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Effective on February 1, 2021

This Privacy Policy sets out the terms of personal data processing according to EU’s General Data Protection Regulation as well as Finnish Data Protection Act and Act on the Protection of Privacy in Working Life.

Content

1. Controller of the filing system

2. Definitions

3. To what purposes we process your data and based on which grounds?

4. What types of information we may collect about you?

5. Which sources we gather your personal data from?

6. To whom we may transfer and assign your personal data?

7. Is your data transferred to countries outside the European Union?

8. How long do we process your data?

9. What are our principles for securing your personal data?

10. How can you exercise the different types of rights you have?

10.1 Right of access to your personal data.

10.2 Right to rectification.

10.3 Right to erasure ('right to be forgotten').

10.4 Right to restriction of processing.

10.5 Right to object.

10.6 Right to data portability.

11. Do we make decisions affecting you based on automated means?

12. Do we process your personal data in order to profile you?

13. How can you exercise your right to lodge a complaint to the supervisory authority?

14. Which law do we apply for processing personal data?

15. How can we update this Privacy Policy?

1. Controller of the filing system

Controller of this filing system is the Finnish company Avant Advisors Ltd (business registration number: 3183730-5), hereinafter referred to as ”Avant”.

Avant’s contact details in HR related privacy matters are:

Avant Advisors Ltd / privacy

Erottajankatu 15-17, 00130 Helsinki

Tel: +358 40 587 1429

Please do not hesitate to contact us if you have any questions, concerns or ideas related to Avant’s personal data procedures.

2. Definitions

In the following the most essential terms used in this privacy policy are explained:

'Applicant' means any person who has sent a specific or general job application to any of positions promoted by Avant on behalf of its corporate clients or on behalf of Avant itself, and any person who is a candidate for such position based on Avant’s suggestion.

'Personal data' means any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly.

'Consent' of the data subject means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

'Profiling' means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

3. To what purposes we process your data and based on which grounds?

Avant may process your personal data directly necessary for your recruitment process and possible employment relationship which is connected with managing the rights and obligations of the parties to the relationship or with the benefits possibly provided by Avant or its corporate client for you, or which arises from the special nature of the work concerned.

Avant may also process your personal data for communication and marketing purposes, for example to inform you of possible new job openings and to invite you to Avant’s and/or its corporate clients’ events.

Processing of your personal data is based on the following grounds of the EU’s General Data Protection Regulation (one or more grounds may apply simultaneously):

Processing is necessary in order to take steps at your request prior to entering into a contract.
Processing is necessary for the purposes of the legitimate interests pursued by Avant and/or its corporate clients.
You have given consent to the processing of your personal data.

The legitimate interests of Avant or third party referred to in point b) above may include amongst others the following matters:

maintaining candidate pool for possible new recruitment needs
business development

In addition to the above, Avant uses your data if we think it’s necessary for security purposes or to investigate possible fraud or other violations of our agreements or this Privacy Policy.

4. What types of information we may collect about you?

Content of Avant’s filing system may include the following types of data and changes made to these data types:

Personal information

last name, all first names, previous last name
home address and e-mail address
phone number(s)
date of birth
national identification code
gender
nationality
photo and video clips
languages
medical and drug test data (where applicable)
use of your rights related to your personal data (such as right to access your personal data)

2. Employment related information

work history and interests in the future
education, trainings and certificates you have completed
knowledge, skills and expertise (e.g. language and ICT skills)
cover letter and CV
salary and benefit data and requests
examples of previous work or presentations (e.g. portfolio of creative works)
personality and aptitude assessment results (e.g. via recruitment consultants)
other information during recruitment interviews and reference checking
credit rating (where applicable)
extract from criminal records (where applicable)
work permit (where applicable)
social media content (with consent)

5. Which sources we gather your personal data from?

Avant gathers personal data directly from you, for example from:

website forms
physical forms
telephone conversations during which you provide personal data to Avant
e-mail correspondence in which you provide personal data to Avant
personal discussions
job application videos
public social media profiles

Avant may gather personal data from third parties based on your consent, for example from:

persons you have indicated as a reference
companies offering recruitment consultancy and personality and aptitude assessment tests to Avant

Avant may gather personal data from third parties without your consent when:

we collect personal data within our candidate research work in order to add a person to our candidate pool and/or to add a person to our corporate client’s shortlist
a corporate client proposes a candidate for an open position and shares his/her personal data
an authority discloses information to the employer to enable the latter to fulfil a statutory duty or
the employer acquires personal credit data or information from the criminal record in order to establish the employee's reliability

Avant may obtain and update the personal data in its filing system from officials and companies offering personal data services.

Avant gathers personal data from the technical device you use in your communication with Avant.

6. To whom we may transfer and assign your personal data?

Avant does not sell, lease or otherwise disclose your personal data to third parties outside of Avant unless otherwise stated below.

Avant may share your personal data with authorized third parties that perform services for Avant for the purposes described in this Privacy Policy within the limits of the applicable legislation. This may include for example providing services such as software services (for example TalentAdore), managing and analyzing personal data and conducting research.

