This Privacy Statement has been published on March 4th 2019, version 1.0.
As part of any recruitment process, Varjo Technologies Oy (later “Varjo”) collects and processes personal data relating to job applicants and other people involved in recruitment processes. Varjo is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.
What data is collected, stored and processed?
Varjo collects, stores and processes a range of information about job applicants, including:
- name, address and contact details, including email address and telephone number
- details of qualifications, skills, experience and employment history
- information about current level of remuneration, including benefit entitlements, and salary requirements
- other information relevant for job application provided, such as information about the progress of the recruitment, notes concerning the application and about possible interviews, and information concerning possible aptitude tests and background checks.
- information about other people involved in the recruitment processes such as referees.
Primarily, Varjo gathers personal data directly from the job applicant. Data collected from the applicant includes application forms, CVs or resumes, data obtained from passport or other identity documents provided by job applicant (where required under applicable laws). Data may also be collected through interviews or other forms of assessment.
Varjo may also collect personal data from third parties, such as references supplied by former employers and possible partners performing aptitude tests. Information shall be sought from third parties only after informing job applicant and only with the job applicant’s consent, unless otherwise required or allowed by applicable laws.
Why does Varjo process personal data?
Varjo processes personal data of job applicants to manage the recruitment process, to handle job applications, assess and confirm a job applicant’s suitability for employment, to inform job applicants about the progress of recruitment, to arrange interviews and, eventually, to select the right applicant to work with us. Varjo needs to process personal data to take steps at job applicant’s request prior to entering into a possible employment contract with the job applicant.
In some cases, Varjo needs to process data to ensure compliance with its legal obligations. For example, according to the Aliens Act (301/2004), it is mandatory to check a successful applicant’s eligibility to work in Finland before employment starts. Varjo may also need to process data from job applicants to respond to and defend itself against legal claims.
Job applicant is under no statutory or contractual obligation to provide data during the recruitment process. However, if the job applicant does not provide the information for Varjo that is necessary for Varjo to handle the job application, Varjo may not be able to process job application properly or at all. When the job applicant provides data to Varjo, we have legitimate interest to process the data.
Who has access to data?
Job applicant information may be shared internally for the purposes of the recruitment exercise. This includes members of the HR team, interviewers involved in the recruitment process and managers in the function with a vacancy if access to the data is necessary for the performance of their roles.
Varjo may share job applicant data with former employers to obtain references for job applicant after informing the job applicant and obtaining consent of the job applicant.
Otherwise, Varjo will generally not share job applicant data with third parties. However, Varjo may disclose personal data of job applicant to third parties
- when permitted or required by law;
- when our trusted services providers provide services to us on behalf of us and under our instructions (e.g. outsourced recruitment and aptitude tests);
- if we are involved in a merger, acquisition, or sale of all or a portion of our assets; and
- when we believe in good faith that disclosure is necessary to protect our rights, protect the job applicant’s safety or the safety of others, investigate fraud, or respond to a government request.
In addition, job applicant information may be processed by our IT service providers, but only to the extent necessary to provide the services.
Job applicant data may also be transferred outside the European Union and the European Economic Area (“EU/EEA”) to our service providers. In case job applicant data is transferred outside EU/EEA, such transfers are either made to a country that is deemed to provide a sufficient level of privacy protection by the European Commission or transfers are carried out by using appropriate safeguards such as standard data protection clauses adopted or the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework.
- List of our processors and other recipients and more information regarding the safeguards can be provided upon request.
How does Varjo protect data?
Varjo takes the security of job applicant data seriously. Varjo has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by Varjo employees and trusted service providers of Varjo in the proper performance of their duties.
For how long is data kept?
Personal data of job applicants will be retained only for as long as necessary to achieve the purposes defined in this statement. Varjo will keep job applicant personal data on the file approximately twelve (12) months after the recruitment process has ended due to legal requirements. After that personal data of the job applicant will be deleted, unless it is still required by our legal rights or obligations.
Job applicant rights
As a data subject, job applicant has a number of rights under applicable data protection laws. The job applicant can:
- access the personal data processed
- obtain a copy of the personal data on request in a structured, commonly used and machine-readable format insofar as the job applicant self has provided the information to Varjo
- require Varjo to change incorrect or incomplete personal data
- require Varjo to delete or restrict processing personal data, for example where the data is no longer necessary for the purposes of processing. However, please note that certain personal data is strictly necessary in order to achieve the purposes defined in this statement and may also be required to be retained by applicable laws. Thus, you may not delete such personal data
If job applicant believes that Varjo has not complied with applicable data protection laws when processing the job applicant’s personal data, the job applicant can lodge a complaint with a supervisory authority. In Finland, that is the Data Protection Ombudsman.
Varjo may make changes to this Privacy Statement at any time by giving a notice on the website and/or by other applicable means.
Varjo Technologies Oy (registered in Finland, business ID 2773901-6) is the legal entity determining the purposes and means of processing the information gathered and is the data controller of all the data collected from job applicant.
If, at any time, job applicant has questions or concerns about this Privacy Statement, please contact us via email firstname.lastname@example.org.