Art. 77 GDPR) to a data protection supervisory authority.

Where we collect personal data to administer our contract with you or to comply with our legal obligations, this is mandatory and we will not be able to manage the employment relationship without this information. In all other cases, provision of the requested personal data is optional, but this may affect your ability to participate in certain programs or systems, where the information is needed for those purposes. For example, you may not be able to participate in a team activity if you choose not to provide relevant information.

Right to lodge a complaint

You also have the right to lodge a complaint with a data protection authority (Art. 77 GDPR) in the EEA if you believe we have not complied with applicable data protection laws. The relevant local authority differs depending on your country of residence. For the EEA you may
refer to the website of the European Data Protection Board to find out more about how to contact your local data protection authority. For Germany you may refer to the website of the Federal Data Protection Commissioner to find out more about how to contact your local data
protection authority. If you live in the UK, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO). Their website Information Commissioner's Office has details on how to Make a complaint | ICO.

10. Contact us

Candidate Privacy Notice に関するお問い合わせは、お問い合わせフォームよりご連絡ください。

Last updated: October 2025