GDPR - Integrity policy

Last updated: 30 August 2023

At KeyMan, we work to ensure that you as a consultant/client feel secure when sharing your personal data with us, and we therefore prioritize always protecting your privacy. To achieve this, we always strive to protect your personal data in the best possible way and to always work in accordance with applicable data protection laws and regulations. When you as a consultant/client become part of KeyMan’s network by creating an account with us or applying for an assignment, we want you to always know how, when and why we process your data. We also want you to always be aware of the rights you have as a member of our network. As a rule, KeyMan does not process your personal data unless you have given us your explicit consent to do so.

In our Privacy Policy you can read more about:

· Which personal data we process

· For which purposes we process your personal data

· Who can gain access to your personal data

· How long we store your personal data

· Your rights as a data subject

Who is the data controller for us?

KeyMan AB is the data controller for the processing of your personal data. KeyMan AB is registered with the Swedish Companies Registration Office (Bolagsverket) with corporate identity number 556527-0153 and address: Söder Mälarstrand, berth 16, 118 25 Stockholm.

If you as a consultant/client have questions or comments regarding our Privacy Policy, want to know how your personal data is handled by KeyMan, or want to exercise your rights as a data subject, you are welcome to contact KeyMan. We have appointed a Data Protection Officer so that you can get answers to such questions. You can reach our Data Protection Officer at the email address: info@keyman.se.

Which personal data do we process at KeyMan:

What is personal data? Personal data is information that can be used to identify you as an individual, directly or indirectly.

Personal data that you provide to us: When you join KeyMan’s network, you will provide certain information about yourself to us. This is regarded as personal data that you have provided to us.

This information includes for example

details such as name, email address, telephone number, date of birth, current employment and/or title. This naturally also includes the application documents that you choose to send to us, such as proposals, your CV, cover letters or certificates. We only process your personal data for the purpose specified in the consent that you provide in connection with registration. In some cases, you as a consultant/client may provide so-called sensitive personal data to us, for example personal identity number, ethnic origin, sexual orientation, political opinions, religious beliefs or trade union membership. As a principle, we recommend that you do not provide this type of particularly privacy-sensitive personal data. However, if you still choose to do so, we will only process it in accordance with your explicit consent. This type of data is of course processed with particular care in order to protect your privacy as far as possible.

Personal data that we collect:

Sometimes KeyMan also processes personal data that we have collected from you or from a third party, for example if, at the time of registration, you have chosen to retrieve your personal data from your LinkedIn profile. If you choose to do this, KeyMan gains access to the personal data that you yourself have chosen to provide on your LinkedIn profile. KeyMan does not obtain any deeper access to your LinkedIn profile. If you proceed in a selection process, KeyMan may process information about you that your referees provide to us. It is also possible that KeyMan may process the results of personality, aptitude and skills tests that you have completed in connection with a selection process.

For which purposes do we process your personal data?

Your competence profile: We process your personal data in order to manage your competence profile as a consultant/client and thereby be able to match you to available assignments. The legal basis for our processing of your personal data is your consent, which you provide when you become part of our network. If you choose not to give your consent to this processing, we unfortunately have no possibility to store your data or match your profile to available assignments.

References and test results:

If we have collected information about you in connection with taking references, that is from a third party, this information is processed on the legal basis of legitimate interest. KeyMan also follows a reference routine which means that we do not store such information longer than necessary. If you complete a personality, aptitude or skills test in connection with a selection process with KeyMan, we will process the results of these. This processing, and any supplementation of your competence profile, is carried out on the basis of your explicit consent as the legal basis. Who can gain access to your personal data? As a general rule, your personal data is mainly processed by KeyMan as data controller. However, we may need to share your information as described below. If you are part of a selection process, KeyMan may share your personal data with our customer, that is, the party that has engaged KeyMan.

We may share your information with internal and external IT suppliers. Other suppliers that KeyMan chooses to engage may also gain access to your information, but only to the extent necessary to fulfill their obligations to KeyMan. Your personal data may also be shared with other companies within Werkey AB, the group of which KeyMan is a part, for internal administrative purposes, for example where, by sharing the data, we can provide a better match to available assignments for you as a consultant/client.

How long does KeyMan store your personal data?

In order to fulfill our obligations towards you, KeyMan will store your personal data for three years from the time you provide your consent, or until you choose to withdraw your consent. After three years, KeyMan will ask you to provide new consent and thereby continue to be part of our network.

Note that KeyMan may need to store information about you for longer than three years to the extent that we are obliged to do so under laws, regulations or decisions by public authorities.

Your rights as a data subject in KeyMan’s network: As a data subject, you have certain rights regarding the processing of your personal data. If you want to exercise these rights or have questions about them, please contact the data controller or our Data Protection Officer.

Withdraw consent:

You have the right to withdraw the consent you have given for the processing of personal data. However, this does not affect the lawfulness of the processing that took place before your consent was withdrawn.

Right of access:

You have the right to receive confirmation as to whether your personal data is being processed and information about how your personal data is processed. You also have the right to obtain a copy of the personal data that is being processed.

Right to rectification:

You have the right to have inaccurate personal data corrected. You also have the right to complete incomplete data by providing additional information.

Right to erasure:

You have, under certain conditions, the right to request the erasure of your personal data.

This applies when:

· The data is no longer needed for the purpose for which it was processed

· You withdraw your consent, and there is no other legal basis for the processing

· You object to the processing and there are no overriding legitimate grounds for continued processing

· The personal data has been processed without a legal basis

A legal obligation requires erasure and KeyMan is subject to such an obligation.

KeyMan will erase your personal data at your request, provided that KeyMan is not required to retain your personal data under applicable laws, regulations or decisions by public authorities.

Right to restriction of processing:

Under certain conditions, you have the right to request a restriction of KeyMan’s processing of your personal data. This applies for example if you contest the accuracy of the data and KeyMan therefore needs to verify it.

Right to data portability:

Under certain conditions, you have the right to receive the personal data that you have provided to us and that concerns you. In such cases, the data shall be provided in a structured, commonly used and machine-readable format. You have the right to transfer this personal data to another data controller if the processing is based on your consent or is carried out by automated means. If technically feasible, you have the right to ask KeyMan to transfer the personal data directly from us to another data controller.

Right to lodge a complaint:

You have the right to lodge a complaint with a competent supervisory authority. In Sweden, the competent supervisory authority is the Swedish Authority for Privacy Protection (Integritetsskyddsmyndigheten).

Changes to KeyMan’s Privacy Policy: KeyMan reserves the right to make changes to the terms set out in our policy above. Material changes to the terms will be communicated digitally and the latest version will be published on www.keyman.se.