Should a GDPR information clause be placed on a poster advertising jobs at our company (with a phone number provided where candidates can find out which positions we are recruiting for)?
ANSWER
A GDPR information clause should not be placed on an advertising poster. The controller should provide the job candidate with the content of the GDPR information clause, i.e. the information obligation under Article 13(1) and (2) GDPR, at the time of collecting their personal data for a specified processing purpose. In the situation described in the question, the content of the GDPR clause should be available to job candidates during the first telephone conversation (as in this case the data subject may wish to familiarise themselves with such a clause). The person answering the phone should therefore be prepared to provide the content of such a clause if the data subject wishes to hear it, as already during the first telephone conversation a job candidate may provide some of their personal data. Next, that clause should be provided when obtaining a CV from the job candidate. If CVs are sent by email, it should be sent to the candidate after the CV is submitted, or should be available at the premises if the CV is delivered in person by the job candidate.
