Privacy Policy for Rubino Rekrytering – Recruitment and Candidate Data
Last updated: September 2026
1. About this Privacy Policy
Rubino Rekrytering AB (“Rubino”, “we”, “us”) provides recruitment and executive search services. In connection with our services, we process personal data relating to candidates and other individuals involved in recruitment processes.
This Privacy Policy explains how we collect, use, store and protect your personal data and what rights you have under the General Data Protection Regulation (“GDPR”).
When we use the term “Candidate”, we mean individuals who apply for a position, join our Candidate network through Rubino Connect, are identified through search or are referred to us for potential recruitment opportunities.
Rubino Rekrytering AB, organisation number 556641-9098, is the data controller for the processing described in this Privacy Policy.
2. What personal data do we process?
Depending on how you interact with us and the recruitment process, we may process:
Contact information, such as name, email address, telephone number and location.
Application and professional information, such as CV, cover letter, employment history, education, qualifications, skills and other information you provide to us.
Recruitment process information, such as interview notes, assessments, salary expectations, availability and information relevant to evaluating your suitability for a position.
Communications, such as emails and other correspondence with us.
Publicly available professional information, for example information from professional networking platforms, company websites and other relevant professional sources.
Reference information, where references are obtained as part of a recruitment process.
Technical information generated when you use our career site or recruitment platform.
Please do not provide sensitive personal data unless it is specifically relevant and necessary for a recruitment process.
3. Where do we obtain your personal data?
We may collect personal data:
directly from you when you apply for a position, join Rubino Connect or otherwise communicate with us;
from publicly available professional sources, such as professional networking platforms and company websites;
through referrals;
from references you or another relevant person provide; and
through information created during the recruitment process, such as interview notes and assessments.
If we identify you through search or receive your details through a referral, we will provide you with information about our processing in accordance with applicable data protection requirements.
4. Why do we process your personal data?
We process personal data in order to:
manage applications and recruitment processes;
assess Candidates' qualifications and suitability for positions;
communicate with Candidates during recruitment processes;
identify and contact potential Candidates for relevant recruitment opportunities;
present Candidates to clients where appropriate in a recruitment process;
obtain and assess references where relevant;
maintain our professional Candidate network, Rubino Connect, and stay in touch with Candidates who have chosen to join the network, including contacting them about future job opportunities that may be relevant to their experience and career interests;
improve and administer our recruitment services and systems; and
comply with legal obligations and, where necessary, establish, exercise or defend legal claims.
5. Who do we share your personal data with?
We may share personal data with:
clients involved in a recruitment process where this is relevant and appropriate;
service providers that provide systems and services used in our recruitment activities; and
authorities or other parties where required by law.
We do not sell Candidate personal data.
Where a client receives Candidate information and processes it for its own purposes, the client may be independently responsible for its processing of that information.
6. What are our legal bases for processing?
Applications and recruitment processes
When you apply for a position or participate in a recruitment process, we generally process the personal data necessary to manage the recruitment on the basis of our legitimate interests in providing recruitment services, assessing Candidates and managing the recruitment process.
When submitting an application, you may be asked to confirm that you have read this Privacy Policy. This confirmation is an acknowledgement of the information provided to you and is not consent to the processing required to manage your application.
Candidates identified through search or referrals
As part of our executive search and recruitment activities, we may identify potential Candidates through publicly available professional sources or receive Candidate information through referrals.
We initially process relevant professional information on the basis of our legitimate interests in identifying and contacting potential Candidates for recruitment opportunities.
We limit this processing to information that is relevant to professional recruitment purposes and balance our interests against the Candidate's interests, rights and reasonable expectations.
If we wish to retain your profile as part of our Candidate network beyond this initial recruitment-related period, we will ask for your consent.
Rubino Connect and future recruitment opportunities
You may choose to join our professional Candidate network, Rubino Connect.
By joining Rubino Connect, you actively consent to Rubino Rekrytering AB storing and processing your personal data as part of our Candidate network and contacting you about future job opportunities that may be relevant to your experience and career interests.
Joining Rubino Connect is voluntary and is not a condition for applying for a position or participating in a recruitment process.
If you apply for a specific position, you may separately choose to consent to being part of our Candidate network so that we can contact you about relevant future opportunities.
You may withdraw your consent at any time.
Legal obligations and legal claims
Where necessary, we may also process personal data to comply with legal obligations or, where applicable, on the basis of our legitimate interests in establishing, exercising or defending legal claims.
7. International transfers
Some of the service providers we use may process personal data outside Sweden or the European Economic Area (EEA).
Where personal data is transferred outside the EEA, we take appropriate measures to ensure that the transfer complies with applicable data protection law, including the use of approved safeguards where required.
8. How long do we keep your personal data?
We do not keep personal data for longer than necessary for the purposes for which it is processed.
If you apply for a position
We normally retain personal data relating to your application for up to 24 months in order to manage and follow up the recruitment process and, where necessary, establish, exercise or defend legal claims.
Applying for a position does not automatically mean that you join Rubino Connect. You may separately choose to consent to being part of our Candidate network for future recruitment opportunities.
If we identify you through search or receive your details through a referral
Where we identify you as a potential Candidate through search or receive your details through a referral, we may initially retain relevant professional information on the basis of legitimate interests.
We normally retain this information for up to 120 days unless there is an ongoing recruitment process or another lawful reason for continued processing.
If we would like to retain your profile beyond this period as part of our Candidate network, we will ask for your consent.
Rubino Connect and our Candidate network
If you join Rubino Connect or otherwise consent to being part of our Candidate network, your consent is valid for 24 months.
Before or when this period expires, we will ask you to actively renew your consent if you wish to remain in our Candidate network. If you renew your consent, a new 24-month consent period begins.
Consent is not renewed automatically.
If you do not provide or renew your consent, your Candidate profile will be deleted in accordance with our deletion procedures, unless we have another lawful basis or legal obligation to retain specific information.
You may withdraw your consent at any time.
Other retention
In certain circumstances, we may need to retain specific information for longer where this is necessary to comply with a legal obligation or to establish, exercise or defend legal claims.
When personal data is no longer required, it is deleted or anonymised in accordance with our procedures.
9. How do we protect your personal data?
We take appropriate technical and organisational measures to protect personal data against unauthorised access, loss, alteration or disclosure.
Access to Candidate information is limited to persons who need it for the relevant purposes.
10. Your rights
Depending on the circumstances, you have the right to:
receive information about how we process your personal data;
request access to your personal data;
request correction of inaccurate or incomplete information;
request deletion of your personal data;
request restriction of processing;
object to processing based on legitimate interests;
receive certain personal data in a portable format where the right to data portability applies;
withdraw your consent at any time where processing is based on consent; and
lodge a complaint with the Swedish Authority for Privacy Protection (Integritetsskyddsmyndigheten, IMY).
Withdrawing consent does not affect the lawfulness of processing carried out on the basis of your consent before it was withdrawn.
11. How can you exercise your rights?
If you have questions about how we process your personal data or wish to exercise any of your rights, please contact us at:
[email protected]
We may need to verify your identity before responding to certain requests.
You may also use the data privacy functions available through our career site where applicable.
12. Automated decision-making
Rubino does not use solely automated decision-making that produces legal effects or similarly significantly affects Candidates.
Technology and recruitment systems may be used to support our recruitment processes, but recruitment decisions involve human assessment.
13. Updates to this Privacy Policy
We may update this Privacy Policy from time to time, for example when our recruitment processes, systems or legal requirements change.
The current version will always be available through our career site. The date of the latest update is shown at the top of this Privacy Policy.
