Ogunsen Group's Privacy Policy

This Privacy Policy applies to candidates, clients, supplier/vendors and other external parties and stakeholders.

Valid as of September 9, 2024

Introduction

Your personal integrity and the security of your personal data is very important to Ogunsen AB and its subsidiaries (hereinafter referred to as “Ogunsen”, “we”, “us”) who are responsible for ensuring that all personal data is processed and maintained correctly and in accordance with applicable data protection legislation.

This Privacy Policy describes Ogunsen's processing of all personal data. We ask you to carefully read this Privacy Policy before you share any personal data with us.

Personal data controller and contact information

The following companies within the Ogunsen Group can serve as the personal data controller (“controller”) for the processing of your personal data:

Ogunsen AB, org.nr 556443-2929
W Executive Search Sweden AB, org.no 556850-1331
SJR in Sweden AB, org.nr 556652-3980

The companies have a joint data protection officer and you only need to use one communication channel should you have any questions regarding Ogunsen's processing of personal data. If you have any questions, please contact our data protection officer Petra Förnell at dataskydd@ogunsen.se.

Scope

This Privacy Policy addresses the processing of the personal data for which Ogunsen is the controller, i.e., in those instances where Ogunsen has a specific purpose and means for processing. The Privacy Policy regulates how Ogunsen collects and processes personal data for the range of services we offer, which include temporary employment, recruitment and other associated business activities (“the Service”). The Policy also regulates the management of personal data for other associated parties, such as references and contact persons at clients and suppliers.

Candidates

What personal data we process in our candidate database and how it is collected

When you join Ogunsen's candidate network, either by applying for a position/assignment that we mediate or by submitting a spontaneous application, you will provide information about yourself that we will store in our candidate database.

If you apply for a position with us, the following personal data will be collected and stored in our candidate database: first name, last name, email address, phone number, LinkedIn profile link, details on why you are suitable for the role, how you came into contact with us, and your CV.

If you submit a spontaneous application for future jobs, the following personal data will be collected and stored in our candidate database: first name, last name, email address, phone number, any comments from you, LinkedIn profile link, details on how you came into contact with us, which city/region you want to work in, the type of position you are looking for, when you are available for assignments, areas that match your profile, role/level that matches your profile, and your CV.

Information about you may also be registered in our candidate database by Ogunsen employees at your request, for example, after a phone call.

We collect and process personal data that you provide:

in connection with applying for a position/assignment we mediate,
during the recruitment process, such as during an interview,
when you have submitted a spontaneous application,
while you are part of our candidate network, e.g., information about career aspirations, skills, industries you want to work in, etc.

How we use your personal data

Purpose of processing

When you have applied for a position that we mediate

We process your personal data to assess your skills and suitability for the current assignment and to be able to contact you to obtain more information about your experience and skillset. Your information will also be searchable for us so that we may match you with other assignments we mediate.

If you do not want us to match you with assignments other than the one you applied for, you can request to have your data deleted after the application process. You can send your request to raderamindata@sjr.se (applies to candidates in SJR's network) or to raderamindata@wesgroup.se (applies to candidates in Wes' network).

When you have registered a spontaneous application

We process your personal data to be able to match you with the positions we mediate and to communicate with you about current assignments, career aspirations, and your skills.

Other processing

We may also share your profile with clients who may be interested in your skills.

We may also use your personal data to ensure that our services and IT systems meet our candidates' and clients' needs over time.

Legal basis for the processing

Necessary to fulfill our contractual obligations to you. Necessary for our legitimate interest in ensuring that the services and our systems meet the needs of candidates and our clients over time.

Processing of additional personal data during assignments/processes

When we provide services to you, we may process additional personal data about you in our assignments and processes. Personal data that may come from a source other than yourself.

Purpose of the processing

Obtain additional information from references.
Conduct personality tests and in-depth interviews.
If you are a final candidate in a process, a credit check may be obtained if there is a reason to make a financial risk assessment concerning you.
If you are a final candidate in a process, background checks may be conducted to assess your suitability for a position that requires this suitability assessment.

Legal basis for the processing

Necessary for our legitimate interest in ensuring that the candidate is suitable for the position or assignment.

Processing of personal identification numbers

We avoid processing personal identification numbers as much as possible. However, in some cases, it is justified, mainly because we need secure identification, such as during background checks and credit reports (UC).

In the event of employment with Ogunsen

If you are employed by Ogunsen, for example as a consultant, you will be informed of the additional processing of personal data that will occur during and in connection with your employment.

