Last updated: October 2026
At Think About People, we take the protection of personal data seriously. As a recruitment and search firm, we process personal data about candidates, potential candidates, clients, business partners and other individuals we are in contact with.
This privacy policy describes how Think About People collects and processes personal data, why we do so, how long the data is retained, and what rights you have.
1. Who is the data controller?
Think About People is the data controller for the processing of personal data described in this privacy policy.
Think About People
Nordre Toldbod 23
1259 København K
CVR no. (Danish company registration number): 32892892
Email: hello@thinkaboutpeople.com
Telephone: +45 24 52 80 00
If you have any questions about our processing of your personal data or wish to exercise your rights, you are always welcome to contact us.
2. Whose data do we process?
We primarily process personal data about:
- candidates applying for a specific position
- individuals we identify and contact in connection with search and headhunting
- candidates who wish to be part of our candidate network
- references and other individuals involved in a recruitment process
- clients and potential clients
- contact persons at our clients and business partners
- individuals who contact us via our website, email, LinkedIn or other channels.
3. Candidates and potential candidates
Think About People works with executive search, search and recruitment. This means that we process data both about individuals who approach us themselves and about individuals we identify as potential candidates for a position.
4. What data do we collect?
Depending on the recruitment, we may process data such as:
- name and contact details
- current and previous positions
- employers and professional experience
- education and professional qualifications
- language skills and certifications
- information from your CV and LinkedIn profile
- salary level and expectations regarding future terms of employment
- geographical preferences and willingness to relocate
- career aspirations and motivation
- notes from conversations and interviews
- assessments of experience and competencies in relation to specific roles
- test results, where tests form part of a recruitment process
- reference information, where references are obtained
- any other information the candidate provides to us.
We strive to process only data that is relevant and necessary for the specific recruitment process.
5. Where do we obtain the data?
We receive data directly from you, for example when you send us your CV, apply for a position through our recruitment system, speak with one of our consultants, send us information via email or LinkedIn, or take part in an interview, test or reference process.
In connection with search, we may also collect relevant professional information from publicly available sources, such as LinkedIn, company websites, public company registers, professional networks, articles, press coverage and other publicly available sources.
We may also receive information from individuals in our professional network, clients or other sources who make us aware of relevant profiles.
6. Why do we process the data?
We process personal data in order to, among other things, identify relevant candidates for specific positions, contact potential candidates, assess candidates’ experience, qualifications and suitability for a role, conduct interviews and candidate assessments, present relevant candidates to our clients, communicate with candidates throughout a recruitment process, carry out tests and reference checks where relevant, manage our candidate database and candidate network, contact previous candidates about relevant future opportunities, document completed recruitment processes, and develop and improve our recruitment services.
7. Legal basis for processing
When we process ordinary personal data as part of a recruitment or search process, the processing is generally based on our and our clients’ legitimate interest in identifying, contacting and assessing relevant candidates, cf. Article 6(1)(f) of the General Data Protection Regulation (GDPR).
When you approach us yourself regarding a specific position or a possible employment relationship, the processing may also be necessary in order to take steps at your request prior to entering into a possible contract.
If we wish to retain your candidate profile after the conclusion of a specific process in order to contact you about other future positions, the processing may be based on your consent.
You may withdraw such consent at any time. Withdrawal of consent does not affect the lawfulness of the processing carried out before the consent was withdrawn.
In certain cases, we may also need to retain data in order to establish, exercise or defend legal claims.
8. Special categories of personal data
As a general rule, Think About People does not need special categories of personal data about candidates. We therefore encourage you not to send us information about racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, health, or sex life or sexual orientation, unless the information is relevant and necessary in connection with the specific process.
We also ask that you do not send us your CPR number (Danish civil registration number) unless we have specifically requested it and there is a lawful and necessary purpose for doing so.
If the processing of special categories of personal data is exceptionally necessary, we ensure that a separate lawful basis for processing is in place.
9. Presentation of candidates to clients
As a recruitment firm, a central part of our work is presenting relevant candidates to the companies that have asked us to assist with a recruitment.
We only share information that, in our assessment, is relevant to the specific recruitment process. As a general rule, we inform the candidate before an actual candidate presentation or a CV is shared with a client.
