Pelago Privacy / GDRP Policy - Pelago
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Pelago Privacy/GDPR Policy

Introduction to this policy

 

This Pelago Privacy/GDPR Policy (below “Policy” or “Privacy Policy”) is available at request at christoffer.lindblad@pelago.se and applies to Pelago AB (below “Pelago”), 559098-5874, Västra Trädgårdsgatan 15, 111 53 Stockholm, Sweden.

Our processing of your personal data

You have been referred here because Pelago AB (”Pelago”, ”we” or ”us”), as personal data controller, process personal data about you. We do this because you are an important person for us and our operations. The processing takes place in accordance with applicable regulations, including the general data protection regulation (”GDPR”), and as described further below. If you have questions or queries concerning how we process your personal data or want to have advice on data protection and privacy issues, you are welcome to contact us, see contact details below.

Besides ensuring that our processing of your personal data is correct and transparent in relation to you, we always endeavour to maintain a high level of security in all processing of personal data where we continuously assess and take into account both technical and organisational risks in order to optimally protect your personal data from unauthorised access, use, change and deletion.

Contents

Our processing of your data is described below in four different sections, Section 1 – 4, one or several of which may affect you depending on the relationship you have with us. These Sections are followed by a general description of how and what you can contact us about concerning our processing of your personal data. As an important person to us you may also quickly move between the different groups as our way of conducting business means you can potentially e.g. quickly move from the role as candidate into the role as client or e.g. a referee.

 

1. Candidates and Candidate assessments

1.1 General

Knowing the market of individuals available to match the needs of our clients is at the core of Pelago’s business. This means that it is critical that you are confident in entrusting your personal data to us. We maintain a network of potential candidates by networking and staying in contact with the most relevant individuals we connect with. This means that you may be registered in our systems already before an active selection or assessment is initiated. As you may further read in section 1.2 below, the information we keep about you in this stage is limited.

When you are contacted by us for a specific position, we will collect further information about you which may be relevant for the position in question, as described in section 1.3.

Should you be subject to a structured interview, assessment, or similar situation in which we collect even more information about you, including potentially private information, we will always request your permission first. Read more about our processing under the legal basis consent in section 1.4.

1.2 Pelago network of contact and candidates

Why we process (Purpose)

We process your data in order to broaden our network and perform our services, i.e. to be able to find suitable candidates for our clients.

We store your data as indicated below so that we can contact you if a new need should arise within the retention period.

How we process

We collect, compile and store the public information available on the professional networking website LinkedIn in order to provide suitable candidates to our clients and suitable positions for you, current or future.

What we process

We process such information that you have submitted yourself online and which is relevant to determine your suitability for a position, i.e. your name, contact information, working experience, education etc.

Legal basis – Legitimate interest:

In the processing detailed above we consider and weigh up your interest of privacy in relation to our interest and purpose (as indicated above) in performing the processing. We then balance these interests, considering both positive and negative effects and draw the conclusion that our interest is legitimate.

Collection and distribution:

The data we have about you is primarily collected from public sources which have been populated by you. We may collect data from other public sources or people in our network, should we be made aware of you per recommendation.

We do not share other than public data outside Pelago except to the external systems used to host and organise our data.

Retention period:

We only keep your data for as long as we judge it to be legitimate, taking into account what is indicated above regarding legal basis and purpose. In this case this means that we will save your data for as long as we judge you to be relevant to future positions which Pelago will be tasked to fill. We will, however, update your data at least once every year to ensure that the data is current and correct. Your data will be stored and processed in accordance with that stated in our policy for processing of our candidates’ data, which is provided solely to our employees.

1.3 Pelago executive search

Why we process (Purpose)

During an executive search process we process your data in order to allow Pelago to carry out our services, i.e. to match candidates to positions we have been tasked to fill by our clients.

We store your data as indicated below so that we can contact you if a new need should arise within the retention period.

How we process

We collect, compile, map, aggregate and store the information available on public sources and information submitted by you and compare it to the profile of other candidates and the requirements for the relevant position.

If we believe you could be a suitable candidate for the position, we will share your information with our client.

What we process

We primarily process such information that you have submitted yourself online and which is relevant to determine your suitability for a position, i.e. your name, contact information, resume, open references etc.

We may supplement this information with data from other public sources.

If you are recommended to us from someone in our network, we will gather limited information from that person.

Legal basis – Legitimate interest:

In the processing detailed above we take into account and weigh up your interest of privacy in relation to our interest and purpose (as indicated above) in performing the processing. We then balance these interests, taking into account both positive and negative effects and draw the conclusion that our interest is legitimate.

Collection and distribution:

The data we have about you is primarily collected from you or public sources populated by you. We may collect data from other public sources, people in our network and your former colleagues.

If we believe you could be relevant for the position, we may share your data with the client. Your data may be hosted and organised by external systems.

Retention period:

We only keep your data for as long as we judge to be legitimate, taking into account what is indicated above regarding legal basis and purpose, in this case, until the position in question has been filled. We may ask for your consent if you would like us to save your data longer. Your data will be stored and processed in accordance with that stated in our policy for processing of our candidates’ data, which is provided solely to our employees.