Who we share your personal data with

We may share your personal data with other companies within the Ogunsen Group and our suppliers who provide services to us, such as suppliers of the operation and support of our IT systems. If the supplier is considered a data processor for Ogunsen, Ogunsen remains responsible for the processing of your personal data that the supplier performs on behalf of Ogunsen, and the supplier may not use the personal data for purposes other than those we specify. Sharing of personal data within the Ogunsen Group or to subcontractors occurs in order to fulfill the agreement between us, i.e., to be able to provide the agreed services to you.

When we share personal data as described above, personal data may be transferred to companies both within and outside the EU/EEA. All such transfers are based on applicable law, and if the processing is done outside the EU/EEA, it will be subject to appropriate safeguards, such as the EU Commission's standard contractual clauses for such transfers.

Your personal data will also be shared with Ogunsen’s client(s) when necessary to perform our services for you, i.e., to find an employment or consulting assignment with a client. If we share your personal data with our client, the client becomes independently responsible for its processing of your personal data after receiving it from us. In consideration of your privacy, Ogunsen only transfers your personal data to a client after we have had a dialogue with you in which you have shown interest in the assignment in question.

We also share your personal data with suppliers who are independently responsible for personal data, such as suppliers of background checks. When your personal data is shared with a supplier who is independently responsible for personal data, the privacy policy and data handling of that organization apply.

Furthermore, we may disclose personal data if we are required to do so under applicable law, court rulings, or if such disclosure is otherwise necessary to participate in a legal investigation.

How long we store your personal data

You can notify us at any time that you no longer wish to be part of our candidate network. You can do this by sending an email to raderamindata@sjr.se (applies to candidates in SJR’s network) or raderamindata@wesgroup.se (applies to candidates in Wes’ network). In that case, we will delete all the information we have about you in our candidate database, and you will no longer be searchable.

Please note that there are exceptions to complete deletion: if you have applied for a job or consulting assignment through us at Ogunsen, we will retain your data for as long as necessary to manage the application and selection process and the assignment with the client. We also need to retain your application documents for 24 months after the end of the consulting or recruitment process, in reference to the Anti-Discrimination Legislation. After 24 months, your data will be deleted.

References

To be able to conduct well-substantiated recruitment and consultant staffing processes, Ogunsen will process personal data about those persons who act as a reference. We use the digital service Refapp in our reference process. We process your name, phone number, email, IP-address, and other personal data that may be relevant for the reference you are providing for one of our candidates. Your profile picture from Facebook or LinkedIn is obtained if you choose one of those methods for verification. Your name may be shared with our client.

This processing is necessary for Ogunsen's legitimate interest to ensure that the candidate is appropriate for the position or the assignment.nt staffing processes that are as well-substantiated as possible.

Your personal data may be stored for 2 years after the concerned position is appointed.

Contact person at the client

Maintaining business relationships with clients is an integral part of Ogunsen's business activities. Ogunsen only processes personal data of the client contacts that are necessary to maintain and follow up our services as well as to enable future business relationships, e.g., name, title and contact information. In order to be able to enter into and manage agreements with our clients, Ogunsen, as a personal data controller, processes personal data belonging to representatives of the client. This processing is based on the company’s legitimate interest to conclude and fulfill the contract with the client.

As a general rule, we store client data for the purposes stated above as long as the client relationship exists and up to 12 months thereafter. We may also store this information for a longer period for specific purposes, such as accounting purposes. As a general rule, Ogunsen will store personal data included in client contracts as well as information concerning business events during the contractual period and 10 years thereafter.

Your personal data may be used for marketing purposes. In the event you no longer wish to receive marketing material you may contact us and indicate that you no longer wish to be contacted for marketing purposes.

Contact person at potential clients

Establishing business relationships with new clients is a part of Ogunsen's core business. For the purpose of being able to contact you as a representative for a potential client to offer our services, Ogunsen collects personal data about you, e.g., name, title, email, phone number, and previous employer (if you are a former client). The data, which we collect via our website, internal network, company websites, public registers and social media, is stored in our CRM system, with the objective of establishing a business relationship with the company you represent.

The processing of your personal data is based on Ogunsen's legitimate interest to be able to establish business relationships and develop our services.

Ogunsen will process your personal data until it is no longer necessary to fulfill the purposes above or until such time where you request its removal from our CRM system. If a business relationship has not developed within two years of Ogunsen's initial contact and there are no ongoing discussions, your personal data will be deleted.

