Employee Candidate Data Protection Statement
Last updated: 9 April 2021
Siili Solutions Plc and its subsidiaries ("Siili", also "we", "us", "our"; Finnish Business ID 1979903-5) place the highest value on protecting your personal data. Siili is the data controller of your personal data in the context described in this Employee Candidate Data Protection Statement ("Statement"). As a data controller, Siili is responsible for your personal data processing and defines the purposes and means for the processing of your personal data.
This Statement explains our commitment to keeping your personal data ("Employee Candidate Data") confidential and secure. Further, the Statement informs you on the Employee Candidate Data processing practices related to our recruitment process activities ("Recruitment Process"). Employee Candidate Data processing in Siili online Recruitment Process tools, used e.g. for publishing job advertisements and receiving job applications, belongs to the scope of this Statement.
Siili processes your Employee Candidate Data always in accordance with all applicable laws.
Please read this Statement carefully before participating in the Recruitment Process. By participating in the Recruitment Process and/or by submitting (directly or indirectly) your Employee Candidate Data to us, you express your understanding to the processing of your Employee Candidate Data in accordance with this Statement. Otherwise, we expect that you will discontinue participating in the Recruitment Process and not to provide or cease providing us with your Employee Candidate Data. Please note that the absence of your Employee Candidate Data might prevent us from taking you into account in the Recruitment Process.
Your consent to Employee Candidate Data processing by us covers all collecting (also from any third parties or third-party sources relevant for Recruitment Process) and processing activities for all Employee Candidate Data obtained in connection to the Recruitment Process for the purposes defined in this Statement.
You submit your consent to us by providing us with your Employee Candidate Data either by continuing the use of our online Recruitment Process tool or by contacting us by other means, e.g. by sending us an e-mail or a letter.
Although we do not on our initiative generally collect or process Sensitive Employee Candidate Data (as described below), your consent would also cover all collection and processing of Sensitive Employee Candidate Data should the case that require. For instance, if you independently, without our general or specific request, provide us with any Sensitive Employee Candidate Data (e.g. by enclosing any health information as part of your application or curriculum vitae), you will be deemed to have provided us with your separate intentional consent for Sensitive Employee Candidate data processing for the purposes described in this Statement.
You have the right to withdraw your consent at any time. To do so, please contact us with the email email@example.com.
Please note that the withdrawal of your consent will immediately prevent us from taking you into account in the Recruitment Process.
Lawfulness of Processing of Your Employee Candidate Data
Processing of your Employee Candidate Data by us is based on:
- Consent(s) received from you and third parties (as may be required by the law);
- Obligations and rights of Siili based on mandatory laws – such laws include but are not limited to labour, data protection and non-discrimination laws as well as penal codes;
- Siili’s legitimate interests – i.a. to assess your suitability for position; and
- Entering an employment contract with you in case you are hired for the position.
We may desire to retain your Employee Candidate Data to consider you for future employment opportunities. In such an event, we will seek your consent, either prior to or after you formally apply for a job opportunity.
Data Collection Methods and Sources of Personal Data
Participating in the Recruitment Process requires you to personally submit to us certain Employee Candidate Data. Besides the utilization of our online Employee Candidate Data collection methods, depending on the Recruitment Process, we may also collect all or certain Employee Candidate Data from you in a phone call, job interview or with other non-computerized means common in a Recruitment Process.
Additionally, but always informing you and obtaining your consent in advance, we may collect your Employee Candidate Data from any public sources (e.g. online profiles), third parties (e.g. former employers), our own employees and/or other persons providing services for us. We may also collect Employee Candidate Data from personality and aptitude assessments you might be required to participate during the Recruitment Process. By providing us your consent as described above, you consent also to such data collection from third parties.
Employee Candidate Data Siili Collects and Processes
Basic Employee Candidate Data typically collected and processed by us consists mostly of your name, contact details, work experience, education, skills, references, curriculum vitae and letter of application. When providing us with information about a third-party individual (such as in form of references or recommendations), you are responsible for ensuring that you have attained all such third-party consents possibly required for providing us with the information as stipulated by the law.
In addition, we may collect other types of Employee Candidate Data necessary for the Recruitment Process in question.
We do not generally collect or process any Employee Candidate Data belonging to special categories ("Sensitive Employee Candidate Data" such as personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or data concerning health or sex life). However we may occasionally need to collect and process some Sensitive Employee Candidate Data about you e.g. if it is necessary to ensure the compliance with any mandatory legal requirement or for other justifiable reason.
Identification and general Employee Data attributes processed may include the following:
- Name information;
- Home address;
- Email address;
- Mobile telephone number;
- Curriculum vitae (document);
- Letter of application (document);
- Desired pay;
- Potential internal recommendations;
- Potential external recommendations;
- Internal offering match discussion;
- Minutes of the job interviews;
- Estimation of the employee candidate suitability;
- Employment contract proposal;
- Salary proposal;
- Start date;
- Agreed benefits;
- Other information that you provide in connection with the Recruitment Process.
Purposes of Processing
We process your Employee Candidate Data mainly in the Recruitment Process including receiving job applications, arranging and concluding job interviews, assessing employment potential, and any other actions necessary for the conclusion of the Recruitment Process. Therefore, the primary purpose of processing of your Employee Candidate Data is:
- Fulfilling Siili open job positions.