1.4 Pelago interviews and assessments

When you become relevant for an interview and assessment, we will not process data without your separate consent which will be collected prior to the first interview.

Why we process (Purpose)

The data we process with such a consent is processed in order to allow Pelago to carry out its services, i.e. to ensure the most suitable candidate for a specific position.

How we process

We collect, compile, map and store information submitted by you through interviews or other assessments and information provided at pervious stages of the process and compare this information to the requirements of the relevant position.

We may check the information verbally with referees, both anonymous and those named by you, and also supplement the information with whatever data we receive from these referees. Our processing of data related to referees is described below in section 2.

If we believe you could be a suitable candidate for the position, we will share your information with our client.

What we process

We primarily process such information that you have submitted yourself through interviews or assessments, including sensitive information regarding your personality traits, your health and results from psychological and intellectual tests.

We may supplement this information with data which is relevant to determine your suitability for the position in question from other public sources, our network and references.

Legal basis – Legitimate interest:

The processing of data described above will always be subject to your written, informed and freely given consent.

Collection and distribution:

The data will be collected from you as well as other people in our network and referees, as well as public sources.

If we believe you could be relevant for the position, we may share your data with the client. Your data may be hosted and organised by external systems.

Retention period:

We only keep your data for as long as you have consented to. You shall always be entitled to withdraw your consent at which point we will delete all data collected with the legal basis of consent.

2. Referee

References with regards to verification of previous experiences and professional relationships can be crucial when assessing the suitability of a candidate. We may therefore reach out to you as a referee, either because your name was provided by the candidate, or because we assessed that your current or past relationship with the candidate was of importance to our assessment. We will not disclose your name or information which can be related to you to the candidate, however, we cannot guarantee that the candidate cannot deduce your identity based on other information available to the candidate and not to us.

Why we process (Purpose)

We process your data in order to provide our services, i.e. to verify and collect information which will help us determine the most suitable candidate for a specific position.

How we process

We collect, compile and store the information available on public sources as well as information submitted by you in order to verify your relationship to the candidate and to contact you.

What we process

We primarily process such information that you have submitted yourself online and information submitted by you and the candidate i.e. your name, contact information, work experience, education etc.

We may supplement this data by collecting information from people in our network.

Legal basis – Legitimate interest:

In the processing detailed above we take into account and weigh up your interest of privacy in relation to our interest and purpose (as indicated above) in performing the processing. We then balance these interests, taking into account both positive and negative effects and draw the conclusion that our interest is legitimate.

Collection and distribution:

The data we have about you is primarily collected from you, public sources populated by you or the candidate. We may collect data from other public sources or people in our network.

We may share information you provide with regards to the candidate, as long as it does not reveal your identity. Your identity can only be disclosed if you consent to such disclosure. However, we can never guarantee that the candidate cannot deduce your identity when combined with other information available to the candidate.

Retention period:

We only keep your data for as long as we judge it to be legitimate, taking into account what is indicated above regarding legal basis and purpose, in this case, until the position in question has been filled or the candidate is not of any relevance to us anymore. Your data will be stored and processed in accordance with that stated in our policy for processing of our candidates’ data, which is provided solely to our employees.

3. Job applicants

As an applicant to a position at Pelago, we process your data in the same we process candidates in our services to our clients and customers, as further described in sections 1.3 and 1.4.

Why we process (Purpose)

We process your data in order to manage your application and to be able to evaluate, compare and match with the needs we have.

We store your data as indicated below so that we can contact you if a new need should arise within the retention period.

How we process

We compile the information you submitted and compare with other candidates as well as with our needs. We check the information verbally with references you have provided, and also supplement the information with whatever data that we receive from these references.

What we process

We primarily process such information that you submitted to us in your application, i.e. your resumé and your personal letter.

We supplement this information with data from the references you have provided in order to obtain as useful picture as possible of you as a candidate.

Legal basis – Legitimate interest:

In the processing detailed above we take into account and weigh up your interest in privacy in relation to our interest and purpose (as indicated above) in performing the processing. We then balance these interests, taking into account both positive and negative effects and draw the conclusion that our interest is legitimate.

Collection and distribution:

The data we have about you is primarily collected from you. In connection with the application we may collect data from references you give to us in your application. We do not share your application unless we have specifically requested to.

Retention period:

We only keep your data for as long as we judge to be legitimate, taking into account what is indicated above regarding legal basis and purpose, in this case, two years from the time of your application (unless you request otherwise, which we of course will respect). If you are subsequently employed by us, the data in your application will be stored and processed in accordance with that stated in our policy for processing of employees’ personal data, which is provided solely to our employees.

4. Clients’ and client representatives

Why we process (Purpose)

We process the data in order to perform mandatory conflict of interest checks and (when required) money laundering checks, to execute and administer the assignment, to safeguard your interests, and for accounting and invoicing purposes.

The data can also be used for business and organisational development, market analysis, statistics and risk management.

