COWI Privacy Notice

The COWI Group (hereafter "COWI") recognises and respects the right to personal data protection for all individuals. COWI is committed to protecting our customers, employees and business partners’ personal data. Please take the time to read this privacy notice, as it provides information about the personal data that COWI may collect and how it is processed.

All articles stated in this privacy notice refer to Regulation (EU) No 2016/679 of the European Parliament and of the Council.

This COWI Privacy Notice was last updated 08.10.2019.

1) Identity and Contact Information of COWI

COWI A/S (The Data Controller)
Parallelvej 2
2800 Kongens Lyngby
Denmark
+45 56 40 00 00
For additional information or questions, please contact dataprivacy@cowi.com

2) Personal Data Processing

2.1) Consultancy Services

As a client or as a potential client, COWI may process personal data in order to provide consultancy services, or to conclude or fulfil an agreement we have entered into with you or the organisation that you represent.

In this regard, COWI may process personal data such as name, email, phone number, mail conversations, address, and other contact details, job title, job position, CV and personal data contained therein as well as information about our business relations.

The legal basis for the processing of this personal data is article 6 (1)(b), as the processing of personal data is necessary to enter into or to fulfil an agreement between COWI and the organisation that you represent. If no agreement has been reached, the legal basis for the processing of this personal data is article 6 (1)(f), as it is a legitimate interest of COWI to try to reach an agreement with you or the organisation that you represent.

The personal data is received from you directly, from the organisation that you represent and or from any other party that may be associated with the consultancy services.

2.2) Street Photos

COWI processes personal data in connection with its street photo products offered to public authorities and private organisations for professional use. The processing of street photos, and the personal data associated therewith, is to provide tools for urban development and planning.

In this regard, COWI may process personal data such as photos of buildings, roads, address registration and date and time of when the photos were taken. The personal data, which may include photos of individuals and license plates, is blurred.

The legal basis for the processing of this personal data is article 6 (1)(f), as it is a legitimate interest of COWI to offer public authorities and private organisations tools for urban development and planning.

The personal data is collected from publicly available sources, mainly public roads.

2.3) Mapping and Geo Services

COWI offers services within aerial photography, LIDAR data, 3D mapping, terrain models, city planning and thermographic assessments.

In this regard, COWI may process personal data such as photos of buildings, properties, roads, address registration and date and time of when the photos were taken. The personal data, which may include photos of individuals and license plates, is blurred.

The legal basis for the processing of this personal data is article 6 (1)(f), as it is a legitimate interest of COWI to offer services within mapping and geo services.

The personal data is collected from public roads, train routes and airspace.

2.4) Use of COWI Websites

Websites owned or operated by COWI may require you to enter personal data in order to use the websites’ functionalities. The categories of personal data, the purpose of the processing, and whether the disclosure of personal data is mandatory or voluntary, is stated by independent terms that are associated with the functionality. Certain functionalities may not work, if you choose not to provide your personal data, such as the recruitment system.

Additionally, COWI collects personal data in connection with your visit to COWI websites including IP address, geographic location, time of visit, browser type, language, operating system, screen resolution and information about other websites you have visited before COWI websites through cookies.

The legal basis for the processing of this personal data is article 6 (1)(f), as it is a legitimate interest of COWI to improve the user experience of visitors’ equipment and location, and to personalise the content of the websites. Please visit our Cookie policy for further information.

The personal data is collected from you directly, and through third-party cookies.

Please note that websites owned by COWI may allow you to link to other websites that are not controlled by COWI. COWI is not responsible for the content of these sites, including any privacy notices.

2.5) Social Media

COWI uses social media, such as Facebook, LinkedIn, Twitter, Instagram, Youtube and Vimeo, to reach and communicate with target groups, such as customers, potential employees, partners, decision makers and the general public. The purpose is to strengthen COWI's position as a consultant, employer, expert and as a stakeholder in the public agenda.

COWI may process personal data that you have made available through social media including your interactions with COWI on these channels.

The legal basis for the processing of this personal data is article 6 (1)(f), as it is a legitimate interest of COWI to reach and communicate with target groups on social media by producing content and marketing based on followers and interactions on these platforms.

The personal data is collected from you directly, and through social media.

2.6) Newsletters

COWI processes personal data in connection with your subscription to our newsletters in order for us to send you news stories, invitations, marketing and other information regarding our consultancy services and about COWI in general. This personal data may include name, email, interest areas and other information you may have provided in connection with your subscription.

The legal basis for the processing of this personal data is article 6 (1)(a), and is therefore based on your consent. You can withdraw your consent at any time by contacting COWI according to section 1, or by using the unsubscribe link in any newsletter you may have received.

The personal data is collected from you directly.

2.7) Attendance at an Event, Seminar, Workshop or Webinar

COWI facilitates events, seminars, workshops and webinars for customers, potential customers, potential job candidates and other business partners.

