The individual’s personal integrity and the security of his or her personal data is important to companies in Inteno Group AB and its subsidiaries (all jointly hereinafter referred to as ”Inteno” or the ”Company”), which is responsible for ensuring that all personal data is processed properly and in accordance with applicable data protection legislation. This Integrity Policy (the “Integrity Policy“) is a consent document and describes how Inteno processes personal data. We therefore ask you to carefully read the Integrity Policy before you share your personal data with us.
2. Scope of applicability of the integrity policy
This Integrity Policy applies to individuals in the capacity of candidates, employees, customers, suppliers and other stakeholders. Different parts may be relevant to you, depending on your relationship with Inteno.
This Integrity Policy governs how Inteno collects and processes personal data for our range of services consisting of sales of CPE and Network products, software licenses and related services (consulting and technical support services) to enterprises (our “Service”). The policy also governs personal data processing for individuals at the parties with which Inteno has a business relationship, such as suppliers and customers and their representatives.
Inteno may occasionally advertise news and press releases on third party websites that are not owned or managed by Inteno. Inteno has not inspected these websites or other websites that contain links to the Inteno website. This Integrity Policy does not apply to any personal data processing that takes place on such websites and Inteno is not responsible for personal data processing on websites that are not part of Inteno’s website. Nor does the Inteno Integrity Policy apply to processing carried out by testing companies.
Inteno may occasionally advertise news and press releases to existing and prospective new customers, suppliers and partners. Such advertisement sole purpose is to generate new business with your company and Inteno is responsible for processing of personal data related to such advertisement.
3. Processing of personal data
Inteno’s personal data processing based on your relationship with Inteno is described below.
For Candidates and Employees
The purposes for which personal data is processed
Personal data is only processed for the purposes and objectives described in this Integrity Policy.
Inteno only processes personal data if such processing is necessary for providing our Service or for the other purposes described below.
Inteno processes job applicants’ and employees’ personal data to enable us to offer you the opportunity to be part of the Company (as candidate and/or employee) and manage our relationship with you as candidate and/or employee.
By accepting this Integrity Policy, you give your consent for Inteno to process your personal data in accordance with this Integrity Policy. If you do not give your consent for your data to be processed, you should not provide us with personal data. Below you will find information on the types of personal data that Inteno processes and how Inteno can obtain/acquire that information.
The personal data that Inteno processes on candidates is based on the details you yourself provide to Inteno via the Inteno website, e-mail and through contact with Inteno personnel to allow Inteno to provide review you as a candidate and potential future employee of Inteno. Inteno will not process your personal data unless you have first given your approval by accepting the Inteno Integrity Policy.
The personal data we may process on you includes data such as your name, address, e-mail address, personal ID number, grades, certificates, training and work experience, photographs, results of tests, information om background checks, results of drug tests, information from referees (such as assessments and health, observations on absence due to illness, for example) and information that is necessary for reviewing you as a candidate and potential future employee of Inteno.
If you agree to be photographed or provide a photograph of yourself without being asked to do so by Inteno, you are giving your consent for Inteno to process any such photograph.
The personal data we will process on you includes contact details for relatives, salary and account details in addition to the data specified in section Candidates.
Inteno may also need to process sensitive personal data such as information on your health. Health data may need to be processed to allow Inteno to comply with its obligations as an employer, for example.
Saving personal data
The length of time for which personal data is saved depends on the type of personal data in question and the purpose for which it is processed.
Inteno has to save some personal data related to you as an employee as this is provided by law, and Inteno consequently has to comply with any such legislation.
Inteno will, as a general rule, save personal data relating to:
information linked to the application and recruitment process (e-mail applications), during the current year for the most recent activities and for two (2) years thereafter;
contract for employment, during current year for the most resent activities and for ten (10) years thereafter;
client and supplier agreements and information on business events such as information on timesheets, participants, assignments, salaries, invoices, declarations, accounts during the term of the agreement and thereafter for ten (10) years; and
control data until Inteno’s pension obligation has ceased.
For Customers or Suppliers
Purposes for which personal data is processed
Personal data is only processed for the purposes and objectives described in this Integrity Policy. If you choose not to provide certain personal details, it may affect the use of the Service or the provision of the Service. Inteno only processes personal data if such processing is necessary for the Service and for services provided by suppliers for Inteno or for other purposes as specified below. Inteno processes personal data on Customers’ and Suppliers’ employees:
to enable you to take advantage of the Service or provide other services for Inteno;
to manage our relationship with you;
to enable Inteno to manage its obligations in relation to you or the individual concerned, deal with cases of alleged discrimination, deal with disputes and complaints; and
to facilitate future business relationships.
By accepting this Integrity Policy, you give your consent for Inteno to process, where applicable, your personal data in accordance with this Integrity Policy.
Inteno can also ask individuals to provide more personal information than is specified herein. Personal information that is provided/processed through a specific approval will also be covered by this Integrity Policy.
Inteno may process contact persons’ personal data. Such data includes their name, address, e-mail address, post, responsibilities and other data necessary for providing and monitoring the Service and for facilitating future business relationships.