The client then becomes an independent data controller for the processing of personal data that the client carries out in connection with its own recruitment process.
10. References, tests and background checks
Certain recruitment processes may include personality or skills tests, reference checks, background checks or security checks. This takes place only where it is relevant to the specific position and in accordance with applicable law.
We inform the candidate before such activities are initiated. If an external provider is used, the provider will act either as our data processor or as an independent data controller, depending on the specific service.
11. How long do we retain data?
We do not retain personal data for longer than is necessary for the purpose for which the data was collected.
Data from a specific recruitment process may generally be retained for up to 24 months, among other things in order to document the recruitment process and handle any subsequent questions or legal claims.
If you have given your consent for us to retain your candidate profile for the purpose of other future opportunities, the data may be retained for up to 24 months from your most recent consent or your most recent relevant contact with us.
After this, the data is deleted or anonymised, unless you give new consent, we have another lawful basis for continued retention, or the law requires the data to be retained for longer.
You can ask us to delete your data or withdraw your consent to future contact at any time.
12. Clients and business contacts
If you are a client, potential client, supplier or other professional contact, we may process, among other things, your name, position and place of work, telephone number and email address, correspondence and meeting notes, information about our business relationship, as well as agreements, quotations and invoicing information.
The processing is carried out in order to establish and manage our professional relationship, deliver our services, follow up on collaborations and develop our business. The processing will normally be based on the performance of a contract or our legitimate interest in operating and developing Think About People’s business.
Data that is necessary for accounting or other statutory requirements is retained for the period required by law.
13. Communication and marketing
We may use business contact details for relevant professional communication about Think About People’s services and activities, where this is permitted under applicable law.
Where the law requires consent for marketing, we obtain this in advance. You can always ask us to stop sending you marketing.
14. Recruitment system and data processors
Think About People uses Loxo as its recruitment and candidate management system. Loxo is used to record, manage and structure information about candidates and recruitment processes.
To the extent that Loxo processes personal data on our behalf, this takes place on the basis of a data processing agreement and in accordance with our instructions.
We also use other suppliers that process personal data on our behalf as data processors, for example in connection with the hosting of our website, email, and the job application module on our website that forwards applications to Loxo. Such suppliers process personal data only on the basis of a data processing agreement and in accordance with our instructions.
We assess the security and data protection of our suppliers on an ongoing basis.
15. Transfer of data outside the EU/EEA
If a supplier processes personal data in countries outside the EU/EEA, we ensure that a lawful basis for the transfer exists under the data protection rules. This may, for example, be a European Commission adequacy decision, the European Commission’s Standard Contractual Clauses or other approved transfer mechanisms.
16. Information security
We have organisational and technical security measures in place to protect personal data against accidental or unlawful deletion, loss, alteration, unauthorised access, unauthorised disclosure or other unlawful processing.
Access to personal data is restricted to employees and business partners who have a work-related need for the data.
17. Your rights
Under the data protection rules, you have a number of rights. Depending on the circumstances, you may have the right to access, rectification, erasure, restriction of processing, objection, data portability and withdrawal of consent.
If our processing is based on a legitimate interest, you have the right to object to the processing on grounds relating to your particular situation.
If processing is based on your consent, you may withdraw your consent at any time.
If you wish to exercise your rights, you can contact us at hello@thinkaboutpeople.com.
In certain cases, we may have the right or the obligation to continue to retain data even if you request erasure.
18. Complaints to the Danish Data Protection Agency
If you are dissatisfied with the way we process your personal data, we would very much like the opportunity to look into the matter. You are therefore welcome to contact us first.
You also have the right to lodge a complaint with the Danish Data Protection Agency (Datatilsynet), Carl Jacobsens Vej 35, 2500 Valby, www.datatilsynet.dk.
19. Cookies
Our website uses cookies, and you can read more about which cookies we use and how to manage them in our separate cookie policy.
20. Changes to this privacy policy
We may update this privacy policy from time to time, for example if our processing of personal data changes, we introduce new systems, or the law changes.
The current version will always be available at www.thinkaboutpeople.com.
