Data Retention Policy

1. Introduction

Proscia GmbH (“Proscia”, “we”, “us”, “our”) is committed to handling personal data in compliance with the General Data Protection Regulation (GDPR), the Bundesdatenschutzgesetz (BDSG), and other applicable data protection laws. One of the key principles under the GDPR is data retention — personal data should not be kept longer than necessary for the purposes for which it was collected.

This Data Retention Policy outlines how Proscia GmbH ensures that personal data is retained for no longer than required, defines retention periods for various categories of data, and establishes procedures for the secure deletion of data once the retention period has expired.

2. Scope

This policy applies to all personal data processed by Proscia GmbH in the course of its recruitment, employer services, and business operations, including data collected through:

• Job applicant applications
• Communication with candidates and employers
• Website interactions (cookies, forms, etc.)
• CRM and recruitment management systems (e.g., Zoho)
• Social media engagement
• Employee records (if applicable)

3. Retention Principles

Proscia GmbH adheres to the following key retention principles:

• Data minimization: Personal data is only retained for the minimum period necessary to fulfill the purpose for which it was collected.
• Purpose limitation: Data is only retained for the purposes for which it was originally collected, and once the purpose is achieved, data is securely deleted.
• Storage limitation: We ensure that personal data is stored only for as long as necessary and in accordance with legal, contractual, and business requirements.
• Security: We ensure that personal data is stored securely during the retention period and deleted or anonymized once it is no longer needed.

4. Retention Periods

The retention periods for personal data processed by Proscia GmbH vary depending on the nature of the data and its purpose. Below are the key categories of data and their corresponding retention periods:

4.1. Job Applicants’ Data

• Successful candidates: Personal data related to the hiring process will be retained for the duration of the candidate’s employment and for a maximum of 6 years after the end of the employment relationship (to comply with German tax and employment laws).
• Unsuccessful candidates: Personal data will be retained for a period of 6 months following the conclusion of the recruitment process. If the candidate has consented, data may be retained for up to 2 years for consideration for future job opportunities.
• Special category data (health information, disability data, criminal background checks): Retained only as long as required for the purposes of recruitment and employment suitability. Data is deleted immediately after the decision-making process.

4.2. Employer Data

• Employer contacts: Personal data such as name, job title, and business contact details are retained for the duration of the business relationship and for 5 years after the last interaction, to ensure that we can manage business inquiries, contracts, and follow-ups.
• Employer recruitment requirements: Retained for 1 year after the job vacancy is filled or the recruitment process ends.

4.3. Website Visitors’ Data

• Cookies and tracking data: We retain cookies and tracking data (such as Google Analytics data) in accordance with the Cookie Policy. These data are typically retained for a maximum of 26 months, depending on settings provided by the cookie provider.
• Contact form submissions: Data collected via contact forms will be retained for 12 months after submission, or longer if required for follow-up or legal obligations.

4.4. Social Media Engagement Data

• Interaction data (likes, shares, comments): Personal data derived from social media interactions is retained for 1 year from the last interaction unless the individual requests deletion.
• Messaging data: Personal data shared through direct messages or inquiries via social media platforms (e.g., LinkedIn, Facebook, Instagram, TikTok) will be retained for 6 months after the message has been addressed.

4.5. Employee Records

(If applicable for any employee data)

• Employee personal data, including contract details, performance reviews, salary information, and benefits, will be retained for 6 years after the end of employment, in compliance with German tax and labour laws.

5. Deletion of Data

Proscia GmbH takes appropriate measures to ensure that personal data is securely deleted when it is no longer required. Data that is no longer needed for the purpose it was collected will be securely deleted in a manner that ensures it cannot be recovered.

5.1. Secure Deletion Process

Personal data will be deleted either by:

• Physical destruction (for paper documents and records)
• Secure electronic deletion (for digital data, files, and records)

We ensure that all data deletion processes are documented and auditable, to guarantee compliance with the GDPR.

5.2. Deletion Request by Data Subject

If an individual requests deletion of their personal data (where they have the right to do so), we will act promptly to delete the data in accordance with GDPR regulations, provided that there are no legal grounds for retaining the data (e.g., for legal, tax, or contractual obligations).

6. Data Retention in Special Circumstances

In some cases, the retention periods outlined in this policy may be extended for specific reasons, such as:

• Legal obligations: We may need to retain personal data for longer periods if required by tax laws, employment laws, or other legal obligations (e.g., for 6 years in accordance with German tax law).
• Litigation or dispute resolution: Personal data may need to be retained for the duration of a legal dispute or claim, for example, to comply with the statute of limitations.
• Research or statistical purposes: In cases where data is anonymized or aggregated, it may be retained indefinitely for research or statistical purposes.

7. Data Access and Security

Proscia GmbH ensures that personal data is stored securely during the retention period. Access to data is limited to authorized personnel only, who are bound by strict confidentiality agreements. Security measures include:

• Access control and authentication systems to ensure only authorized personnel can access personal data.
• Data encryption for digital data stored on systems.
• Regular data audits to assess retention practices and ensure compliance with this policy.

8. Rights of Data Subjects

As a data subject, you have the following rights under the GDPR with respect to your personal data:

• Right of access (Art. 15)
• Right to rectification (Art. 16)
• Right to erasure (Art. 17)
• Right to restriction of processing (Art. 18)
• Right to data portability (Art. 20)
• Right to object (Art. 21)
• Right to withdraw consent at any time (Art. 7(3))

If you wish to exercise any of these rights, please contact us at:
info@Proscia.de

9. Changes to the Data Retention Policy

Proscia GmbH reserves the right to update this Data Retention Policy from time to time to reflect changes in legal or operational requirements. Any updates will be posted on this page and communicated as necessary to affected stakeholders.

10. Contact Information

If you have any questions regarding this Data Retention Policy or any other privacy-related inquiries, please contact:

Proscia GmbH
Paulsborner Str. 50a
14193 Berlin, Germany
Email: info@proscia.de
Phone: +49 (0)30 12345678