Inteno may process contact persons’ and other employees’ personal data. Such personal data includes the information specified in section Customers and other data necessary for providing and monitoring the Service, for ensuring satisfactory supply of services to Inteno and for facilitating future business relationships.
Storage of personal data
The length of time for which personal data is saved depends on the type of personal data in question and the purpose for which it is processed. Inteno does not save personal data for longer than is necessary for the purposes for which it was collected, unless otherwise provided by law.
Inteno will, as a general rule, save personal data contained in:
application and recruitment processes during the current year for the most recent activities and for two (2) years thereafter;
customer and supplier agreements and information on business events such as information on timesheets, participants, assignments, salaries, invoices, declarations and accounts, during the term of the agreement and thereafter for ten (10) years;
Personal data for marketing purposes
The consent given also covers the fact that the information that you supply to Inteno can be used by Inteno and companies in Inteno for marketing and market research purposes in order to provide candidates, employees, customers and suppliers with an enhanced experience and improve and optimise the quality of the Service (for example, by displaying content that may be of interest to you and providing information that is more relevant to you) and generating new business to Inteno.
If you no longer wish to receive marketing, you can contact us and indicate that you do not wish to be contacted for marketing purposes.
Use of the Inteno website and cookies
4. Protection of personal data
Inteno has adopted the appropriate technical and organisational measures to protect personal data from loss, misuse, unauthorised access, disclosure, alteration and destruction. To ensure that personal data is processed in a secure, confidential manner, we use data networks that are protected against hacking by such means as firewalls and password protection according to industry standards. Relevant Inteno employees and suppliers are bound by confidentiality agreements and are obliged to comply with Inteno’s rules for information and IT security, this Integrity Policy and other internal regulations that further govern the processing of personal data.
5. Sharing of personal data between companies in Inteno Nordic
As a general rule, Inteno shares personal data obtained from candidates, customers and suppliers’ personnel with all companies in Inteno to enable us to conducting our business. Employee related personal data is only available to very few individuals – those that need the information to handle administrative aspects of an employment such as paying out salary.
As a general rule, sensitive personal data is not shared between the companies in Inteno. Before sensitive personal data is shared, Inteno always carries out an assessment to ascertain whether it is necessary for the sensitive personal data to be shared for the purpose for which it was collected and whether further consent is required in order for the data to be shared or whether legal support for sharing the personal data exists.
6. Sharing of personal data outside Inteno
Inteno will not sell, disclose or distribute personal data to third parties, except as specified in this Integrity Policy. Within the framework of the Service, personal data may be forwarded to an Inteno customer, supplier, contractor and partner if such is necessary for the performance and supply of the Service. Inteno may occasionally also disclose your personal data to other third parties such as Inteno’s suppliers for business activities such as salary administration or suppliers that manage job searches on our behalf.
Parties to which Inteno may disclose personal data may be located outside the European Economic Area, EEA, which means that personal data may be transferred to countries outside the EEA. If Inteno discloses personal data to Inteno suppliers outside the EEA, we will take steps to ensure that the personal data continues to be protected and we will also take the necessary steps to transfer personal data to countries outside the EEA in a lawful manner.
Furthermore, we may disclose personal data if we are required to do so by law or through a court order or if such disclosure is otherwise necessary to cooperative with a legal investigation
7. Personal Data Controller
Inteno Group AB and its subsidiaries, Id No 559058-0634, Stensätravägen 13, S-127 39 Skärholmen, Sweden, is the personal data controller for processing your personal data and is responsible for ensuring that such processing takes place in accordance with applicable legislation.
8. Inteno as a Personal Data Processor
Inteno is the personal data controller for Inteno personal data, but situations may occur in which Inteno is not the personal data controller, but only a personal data processor for third parties. When Inteno processes personal data as a personal data processor, the data is processed on behalf of a third party and Inteno is then bound by the instructions that Inteno received from the personal data controller. Inteno will always ensure that processing takes place in accordance with applicable legislation and as far as possible in accordance with this Integrity Policy.
9. Your rights
As an individual, you have the right to obtain information on what personal data Inteno processes on you and information on the scope and purpose of such processing by submitting a signed application in writing to Inteno at the above address (under “Personal Data Controller”). As an individual, you also have the right to request at any time that we block, delete or correct your personal information. You have the right at all times to revoke any consent you have given and inform us that you do not wish us to continue to process your personal data.
10. Amendments to this integrity policy
Inteno reserves the right to revise this Integrity Policy from time to time. The date of the most recent amendment is specified at the end of the Integrity Policy. If we carry out any amendments to the Integrity Policy, we will publish those amendments at the website. It is therefore recommended that you read this Integrity Policy regularly in order to note any amendments. If we amend our Integrity Policy so that it clearly differs from what was specified when your consent was obtained, we will notify you of these amendments and, if necessary, ask you to give your consent once again for Inteno to process your personal data.
If you have any questions regarding this Integrity Policy or our use of your personal data, please contact us at firstname.lastname@example.org.
Integrity Policy updated on May 25, 2018.