In this regard, COWI may process personal data such as name, email and other registration related information. COWI uses this information to provide you with access to and service during the event, seminar, workshop or webinar. Furthermore, COWI may take photos and shoot videos during the event, seminar, workshop and webinar and publish this content on our online channels and in printed materials.

The legal basis for the processing of this personal data is article 6 (1)(a), and is therefore based on your consent. You can withdraw your consent at any time by contacting COWI according to section 1.

The personal data is collected from you directly.

2.8) Information Request

As a data subject, you may file an information request from COWI. In relation to the information request, COWI may need your personal data such as name, address, email, phone number and other data in order to respond and locate the information requested. The data may also be used by COWI to verify your identity. The personal data enables COWI to comply with our legal obligations.

The legal basis for the processing of this personal data is article 6 (1)(c), which relates to the processing necessary to comply with a legal obligation to which COWI is subject.

The personal data is collected from you directly.

Information Request Formula and Procedure.

2.9) VISITORS TO OUR OFFICES

COWI hosts visitors across our offices, including clients, potential clients, suppliers, tradespeople, stakeholders, job applicants and organisations.

In this regard, COWI may process personal data such as name, email, phone number and other contact details. If your visit is planned, we may send your contact details to reception before your visit so that a personalised visitor card or label can be granted upon arrival. If you arrive without an appointment, you will need to enter your personal data so that a personalised visitor card or label can be granted.

The legal basis for the processing of this personal data is article 6 (1)(f), as the processing is for security and safety reasons.

Furthermore, COWI may process personal data such as device address, IP address and traffic logs, if you choose to use our on-site Wi-Fi.

The legal basis for the processing of this personal data is article 6 (1)(f), as it is a legitimate interest of COWI to provide access to our Wi-Fi while on site.

The personal data is collected from you directly or from the organisation you represent.

2.10) RECRUITMENT

2.10.1) SOLICITED AND UNSOLICITED APPLICATIONS

COWI's processing of your personal data in connection with our recruitment activities is to assess your qualifications and suitability for a solicited role you have applied for, or if you have submitted an unsolicited application. The personal data may also be used to contact you to progress your application with a view to offering you an employment contract, and may further be used to screen if other open job vacancies might be of interest to you.

When applying for a position within COWI, you will be requested to submit personal data such your name, email, phone number, resume, CV, cover letter, primary language, experience, education, qualifications and any other relevant information required for COWI to evaluate your application.

If you are called in for an interview, COWI may also process personal data you provide during the interview, including assessment tests and personality tests which have independent privacy notices which you will be presented beforehand.

Under certain circumstances, COWI may ask you to provide contact details to referees from former employer to collect information about you. COWI will never contact any referrer before your approval.

The legal basis for the processing of this personal data is article 6 (1)(b), as the processing of personal data is necessary for COWI in order to take steps at your request prior to entering into a contract.

If you provide your job application with special category data, such as health, religious or ethnical information, the legal basis for the processing of this personal data is article 9 (2)(b), which relates to COWI’s obligations in employment law.

In some circumstances, COWI will also request a copy of your personal data relating to criminal convictions and offences or related security measures depending on the role you have applied for. The legal basis for the processing of this personal data is article 9 (2)(a), which is your explicit consent, or when the processing is authorised by national law.

COWI will process additional personal data about you, if your application is successful and you accept our conditional offer of employment. Please visit the COWI Privacy Notice for Employees to get insight in the personal data COWI may process about you as part of your employment.

The personal data is collected from you directly. 

2.10.2) OUTREACH RECRUITING

COWI may also obtain your personal data indirectly from third-party sources such as recruitment platforms and websites, such as social media sites of which you are member. The processing of your personal data is to identify and source talent for COWI to evaluate you for open positions that match your qualifications or interests.

In this regard, COWI may process your publicly available personal data, including your name, email, phone number, resume, CV, cover letter, primary language, experience, education, qualifications and any other relevant personal data you have made available.

COWI may contact you through the above-mentioned platforms of which you are member, or directly based on the information you have made available, to investigate if you are open for further recruitment activities as stated and processed in accordance with section 2.10.1.

The legal basis for the processing of this personal data is article 6 (1)(f), as it is a legitimate interest of COWI to attract talented candidates to the workforce.

The personal data is collected from you directly or through recruitment platforms and third-party websites of which you are member.

2.10.3) TALENT POOL

If you have submitted a solicited or unsolicited application with COWI, you may be asked if you would like to be added to COWI’s talent pool prior to erasure of your candidate profile. If you consent to this, COWI may proactively contact you if suitable vacancies arise.

The legal basis for the processing of this personal data is article 6 (1)(a), and is therefore based on your consent. You can withdraw your consent at any time by contacting COWI according to section 1, or by deleting your candidate profile in the recruitment system.

