Privacy Notice to individuals with whom Deloitte has no direct contact
Version: 1 March 2019
This privacy notice addresses Deloitte’s Clients’ and vendors’ employees, customers and other relations with whom Deloitte has no individual contact.
In connection with Deloitte’s provision of services to our clients, Deloitte may as the data controller collect and process personal data of our client’s employees, customers and other relations. Such collection and processing takes place in accordance with the principles in EU’s General Data Protection Regulation (GDPR) and the Finnish Data Protection Act (1050/2018).
Please read this text carefully in order to understand how we process your personal data.
- Which data do we collect about you and for which purposes?
- From whom do we collect your personal data?
- The legal basis for the collection and processing of your personal data
- Who do we share your personal data with and why?
- Who do we transfer your personal data to?
- How long do we store your data?
- Your rights
- Revision of our privacy notice
1. Which data do we collect about you and for which purposes?
We may collect and process your personal data for the purposes of providing services to our clients and for the purposes of compliance with applicable legal or regulatory requirements and/or internal policies; documentation requirements; handling requests, complaints and claims from third parties; handling inspections and queries by supervisory authorities; external audit and legal advice, such as:
- Your name; age; date of birth; national identification number; gender; phone number, home address; country of residence; visa; family circumstances (e.g. civil status and contact details on dependents and close relatives); photo; email address; title; employment and education details (e.g. previous employment and education details); salary and pension information; leaves of absence; bank account details; tax-related information and investments.
We may also collect the following types of special categories of personal data for the purposes specified above:
- racial or ethnic origin,
- trade union membership,
- data concerning health
2. From whom do we collect your personal data?
We collect your personal data from our clients and our vendors as well as from public authorities; other Deloitte entities, and other third party business relations, depending on the character of the engagement.
3. The legal basis for the collection and processing of your personal data
We collect and process your data based on one or more of the following articles in GDPR:
- Art. 6 paragraph 1 (c) compliance with legal obligation to which our client or Deloitte is subject
- Art. 6 paragraph 1 (f) Deloitte’s legitimate interests
- Art. 9 paragraph 2 (f) establishment, exercise or defence of legal claims
The legitimate interests pursued by Deloitte include the following purposes: Effective delivery of services to our clients and from our vendors with the purposes specified in section 1. These processes are necessary for the effective operation of our business and require collection and processing of your personal data.
4. Who do we share your personal data with and why?
In connection with one or more purposes outlined above, your personal data may be disclosed to and shared with the following recipients: Our client; public authorities; our professional advisors (e.g. auditor and legal advisors); service providers; IT-providers including cloud services; insurance and pension companies (if part of our services to our client) and other Deloitte entities.
5. Who do we transfer your personal data to?
Transfer of personal data to data processors
We may transfer your personal data to other Deloitte entities. We may also transfer your data to IT providers, including cloud service providers, or to external service providers, who process and/or store the personal data on our behalf.
Transfer of personal data to recipients in countries outside the EU/EEA
We may transfer your personal data to recipients located in countries outside the EU/EEA for the purposes listed in section 1. In such case, the legal basis for the international transfer is either EU’s Model Clause Agreement, the US Privacy Shield Certification, or Deloitte’s Binding Corporate Rules, when applicable.
6. How long do we store your data?
We store your personal data for as long as necessary to fulfil the purposes above.
7. Your rights
Subject to the conditions set out in the applicable data protection legislation, you have the following rights:
- The right to request access to your personal data
- The right to rectification of your personal data
- The right to erasure of your personal data
- The right to restriction of processing of your personal data
- The right to data portability
- The right to objection to the processing of your personal data
Please note that these rights are not absolute, as they should be balanced against legal requirements and Deloitte’s legitimate interests.
You also have the right to file a complaint with the competent supervisory authority: Tietosuojavaltuutetun toimisto (Office of the Data Protection Ombudsman).
Ratapihantie 9, 6. krs
Telephone: 02956 66700
Please contact us at firstname.lastname@example.org if you have any questions in regards to the protection of your personal data, or if you wish to exercise your legal rights.
00180 Helsinki, Finland
9. Revision of our privacy notice
We keep our privacy notice under regular review and thus the privacy notice may be subject to changes. The date of the latest revision of the privacy notice can be found at the top of the page.