Privacy notice for the Recruitments and Assessments Common Data File

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Privacy Policy

Updated 15.11.2024

1 Controller

In general, “MPS” is a joint controller together with its customer in relation to recruitment services (incl. executive searches) as well as personality and aptitude assessments. The parties have agreed on their responsibilities by means of an agreement in accordance with Article 26 of the Data Protection Regulation. Candidates participating in our recruitment services or personality assessments are entitled to exercise their data protection rights in relation both MPS and the recruiting organization /their employer.

Depending on the nature of the assignment between MPS and its customer, MPS may in certain limited situations act on behalf of the customer as a personal data processor (e.g., this may be the case if a consultant of MPS assists in the customer’s own interview processes). In such cases, MPS directs any possible questions and requests regarding personal data processing to the customer.

MPS Enterprises Ltd
Business ID: 0201148-3
Keilaranta 17 C, 02150 Espoo
+358 (0)20 7469 400
privacy@mps.fi

2 Contact for the register and data protection officer

Please contact us at privacy@mps.fi.

3 Name of the register

MPS’s and customer’s joint register for recruitment services and personality and aptitude assessments.

4 Purpose and legal basis of processing and retention of personal data

The purpose of processing the personal data contained in the register is to perform recruitment services (incl. executive searches) and carry out personality and aptitude assessments commissioned by the customers of MPS.

In recruitment services, the processing of personal data is based on an agreement, and in personality and aptitude assessments, the consent of the participant. In the initial phase of an executive search, the candidate data is processed on the basis of a legitimate interest. Executive search companies consider that, due to the nature of their business operations, they have a legitimate interest to process personal data based on the meaningful and appropriate relationship between candidates and executive search companies. The use of a legitimate interest has been assessed using a balancing test.

MPS stores the recruitment and assessment information for two years after the creation of a candidate profile, submitting an application, receiving the executive search information or the conclusion of a personality or aptitude assessment. The retention period is based on the statute of limitations. After the retention period, the data will be deleted or anonymised for research purposes. Data subjects have the option to prolong the retention period of their data with their consent (e.g., with profiles candidates have created in MPS’s electronic portals).

MPS monitors the functionality of their assessment methods and the success of their assessments by conducting follow-up studies and developing their tools. When used for methodological development and research purposes, data are treated anonymously so that an individual respondent cannot be identified.

The applicant's information may be used in other recruitments within the MPS client company where the position the applicant originally applied for is located for a period of six months from the submission of the application. If the applicant wishes to also make their information available to searches commissioned by other customers of MPS, the information is added to MPS’s applicant data register. Personal data processing in connection to MPS applicant register is described in the Privacy Notice for Career Services. Without this permission, the data will not be used for other purposes.

The information of the candidates selected through recruitment or evaluation are transferred to the data register of the customer of MPS.

5 Personal data contained in the register

The data subjects are persons participating in recruitment and personality or aptitude assessments commissioned by a customer of MPS. The data stored varies according to the service. The register may contain personal data as per the following groupings:

  • contact information (name, telephone number, e-mail, address)
  • other basic personal data, such as date of birth and gender, current position and employer
  • photo
  • other information related to employment history and educational background
  • information and wishes related to employment and career development
  • documentation saved or supplied by the data subject, such as CVs and applications
  • data generated in personality tests and other evaluation methods, as well as assessment reports
  • recorded answers to questions in video interviews
  • information concerning the status and progress of the recruitment process, such as scheduled interviews and communication between the data subject and MPS

The data subject can create a profile in MPS’s electronic portals where he/she can fill out tests related to personality or aptitude assessments, and where the different phases of the recruitment process are managed. In such a case, MPS will process the data provided by the person when registering to the portal and creating their candidate profile.

6 Data sources

The data in the register is obtained from the data subject (e.g., when the data subject submits information through MPS’s portal) or another joint controller (customer). In executive searches, candidates may be sought using various public sources. These include public websites as well as databases and services protected with access rights that contain data on candidates, companies and industries.

7 Transfer and disclosure of data

As joint controllers, MPS and the customer transfer information to each other for the purposes of carrying out the recruitment or assessment in accordance with the service agreement. When necessary, MPS will transfer contact details (name, e-mail) to suppliers of personality and aptitude tests potentially used in connection with recruitment. As subcontractors of MPS, the suppliers act as processors of the personal data.

In addition, MPS uses IT service providers who are responsible for hosting and maintenance of the data systems used for recruitment processes and assessments. These service providers are also MPS’s subcontractors and personal data processors.

The data is not disclosed to outsiders or used for other purposes without the consent of the data subject unless the disclosure of data is based on statutory obligations or government regulations.

The processing of personal data mainly takes place within the European Economic Area. Some of our partners may process data outside the EU. All of our service providers are committed to complying with the requirements of the EU General Data Protection Regulation.

8 Principles for data security

Personal data is kept confidential. Only the employees who need to process personal data for their work duties have access to the system where the personal data is stored. Each user has their own username and password for the system.

The data is collected in data systems that are protected with firewalls, passwords and other technical measures. The data systems and their backup copies are kept in a locked space, and the data can only be accessed by specific, previously appointed persons.

9 Right of access and erasure

The data subject has a statutory right to access the data concerning them that has been stored in the personal data file, erase or rectify the data and restrict its processing. The data will be deleted as requested unless the law requires for it to be stored.

The request for access (incl. the request for erasure or rectification) must be made using the data file access request form or submitted in writing and with a signature to the address of the controller provided above.

10 Other rights

The data subject has the right to withdraw their consent at any time or object to the processing of their data (agreement, legitimate interest). Each data subject has the right to issue a complaint to the supervisory authorities on any defective processing of personal data.

11 Profiling and automatic decision-making

The service does not use automatic decision-making.

12 Modifications to this description of file

We are continuously improving and developing our services and websites, which means that the descriptions of file may occasionally be modified. We will publish the updated description of file on our website and record the date it was updated on it. Please read the description of file every now and then to receive up-to-date information about potential changes.