Privacy Notice for the Study

‘Neuro-inclusive Recruitment and Selection Processes’

This privacy notice explains how your personal data will be processed and protected as part of the study ‘Neuro-inclusive Recruitment and Selection Processes’.

In the study, we are investigating how neurodivergent adults experience application and selection processes for paid employment. In doing so, sensitive personal data may also be processed, in particular information relating to neurodivergence, diagnoses, ongoing diagnostic assessments or other health-related experiences.

1. Responsibility and Contact

The research project is led by:

Prof. Dr. Katrin Böttcher
Hochschule für Wirtschaft und Recht Berlin (HWR Berlin)

and

Prof. Dr. Timo Lorenz
MSB Medical School Berlin

Data controller responsible for the processing of research data:

Hochschule für Wirtschaft und Recht Berlin
represented by the President
Badensche Straße 52
10825 Berlin

Study contact:
Prof. Dr. Katrin Böttcher
katrin.boettcher@hwr-berlin.de

Data Protection Officer at HWR Berlin:
datenschutz@hwr-berlin.de

2. Purpose of data processing

Your data will be processed for scientific research purposes.

In particular, the processing serves to:

•    verify the eligibility criteria for the study,

•    provide a scientific description of the sample,

•    select a specific application or selection process for the interview,

•    assign suitable participants to a sub-study,

•    to arrange interview appointments,

•    to conduct, transcribe and analyse qualitative interviews,

•    to produce student dissertations as part of the project, and

•    to analyse and publish the results of the joint research project in an academic context.

Depending on the sub-study, the research may examine, amongst other things, experiences with organisational signals, safety, trust, perceived fairness, disclosure of neurodivergence, masking or camouflaging, support and accommodation options, flexible working conditions, leadership behaviour, virtual or international selection processes, as well as automated or AI-supported application and selection processes.

The study is not intended for medical or psychological diagnosis.

3. What personal data is processed?

Depending on the course of your participation, the following data in particular may be processed:

Registration and contact details

•    Name

•    Email address

•    Recruitment channel

•    Where applicable, the person through whom you became aware of the study

This data is required, in particular, to grant access to the study, to contact you and, where applicable, to arrange an interview appointment.

Information from the preliminary questionnaire

This may include, in particular:

•    Age

•    Gender, where provided voluntarily

•    Educational qualifications

•    Employment status and work experience

•    Details of a specific application or selection process

•    Type of role applied for

•    Sector and size of organisation

•    Elements of the application and selection process

•    Course and outcome of the process

•    Personal decision regarding whether to continue or withdraw from the process

•    Experiences with disclosure and support

•    Information regarding neurodiversity

Information on neurodiversity

For example, you can indicate whether you identify as a person with ADHD, autism, dyslexia or another neurodivergent experience relevant to the project.

You may also specify whether you have a formal diagnosis, are currently undergoing assessment, or are self-identifying.

Proof of a diagnosis is not required.

Information on neurodiversity, diagnoses or other health-related experiences may constitute health data and thus special categories of personal data.

Interview data

The following, in particular, may be processed as part of the interview:

•    the audio recording of the interview,

•    the interview transcript,

•    details of your experiences during the application or selection process,

•    where applicable, details of individuals, organisations or professional situations, and

•    a brief reflection memo by the interviewer.

Consent data

Your consents are documented electronically via LimeSurvey. A handwritten signature is not required.

4. Legal basis

The processing of your personal data is carried out on the basis of your voluntary consent in accordance with Article 6(1)(a) of the GDPR.

Where special categories of personal data are processed, in particular information relating to neurodivergence, diagnoses or other health-related experiences, this is done on the basis of your explicit consent in accordance with Article 9(2)(a) of the GDPR in conjunction with Article 7 of the GDPR.

5. Voluntary Participation

Your participation is voluntary.

You are under no legal or contractual obligation to take part in the study or to provide personal data.

