International Data Transfer Statemen

1. Introduction

Proscia GmbH (“Proscia”, “we”, “us”, “our”) is committed to ensuring that personal data is handled with the utmost care and in compliance with the General Data Protection Regulation (GDPR) and the Federal Data Protection Act (BDSG), particularly in relation to international data transfers.

As a company providing recruitment and placement services, we may need to transfer personal data to third parties, including partners and service providers, located outside the European Economic Area (EEA). This International Data Transfer Statement explains the mechanisms, legal safeguards, and the steps Proscia GmbH takes to ensure compliance with the GDPR when transferring personal data outside the EEA.

2. Scope of International Data Transfers

Proscia GmbH primarily operates within the European Union (EU) and processes personal data for recruitment purposes within this jurisdiction. However, in certain circumstances, personal data may need to be transferred to third parties located in countries outside the EU, including potential future transfers to Japan, Vietnam, or other non-EU countries.

These international data transfers may involve the following types of personal data:

• Job applicants’ data (e.g., CVs, qualifications, health data, criminal records)
• Employer data (e.g., company contact information, job requirements)
• Website visitor data (e.g., cookies, tracking information)
• Social media engagement data

3. Legal Mechanisms for International Data Transfers

Proscia GmbH ensures that any international data transfers are conducted in compliance with the requirements of the GDPR, specifically Articles 44–50, which regulate the transfer of personal data outside the EU. The legal bases and mechanisms for these transfers are as follows:

3.1. Standard Contractual Clauses (SCCs)

Proscia GmbH may use the Standard Contractual Clauses (SCCs) issued by the European Commission to facilitate data transfers to non-EU countries. These clauses provide legally binding safeguards for the protection of personal data.

• SCCs for Data Processing: Proscia GmbH will ensure that third-party service providers and data recipients in non-EU countries implement the SCCs to ensure the protection of personal data during transfers.

3.2. Adequacy Decisions

Where applicable, Proscia GmbH will rely on adequacy decisions issued by the European Commission, which confirm that certain non-EU countries offer an adequate level of data protection (e.g., Japan has been recognized by the European Commission as offering adequate protection under GDPR).

4. Countries with Adequate Protection

Currently, personal data may be transferred to countries that the European Commission has determined provide an adequate level of data protection. These countries include:

• Japan: Recognized by the European Commission as providing an adequate level of protection for personal data.

Any data transfer to Japan is conducted in compliance with the adequacy decision, and appropriate safeguards are implemented.

5. Countries Without Adequate Protection

If personal data is transferred to countries that do not have an adequacy decision (i.e., countries that the European Commission has not recognized as offering adequate protection for personal data), Proscia GmbH will take the following steps to ensure data protection:

• Use of Standard Contractual Clauses (SCCs)
• Additional safeguards (such as encryption, pseudonymization) where necessary to protect personal data during transfer.

Countries to which Proscia GmbH may transfer personal data in the future for recruitment or other purposes (e.g., Vietnam) are currently not covered by an adequacy decision. Proscia GmbH will use the necessary contractual safeguards to ensure that personal data remains protected in these cases.

6. Security Measures for International Data Transfers

Proscia GmbH ensures that any international data transfers are conducted securely by implementing the following technical and organizational measures:

• Data Encryption: All sensitive personal data is encrypted during transmission to prevent unauthorized access.
• Access Control: Personal data is accessible only by authorized personnel who are bound by confidentiality agreements.
• Monitoring and Audits: We conduct regular security audits and monitor the effectiveness of our security measures to ensure compliance with data protection standards.

Additionally, all data processors and third parties involved in international transfers are required to adhere to GDPR-compliant data protection practices and have contractual obligations to ensure the security and confidentiality of personal data.

7. Data Subjects’ Rights

Individuals whose data is transferred internationally have the same rights as they would if their data were processed within the EU. These rights include:

• Right to Access: You can request a copy of the personal data we hold about you.
• Right to Rectification: If your personal data is inaccurate or incomplete, you can request that it be corrected.
• Right to Erasure: You can request that your personal data be deleted, subject to applicable legal exceptions.
• Right to Restriction of Processing: You may request that we limit the processing of your data.
• Right to Object: You have the right to object to the processing of your personal data in certain circumstances.
• Right to Data Portability: You can request that your personal data be transferred to another controller, in a structured, commonly used, and machine-readable format.

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

8. Retention of Personal Data

Personal data transferred internationally is subject to the same retention periods as outlined in our Data Retention Policy. In general, personal data will be retained for no longer than necessary for the purposes for which it was collected.

Once the data is no longer needed for its original purpose, it will be securely deleted or anonymized, in accordance with the GDPR.

9. Changes to the International Data Transfer Statement

Proscia GmbH reserves the right to update this International Data Transfer Statement to reflect changes in data processing activities or international data transfer practices. Any updates will be posted on this page, and the updated version will be effective immediately upon publication.

10. Contact Information

If you have any questions or concerns regarding this International Data Transfer Statement or how we handle your personal data, please contact us at:

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