Privacy Policy

What is GDPR?

The GDPR is the EU’s new general data protection regulation which came into force on 25^th May 2018.  The purpose of the GDPR is for all EU countries to have the same data protection laws, as well as to give citizens more control over how and when their data is used.  The GDPR is an EU regulation which covers all companies that market goods or services to EU citizens, regardless of which country the company operates in.

Privacy Policy

H&P works within recruitment and staffing and has built up its business gaining insights on entrepreneurship, working life, people and what makes them tick.  Within the framework of our business, we process an array of personal data either that you yourself have disclosed or that we have collected elsewhere (i.e. a third party).  Your personal data is handled, for example, in connection with recruitment processes, hiring of consultants or the supply of digital HR services.  Because we care about your privacy and deal with questions surrounding data protection very seriously, we want to describe how H&P handles your personal data through this privacy policy (“The Policy”).

In The Policy we will thus explain which categories of personal data H&P processes, for what purpose we process them and on what legal grounds the processing is based.  We also discuss who is allowed to have access to and process the data, which third parties H&P may share the personal data with, where the personal data is processed, as well as your rights regarding the right to information, rectification and erasure, etc.  We ask you to carefully read The Policy and familiarise yourself with the contents, as it is applied to all processing of personal data within H&P.

H&P processes your personal data within its role as personal data controller and has therefore an obligation to ensure that the processing takes place in accordance with this policy and the current personal data legislation.  As a registrant you always have the right to contact H&P and exercise your rights.

It can be the case, however, that we need to update or change The Policy.  Should this happen, we will inform you accordingly and ask you to take note of the changes that have been made.  You will always find the latest version of The Policy on our website.

We hope that this policy answers your questions regarding our collection, use, disclosure, as well as the protection, of your personal data.  If you have any further questions or concerns, you are welcome to contact us by sending an email to info@hpsearch.se

Personal data and personal data processing

“Personal data” refers to all kinds of information that can be directly or indirectly attributed to a natural person who is alive.  This can therefore be information such as names, email addresses or telephone numbers, but information such as photos or IP-addresses can also be included if the information can be linked to a natural person.

“Personal data processing” refers to any operation, or set of operations, concerning personal data, regardless of whether the operation is automated or not.  Examples of common methods of data processing include collection, registration, organisation, structure, storage, disclosure by transmission, and erasure.​

Contact person with potential/existing customer

An important part of H&P’s core business involves establishing working relationships with clients in order to develop our services, products and systems.  In order to be able to contact you/maintain contact with you as a potential/existing client regarding H&P’s services, products and marketing activities, H&P collects your personal data.  This is collected either via internal networks or from third parties, such as public registers and social media, and is stored in H&P’s system with the intention that H&P will be able to establish a working relationship with you and include you in marketing activities. 

The processing of this personal data is based on H&P’s legitimate interest in being able to establish and maintain working relationships and in being able to develop its services, products and systems.

Your personal data is stored on H&P’s platforms for marketing purposes.  H&P will only make such disclosures that are deemed relevant to your professional role.  For every disclosure you will be given the opportunity to deregister, a so-called ‘opt-out’. 

In those cases where H&P has made contact with you and you decide not to create or explore a further relationship, the personal data in H&P’s business system will be marked with a note not to resume contact.  We will also stop notifying you of market mailings.

H&P will process your data until it is no longer needed to fulfil the above-mentioned purposes, or until you request that you no longer be registered with H&P.  In such cases the personal data will be erased without undue delay. 

The personal data H&P processes for the above-mentioned purposes are:

• First and last name
• Contact information such as e-mail address, telephone number, job title and work address
• Information about previous employer (in case you have been a client before)
• Social security number (only if you are a sole trader)
• Correspondence between you and H&P
• Technical information about how you have interacted with H&P
• IP address and browser settings
• Information on dietary preferences (in connection with lectures, events, etc.)

Applications of interest via the website

In order to be able to contact you as a stakeholder, H&P collects your personal data.  This personal data is collected from you when registering your interest via our website.  The information will be stored in H&P’s marketing tools with the intention of establishing a working relationship with you.

Your personal information is stored on H&P’s platforms for marketing purposes.  H&P will only make such disclosures that are deemed relevant to your professional role.  For every disclosure you will be given the opportunity to deregister, a so-called ‘opt-out’. 

H&P will process your data until it is no longer needed to fulfil the above-mentioned purposes, or until you request that you no longer be registered with H&P.  In such cases the personal data will be erased without undue delay.

