1 INTRODUCTION

This document describes how LeadDesk Oy (hereinafter ”LeadDesk”) and its staff process the personal data of job applicants applying to LeadDesk. LeadDesk acts as a controller to such personal data.

As a controller, we are responsible for the personal data of job applicants, and for the processing of such personal data. Protecting your privacy and your personal data is of utmost importance to us. We are committed to complying with the requirements of data protection regulation applicable to us in the processing of your personal data. The means and purposes of processing the personal data of job applicants are described in more detail in this Privacy Notice.

2 DATA CONTROLLER

LeadDesk Oy
(Business ID: 2299022-8)
Hämeentie 19
00500 Helsinki
Tel.: +358 931544800

 

Contact Person

Olli Nokso-Koivisto

c/o LeadDesk Oy

Tel.: +358 440665765

Email: olli.nokso-koivisto@leaddesk.com

3 LEGAL BASES FOR PROCESSING AND PROCESSING PURPOSES

The EU General Data Protection Regulation (EU) 2016/679 (“GDPR”) applies to all processing of job applicants’ personal data as a general law. Furthermore, certain provisions of the Finnish Act on Protection of Privacy in Working Life (759/2004) apply.

Processing of personal data must always be based on a legal basis set forth in the GDPR. Processing of job applicants’ data is based on the following legal bases:

  • Processing is necessary in order to take steps at the request of the data subject prior to entering into an employment contract
  • Legal obligation to which LeadDesk is subject
  • Data subject’s consent under applicable legislation
  • Legitimate interest of LeadDesk. A legitimate interest may be, for instance:
    • ensuring and improving data security or the security of premises and data network; preventing and investigating suspected fraud or misuse; and protection of LeadDesk’s property.

Personal data of job applicants is processed in particular for the following purposes:

  • Recruiting; receiving and processing applications;
  • Conducting personal and aptitude assessments;
  • Maintaining a CV database;
  • Informing the candidates whether they were selected to the position or not, as well as other communications between the job applicant and LeadDesk.

4 CATEGORIES OF PERSONAL DATA PROCESSED BY LEADDESK

LeadDesk may process the following personal data directly necessary for the processing purposes mentioned above. These necessary personal data can be categorised as follows:

Basic information, such as

  • Name of the applicant
  • Personal identity number
  • Contact details (such as address, telephone number and email address)

Information relating to suitability to the position, such as

  • Information on work experience, qualification data and information relating to education
  • Results of personal and aptitude assessment or other suitability assessment data.

Other information obtained from the job applicant, such as

  • Job application and possible appendices of the application

Other information accumulated during the recruitment, such as

  • Notes made by the interviewers
  • Communications between the job applicant and LeadDesk

Data collected through technical monitoring, such as

  • Data collected from the job applicant’s use of LeadDesk’s recruitment systems
  • Data relating to call and surveillance recordings

 

In addition to the categories of personal data presented above, LeadDesk may process special categories of personal data or personal data that is otherwise sensitive as follows:

  • Drug test certificate or data included in it to the extent permitted in applicable legislation in order to establish the employee’s performance and ability to work;

 

5 REGULAR SOURCES OF PERSONAL DATA

According to the principal rule set forth in the Act on Protection of Privacy in Working Life, data relating to job applicants shall primarily be collected from the job applicant him/herself. In addition, data is collected also from other permitted sources, such as from data systems to which personal data of the applicant is recorded in connection with the job applicant’s use such data system.

6 TRANSFERS AND DISCLOSURES OF PERSONAL DATA

LeadDesk may transfer job applicant’s personal data to third parties in the following manner in order to fulfil the processing purposes described in this Privacy Notice. When personal data are transferred to an entity which processes personal data on behalf of LeadDesk (i.e. data processor) LeadDesk has through contractual arrangements ensured that personal data is processed only in accordance with LeadDesk’s written instructions and only for the purposes described in this document and that access to personal data is restricted to persons who need access to data based on their tasks.