Because Avant takes the responsibility to safeguard your personal data seriously, Avant does not allow those companies to use the data for any purpose other than to perform those services, and Avant requires them to protect your personal data in a way consistent with this Privacy Policy.

Avant may share your personal data with the corporate clients who engage Avant to assist with their recruiting processes. Avant takes minimization and transparency principle into consideration in connection with any data sharing.

Avant may share your personal data as part of any merger, acquisition, sale of company assets or transition of service to another provider. This also applies in the unlikely event of an insolvency, bankruptcy or receivership in which your personal data would be transferred to another entity as a result of such a proceeding.

Avant may share your personal data based on a valid order from a court or other official body with sufficient authority.

7. Is your data transferred to countries outside the European Union?

Avant’s services may be provided using resources and servers located in various countries around the world. Avant’s primary aim is to use resources located within the EU.

Avant may sometimes transfer your personal data outside the country where you use our services, including to countries outside the EU and EEA that do not have laws providing specific protection for personal data or that have different legal rules on data protection. In such cases Avant ensures that a legal basis for such a transfer exists and that adequate protection for your personal data is provided as required by applicable law, for example, by using standard agreements approved by relevant authorities (where necessary) and by requiring the use of other appropriate technical and organizational information security measures.

8.How long do we process your data?

Avant may process your data in its job applicant system at maximum until the end of the second year following your application year (for example: application 1 May 2021 => 31 December 2023).

Based on your consent Avant may process your personal data for as long as the consent describes.

Avant may process your personal data based on legal requirements for as long as the applicable legislation allows.

9. What are our principles for securing your personal data?

Avant has established electronic and administrative safeguards designed to make the information processed secure.

Only appointed personnel of Avant and of organizations operating by Avant’s assignment or on behalf of Avant are entitled to use the personal data filing system. All persons processing the system have a personal right of use granted by Avant or its co-operation partner. Different levels of access have been created based on the data a person needs according to his/her job description. The system is protected with a fire-wall which protects it from contacts outside of Avant.

Manually processed documents containing personal data are protected against unauthorized access.

All personnel of Avant and its subcontractors are obliged to keep the information of the personal data which they obtain in their work confidential.

10. How can you exercise the different types of rights you have?

All rights can be exercised by contacting Avant’s privacy team by using the contact details issued at section 1 above. The team will then give further instructions on how to exercise a specific right. Where Avant has reasonable doubts concerning the identity of the person making the request, Avant may request the provision of additional information necessary to confirm your identity.

Avant will provide information on action taken on a request to you within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests.

10.1 Right of access to your personal data

You have the right to obtain from Avant confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, receive information about your personal data.

10.2 Right to rectification

You have the right to obtain from Avant without undue delay the rectification of inaccurate personal data concerning you.

10.3 Right to erasure ('right to be forgotten')

You have the right to obtain from Avant the erasure of personal data concerning you without undue delay where one of the following grounds applies:

your personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
you withdraw consent on which the processing is based and where there is no other legal ground for the processing;
you object to the processing and there are no overriding legitimate grounds for the processing;
your personal data have been unlawfully processed;
your personal data have to be erased for compliance with a legal obligation in Union or member state law to which Avant is subject;
the personal data have been collected in relation to the offer of information society services.

However, you do not have the right or erasure if the processing is necessary:

for exercising the right of freedom of expression and information;
for compliance with a legal obligation which requires processing by Union or member state law to which Avant is subject; or
for the establishment, exercise or defence of legal claims.

10.4 Right to restriction of processing

You have the right to obtain from Avant restriction of processing where one of the following applies:

the accuracy of the personal data is contested by you, for a period enabling Avant to verify the accuracy of the personal data;
the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
Avant no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;
you have objected to processing pending the verification whether the legitimate grounds of Avant override those of you.

10.5 Right to object

You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on legitimate interests pursued by Avant, including profiling. Avant shall no longer process the personal data unless Avant demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms for the establishment, exercise or defence of legal claims.

Where personal data are processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.

Please be aware that you cannot opt out of receiving service messages from Avant, including but not limited to security and legal notices.

10.6Right to data portability

You have the right to receive the personal data concerning you, which you have provided to Avant, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller where:

the processing is based on consent or on a contract; and

(b) the processing is carried out by automated means.

11. Do we make decisions affecting you based on automated means?

Avant does not make decisions based solely on automated processing which produces legal effects concerning you or similarly significantly affect you.

12. Do we process your personal data in order to profile you?

Avant does not currently carry out job applicant profiling in a way meant in the GDPR.

13. How can you exercise your right to lodge a complaint to the supervisory authority?

In case you suspect a breach of data protection legislation, please contact Avant’s privacy team first (contact information in section 1). In case the matter is not solved amicably between you and Avant, you may contact the Finnish Data Protection Authority. Contact information of the competent authority can be found here.

14.Which law do we apply for processing personal data?

The processing of personal data in Avant’s filing system is governed by the European Union’s applicable data protection legislation as well as national laws of Finland.

15. How can we update this Privacy Policy?

Avant may modify this Privacy Policy, and if we make material changes to it, we will provide notice on our website or by other means, to provide you the opportunity to review the changes as they become effective and binding.