Privacy Notice for HPP Attorneys Ltd’s Client and Assignment Data Filing System
1. General
HPP Attorneys Ltd (”HPP”) is committed to ensure the confidentiality and data protection of the personal data at its possession. This privacy notice is applied to personal data that HPP collects in relation to its clients and assignment data filing system (“Data Filing System”). The personal data and its processing in the Data Filing System are described in this privacy notice. Additional information regarding the processing of personal data in the Data Filing System.
This privacy notice may be updated from time to time, for example due to changes in applicable legislation. HPP endeavors to carry out reasonable means to inform the data subject before-hand of any potential amendments and those effects. HPP advises the data subject to review this privacy notice every time you receive information about such amendments. This privacy notice was last updated on 24 May 2018.
2. Data Controller
Name: HPP Attorneys Ltd
Address: Bulevardi 1 A, 00100 Helsinki
Telephone: +358 9 474 21
Business ID: 0224138-5
3. Whose Personal Data Are Collected?
HPP processes its clients and their possible contact persons (“Client”) and the Client’s opposing parties and other party’s representative’s (“Opposing Party”) personal data in the Data Filing System.
4. What Categories of Personal Data Are Processed?
HPP processes the following personal data of its Clients and Opposing Parties in the Data Filing System:
- Name and identification number;
- Contact details (postal address, email address and telephone number); and
- Video camera footage filmed at HPP’s conference room for arbitration.
5. Which Sources Are Used to Collect Personal Data?
Personal data is collected primarily from the Client himself or herself. The personal data of the Opposing Party is collected primarily from the Client and, when necessary, from the Opposing Party himself or herself. In addition, the personal data may be collected from paid registers and publicly available sources.
6. Basis for, Purpose and Effects of Processing Personal Data
The basis for processing the Client’s and Opposing Party’s personal data is, depending on the case, HPP’s legitimate interest based on its purposes of use determined below.
The purpose of the processing of personal data is carrying out and maintaining the client and assignment relationship between HPP and the company the Client represents. The processing of personal data enables HPP to offer better services to the Client and the company he or she represents. The processing of personal data does not have any other effects to the Client or the Opposing Party.
HPP further processes the personal data of the Client for marketing purposes. However, the Client may, at any time, object the processing of his or her personal data for marketing purposes. HPP always endeavors, whenever possible, to anonymize or pseudonymize all the personal data used for marketing purposes before processing them further.
HPP does not further process Opposing Party’s personal data.
7. Regular Disclosures and Transfers of Personal Data to Third Parties
Personal data of the Client and the Opposing Party are transferred to the business partners and subcontractors of HPP. An up-to-date list of HPP’s business partners and subcontractors:
- AST-Accounting Services Tilimatic Oy
- Config Oy
- CSI Helsinki Oy
- Visma Solutions Oy
- Fennoa Oy
The business partners and subcontractors of HPP process the personal data of the Client and the Opposing Party in respect with the carrying out and maintaining the client and assignment relationship only on behalf of HPP. HPP always ensures that its business partners and subcontractors do not process the personal data transferred to them for any other purposes.
The personal data of the Client are disclosed to the banks for opening the client assets accounts.
HPP discloses, if necessary, the personal data of the Client and the Opposing Party to a competent authority (including the Finnish Bar Association) in accordance with the applicable data protection legislation.
8. Transfers of Personal Data outside the EU or the European Economic Area
HPP does not transfer the personal data of the Client and the Opposing Party outside the European Union (“EU”) or the European Economic Area (“EEA”).
9. Principles for the Storage of Personal Data
The personal data of the Client and the Opposing Party shall be stored in the Data Filing System for as long as the client and assignment relationship exists. After the termination of the client and assignment relationship the documentation containing the personal data of the Client and the Opposing Party shall be stored for a maximum period of 10 years in accordance with the recommendation of the Finnish Bar Association. The Client and the Opposing Party should, however, note that his or her personal data may be stored for a longer period of time if applicable legislation or HPP’s binding contractual obligations towards third parties require a longer storage period.
10. Rights of Data Subject in relation to Processing of Personal Data
The Client has the right to, according to applicable data protection legislation, at any time:
- be informed about the processing of his or her personal data;
- obtain access to data relating to him or her and review his or her personal data processed;
- require rectification and completion of inaccurate and incorrect personal data;
- require erasure of his or her personal data;
- object the processing of his or her personal data on grounds relating to his or her particular situation in so far as the processing of his or her personal data is based on HPP’s legitimate interest; and
- require restriction of processing of his or her personal data.
The Opposing Party has also similar rights mentioned above to the extent that it is possible considering the obligation of confidentiality in compliance with the Advocates Act as well as the rules of good advocacy practice.
In addition, the Client has the right to, in accordance with the applicable data protection legislation, at any time, obtain his or her personal data in machine-readable format and transmit the personal data to another data controller provided that the Client has himself or herself provided his or her personal data to HPP, and HPP’s processing of his or her personal data is based on a contract and the processing is carried out by automated means.
The Client and the Opposing Party should present his or her request for exercising any of the above-mentioned rights in the manner described in the ’Contacts’ section of this privacy notice. HPP may ask the Client or the Opposing party to specify his or her request in writing and to verify his or her identity before processing the request. HPP may refuse to fulfil the Client’s or the Opposing Party’s request on grounds set out in applicable data protection legislation.
The Client and the Opposing Party also have to right to lodge a complaint with the supervisory authority concerned or with the supervisory authority of the EU member state of his or her residence or place of work if the Client or the Opposing Party considers that HPP has not processed his or her personal data in accordance with the applicable data protection legislation.
11. Principles of Data Security
HPP respects the confidentiality of the personal data of the Client and the Opposing Party. Manual material shall be restored in the locked premises of HPP. Personal data processed and restored digitally are stored in the information system accessible to HPP’s partners and employees as well as designated CSI Helsinki’s and Config Oy’s employees with their personal user credentials and passwords. HPP takes regular back-up copies of the data processed in HPP’s information system.
12. Contacts
All requests concerning the use of the above-mentioned rights, questions about this privacy notice and other contacts should be made by e-mail to the address tietosuoja@hpp.fi. The Client and the Opposing Party may also contact HPP in writing or in person:
HPP Attorneys Ltd
Bulevardi 1 A
00100 Helsinki