  • Data processors: LeadDesk may transfer personal data to processors in order for the processors to perform services and tasks assigned to them. Data processors’ tasks relate, for instance, to recruitment management, offering and managing of devices, data systems and software as well as offering other data processing services.

Some of the data processors used by LeadDesk may be located outside the EU or EEA area. LeadDesk has contractually ensured that these entities undertake to apply an appropriate level of data protection in their processing practices, and thus the data transfers are subject to appropriate safeguards. More information on cross border transfers of personal data and on the appropriate safeguards applied thereto from time to time is available from the contact person mentioned under Section 2 of this Privacy Notice.

LeadDesk discloses personal data for instance to authorities and LeadDesk’s service providers within the limits allowed or required in currently applicable legislation.

7 DATA RETENTION PERIOD

LeadDesk retains the personal data of the job applicants in accordance with the applicable legislation only for as long as the retention of data is necessary for processing purposes specified in this Privacy Notice. When LeadDesk no longer needs personal data for the specified purposes, the data will be deleted from the data systems of LeadDesk as well as from other files.

The general maximum retention period of personal data of job applicants is one year from the relevant recruitment decision, based on the limitation period for raising discrimination change under the Gender Equality Act (609/1986).

8 RIGHTS OF THE DATA SUBJECT

The General Data Protection Regulation provides the data subject with several rights based on which the data subject can in many situation himself/herself decide on the processing of his/her personal data. The data subject may use the following rights with regard to LeadDesk to the extent LeadDesk acts as the controller to the personal data of the data subject in question.

  • Right of access: The data subject has the right to obtain a confirmation from the controller on whether the controller processes personal data concerning the data subject and the right to access such data. The data controller may ask the data subject to specify his/her access request, amongst others, with regard to the details of the data to be delivered.
  • Right to rectification: The data subject has the right to obtain from the controller the rectification of inaccurate personal data concerning him/her processed by the controller, or to have incomplete personal data processed by the controller to be completed.
  • Right to be forgotten: The data subject has the right to obtain from controller the erasure of personal data related to him/her and the controller has the obligation to erase such data in case there is no longer a legal ground for the processing of such data or, where the legal or contractual obligation binding the controller related to the storing of the personal data has ended or, where the data subject has withdrawn his/her consent to the processing of his/her personal data.
  • Restriction of processing: In certain cases, where so prescribed by law, the data subject may have the right to obtain from the controller restriction of processing of his/her personal data.
  • Right to data portability: The data subject may, subject to certain conditions prescribed by law, have the right to receive the personal data concerning him/her processed by the controller in a commonly used and machine-readable format, and the right to transmit those data to another controller without hindrance from the original controller.
  • Right to object to processing of his/her personal data: In certain cases, the data subject may have the right to object to processing of personal data concerning him or her. The right to object is applicable in such situations in particular where the processing of personal data is based on the controller’s legitimate interest. In such situations the controller has to follow the data subject’s request, unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
  • To the extent the processing of personal data has been based on the data subject’s consent, the data subject has, at any time, the right to withdraw his/her consent regarding the processing.

In certain cases the job applicant can access and rectify his/her personal data through electronic services provided by LeadDesk. In other cases, the requests shall be directed to the contact person mentioned in section 2 of this document.

In addition, the data subject has the right to lodge a complaint with the supervisory authority on the processing of the personal data by the controller. The complaint shall be made to the competent supervisory authority, in Finland to the Data Protection Ombudsman, in accordance with its instructions. The website of the Data Protection Ombudsman can be found here.

9 CHANGES TO THIS PRIVACY NOTICE

LeadDesk may, from time to time, change this Privacy Notice. You can tell when changes have been made to the Privacy Policy by referring to the “Last Updated” legend at the top of this webpage / each page of this document. LeadDesk encourages you to review this document regularly for any changes.