Last updated: 16 July 2026

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1. Who is responsible for your personal data

The controller of your personal data is:
Green SM Sweden AB (“Green SM”), with registered address at Östermalmstorg 1, 114 42 Stockholm, Sweden, company registration no. 559587-6375, privacy contact: eu.privacy@greensm.com

If you live in the EU/EEA, you may also lodge a complaint with the Swedish Authority for Privacy Protection, Integritetsskyddsmyndigheten (“IMY”), Box 8114, 104 20 Stockholm, Sweden, www.imy.se, or with another competent supervisory authority in the EU/EEA where you live or work.

2. What this notice covers
This notice explains how Green SM collects, uses, stores, shares and protects personal data about people who apply for, are considered for, or express interest in working with Green SM in Sweden (“Candidates”; their personal data, “Candidate Data”).
It applies to:

• driver candidates;

• office, operations, dispatch, customer support, fleet, depot, HR, finance, legal, IT, marketing, management and other non-driver candidates;

• candidates introduced through agencies, referrals, job boards, direct sourcing, recruitment events or the Green SM careers page;

• candidates for full-time, part-time, fixed-term, on-call or temporary roles;

• people who consent to remain in a Green SM talent pool.

3. What personal data we collect
Green SM collects Candidate Data in stages. We do not collect everything at the start of the process and we follow strict data-minimisation rules (Art. 5(1)(c) GDPR).

3.1 Data we may collect from all candidates

• name and contact details (postal address, e-mail, telephone);

• city, country and language preference where relevant;

• role applied for or role interest;

• CV / résumé, cover letter, portfolio, certificates, education and work history;

• application source (career page, job board, agency, referral, event);

• availability, expected start date and work-location preference;

• job-related qualifications, skills, experience and interview answers;

• interview notes, assessment results and hiring-manager feedback;

• communication history with Green SM recruiters, HR, hiring managers and agencies;

• offer details, acceptance or rejection status and relevant decision reasons;

• right-to-work indication needed to assess whether Green SM may employ you in Sweden.

3.2 Additional data for driver candidates
For driver candidates, Green SM may also process:

• confirmation that the applicable statutory age and driving-licence requirements for obtaining a Swedish taxi driver licence are met;

• Category B driving licence status, issuing country and validity and, where necessary, driving-licence number or a copy of the licence;

• taxi driver licence (taxiförarlegitimation) status and related licensing information;

• professional driving experience;

• customer-service experience;

• lawful shift availability;

• depot / location preference where relevant;

• language ability relevant to passenger service;

• internal driving, EV-handling, app-use, navigation and service-quality assessment results;

• training and onboarding completion status;

• vehicle-handover readiness once employment and licensing conditions are met.

3.3 Additional data for non-driver candidates
For non-driver candidates, Green SM may also process:

• professional licences or certifications relevant to the role;

• technical, operational, managerial, legal, financial, HR, IT, marketing, fleet, depot, customer-support or dispatch skills;

• role-specific assignments, work samples or case-study results;

• language ability where relevant to the role;

• information needed to assess seniority, reporting line, role fit and business need.

3.4 Data collected only after conditional offer or hiring
Green SM normally collects the following only after a conditional offer has been accepted or when legally
required for employment onboarding:
• Swedish personal identity number (personnummer) or coordination number
(samordningsnummer);bank account / IBAN;
• payroll and tax information;
• copy of a passport, national identity card, residence permit, work permit or other work-authorisation
document where necessary to verify the right to work in Sweden or to comply with Swedish
employment, immigration, payroll or tax requirements;
• pension and benefits information;
• emergency contact information (if required by Green SM HR policy);
• signed employment documents and onboarding records.

4. Sensitive data and data Green SM does not ask for
Green SM does not ask candidates to provide:

• health or medical details;

• pregnancy or family-planning information;

• marital status, family status or childcare arrangements (unless a later statutory benefits or pension process specifically requires it);

• racial or ethnic origin;

• religion or belief;

• political opinions;

• trade-union membership;

• sexual orientation or sex life;

• biometric data used to identify you;

• criminal-offence data;

• prior deactivation from third-party ride-hailing platforms (Uber, Bolt, FreeNow, etc.). We assess you on your own merits.

If you need an adjustment to participate in the recruitment process (for example, accessibility support, alternative interview format), Green SM may process the limited information needed to arrange that adjustment. This information will be kept confidential, processed separately from your application file, and will not be used to assess your suitability except where strictly necessary.
If you voluntarily provide information that Green SM did not ask for and does not need, Green SM will not use it for the recruitment decision and may delete it.