The personal data H&P processes for the above-mentioned purposes are:

• First and last name
• Contact information such as e-mail address and telephone number
• Correspondence between you and H&P
• Technical information about how you have interacted with H&P
• IP-address and browser settings

The processing of this personal data is based on the consent you give in connection with your submitting your expression of interest.

Potential candidates

A large part of H&P’s core business consists in finding candidates for recruitment and/or consultant hiring processes, as well as being able to contact and send job offers to them.  The interest in finding candidates and offering them work is important to us because it promotes individuals’ opportunities for career development and mobility in the labour market.  The processing of personal data collected through a search by a third party is in the potential candidate’s interest, as he or she is given the opportunity to be privy to job offers that are tailored to his or her skills.

In order to be able to contact you as a potential candidate regarding relevant career opportunities and professional communication, H&P collects personal data both through internal networks and external searches from third parties, and processes it in H&P’s candidate system. 

The processing of this personal data is based on H&P’s legitimate interest in being able to find you, as a potential candidate, what H&P considers to be relevant recruitment and/or consultant hiring processes, and to be able to contact and relay future career opportunities to you.  The personal data is stored in H&P’s candidate system in order to be able to create a relationship between you and H&P, with the intention that the contract will be transferred to a recruitment and/or consultant hiring process.

If you, when in contact with an employee of ours, state that you are no longer interested in a working relationship with H&P, H&P will discontinue processing your data in its candidate system.

The personal data which H&P processes for the above-mentioned purposes are:

• First and last name
• Contact information such as e-mail address, telephone number, job title and home address
• URLs for a candidate profile with a third party
• Competence-based suitability for the job
• Information posted on social media, e.g. Linked-In, which is deemed relevant and essential to assess your professional qualifications
• Photographs

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Candidates who have agreed to be part of our network by registering on the website/database

In addition to dietary preferences (in connection with lectures, events, etc.), H&P will not actively collect or process sensitive data (such as trade union membership information, political opinions, sexual orientation or religious beliefs), or information that is irrelevant to recruitment and/or consultant hiring purposes.  It is therefore important that you as a candidate do not provide such sensitive personal information or information that is not relevant to the positions for which you are applying.  It is also important that you inform any potential referees that their personal information has been submitted to H&P.

It can be the case that you as a candidate will carry out personality and/or competency tests provided by an external supplier.  Your personal data may be transferred to, and processed by, the supplier for carrying out such tests.

The processing that takes place in H&P’s database in order to be able to carry out recruitment and/or consultant hiring processes can only be undertaken with the support of your consent.  H&P will save your personal information for future career opportunities.  You can send an e-mail to info@hpsearch.se at any time to revoke your consent (read more under “Withdrawal of consent”).  Information that is relevant to a particular recruitment or consultant hiring process, such as interview notes, candidate presentations and information from referees, is stored in our database. 

Transfer of personal data to client

Recruitment processes

The personal data that H&P processes about you as a candidate may be transferred to a client during a recruitment process. With regards to your privacy, H&P only transfers your profile to a client after H&P has first had a discussion with you, during which you have shown interest in the position in question and given your consent to share the information with our client.

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Consultant hiring processes

The personal data that H&P processes about you as a consultant may be transferred to both potential and existing clients during a consultant hiring process.  With regards to your privacy, H&P only transfers your profile to a client after H&P has first had a discussion with you, during which you have shown interest in the position in question and given your consent to share the information with our client.  Test results from the test supplier may be transferred to the client for the assignment in question. 

The personal data which H&P processes for the above-mentioned processes are:

• First and last name
• Contact information such as email address, telephone number, job title and home address
• Information posted on social media, e.g. LinkedIn, which is deemed to be relevant and of significant importance for assessing your professional qualifications
• IP address and browser settings
• URLs
• Gender
• Date of birth
• Competence-based suitability for the role
• Interview notes and candidate presentations
• Test results from testing instruments used in selection and development work
• References provided
• Correspondence between you and us
• Information about how you have interacted with us
• Information about dietary preferences (in connection with lectures, events, etc.)

