Description of file

1. Controller

MPS Lifeworks Ltd

address:

Business ID: 2887179-9

Domicile: Helsinki, Finland

mps@mps.fi

2. Matters concerning the data file

Our customer service will respond to questions and feedback concerning the data file within two working days.

Data Protection Officer: Marko Viitikko

privacy@mps.fi

3. Name of the data file

The consumer customer data file of MPS Lifeworks Ltd.

4. Purpose of processing personal data

The main purpose of the personal data is to form a personal data file of the consumer customers of MPS Lifeworks Ltd (hereinafter referred to as Lifeworks). The data file contains personal data concerning the natural persons who have registered to use the services of Lifeworks. The data file may also contain group-level customership data from MPS Enterprises Ltd. In addition to basic customer data, data concerning the customer’s contracts, use of services, areas of service use as well as data required for service production and direction are also collected. The data file may also contain data concerning the areas of interest communicated by the customer. The data is processed on the basis of the customer relationship, the carrying out of a contract or a legitimate interest. We process data ourselves and we also outsource some of the personal data processing to our subcontractors.

Personal data is processed for the following purposes:

- The provision, development and maintenance of services chosen by the customer.

- The management of the customership, such as

Identification of the customer at different branchesSales and marketingCommunicationsCustomer supportThe management of the customer relationship as well as the development of the operations of Lifeworks and the marketing of services.

- The operational requirements of Lifeworks’ business operations, such as

Carrying out the service processInvoicingReportingProviding information to guide the operations of Lifeworks

- The planning and development of Lifeworks’ business operations

- Communication about the services of Lifeworks, sales promotion and market research

- The data is also processed for the purpose of carrying out the recruitment and executive search assignments received by Lifeworks or its group of companies.

5. Data content of the file

The Lifeworks consumer customer data file contains the following data (the required information has been bolded):

- Names

- Addresses

- Language used

- Gender

- Date of birth

- Telephone numbers

- E-mail address

- Direct marketing choices made by the customer

- Customer number

- Other data potentially required by the services

Providing the bolded personal data is a prerequisite for establishing a contractual relationship and/or a customer relationship with us. We cannot provide the service without the necessary personal data. The applicant can update their information with the user credentials they are given.

6. Regular data sources of the file

- The data subject themselves

- With the consent of the data subject, data can be collected from the bank used for the identification of the data subject or another third party.

Personal data can also be collected and updated for the purposes described in this description of file by using publicly available sources or data received from authorities or other third parties within the limits set by the applicable legislation. This kind of data updating is carried out either manually or by automated means.

7. Disclosure of data

Personal data is disclosed

- To partners who have an electronic business operations contract with Lifeworks for the purpose of service-related communications and marketing or for providing the services chosen by the customer.

- To the following companies in Lifeworks’ group of companies: MPS Career Ltd, MPS Executive Search Ltd, MPS Enterprises Ltd, MPS Prewise Ltd.

- To those customers of Lifeworks or the companies stated above who have given a recruitment or executive search assignment to the company in question.

- Lifeworks may also transfer or disclose personal data according to what is allowed or required by current legislation.

8. The transfer of data to third countries or international organisations

Due to the technical implementation of data processing, some of the data may be physically located on subcontractors’ servers or hardware, where they are processed by means of technical access. 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.

9. Principles of file protection and the storage of data

The system can only be accessed by the employees of MPS Enterprises Ltd Group. All employees have personal usernames and passwords for the system. The persons who process data are bound by a valid non-disclosure agreement. The data is collected in databases that are protected with firewalls, passwords and other technical measures. The databases and their backup copies are kept in a locked space, and the data can only be accessed by specific previously appointed persons.

Personal data will be stored as long as is necessary for the purposes of the personal data.

We regularly assess the necessity of storing the data, taking into account the applicable legislation. In addition to this, we have adopted reasonable measures to ensure that personal data concerning the data subject that is incompatible with the purposes of processing or out of date or inaccurate is not stored in the data file. We will rectify or erase such data without delay.

10. Rights of the data subject

As the data subject, you can edit and update your data in the service using your own credentials.

As the data subject, you have the right to access the data concerning you that has been stored in the personal data file and to request the rectification or erasure of inaccurate data. You also have the right to withdraw your consent. Please submit the requests concerning the matter by email to the contact person stated in point 2.

As the data subject, you have a right under the General Data Protection Regulation to object to or to restrict the processing of your personal data as well as to lodge a complaint about the processing of your personal data to a supervisory authority.

You also have a right, on grounds related to your particular situation, to object to the processing of your personal data when the processing is based on the customer relationship between us. In situations like these, please submit your objection by email to the contact person stated in point 2. When making the request, you are required to specify the particular situation on the basis of which you object to the processing. We may refuse to comply with the request on statutory grounds.

As the data subject, you also have the right to object to processing that is related to direct marketing at any time and free of charge.

11. 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.