Q: 3
Scenario 5:
Recpond is a German employment recruiting company. Their services are delivered globally and
include consulting and staffing solutions. In the beginning. Recpond provided its services through an
office in Germany. Today, they have grown to become one of the largest recruiting agencies,
providing employment to more than 500,000 people around the world. Recpond receives most
applications through its website. Job searchers are required to provide the job title and location.
Then, a list of job opportunities is provided. When a job position is selected, candidates are required
to provide their contact details and professional work experience records. During the process, they
are informed that the information will be used only for the purposes and period determined by
Recpond. Recpond's experts analyze candidates' profiles and applications and choose the candidates
that are suitable for the job position. The list of the selected candidates is then delivered to
Recpond's clients, who proceed with the recruitment process. Files of candidates that are not
selected are stored in Recpond's databases, including the personal data of candidates who withdraw
the consent on which the processing was based. When the GDPR came into force, the company was
unprepared. The top management appointed a DPO and consulted him for all data protection issues.
The DPO, on the other hand, reported the progress of all data protection activities to the top
management. Considering the level of sensitivity of the personal data processed by Recpond, the
DPO did not have direct access to the personal data of all clients, unless the top management
deemed it necessary. The DPO planned the GDPR implementation by initially analyzing the
applicable GDPR requirements. Recpond, on the other hand, initiated a risk assessment to
understand the risks associated with processing operations. The risk assessment was conducted
based on common risks that employment recruiting companies face. After analyzing different risk
scenarios, the level of risk was determined and evaluated. The results were presented to the DPO,
who then decided to analyze only the risks that have a greater impact on the company. The DPO
concluded that the cost required for treating most of the identified risks was higher than simply
accepting them. Based on this analysis, the DPO decided to accept the actual level of the identified
risks. After reviewing policies and procedures of the company. Recpond established a new data
protection policy. As proposed by the DPO, the information security policy was also updated. These
changes were then communicated to all employees of Recpond. Based on this scenario, answer the
following Questio n:
Questio n:
Recpond stores files of candidates who are not selected in its databases, even if they withdraw
consent. Is this acceptable under GDPR?
Options
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