You may leave optional questions unanswered. However, certain details are necessary to verify whether the eligibility criteria are met.

To take part in the interview, you must consent to the audio recording and transcription. It is not possible to take part in the interview without an audio recording.

You will not suffer any disadvantages as a result of not taking part or withdrawing from the study.

6. Pseudonymisation

Wherever possible, your research data will be processed using a participant code.

Names and contact details are stored separately from the research data itself.

The link between participant codes and contact details is stored separately and with restricted access.

Names of individuals and organisations, as well as other directly identifying details, are removed or generalised during transcription, insofar as this is possible for the purposes of scientific analysis.

Pseudonymised data remains personal data as long as it is possible to link it to you.

As qualitative interviews may contain a great deal of contextual information, complete anonymity cannot be guaranteed during the internal academic analysis.

For publications, identifying details are removed or generalised. Quotes are selected and, where necessary, generalised in such a way that the risk of identification is kept to a minimum.

7. Audio recording and transcription

The interview will be recorded digitally as an audio file.

No video recording will be stored for research purposes.

For online interviews, you can decide for yourself whether you wish to switch on your camera.

The audio recording will be used to transcribe the interview in full and to check the completeness and accuracy of the transcript. The academic analysis will then be carried out on the basis of the pseudonymised transcript.

8. Storage and Data Security

The research data will be stored in a secure institutional storage environment.

Access rights will be restricted to those individuals who require the data for the conduct, supervision, joint coding or scientific analysis of the study.

Contact details and identification information will be stored separately from the pseudonymised research data.

Audio recordings will also be stored separately from the other analysis data.

9. Who has access to the data?

Access is granted only to those who require it for the purposes of carrying out the research or conducting a scientific analysis.

This may include:

•    the student conducting the interview,

•    the project leaders,

•    supervising researchers,

•    other students or researchers involved in the joint research project, provided they are involved in joint coding or analysis,

•    where applicable, IT, storage or transcription service providers commissioned by the institution, provided that the data protection requirements are met.

Other students and researchers involved in the joint coding or analysis will, as a rule, only be granted access to the pseudonymised research data required for their task. Access to contact details, the allocation list or audio recordings will only be granted insofar as this is absolutely necessary for the task in question.

Your research data will not be disclosed to employers, HR managers or other external parties.

10. Transfer outside the EU or the EEA

Audio recordings or interview transcripts will not be transferred to countries outside the European Union or the European Economic Area.

11. Retention period and deletion

Different retention and deletion periods apply to different types of data.

LimeSurvey

The survey and consent data stored on the HWR Berlin LimeSurvey server will be irrevocably deleted no later than six months after the survey has ended.

Data that is still required for the research project will be exported beforehand and stored in a secure institutional environment.

Audio recordings

The audio recording is used exclusively for the creation and quality assurance of the interview transcript. It is deleted as soon as

1.    a pseudonymised transcript has been created and

2.    this has been checked for completeness and accuracy.

The audio recording is not retained for long-term academic archiving.

Contact details and mapping list

Contact details, as well as the link between your name and your participant code, are stored separately from the research data.

They will be deleted as soon as they are no longer required for contacting participants, arranging appointments, exercising rights of withdrawal and data protection rights, or for necessary quality assurance measures.

The mapping list will be deleted as soon as individual mapping of the research data is no longer required for the conduct of the research project described. Once the mapping list has been deleted, it will no longer be possible to map participants using their participant codes. Where interview transcripts may still allow for personal identification due to contextual information they contain, identifying or potentially identifying details will be removed or generalised as far as possible.

Records of consent

The consents documented via LimeSurvey are exported before the LimeSurvey data is deleted and retained separately from the rest of the research data as evidence of consent.

The records of consent are retained for as long as is necessary to demonstrate the lawfulness of the data processing based on consent and, where applicable, to establish, exercise or defend legal claims. They are subsequently deleted. The specific retention period is determined by the relevant institutional guidelines of HWR Berlin.