Candidates who have appeared in our network before

In order to be able to contact and pass on career opportunities to candidates who have been registered in H&P’s candidate database in the past, as well as to be able to maintain a relationship with such candidates, H&P processes the candidates’ personal data.  H&P may have collected your personal information during a previous recruitment process or in a general application.  The personal data is processed in H&P’s candidate database.  H&P’s processing of your personal data is founded on H&P’s legitimate interest in being able to develop and maintain a working relationship with you as an existing candidate and in being able to continue to present relevant job offers.  The information under the section “Candidates who have agreed to be part of our network” above, regarding which categories of personal data we process, transfer of data to customers, etc. also applies to you as a candidate who existed in our system prior to 25^th May 2018.

Referees

In order to be able to carry out well researched recruitment and/or consultant hiring processes, H&P will process your personal data as a referee provided by the candidate.  The processing of the referee’s personal data is based on H&P’s legitimate interest in being able to contact referees provided in order to carry out as thorough and well-founded recruitment and consultant hiring assignments as possible.

The personal data H&P processes for the above-mentioned purposes are:

• First and last name
• Contact information such as e-mail address, telephone number, job title and work address

Seminars and training days

In order to be able to provide seminars and training days, to register the number of participants, print the necessary documentation, and to be able to send out marketing material, H&P has a need to process the participants’ personal data.  The processing of your personal data is based on H&P’s legitimate interest in being able to establish participant lists, etc. and otherwise deliver the seminars and training days for which you have expressed an interest.  Your personal information that has been included within a list of participants may be transferred to external lecturers who hold the training, as well as to hired printing companies.  This is done for preparatory printing purposes, such as the printing of teaching materials, certificates and diplomas. 

The personal data H&P processes for the above-mentioned purposes are:

• First and last name
• Contact information such as e-mail address, telephone number, job title and work address
• Invoicing information
• Notes for training opportunities
• Information on dietary preferences

Processing of social security numbers

H&P will only process your social security number without your consent when it is clearly justified, this usually being to prove identity, carry out background checks or some other notable reason.  This means that social security numbers from the outset will only be processed during background checks or in cases where a client’s business is conducted in the form of a sole trader.  For this reason, you as a candidate should not disclose your social security number in your CV/application/candidate profile.

Direct marketing

You have the right to prevent us from using your personal data in direct marketing.  Direct marketing refers to all types of outreach marketing measures, e.g. via digital mailings, e-mails and text messages.  You have the right to object free of charge to your information being used for such purposes and every mail correspondence from H&P for marketing purposes contains an opportunity to deregister, a so-called opt-out.  If you choose to unsubscribe to our mail correspondence, H&P will make a note of it in its system and cease sending direct marketing material to you.​

The protection of your personal data

H&P has taken a number of security measures to make sure that H&P’s processing of personal data takes place in a secure manner, and to protect the personal data that is processed against illegal access, unauthorised processing and misuse.  For example, access to the systems in which personal data is stored is limited to H&P’s employees and service providers who need to access the data within the ambit of their tasks.  The employees are also informed about the importance of maintaining the security of personal data and internal routines, such as regulating the use of passwords.  H&P also continuously monitors its systems to detect vulnerabilities and to protect your personal data.

Use of personal data assistants

In cases where it is necessary for H&P to be able to offer its services, we will transfer your personal data to companies that assist in the handling of personal data.  These companies may only process the transferred data on behalf of H&P and in accordance with H&P’s express instructions.  H&P only transfers your personal data to such personal data assistants for purposes that are compatible with the reasons H&P have collected the data in the first place.  H&P has entered into written agreements with relevant personal data assistants to ensure that they comply with H&P’s security requirements and restrictions, as well as requirements concerning the international transfer of personal data.

The place for handling personal data

H&P aims to always process your data within the EU/EEA where all H&P’s own IT systems are located.  However, it may occur that your personal data is shared with personal data assistants who are, either themselves or through sub-contractors, established and store information in a country outside the EU/EEA.  In such cases, H&P will take all reasonable legal, organisational and technical measures to ensure that the level of protection is the same as it would be within the EU/EEA.  This will be done either through a decision by the European Commission ensuring that the country in question provides an adequate level of protection, or through the use of appropriate protection measures such as standard contract clauses or approved codes of conduct in H&P’s agreements with such personal data assistants.

Your rights as a registrant

As a registrant, you always have the right to exercise your rights against H&P by contacting H&P at info@hpsearch.se .  The following pages provide a brief description of your rights.

The right of access

If you want to gain a better understanding of which personal data about you we process, you can request access to the data.  The information will be provided in the form of a register extract stating which personal data we process, for what purposes we process them, from where the data was obtained, which third parties the data has been transferred to and how long the data will be stored.  If your request is made by electronic means, the information will be provided in a commonly used electronic form, unless you request otherwise.