In detail, the purposes for processing and use of the Employee Candidate Data include the following items:
- Recognition of employee candidates (also potential for the future);
- Communication with employee candidates (providing information and enabling discussion);
- Enabling and managing Siili recruitment and onboarding processes;
- Assessing employment potential of employee candidates;
- Offering, negotiating and making decisions (both positive and negative) on employment contracts (including benefits);
- Collecting and maintaining employee candidate pool for future employment opportunities and to prevent unnecessary communication to employee candidates;
- Collecting feedback from the employee candidates; and
- Ensuring the execution and maintaining of the obligations and rights of data controller and employee candidate which are based on mandatory legislation (i.a. Finnish Non-discrimination Act, 1325/2014).
Your Employee Candidate Data will not be used for direct marketing or for any other purpose than those described above in this Statement.
Generally, we retain your Employee Candidate Data no longer than twenty-four (24) months from the earlier of:
- First Recruitment Process decision (whether positive or negative) where your Employee Candidate Data is used; or
- Collection of Employee Candidate Data (in case no Recruitment Process decision concerning you is made).
Notwithstanding the above, if you withdraw your consent for Employee Candidate Data processing, your Employee Candidate Data shall be archived and used only for ensuring your and our rights and our compliance with any other legislation applicable to the Recruitment Process. In this case the retention (in archive but not in any operational IT systems) shall not exceed twenty-four (24) months from the withdrawal of your consent.
Notwithstanding the above, the retention may be extended due to existing or imminent need of Siili to establish, exercise or defend itself against legal claims.
If you accept an offer of employment by us, any relevant personal data collected during your pre-employment period may become part of your personnel records.
Disclosures and Transfers
We will not disclose your personal data except as provided in this section or when you have given your consent.
We do not generally disclose any Employee Candidate Data to be independently used by other data controllers outside Siili unless required by mandatory law (such as to tax and other authorities).
We may transfer your Employee Candidate Data to Siili group companies or to third parties (e.g. subcontractors) who process Employee Candidate Data on behalf of us for the purposes described in this Statement. In this way, we do not release the Employee Candidate Data from our effective control.
If Employee Candidate Data is transferred to external data processors (subcontractors or vendors) to be processed on behalf of Siili, appropriate contractual arrangements (such as data processing agreements), as required by the applicable laws, are executed to secure lawful and appropriate processing of Employee Candidate Data.
As we operate internationally, due to necessary technical and practical requirements your Employee Candidate Data may be processed by Siili group companies or subcontractors located outside the European Union or European Economic Area (incl. Switzerland). Hence, countries to which your Employee Candidate Data may be sent to or accessed from may have a data protection standard differing from the country in which you are situated. In all such Employee Candidate Data transfer situations, the processing of Employee Candidate Data shall be in accordance with applicable legislations (e.g. justified by EU Commission standard contractual clauses and supplementary measures, if necessary) and our data processing policies and instructions.
We may also need to share your Employee Candidate Data with a purchaser or potential purchaser of our business. Such sharing does not occur regularly, but should it be necessary, we will share only the smallest possible amount of your Employee Candidate Data and always in the limits of applicable legislation.
We may provide aggregate statistics about our employee candidates and the Recruitment Process to reputable third parties, but these statistics are anonymized and will not include your Employee Candidate Data.
Employee Candidate Data is protected by appropriate organisational and technical measures against accidental and/or unlawful access, alteration, and destruction or other processing including unauthorized disclosure and transfer of Employee Candidate Data.
Such measures include (without limitation) proper firewall arrangements, malware detection, appropriate encryption of telecommunication and messages as well as use of secure and monitored equipment and server rooms. Data security is of a special concern when third parties (e.g. data processing subcontractors) provide us with and implement IT systems.
Data security requirements are duly observed in IT system access management. Personnel processing Employee Candidate Data as part of their tasks are trained and properly instructed in data protection and data security matters.
We do not make decisions about you through automated decision-making.
Your Rights Concerning Data Processing
At any time, you have the right to:
- Gain access to your Employee Candidate Data and receive a copy of the Employee Candidate Data and related supplementary information concerning Employee Candidate Data processing as required by the law;
- Verify the accuracy of your Employee Candidate Data and at your request, have your incomplete, inaccurate or outdated Employee Candidate Data modified or erased;
- Under certain circumstances, be forgotten by us if;
- Employee Candidate Data are no longer necessary in relation to the purposes of data processing;
- The data subject withdraws consent on which the processing of Employee Candidate Data is based and where there is no other legal ground for the processing;
- Employee Candidate Data must be erased for compliance with a legal obligation in EU or member state law to which Siili is subject; or
- Employee Candidate Data have been unlawfully processed by Siili.
- Under certain circumstances, have the processing of your Employee Candidate Data restricted if;
- The data subject contests the accuracy of the Employee Candidate Data;
- The processing is unlawful, and the data subject opposes the erasure of the Employee Candidate Data and requests the restriction instead; or
- Siili no longer needs the Employee Candidate Data for the purposes of uses, but Employee Candidate Data are required by the data subject for the establishment, exercise or defence of legal claims.
- Receive your Employee Candidate Data which you have provided to us in a structured, commonly used and machine-readable format and have the right to transmit those data to another data controller; and
- Lodge a complaint with a supervisory authority (Finnish Data Protection Ombudsman).
Also, at any time, you have the right to:
- Withdraw your consent to processing of your Employee Candidate Data.
Please note that the withdrawal of your consent will immediately prevent us from taking you into account in the Recruitment Process.
You may contact us to the contact information provided below in order to use your rights.
New Versions of This Statement
We may change or amend this Statement as necessary, and therefore we recommend that you revisit this Statement regularly.
Siili Contact Information
If you want to contact us in data protection related matters, please send us an e-mail at firstname.lastname@example.org.