3) Recipients of Personal Data

The personal data referred to in section 2 may be disclosed to the following categories of recipients if COWI is required by law or if the disclosure is legitimate:

  • Other companies in the COWI Group.
  • Customers, potential customers and business partners.
  • Public authorities such as tax authorities, police and municipalities.
  • As part of the operation of COWI’s business, the personal data may be disclosed to external suppliers, including independent data controllers and data processors.
  • In relation to the use of COWI’s websites, the personal data may be disclosed to third parties in connection with the use of cookies. Please visit our Cookie policy for further information.

4) Transfer of personal data to a third country or an international organisation

COWI may transfer personal data stated in this policy to a third country (non EU/EEA countries), including Bahrain, Canada, China, Hong Kong, India, Kenya, Mozambique, Oman, Qatar, Singapore, South Korea, Tanzania, Turkey, UAE, Uganda, USA and Zambia. COWI has established the necessary and appropriate guarantees to protect this transfer. A copy of the guarantees can be obtained by contacting dataprivacy@cowi.com

5) The period during which the personal data will be stored, or the criteria used to determine this period

COWI stores personal data as long as it is necessary for the purpose(s) which the data is collected.

  • Personal data in relation to consultancy services, including mapping and geo services, is stored for up to ten years after the end of the contract, but may be stored for a shorter or longer time, if certain circumstances require a different retention period, including national limitation periods and liability periods.
  • Personal data in relation to street photos is stored for up to ten years, but may be stored for a shorter or longer time, if certain circumstances require a different retention period, including national limitation periods and liability periods.
  • Personal data in relation to mapping and geo services is stored for up to ten years, but may be stored for a shorter or longer time, if certain circumstances require a different retention period, including national limitation periods and liability periods.
  • Personal data in relation to the use of COWI’s websites is deleted depending on the functionalities you choose to use. The retention period is stated by independent terms that are associated with the functionality, e.g. the recruitment system. Personal data in relation to IP address, geographic location, time of visit, browser type, language, operating system, screen resolution and information about other websites you have visited before COWI websites is stored for up to two years, after which they are deleted. The retention period may vary for third party cookies. Please visit our Cookie policy for further information.
  • Personal data in relation to social media is deleted in accordance with your settings, announcements and or interactions on social media.
  • Personal data in relation to newsletters is usually retained until you unsubscribe or withdraw your consent, after which they are deleted.
  • Personal data in relation to your attendance at an event, seminar, workshop or webinar is retained until you unsubscribe or withdraw your consent, after which they are deleted.
  • Personal data in relation to an information request is deleted two years after the last action, at the latest.

  • Personal data in relation to visitors to our offices is deleted 30 days after visit.
  • Personal data in relation to solicited and unsolicited applications is stored in up to 180 days for candidates based in the EU/EEA and up to 730 days for American, Canadian and Indian candidates. Thereafter, you will be requested by email to advise COWI on whether your candidate profile shall be erased or be part of COWI's talent pool for further storage. Personal data in relation to outreach recruiting is stored according to your settings on the recruitment platforms and third-party websites of which you are member.

Personal data may be stored for a longer time if anonymised.

6) Your rights

Under applicable law, you have a number of rights in relation to COWI’s processing of your personal data. If you wish to make use of your rights, please contact COWI according to section 1.

  • The right to access: You have the right to request access to the personal data that COWI is processing about you, as well as additional information.
  • The right to rectification: You have the right to have inaccurate personal data rectified, or completed if it is incomplete.
  • The right to erasure: In certain circumstances, you have the right to have personal data about you deleted before the time of COWI’s general deletion occurs.
  • The right to restrict processing: In certain circumstances, you have the right to request the restriction of the processing of your personal data. If you are entitled to restrict the processing, COWI may only process personal data – with the exception of storage – with your consent, or for the establishment, exercise or defence of legal claims, or for the protection of the rights of another natural or legal person, or for reasons of important public interest.
  • The right to object: In certain circumstances, you have the right to object to COWI’s processing of your personal data.
  • The right to data portability: In certain circumstances, you have the right to receive your personal data in a structured, commonly used and machine-readable format, and you have the right to transmit this data to another controller without hindrance.
  • The right to withdraw consent: Where the processing is based on consent, you have the right to withdraw your consent at any time. To withdraw your consent, please contact COWI according to section 1. The withdrawn consent will not affect the lawfulness of the processing before its withdrawal.

If you need further guidance in relation to your rights, please contact your national supervisory authority.

7) Complaints

If you wish to complain about the processing of your personal data, please contact COWI according to section 1.

You may also file a complaint to the national supervisory authority. The national supervisory authority responsible for COWI A/S is Datatilsynet (The Danish Data Protection Agency), Denmark.