5. Where we obtain your data
We collect most Candidate Data directly from you.
We may also receive data from:

• recruitment agencies, staffing providers or payroll providers;

• job boards and professional platforms;

• employee referrals (referrer should let you know);

• recruitment events and job fairs;

• references you provide or authorise us to contact (we contact references only with your prior consent, usually at offer stage);

• public professional sources (such as LinkedIn) where relevant and proportionate — we do not systematically screen private accounts and will tell you if a specific public source has influenced our assessment;

• Swedish public authorities and regulatory sources, including the Swedish Transport Agency (Transportstyrelsen), the Swedish Transport Administration (Trafikverket), the Swedish Migration Agency (Migrationsverket) and the Swedish Tax Agency (Skatteverket), where necessary to verify driving qualifications, taxi driver licensing, right to work or other employment-related requirements;

• assessment providers or background-screening providers, only where lawful and pre-approved.

If you provide a reference’s contact details, you should inform that person that Green SM may contact them for recruitment purposes.
 

6. Why we use Candidate Data: purposes and legal bases

 

Manage applications
Green SM may receive applications, track application status, schedule interviews, and communicate with candidates.
Legal basis: Art. 6(1)(b) pre-contractual measures; Art. 6(1)(f) legitimate interests in recruitment administration.

Assess suitability
Green SM may review CVs, qualifications, interview answers, assessments, and role fit; compare candidates and make hiring decisions.
Legal basis: Art. 6(1)(b); Art. 6(1)(f) selecting suitable candidates.

Driver licensing readiness
Green SM may verify driving-licence status, Swedish taxi-driver licence status, relevant test completion and statutory readiness before the candidate performs passenger services.
Legal basis: Art. 6(1)(c); Art. 6(1)(b); Art. 6(1)(f) safe and lawful taxi operations.

Right-to-work checks
Green SM may verify whether the candidate may lawfully be employed in Sweden.
Legal basis: Art. 6(1)(c); Art. 6(1)(b).

Reasonable accommodation
Green SM may process limited data to enable participation in the recruitment process where accessibility support or another reasonable adjustment is needed.
Legal basis: Art. 6(1)(c); Art. 9(2)(b).

Prepare an offer
Green SM may draft offer letters, employment contracts, compensation and start-date arrangements.
Legal basis: Art. 6(1)(b); Art. 6(1)(f).

Onboard hired candidates
Green SM may process payroll, tax, pension, HR records, IT access, training, and system activation.
Legal basis: Art. 6(1)(b) employment contract; Art. 6(1)(c) tax/social-security/immigration; Art. 6(1)(f) secure onboarding.

Talent pool
Green SM may consider candidates for future roles.
Legal basis: Art. 6(1)(a) consent — separate, informed, freely given and withdrawable at any time.

Improve recruitment
Green SM may measure channel effectiveness, time-to-hire and process quality, normally in aggregated or pseudonymised form.
Legal basis: Art. 6(1)(f).

Security and fraud prevention
Green SM may protect systems and detect false applications.
Legal basis: Art. 6(1)(f); Art. 6(1)(c) where applicable.

Legal compliance and claims
Green SM may handle audits, authority requests, disputes, and defence of legal claims.
Legal basis: Art. 6(1)(c); Art. 6(1)(f) establishing/exercising/defending legal claims.

Where Green SM relies on legitimate interests, Green SM balances its interests against candidate rights and reasonable expectations and documents the balancing test. You may object on grounds relating to your particular situation.

Where Green SM relies on consent, you may withdraw consent at any time. With drawal does not affect processing carried out before withdrawal.

7. Screening, references and public sources
Green SM verifies candidate information only where relevant and proportionate.

• References are contacted only with your prior consent, normally at or around the offer stage, and only on job-related matters.

• Background checks are limited to what the role requires under Swedish law.

• Credit checks are not part of standard recruitment unless legally required for a specific role.

• Social media: we do not systematically screen private accounts; we may consult public professional profiles where directly relevant, and we will tell you if a specific source has influenced our assessment.

• No covert checks: Green SM does not carry out covert surveillance, undercover online screening or false-identity contact with candidates.

8. AI, automated tools and human review
Green SM may use recruitment systems to manage applications and workflow. Green SM does not make recruitment decisions based solely on automated processing where the decision produces legal effects or similarly significantly affects you (Art. 22(1) GDPR).
If Green SM uses AI-assisted recruitment tools (such as ranking, matching, scoring or recommendation features) these tools will be used only to support human recruiters and hiring managers. A human reviewer will remain responsible for shortlisting, interview and hiring decisions.

Green SM does not use facial-expression analysis, voice-emotion analysis, biometric identification, personality inference from video/voice, or solely-automated rejection in recruitment.

9. Recruitment communications
Green SM may contact candidates who apply, sign up through a Green SM form, meet Green SM at a
recruitment event, are referred, or otherwise request recruitment contact.
Bulk WhatsApp, SMS, e-mail or direct-message recruitment is allowed where:

• the candidate has specifically consented to recruitment messages through that channel (separate, freely-given, informed and unambiguous consent under Art. 4(11) GDPR);

• Green SM identifies itself in every message;

• the message explains the purpose;

• there is an easy opt-out in every message;

• Green SM can evidence the consent and the opt-out.

