Last updated 24.5.2018
Hanken & SSE Executive Education Ab
(hereafter ”we” or ”Hanken & SSE”)
2 Contact point for register matters
3 Name of register
4 What is the legal basis for and purpose of the processing of personal data?
The basis for processing personal data is the performance of a contract and the legitimate interest of the company based on customer relationship and service provision.
The purpose of the processing of personal data is:
- delivery, management and development of our executive education programs and other consulting services,
- career and development counselling,
- analyzing and profiling of participants,
- feedback, surveys and other information collection and processing,
- requests for referrals and future speaking opportunities,
- organizing events and alumni activities,
- collection of statistics,
- management of customer relations,
- fulfilment of contractual obligations and other undertakings of Hanken & SSE,
- electronic and other direct marketing.
5 What data do we process?
We process the following personal data of the participant or other data subject in connection with the participant register:
- basic information of the data subject such as name*, date of birth, citizenship, country of residence, gender, mother tongue, photograph;
- contact information of the data subject such as email address*, phone number, home address;
- information regarding the customer company and its contact persons, such as business ID and names and contact information of the contact persons;
- program participation application information such as current employer, job title, duties of work, international experience, degrees or other professional studies, language skills, possible referrers, extra-curricular activities, goals and aims for the program as well as reasons for applying, information about where heard of the program;
- information regarding the executive education programs the person has taken part in such as program name, program’s date and duration, content of the program, assignments, project work, thesis, videos and other other materials produced in the program, certificates and diplomas awarded, MBA scores;
- event participation details and possible information regarding the event, such as allergy and diet data (which is collected based on the consent of the participant);
- information regarding the customership and contract, such as information of past and existing contracts and orders, other transaction information;
- possible direct marketing prohibitions and consents;
- other possible information collected based on the consent of the data subject.
Providing the information marked with an asterisk is a prerequisite for our contractual relationship and/or customer relationship. We cannor deliver the product and/or service without the necessary information.
6 From where do we receive information?
We receive data primarily from the data subject him-/herself and/or his/her employer.
For the purposes described in this privacy notice, personal data may also be collected and updated from publicly available sources and based on information received from authorities or other third parties within the limits of the applicable laws and regulations. Data updating of this kind is performed manually or by automated means.
7 To whom do we disclose data and do we transfer data outside of EU or EEA?
We disclose information to the following parties: Hanken and Stockholm School of Economics, statistical and other authorities as required.
We use subcontractors that process personal data on behalf of and for us (data transfer). We have outsourced the IT management and other education information systems to external service providers, on whose servers the data is stored. The server is protected and managed by the external service provider. We also transfer data to our program speakers, accommodation providers and other event partners.
We have ensured your privacy with our subcontractors by entering into the necessary data processing agreements. We cannot name all subcontractors and have thus listed the types of subcontractors.
We may transfer personal data outside of EU/EEA, including to the United States of America. We have taken care of suitable safeguards for the transfer, and use the EU Commission standard contractual clauses or another transfer mechanism approved by the privacy legislation.
8 How do we protect the data and how long do we store them?
Only those of our employees, who on behalf of their work are entitled to process participant data, are entitled to use systems containing personal data. Each user has a personal username and password to the system. The information is collected into databases that are protected by firewalls, passwords and other technical measures. The databases and the backup copies of them are in locked premises and can be accessed only by certain pre-designated persons.
We store the personal data for as long as is necessary considering the purpose of the processing. For personal data used for participant purposes, this retention period is until the claim and reclamation period related to our services has elapsed, or as long as we need to provide the customer with program participation information or certificates or authorities with program participation statistics. This period is by default five (5) years from the end of the program. Personal data used for marketing purposes is deleted or updated when it is discovered to be outdated or the data subject is deemed unresponsive to the marketing.
We regularly assess the need for data retention in light of the applicable legislation. In addition, we take reasonable measures to ensure that the personal data in the register is not incompatible, obsolete or inaccurate considering the purpose of the processing. We rectify or delete such information without delay.
9 What are your rights as a data subject?
As a data subject you have a right to inspect the personal data concerning yourself, which is stored in the register, and a right to require rectification or erasure of the data, provided that the request has a legal basis. You also have a right to withdraw or change your consent.
As a data subject, you have a right, according to EU’s General Data Protection Regulation (applied from 25.5.2018) to object to processing or request restricting the processing and lodge a complaint with a supervisory authority responsible for processing personal data.
For specific personal reasons, you also have the right to object to profiling and other processing operations, when the processing of your data is based on our legitimate interest. In connection with your request, you will need to identify the specific situation, based on which you object to the processing. We can refuse the request of objection only on legal grounds.
As a data subject you have the right to object to the processing of your personal data for direct marketing, including profiling for such purposes.
10 Who can you be in contact with?
All contacts and requests concerning this privacy notice must be submitted in writing or in person to the email address mentioned in section two (2).
11 Changes in the Privacy Notice
Should we make amendments to this privacy notice we will place the amended statement on our website or in another appropriate channel, with an indication of the amendment date. If the amendments are significant, we may also inform you about this by other means, for example by sending an email or placing a bulletin on our homepage. We recommend that you regularly visit out webpage and review this privacy notice to ensure you are aware of any amendments made.