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Privacy Notice for HPP Attorneys Ltd’s Recruitment 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 policy is applied to personal data HPP collects in relation to HPP’s recruitment data filing system (”Data Filing System”). The personal data and related 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

HPP may update this privacy notice from time to time, for example due to changes in applicable legislation. HPP endeavors to carry out reasonable means to inform you beforehand of any potential amendments. HPP advises you to review this privacy notice every time you receive information of such amendments. This privacy notice was last updated on 22 May 2018.

2 Data Controller

Name: HPP Attorneys Ltd
Address: Bulevardi 1 A, 00100 Helsinki
Tel: +358 9 474 21
Business ID: 0224138-5

3 Whose Personal Data Are Collected?

HPP processes the personal data of its job applicants (“Job Applicant”) in the Data Filing System.

4 What Categories of Personal Data Are Processed?

HPP processes the following personal data of Job Applicants:

  • Job Applicant’s name;
  • Job Applicant’s contact details; email address, telephone address, street address;
  • Job Applicant’s date of birth if such has been provided to us by the Job Applicant;
  • name and contact details of Job Applicant’s referees;
  • Job Applicant’s photo if he or she has provided HPP with one, e.g. in the job application;
  • evaluations made by the people taking part in the recruitment process and other similar information; and
  • other information Job Applicant has provided.

5 Which Sources Are Used to Collect Personal Data?

HPP collects personal data primarily from Job Applicant himself or herself. Personal data of Job Applicant may be, however, also collected from the recruiting companies and the consultants participating in HPP’s recruiting process.

6 Basis for, Purposes and Effects of Processing Personal Data

The basis of processing Job Applicant’s personal data is HPP’s legitimate interest for the evaluation of Job Applicant’s job application and for carrying out of the recruitment process.

The purpose of the processing of personal data is to carry out HPP’s recruitment processes and save the data of potential Job Applicants for later recruitment purposes. This includes, i.a. the evaluation of Job Applicants for recruitment purposes, communications with Job Applicants and other measures related to the recruitment process. The processing of the personal data of the Job Applicant has no other effects on Job Applicant than carrying out the recruiting process.

Job Applicant is responsible for obtaining necessary consents for saving and processing the personal data of any Job Applicant’s referees name in accordance with this privacy policy.

HPP does not further process the personal data of the Job Applicant for any other purposes than mentioned in this privacy policy.

7 Regular Disclosures and Transfers of Personal Data to Third Parties

HPP discloses or transfers Job Applicant’s personal data from the Data Filing System only to the recruitment consultants and the recruiting companies that are in contractual relationship with HPP and are bound by professional secrecy obligations in so far as the consultant or the company in question is involved in the recruitment process. HPP does not disclose Job Applicant’s personal data to other parties that have no relation to the recruitment. HPP always ensures that its business partners do not process the personal data transferred to them for any other purposes than mentioned in this data protection record.

List of HPP’s business partners:

  • Sympa Oy
  • Cubiks Finland Oy

HPP does not disclose Job Applicant’s personal data to parties that have no relation to the re-cruitment, e.g. for direct marketing or some similar purposes. However, HPP may be required to share Job Applicant’s personal data with competent authorities in accordance with data protection legislation.

8 Transfers of Personal Data outside the European Union or European Economic Area

HPP does not transfer Job Applicant’s personal data outside the European Union or European Economic Area.

9 Principles for the Storage of Personal Data

Should Job Applicant send HPP an open application, HPP stores the application and personal data in HPP’s system for six months’ period following the submission of the application after which HPP destroys them.

Should Job Applicant apply for a specific vacant post, the application and the personal data shall be stored, however, for a period of two years if the personal data (e.g. CV) are necessary for the defense of legal claims provided for in legislation, for example matters that affected to the recruitment decision.

10 Rights of Data Subject in relation to Processing of Personal Data

Job Applicant has right to, in accordance with applicable data protection legislation, at any time:

  • be informed about the processing of his or her personal data;
  • obtain access to data relating to Job Applicant 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 Job Applicant’s personal data on grounds relating to Job Applicant’s particular situation in so far as the processing of Job Applicant’s personal data is based on HPP’s legitimate interest; and
  • require restriction of the processing of Job Applicant’s personal data.

Job Applicant should note that objecting the processing or erasure of Job Applicant’s personal data may lead to a situation where it is not possible for HPP to consider Job Applicant’s application in the recruitment process.

Job Applicant should present his or her request for exercising any of the aforementioned rights in the manner described in the ’Contacts’ section of this privacy notice. HPP may ask Job Applicant to specify his or her request in writing and verify Job Applicant’s identity before processing the request. HPP may refuse to fulfil Job Applicant’s request on grounds set out in the applicable data protection legislation.

Job Applicant also has right to lodge a complaint with the supervisory authority concerned or with the supervisory authority of the EU member state of Job Applicant’s residence or place of work if Job Applicant considers that HPP has not processed Job Applicant’s personal data in accordance with applicable data protection legislation.

11 Principles of Data Security

HPP respects the confidentiality of Job Applicant’s personal data. Personal data restored manually shall be restored in HPP’s locked premises. Personal data processed digitally are protected and restored in HPP’s information system accessible to people who participate in HPP’s recruitment process with their personal user credentials and passwords. Backups from the data processed in HPP’s data systems are taken daily (changes) and full back-up is taken once per week.

12 Contacts

All requests concerning the use of the aforementioned rights, questions about this privacy no-tice and other contacts should be made by e-mail to tietosuoja@hpp.fi.