• Green SM does not use bought, scraped or unverified contact lists for recruitment outreach.

10. Who we share Candidate Data with
Green SM shares Candidate Data only with parties that need it for recruitment, onboarding, compliance,
security or legal purposes.
Recipients may include:

• Green SM recruiters, HR, hiring managers, interviewers and operational managers (need-to-know);

• Green SM group entities and group support functions, including entities outside the EEA where relevant, where access is necessary for recruitment approval, IT support, reporting or governance;

• recruitment agencies, staffing providers, payroll providers, accounting providers, assessment providers and background-screening providers (where lawfully engaged);

• ATS, HRIS, CRM, cloud, e-mail, document-management and security providers;

• video-conferencing providers used for interviews;

• taxi-licensing and public authorities where required by law;

• competent authorities, courts or regulators (including IMY) where required by law. Green SM does not sell Candidate Data and does not share Candidate Data with third parties for their own marketing.

Processors operate under written agreements meeting Art. 28 GDPR. Where joint controllership exists, Green SM concludes an Art. 26 arrangement.

11. International transfers
Some Green SM group entities and service providers are located outside the European Economic Area.
Where Candidate Data is transferred outside the EEA to a country that has not received an EU adequacy
decision, Green SM applies appropriate safeguards under Chapter V GDPR, in particular:

• the 2021 EU Standard Contractual Clauses (Commission Implementing Decision (EU) 2021/914), which Green SM uses as its standing transfer mechanism for intra-group and vendor transfers;

• a documented Transfer Impact Assessment (TIA) and supplementary technical, contractual and organisational measures where required.

Access by group entities outside the EEA is limited strictly to need-to-know users for defined recruitment, IT-support, governance, security and legal-compliance purposes, and is protected by contractual, technical and organisational measures. You may obtain a copy of the relevant safeguards (with commercially sensitive information redacted) by contacting eu.privacy@greensm.com.

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12. How long we keep Candidate Data
Active application
For the duration of the recruitment process.

Rejected or withdrawn candidates (default)
4 weeks after the end of the procedure.

Talent pool with separate, informed, freely given consent
Up to 12 months, then deleted unless renewed.

Recruitment-event leads
4 weeks after the campaign closes, or up to 12 months with separate, informed, freely given recruitment-follow-up consent.

Right-to-work documents
Copies of documents demonstrating a non-EU/EEA/Swiss national’s right to work in Sweden are retained for the duration of the employment and for at least 12 months after the employment has ended, in accordance with applicable Swedish immigration requirements.

Hired candidates
Data migrates to the personnel file under the Employee Privacy Notice; recruitment-specific data is purged per the schedule above.

Records needed to defend against claims
Up to 2 years, or longer where a specific claim or audit requires.

Assessment materials
Only as long as needed to evaluate the application and handle complaint or challenge periods.

Legal hold / audit / investigation data
As long as necessary for the legal hold, audit, authority request, dispute or claim, with a review date.

When retention expires, Green SM deletes or anonymises the data.
13. Security
Green SM applies organisational and technical measures appropriate to the risk (Art. 32 GDPR),
including:

• role-based access controls;

• confidentiality obligations on all personnel and vendors;

• encryption in transit and, where appropriate, at rest;

• secure cloud hosting and logging;

• vendor due diligence and DPAs;

• retention and deletion controls;

• incident response and breach escalation;

• security training for personnel handling recruitment data.

Candidate Data must not be stored in personal inboxes, private devices, unmanaged messaging apps or
informal spreadsheets unless approved controls are in place.
 

14. Your rights
You have the following rights under GDPR, exercisable free of charge:

• access your personal data and obtain a copy;

• rectification of inaccurate or incomplete data;

• erasure (“right to be forgotten”) where one of the GDPR grounds applies;

• restriction of processing in certain situations;

• object to processing based on legitimate interests, including profiling;

• data portability for data you have provided to us, where technically feasible;

• withdraw consent at any time;

• lodge a complaint with the Swedish Authority for Privacy Protection (Integritetsskyddsmyndigheten, IMY) or another competent EEA supervisory authority.

To exercise your rights, contact eu.privacy@greensm.com. Green SM may ask for reasonable information to verify your identity. We will respond within one (1) month of a verifiable request, extendable by two (2) months for complex requests in line with Art. 12(3) GDPR.
You will not be discriminated against or retaliated for exercising your rights. In some cases, deletion, objection or withdrawal of consent may affect Green SM’s ability to continue considering you for a role; Green SM will explain that consequence to you.

15. Changes to this notice
Green SM may update this notice from time to time. The current version will show its effective date. Material changes will be communicated through the relevant recruitment channel and/or the Green SM careers site. Where a change is material and you are an active candidate, Green SM will inform you directly.