Applicable for JKS A/S and all subsidiaries.

Introduction
The aim of JKS’s policy for data ethics is to describe JKS’s approach to data ethics and the way it guides our overall work with data collection and processing hereof. The policy serves as communication towards our customers, employees’, and the temporary workforce, which is the main purpose of our business. The policy should be seen as an overall framework that ensures a common and transparent approach across our organization.

Scope
The policy considers all JKS entities, including the subsidiaries in Sweden and Norway. Thus, this policy should be followed by all JKS employees. JKS will continuously monitor the implementation of the data ethics policy.

Our position on data ethics in JKS
The increased amount and access to data, entails a risk that data is used inappropriately and ultimately misused for purposes that can be described as unethical. For JKS the concept of data ethics is more far-reaching than compliance with applicable laws. Data ethics covers the way we treat data – which is with respect and includes considerations regarding ethical collection and processing of data.

Data ethics at JKS
To JKS, data ethics and GDPR are closely related, but we acknowledge that it is not limited to GDPR. In JKS, we continuously take conscious ethical decisions around the way we collect and process data by putting the interests of our customers and temporary workers first, when considering the use of their data to increase value for them. The satisfaction of our customers and temporary workers is a prerequisite for running a reliable business.

JKS primarily works with personal data such as customer data, temporary workers data, JKS’ employee data and a limited amount of operational data regarding third parties (e.g. invoices and agreements). Moreover, we do not share or buy data from third parties. Thus the vast majority of JKS’s data is related to GDPR and is covered by our Privacy Policy (jks.dk). The Privacy policy includes specific descriptions on how JKS collects data, process data, ensures the security of the data and not least the rights of the data owner.

In line with the purpose of our business, we mainly receive and collect data for matching the available temporary workers in our portfolio with our customers’ needs for workforce. For this type of data, we use internal systems to collect and process the data, which allows us to manage the data in accordance with our security measures (highlighted in the Privacy policy). Furthermore, we ensure that our employees continuously receive training in GDPR and considers the implications that may arise in case an employee does not live up to the policy when handling personal data.

At JKS we process personal data about our employees, and we take the protection of this personal data very seriously. It is important to us that our employees trust that we treat their data in an ethical manner and run an efficient business and to ensure a good and trustworthy work environment. With the aim of ensuring the protection of our employees’ data, we only manage the data provided in relation with their employment. In practice this means that we only process the personal data that is necessary and sufficient for the purpose of the employment.

JKS currently uses limited amount of new technologies when processing data. However, we recognize the fast-growing digital transformation and see opportunities in developing new ways of working with data including technologies as AI and robotics. In line with future data processes and the implementation of new technologies, we believe that the design should be completed with human intelligence to avoid potential unethical actions that could be biased or discriminatory.

Contact, questions, comments, complaints
If you have questions, comments or complaints concerning JKS’s work in relation to data ethics, please contact us by e-mail on privacy@jks.dk or in writing to JKS A/S, Rødkløvervej 2, DK-6950 Ringkøbing.

Amendments
JKS can at any time choose to amend or add content to this data ethics policy. The newest version of the data ethics policy is always available on the JKS website.

Governance
JKS’s Board of Directors are responsible for the approval of the policy. The overall responsibility of the data ethics policy lies with the ISU Group (Informationssikkerhedsudvalg).