Data Protection Notice for the Medikumppani Oy Direct Marketing Register
Date: 3 August 2021
1. DATA CONTROLLER
Business ID: 1595673-4
Hämeenkatu 30 C 32
20700 Turku, Finland
2. REGISTER CONTACT PERSON
3. REGISTER NAME
Medikumppani Oy Direct Marketing Register
4. PURPOSE AND BASIS OF THE REGISTER
Medikumppani Oy processes personal data in connection with email and SMS contacts, job offers, recruitment matters, advertising, service development, profiling (described in more detail in section 12), opinion or market research, or other similar communication by address, and other client management processes.
The processing of personal data is based on Medikumppani Oy’s legitimate interest (direct marketing), the client relationship between Medikumppani Oy and the data subject or the data subject’s consent.
Medikumppani Oy does not outsource personal data processing to companies in the same group.
5. REGISTER’S DATA CONTENT AND PERSONAL DATA GROUPS
The groups of persons whose data may be processed comprise clients using Medikumppani Oy’s services, job applicants, participants in Medikumppani Oy’s events, people who have contacted Medikumppani Oy, or those who have consented to direct marketing.
The data related to the mentioned groups will be processed only for the register’s necessary intended use. The personal data provided by a job applicant or other person who has signed up for or participated in a Medikumppani Oy event, or who has otherwise provided information to Medikumppani Oy, may contain the following information: name, age or date of birth, personal identity number, sex, mother tongue, telephone number, address, and other contact details such as the data subject’s email address. Medikumppani Oy may also process data related to training, values, and professional skills, as well as start and end dates of employment, desired forms of contact, permission for or objection to direct marketing, as well as other identifying information related to direct marketing, based on consent or client relationship, as well as information pertaining to changes in the mentioned information.
6. STORAGE PERIOD OF PERSONAL DATA
Medikumppani Oy stores personal data in the Direct Marketing Register unless the data subject has specifically objected to direct marketing (right to object). In such a case, however, the information pertaining to the objection to direct marketing will be kept in the register; other information will be erased from the register.
7. REGULAR SOURCES OF DATA
Medikumppani Oy collects personal data in connection with various events (trade fairs, student events, etc), through Medikumppani Oy’s digital service channels or otherwise directly from the data subjects themselves. Medikumppani Oy may also collect and update personal data from registers maintained by trade unions and student organisations, as well as other similar registers.
8. COOKIES AND OTHER SIMILAR TECHNOLOGIES
A cookie is a small text file that the browser stores on the data subject’s device. Cookies contain a unique identifier that can be used to identify users.
Cookies and the information obtained from them may also be used for targeted communication, advertising and creating content in the online service. In practice, after you have visited our website, we may advertise jobs you have previously viewed and similar jobs on our website or on our partners’ websites. Further, cookies and the information obtained from them may be used to develop our website and to measure and optimize marketing.
Medikumppani Oy’s marketing partners’ website cookies enable targeting and marketing surveys on the websites of other companies collaborating in marketing, i.e. in the advertising network.
Clients can restrict the use of their information to target Facebook ads here: https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen.
To see the Google Analytics privacy and security policies, go here: https://www.google.fi/analytics/learn/privacy.html.
To improve accessibility to services, Medikumppani Oy may conduct studies that store information about, for example, clicks made by an IP address on a single website. An individual cannot be identified by an IP address alone.
9. PERSONAL DATA RECIPIENTS AND REGULAR TRANSFERS
Personal data will be disclosed to the client company where the job applicant may be commissioned to work. Data are also disclosed to authorities for legal reasons, such as in the investigation and prevention of misconduct.
Personal data may be transferred or disclosed to parties involved in the production, development or maintenance of Medikumppani Oy’s services and communications, or to a party operating on behalf of Medikumppani Oy, for example in a server environment (CRM system vendor). In this case, however, personal data is in fact used only by Medikumppani Oy’s employees (e.g. when compiling newsletters). See section 10 also.