Pseudonymised research data

Pseudonymised pre-survey questionnaires, interview transcripts and analysis data will be stored and analysed for academic purposes to facilitate the completion of students’ final dissertations and the joint research project.

The data collection phase is currently scheduled to run until 30 September 2027. This will be followed by joint coding and analysis, as well as the preparation of academic publications and conference papers. These activities form part of the research project described.

Once the analysis involving personal data has been completed, the research data will be anonymised as far as possible.

Where research data and underlying materials are necessary for the traceability of research results made publicly available, they will, in accordance with the HWR Berlin’s rules of good scientific practice, generally be archived for ten years from the date on which the respective research results were made publicly available.

Where, for data protection reasons or other justifiable grounds, a shorter retention period or the archiving of only part of the original research data is required, this will be documented.

Fully anonymised scientific results and publications may be retained permanently, provided that no personal reference can be made to them.

12. Use in final-year dissertations and in the joint research project

A condition of participating in the interview is that your pseudonymised data

•    may be analysed for academic purposes in the relevant final-year dissertation and

•    in the joint research project ‘Neuro-inclusive recruitment and selection processes’.

Results may be used, in particular, in Bachelor’s or Master’s theses, academic publications and conference papers.

The data collection, currently scheduled to run until 30 September 2027, does not mark the end of the research project. The subsequent joint coding and analysis of the entire dataset, as well as the preparation and publication of academic papers, form an integral part of the research project described.

13. Use of verbatim quotations

Permission to use anonymised or sufficiently generalised verbatim quotations is sought separately and on a voluntary basis.

You may take part in the study even if you do not consent to the use of verbatim quotations.

Refusal will not affect your participation.

14. Further academic use beyond the research project described

Your pseudonymised interview data will only be used for further academic research projects beyond the scope of the research project described here if you give your separate consent. This may include, in particular, further research into neurodiversity, work, job applications, recruitment or inclusion.

The joint analysis of the dataset collected as part of this study, as well as any resulting academic publications and conference papers, form part of the research project described and do not, as such, constitute further research.

Refusal to consent to any further academic use beyond this will not affect your participation in the current study.

15. Withdrawal of your consent

You may withdraw your consent at any time with effect for the future.

To do so, please contact:
Prof. Dr. Katrin Böttcher
katrin.boettcher@hwr-berlin.de

The lawfulness of the processing up to the time of withdrawal remains unaffected.

As long as your data can be linked to you via your participant code, your personal research data may be deleted at your request, provided there are no legal grounds preventing this.

Once the link between contact details and the participant code has been deleted or the research data has been fully anonymised, it is no longer possible to specifically identify and delete individual contributions.

Any processing carried out lawfully prior to withdrawal remains unaffected by this. Similarly, anonymised scientific results that have already been published cannot subsequently be attributed to individual participants and removed from publications.

16. Your data protection rights

Provided that the legal requirements are met, you have, in particular, the right to

•    access to the personal data processed about you,

•    correction of inaccurate or incomplete data,

•    erasure of personal data,

•    restriction of processing,

•    withdrawal of consent with effect for the future,

•    data portability, where applicable, and

•    to lodge a complaint with a data protection supervisory authority.

17. Right to lodge a complaint

You have the right to lodge a complaint with a data protection supervisory authority.

The following authority is specifically responsible for the HWR Berlin:

Berlin Commissioner for Data Protection and Freedom of Information
Alt-Moabit 59–61
10555 Berlin
Telephon: +49 30 13889-0
E-Mail: mailbox@datenschutz-berlin.de

18. Contact

If you have any questions regarding the study, your data or the withdrawal of your consent, please contact:

Prof. Dr. Katrin Böttcher
Hochschule für Wirtschaft und Recht Berlin
katrin.boettcher@hwr-berlin.de

For general enquiries regarding data protection, you may contact the Data Protection Officer at HWR Berlin:

datenschutz@hwr-berlin.de