Privacy and data policy

Privacy Policy - Recruitment

Respect for the privacy of the individual is important to us at Billogram (“Billogram”, “we”, “us”, “our”) and we work proactively to protect the personal data that we process. All personal data is processed in accordance with applicable law. This policy contains information about how we as data controller process personal data when recruiting new employees to Billogram.

In this policy, we describe how and for what purposes we use your personal data, the lawful basis for the processing and what measures we take to protect personal data. We also describe how you can invoke your rights in regard to our processing of your personal data.


“Applicable Law” means the legislation applicable to the processing of personal data, including the General Data Protection Regulation (GDPR) (EU 2016/679), complementary national legislation and practices, guidelines and recommendations issued by national regulatory or EU supervisory bodies.

“Controller” is the company or organisation that decides for what purpose and in what way personal data is to be processed and which is responsible for the processing of personal data in accordance with applicable law.

“Data Subject” is an identified or identifiable natural person whose personal data is processed.

“Personal data” is any information that relates, directly or indirectly, to an identifiable natural person. 

“Processing” is an action or combination of actions relating to personal data, such as storage, alteration, reading, transmission, etc. 

“Processor” is the company or organisation that processes personal data on behalf of the controller in accordance with the controller’s instructions and applicable law.

The definitions of the concepts above shall apply regardless of whether capitalised or not. 

Information for you who are a jobseeker

General information about our personal data processing

We have an obligation to describe and provide evidence for how we meet the requirements imposed on us when we process your personal data. This section aims to describe general principles governing our personal data processing and to specify the types of personal data we process.

Lawfulness of processing

In order to process personal data, the controller must have a lawful basis in applicable law for the processing. The lawful basis for our processing with regards to recruitment is as follows:

Consent – You have given your explicit consent that we may process your personal data. You may withdraw your consent at any time and we will cease processing your personal data for the purpose to which you have given your consent.

Legitimate interests – We have undertaken a legitimate interest assessment and determined that our interests in processing your personal data outweigh your right not to be covered by the processing.

How long do we store your personal data?

We only save your personal data for as long as is necessary for the purpose for which it was collected. Depending on the lawful basis in question, our processing may be dependent on valid consent or follow from an internal legitimate interests assessment. In the section “How your personal data is processed” below, we specify the criteria for when the purpose ceases and thus the time when we no longer process your data.

When we share your personal data with others

We may share your personal data with others in order for us to perform any of the processing described in this policy, for example for the storage of data. We always enter into data processing agreements with the data processors we use, in which we, among other things, give the processor instructions on how the personal data may be processed and what security measures are required for the processing. The processor may not carry out any processing of your personal data that goes beyond these instructions.

If required by law, decree, regulation, government decision or other ruling binding on Billogram, we may disclose your personal data to various authorities, such as the Swedish Tax Agency or the Swedish Police Authority. 

Transfer of personal data outside the EU/EEA 

Where personal data is transferred to countries outside the EU/EEA, we implement safety measures to ensure that the level of security is adequate and in accordance with applicable law. The safety measures  include, inter alia, ensuring the following:

  • The European Commission has decided that the third country to which your personal data is transferred achieves an adequate level of protection, or 
  • The European Commission’s standard contractual clauses have been signed between Billogram or its processors, as applicable, and the recipient outside the EU/EEA. In these cases, we also assess whether there is legislation in the recipient country that affects the protection of your personal data. Where necessary, we take special measures to ensure that the protection of your data remains in place when transferring it to the relevant country outside the EU/EEA.

Types of personal data

The types of personal data that we process in regards to recruitment are:
Identification data: such as name, age, gender, nationality, date of birth, language, photographs and videos.
Contact details: such as address, email address and telephone number.
Job-qualification information: information from your CV, application and job interviews, references.
Personal information: information about marital status, children, interests and other personal preferences that you share through a CV, application and in job interviews.
Communication information: such as when you contact us with enquiries or otherwise enter into dialogue with us.
Recruitment notes: interview notes, notes from taking up your references, assessment of suitability for the position.
Test results: role fit assessment based on completed personality or logic tests.

How your personal data is processed

This section describes the personal data we process for the purpose of recruiting new employees, where the data has been collected, our lawful basis for processing this data and when the purpose of the processing ceases. 

Personal data we process and where it comes from (source): 

  • Identification data, contact details and job-qualification information (from you or social media, or via recommendation from a current employee at Billogram, or from an external recruitment company we use)
  • Personal information, communication information (from you)
  • Recruitment notes (Billogram)
  • Test results (external provider)

Lawful basis: 

Consent or legitimate interest. Our legitimate interest is based on that we need to process personal data in order to find suitable candidates when filling job vacancies.  

When the purpose ceases: 

  • In the case of consent: when you withdraw your consent. 
  • In the case of legitimate interest: when the specific position is filled.

Recipients we share your personal data with

Sometimes we need to share your personal data with others to fulfil the purposes described above. In the table below, we indicate the data processors we may share your personal data with. 

Data processor
Instruction (application area)
Personality and logic test
Recruitment and career tool 
Digital reference check service    

Information for you who are a reference to a jobseeker with us 

We use the digital reference check service Refapp in our recruitment process. We process your name, your telephone number, your email, your IP address and the personal information that concerns you in the assessment you provide as a reference to one of our candidates with the aim of being able to evaluate and recruit new employees in a quality-assured manner.

In case you prefer to talk to us by phone instead of using the Refapp service the information we process about you is limited to your name, your telephone number and the personal information that concerns you in the assessment you provide as a reference to one of our candidates. 

Lawful basis:

Legitimate interest. Our legitimate interest is based on that we need to process personal data in order to find suitable candidates when filling job vacancies and in some cases to be able to defend us from claims of discrimination.

When the purpose ceases:

The purpose ceases two years after the specific position was filled due to the fact that claims of discrimination is limited to a two year time period. If the employment ends earlier than two years after the position was filled, the purpose ceases when the employment ends.

Recipients we share your personal data with

Data processor

Instruction (application area)

Refapp (Talentwise AB) 

Digital reference check service

Your rights

According to applicable law, you as a data subject have several rights that you should be aware of.

  • You have the right to request a record extract of the information recorded about you. 
  • If the data we hold on you is incorrect, you have the right to have it corrected.
  • You have the right to have your personal data deleted provided that we do not have to process it for the purposes for which it was collected, for example to fulfill a contract we have with you or where we have a legal obligation to continue processing the data.
  • If you believe that the data is incorrect or that our processing is unlawful or that we do not need the data for a specific purpose, you may request that we restrict the processing of data about you. You can also request a restriction of processing while awaiting verification from us as to whether our interest in processing your data outweighs your right not to have this data processed.
  • The right to data portability means that in some cases, where the lawful basis is a contract or consent, you have the right to receive your personal data and use your personal data elsewhere.
  • If we indicate legitimate interest as a lawful basis, you have the right to object to the processing.

Contact details and Data Protection Officer

Billogram AB is registered with the Swedish Companies Registration Office under corporate registration number 556801-7155 and is headquartered at Klara Södra Kyrkogata 1, SE-111 52 Stockholm, Sweden.

If you have questions about how we process your personal data or would like to invoke any of your rights, you can always contact us at

You can also contact our Data Protection Officer by email: or by post to the above address.


If you believe that the processing of your personal data is in violation of applicable law, you should contact us. You can also contact the Swedish Authority for Privacy Protection directly with your complaint.

Privacy Policy updates

This Privacy Policy may be updated due to changes in legislation or changes in our personal data processing as a result of the development of our services.

The latest version will always be available at Billogram’s career site.

This version was updated on 2022-06-10