10. DATA TRANSFER OUTSIDE THE EUROPEAN UNION (EU) OR THE EUROPEAN ECONOMIC AREA (EEA)
As a rule, personal data are not transferred outside the EU or EEA, but it may be possible, for example, when Medikumppani Oy uses subcontractors to process the data. Personal data are not disclosed to parties other than those involved in the production, development and maintenance of the services and communications of the contractual partners providing Medikumppani Oy’s services, except on the basis of an agreement or other consent. Transfers are always made in accordance with data protection legislation and the limitations thereof.
Data may be transferred to third countries in exceptional cases relating to specific situations, such as where the transfer is necessary for the preparation, presentation, or defence of a legal claim.
If we use non-EU services, we will only use Privacy Shield certified service providers who are committed to complying with the EU General Data Protection Regulation by signing a Privacy Shield agreement (including Google Analytics).
11. REGISTER PROTECTION PRINCIPLES
Medikumppani Oy has taken appropriate technical and organisational measures to protect personal data from accidental or unlawful loss, disclosure, misuse, alteration, destruction, or unauthorised access.
Medikumppani Oy stores personal data in printed and digital form. Any printed material is kept in a locked room, which can only be accessed by persons who have been specifically authorised to do so. Digital material can be accessed only with a personal username and password of an authorised employee or partner. There are different levels of access, and each user is given sufficient, but limited access, depending on the task. Unauthorised access is also prevented with firewalls and other technical protection. All register users are bound by confidentiality. Backup copies of the register are made regularly, and the data can be restored if necessary.
Medikumppani Oy may engage in profiling as part of the personal data processing in the direct marketing register. The purpose of profiling is to target job offers and direct marketing communication better.
13. DATA SUBJECTS’ RIGHT TO OBJECT TO PERSONAL DATA PROCESSING AND DIRECT MARKETING (RIGHT TO OBJECT)
Data subjects have the right to object to Medikumppani Oy’s profiling and other processing measures on grounds related to their particular situation insofar as the data processing is based on the client relationship with Medikumppani Oy.
Data subjects may present their objection as stated in section 14 of this notice, whereby the data subject will no longer receive direct marketing communication or job offers. Data subjects may consent to or object to Medikumppani Oy’s direct marketing separately for each communication channel.
14. DATA SUBJECTS’ OTHER PERSONAL DATA PROCESSING RIGHTS
14.1. Right of access
Apart from the exceptions laid down in the Personal Data Act, data subjects are entitled to access and check their personal data stored in the Medikumppani Oy Direct Marketing Register. They must make their request for access in accordance with section 15 of this notice. The right of access may be denied due to legislative reasons. As a rule, right of access is free of charge.
14.2. Rectifying and erasing data or restricting processing
If a data subject notices or is informed about an error in the register, (s)he must, without undue delay and on his/her own initiative, rectify, erase, or supplement the incorrect information.
Data subjects should make a request for rectification to Medikumppani Oy according to section 15 of this notice.
Data subjects have the right to restrict the data controller from processing personal data, for example when waiting for a response to a request for rectification or erasure of their data.
14.3. Data subjects’ right to data portability and right to lodge a complaint with the supervisory authority
Insofar as the data subject has personally provided Medikumppani Oy with personal data, which are processed in the direct marketing register with the data subject’s consent, the data subject has the right to access such information, primarily in electronic format, and the right to transfer this information to another register.
If the data controller has not complied with the applicable data protection regulations, the data subject has the right to lodge a complaint with the competent supervisory authority.
14.5. Other rights
If personal data is processed based on the data subject’s consent, the data subject has the right to withdraw his or her consent by notifying Medikumppani Oy in accordance with section 15 of this notice.
Data subjects should contact Medikumppani Oy in all personal data processing matters and in exercising their personal data rights by post at the following address: Medikumppani Oy / Henkilörekisterit, Hämeenkatu 30 C 32, 20700 Turku, Finland. If necessary, Medikumppani Oy may ask the data subject to provide further details in writing about a request. Medikumppani Oy may request verification of the data subject’s identity, as needed, before other measures are taken.