Your contact information may also be used for marketing purposes, for example in connection with mailings and other communication. In such cases where you may no longer wish to receive marketing information you can contact us to inform us of this.

Contact person at suppliers/vendors

Ogunsen only processes personal data, such as name, title and contact information, with suppliers/vendors if necessary for the contractual relationship. This processing is based on the company’s legitimate interest to conclude and fulfill the contract with the supplier/vendor.

As a general rule, we store personal data as long as the contractual relationship exists. We may also store this information for a longer period for specific purposes, such as accounting purposes. As a general rule, Ogunsen will store personal data included in supplier/vendor contracts as well as information concerning business events during the contractual period and 10 years thereafter.

Use of e-mail

Ogunsen uses e-mail to facilitate communication and effectively communicate with our candidates, references, clients, suppliers/vendors and other external parties. The processing of personal data in e-mail is authorized and takes place through consent, contract, or legitimate interest.

We recommend that you do not send us sensitive personal data or integrity-related sensitive information via e-mail. Our e-mail account is purged periodically in accordance with our guidelines for e-mail. Personal data that is included in e-mail may be transferred to other registers and systems within Ogunsen.

Protection of personal data

Ogunsen has undertaken appropriate technical and organizational measures to protect personal data against loss, abuse, unauthorized access, disclosure, alteration and destruction.

Ogunsen's employees and suppliers are bound by a confidentiality agreements and are obliged to comply with Ogunsen's rules for data protection, information and IT security, this Integrity Policy and other internal directives that further regulate the processing of personal data.

Ogunsen as personal data processor

There may be situations where Ogunsen, in the delivery of certain services, is not the personal data controller, but is only a personal data processor for an Ogunsen client. This may apply to the Second Opinion and Team Development services, for example.

When Ogunsen processes personal data as a personal data processor, this occurs on behalf of the personal data controller and Ogunsen is then bound by the instructions Ogunsen has received from the personal data controller. In such situations, Ogunsen is unable to guarantee that the processing will occur in accordance with this Privacy Policy; however, Ogunsen will ensure at all times that the processing is conducted in accordance with current legislation and in accordance with this Privacy Policy where possible.

Your rights

It is our obligation to only process personal data that is correct, relevant and necessary in view of our legitimate purposes, and that you have the right to verify that this has occurred.

You have certain rights in accordance with the General Data Protection Regulation with regard to your personal data.

Right to withdraw consent – You have the right to withdraw your consent submitted for the processing of personal data. However, a withdrawal of consent does not affect the legality of the processing that occurred prior to the withdrawal of your consent.
Right of access – You have the right to receive information concerning our processing of your personal data. Such information is provided through this Integrity Policy. You also have the right to receive a copy of the personal data undergoing processing, i.e., an extract from the register.
Right to rectification – You have the right to request that inaccurate data about yourself be rectified. You also have the right to supplement any incomplete data by providing the information.
Right to deletion – Under certain circumstances you have the right to request the deletion of your personal data. This is referred to as the “right to be forgotten”. However, the right to erasure is subject to conditions and a request can be dismissed without taking action.
Right to limitation of processing – In certain cases, you have the right to demand that the processing of your personal data be limited. However, the right to limitation of processing is subject to conditions and a request can be dismissed without taking action.
Right to data portability – You have the right to receive the personal data you have provided to us (or request a transfer of the information directly from us to a new controller if this is technically possible) in a structure, commonly used and machine-readable format.
Right to object – You have the right to object to the processing of your personal data when the personal data is processed on the basis of our legitimate interests if you do not believe that SJR has a legitimate interest in the processing of the personal data. The right to object also applies to the processing of personal data for direct marketing purposes.

Read more about your rights here: https://www.imy.se/en/individuals/data-protection/.

Should you want to exercise any of these rights or have questions about this, please contact our data protection officer at dataskydd@ogunsen.se.

You also have the right to lodge a complaint with IMY (the Swedish Authority for Data Protection) at any time if you believe that Ogunsen has processed your personal data in violation of current data protection legislation.

Changes to this Privacy Policy

Ogunsen reserves the right to revise this Privacy Policy from time to time. The date of the most recent change is stated at the beginning of the Privacy Policy. Changes to the Privacy Policy will be published on the website. We recommend that you review this Privacy Policy regularly so that you are up-to-date on any changes to the Policy.