How we process

We collect the data, check it against our registers and store it in our systems for case and invoice management.

We also compile the data in our systems for client management and client care.

What we process

The data we process about you is the data you provide to us that is of relevance for the issue in question, your role in the organisation you represent and in the respective matter. Where appropriate, we may need your personal code/social security number to correctly identify you.

Legal basis:

Legal obligation: The Book-keeping Act requires us to process data in relation to accounting and invoicing.

 

Legitimate interest: Besides the processing that is necessary to meet our statutory obligations, some processing also takes place by virtue of a legitimate interest. In that respect, we take into account and balance your interest in privacy in relation to our interest and purposes (as indicated above) in performing the processing. We then balance these interests, taking into account both positive and negative effects and draw the conclusion that our interest is legitimate.

Collection and potential distribution:

The data we have about you is primarily collected directly from you. In connection with acceptance of new clients, we may need to collect data from public registers such as www.allabolag.se, UC AB or equivalent in order to supplement and confirm the data we have received from you about the activity you represent, and also about you as a person and other representatives for the organisation.

We will not provide personal data to third parties other than in cases where (i) it has been specifically agreed between us and you, or (ii) when it is otherwise necessary within the framework of a particular assignment.

Retention period:

We store your data only for as long as we judge it to be legitimate, taking into account what is stated above regarding legal basis and purpose; in this case for as long as you remain a client or a client representative. Data which is processed for invoicing and other book-keeping purposes are stored for a period of 7 years in order to comply with the Book-keeping Act. When you are no longer a client or client representative, we may choose to process and store some of your personal data for the purpose of keeping you as a part of our network (see section 5 below).

5. Networking, marketing and exchange of knowledge

Why we process (Purpose)

We process your data in order to maintain our contacts and network to keep our knowledge and information about you up-to-date, and also to market our services and maintain the relationship with our suppliers.

We also process for the purpose of complying with accounting requirements in relation to suppliers and in connection with representation activities.

How we process

We collect the data and compile it, including on the basis of the type of services in which we consider you to be interested, and your participation in training and seminars with us. For mailings and invitations, we use external suppliers for technical functionality within the framework of the purposes stated, such as dispatch of mails and processing of registrations for seminars, for example.

What we process

We primarily process your contact details, your role in your organisation and information about which type of services we feel is of the most interest and relevance for you.

To a limited extent we can process data about any leisure interests such as golf or similar that we organise, however, we will provide further information in connection with these events.

Legal basis:

Legitimate interest: In the processing detailed above we take into account and weigh up your interest in privacy in relation to our interest and purposes (as indicated above) in performing the processing. We then balance these interests, taking into account both positive and negative effects and draw the conclusion that our interest is legitimate.

 

Legal obligation: The Book-keeping Act places requirements on us in relation to accounting and invoicing.

Collection and distribution:

The data we have about you is primarily collected from you. We share the data solely with such suppliers that are needed for execution of the processing, and within the framework of the purposes indicated above. For example:

  • Payment solutions (card companies, banks and other payment service providers).
  • Marketing (via advertising agencies, online/media agencies and distribution linked thereto, as well as social media).
  • IT services (companies which handle necessary operations, technical support and maintenance of our IT solutions).

Retention period:

We only keep your data for as long as we judge to be legitimate, taking into account what is stated above regarding legal basis and purpose, in this case, two years from the last time we heard from you.

6. Your rights

In accordance with applicable data protection legislation, you are entitled at any time to request access to the personal data that is processed about you. You are also entitled to have incorrect personal data about you amended, to request deletion of your personal data or place restrictions of our processing of your personal data, exercise your right to data portability and object to processing of your personal data.

If processing is based on consent, you are entitled at any time to withdraw your consent to processing.
If you wish to exercise any of your rights, please contact us via the contact details below.

You are also entitled at any time to submit complaints to applicable supervisory authority, Datainspektionen, if you consider that your personal data is not being processed in accordance with applicable data protection legislation.

7. Contact details – Data Privacy Officer at Pelago

Christoffer Lindblad
Pelago AB
Tändstickspalatset
Västra Trädgårdsgatan 15
111 53 Stockholm
Sweden

 

+46 (0)8 10 73 65
info@pelago.se

8. Cookies

A cookie is a small text file that is stored on your computer and contains information.

There are two types of cookies:
The first type is permanent and can make it easier for you as a visitor to use the website, such as by remembering your login.

The other type is a session cookie. These session cookies are removed when you close your browser. No personal information such as your e-mail or name is saved.

We use both types of cookies at Pelago.se.

If you don’t want cookies

You can turn off cookies in your browser settings. Some browsers also let you ask them to give you a warning each time a web page tries to save a cookie on your computer.

Google Analytics

Pelago.se uses Google Analytics, an analysis tool for websites, to get an idea how visitors use the website. Neither we nor Google can identify you. All data that is sent to Google Analytics is anonymized by removing the last octet in your IP-address before it is sent to Google.

Opt-out

There is an add-on to your web browser if you do not wish to be tracked. You can read more about it here: https://tools.google.com/dlpage/gaoptout?