The right to rectification

You reserve the right to have inaccurate information about you immediately rectified.  You also reserve the right to have incomplete personal data completed, e.g. by providing a supplementary statement. 

The right to erasure

You reserve the right to request erasure of your personal data that we process about you if:

• The personal data is no longer necessary for the purposes for which it was collected or otherwise processed;
• You revoke your consent for the processing of personal data and there is no other legal basis for the processing;
• You object to the processing based on a balance of interests and your reason for objection outweighs our legitimate interest;
• The personal data is processed unlawfully;
• The personal data must be erased as a result of a legal obligation that we have to fulfil.

In the event that there are legal obligations that prevent us from erasing certain personal data, we may deny your request for erasure.  These obligations exist, e.g. in accounting legislation.  It is also possible that further processing is necessary for us to be able to exercise, defend or establish legal claims.  Should it be the case that our legal obligations prevent us from erasing your personal data, we will instead mark them so that they are no longer used in our systems.  At the end of each year, H&P will also seek your active consent to continue to have access to your personal data.  You can then request that it be erased according to the above conditions. 

In addition to the above rights, you also have the right to request that the processing of your personal data be restricted, and to object to any processing of personal data that is based on a balance of interests.  Should this happen, we must demonstrate compelling justifiable reasons that outweigh your interests, rights and freedoms in order to continue the processing.  In cases where our processing of personal data is based on your consent, you also have the right to request that the data concerning you and which you have provided, be transferred to another person responsible for personal data (so-called data portability).  A prerequisite for data portability, however, is that the transfer is technically possible and that it can take place automatically.

The right to restriction of processing

You reserve the right to request that the processing of your personal data be restricted if any one of the following points applies:

• You contest the accuracy of the personal data for a period of time that gives H&P the opportunity to verify the accuracy of the personal data;
• The processing is unlawful and you object to the data being erased and instead request a restriction of their use;
• H&P no longer needs the personal data for the purposes of the processing, but you need them to be able to establish, exercise or defend legal claims;
• You have objected to the processing of data based on a balance of interests and H&P checks whether the company’s legitimate grounds override your legitimate grounds.

If the processing has been restricted in accordance with this paragraph, such personal data shall, with the exception of storage, only be processed with your consent or for the purpose of establishing, exercising or defending legal claims, or for the protection of third party rights or reasons relating to the protection of an important public interest for the EU or for an EU member state. 

The right to data portability

In cases where H&P’s processing of personal data is based on your consent or fulfilment of an agreement, you have the right to request that the data concerning you, and which you have submitted to H&P, be transferred to another personal data controller.  A prerequisite for this, however, is that the transfer is technically possible and that it can take place automatically.  Such personal data, with the exception of storage, will only be processed for the purpose of establishing, exercising or defending legal claims, or for the protection of third party rights or reasons relating to an important public interest of the EU or an EU member state.

Withdrawal of consent

In cases where H&P’s processing of your data is based on your consent, you always reserve the right to revoke your consent at any time.  A withdrawal does not affect the legality of the processing that took place on the basis of your consent, before it was withdrawn.  If you revoke your consent, H&P will no longer process the personal data given in your consent, unless H&P is legally obliged to process it.  Should it be the case that H&P’s legal obligations prevent H&P from erasing your data, H&P will instead mark them so that they are no longer actively used in H&P’s system.  You can send an email to revoke your consent whenever you like.  H&P will respond to your request promptly.  At the end of each year, H&P will also seek your active consent to continue to have access to your personal data.  You will then also be offered the opportunity to update your information. 

Submission of complaints

The Swedish Data Inspectorate is the authority responsible for monitoring the application of the legislation among companies that process personal data. If you believe that we have processed your personal data incorrectly, you can, in addition to contacting us via info@hpsearch.se, submit a complaint to the Swedish Data Inspectorate.

Use of cookies, tags and pixels

H&P’s website uses cookies, tags and pixels to improve your website search, our services and our website.  A cookie is a text file sent from our web server and stored on your browser or device.  We also use cookies for overall analytical information regarding your use of our services, to save functional settings and to be able to direct relevant marketing to you.  You have the opportunity to change the settings in your browser for the use and scope of cookies.  Examples of such adjustments include blocking all cookies or deleting cookies when you close your browser. 

We hope that we have answered your questions!