Whistleblowing Channel Privacy Notice
This privacy notice describes what personal data are saved in the whistleblowing channel data file, for what purposes the data are used, how the data are protected, and where the data subjects can get more information with regard to their personal data.
- LocalTapiola General Mutual Insurance Company
- LocalTapiola Mutual Life Insurance Company
- LocalTapiola Asset Management Ltd
- Seligson & Co Fund Management Company Plc
- LocalTapiola Real Estate Asset Management Ltd
- LocalTapiola Alternative Investment Funds Ltd
- LocalTapiola Services Ltd
- LocalTapiola regional companies (19 companies)*
- LocalTapiola Finance Ltd.
- Persons submitting the reports
- Persons concerned by the reports
- Other persons included in the report
- The standard data of the person submitting the report, if the report was not submitted anonymously, such as:
- name
- telephone number
- email address
- The identification data of the persons concerned by the report, such as:
- name
- title
- managerial position
- The identification data of the other persons included in the report, such as:
- name of witness
- Other personal data given in the report in free format
- Other personal data obtained in course of processing and examining the report and the abuse.
- limitation and management of access rights
- registration of personal data processing operations
- training of and provision of instructions to personnel
- various encryption and protection techniques
- monitoring of cyber security
- firewalls, and differentiation of environments
- ensuring the security of facilities
- access control
Controllers
LocalTapiola Group
Revontulenkuja 1
02010 LÄHITAPIOLA and
Turva Mutual Insurance Company
Järvensivuntie 3
33100 TAMPERE
The following companies part of LocalTapiola Group, as well as Turva Mutual Insurance Company, serve as the controllers:
For more information about LocalTapiola Group, visit LocalTapiola’s website www.lahitapiola.fi. For more information about Turva, visit Turva’s website www.turva.fi.
Data Protection Officer’s contact details
For more information on personal data and the processing of personal data, contact LocalTapiola Group’s or Turva’s Data Protection Officer. Additionally, more information about the processing of personal data at LocalTapiola and at Turva is available at LocalTapiola’s and Turva’s websites, www.lahitapiola.fi and www.turva.fi.
By email: tietosuoja@lahitapiola.fi or tietosuoja@turva.fi
By mail:LocalTapiola Group
Legal & Compliance / Data Protection Officer
02010 LÄHITAPIOLA
or
Turva Mutual Insurance Company
Legal & Compliance / Data Protection Officer
P.O. BOX 117
33101 Tampere
Data file contact person
By email: sisainen.tarkastus@lahitapiola.fi
By mail: LocalTapiola Group
Internal Audit
02010 LÄHITAPIOLA
Purposes of and legal grounds for the processing of personal data
Personal data are used for the purpose of examining reports of abuse and implementing follow-up measures on the basis of these reports.
The processing of personal data is based on the fulfilment of the controllers’ statutory obligations and legitimate interest.
Registered groups of persons
The personal data stored in the data file
Regular sources of data, and disclosure of personal data
The data are acquired through the whistleblowing channel from the person submitting the report. Additionally, data can also be obtained through a supplementary statement from the person submitting the report as well as otherwise in the course of the report and abuse examination process.
All data are processed within a limited circle of processors at LocalTapiola. Personal data are disclosed to parties external to LocalTapiola Group or Turva only when there is a specific legal ground for the disclosure of the data. On the basis of legislation, personal data may be disclosed, for example, to the police for the purpose of investigating an offence.
External service providers that process personal data on behalf of the controllers are used in the provision of system and support services.
Transfer of personal data outside the European Union or the European Economic Area
Insofar as permitted by data protection legislation, personal data are processed outside the EU and the EEA in Great Britain. Transfer of personal data is based on the European Commission’s equivalence decision, which guarantees that transfer does not compromise the level of protection of personal data.
Retention period of personal data
The controllers determine the retention periods of personal data with due consideration of the requirements laid down in applicable legislation. Personal data are retained for as long as this is necessary for the purpose of processing and in order to comply with the requirements of the law.
As a general rule, reports and the related personal data are retained for a period of 5 years from report reception. Reports that are manifestly unfounded will be anonymised immediately after the conclusion of the examination of a report.
Principles for the protection of personal data
In the protection of personal data, we use the necessary technical and organisational means that are aligned with best practices, including:
LocalTapiola Group also requires that the subcontractors it uses ensure the appropriate protection of the personal data processed, and the activity of subcontractors is inspected and audited where necessary.
Data subject’s rights
Right of access
A data subject has the right to obtain confirmation as to whether or not their personal data are being processed, as well as enjoying the right to be given a copy of their data. In individual cases, it may be necessary to restrict the right of access if this is essential in order to safeguard verification of the relevant report or to protect the person who submitted it.
Right to rectification
A data subject has the right to demand rectification of all inaccurate or incomplete data.
Right of erasure
A data subject has the right to request erasure of their personal data.
Other rights
A data subject has the right to object to the processing of their data for the purposes of direct marketing and direct marketing-related profiling. Under some circumstances, a data subject has the right to request restriction of the processing of their personal data, or to otherwise object to the processing of their personal data. In addition, the data subjects may request the transfer, in a machine-readable format, of the data they themselves have submitted, if technically feasible.
The data subjects may exercise their rights using the contact details provided under Section 3 or some other contact details communicated for this purpose.
Where a data subject finds that the processing of their personal data is not lawful, they may lodge a complaint with the relevant supervisory authority.
*The regional companies:
LocalTapiola Etelä Mutual Insurance Company
LocalTapiola Etelä-Pohjanmaa Mutual Insurance Company
LocalTapiola Etelärannikko Mutual Insurance Company - LokalTapiola Sydkusten Ömsesidigt Försäkringsbolag
LocalTapiola Itä Mutual Insurance Company
LocalTapiola Kaakkois-Suomi Mutual Insurance Company
LocalTapiola Kainuu-Koillismaa Mutual Insurance Company
LocalTapiola Keski-Suomi Mutual Insurance Company
LocalTapiola Lappi Mutual Insurance Company
LocalTapiola Loimi-Häme Mutual Insurance Company
LocalTapiola Länsi-Suomi Mutual Insurance Company
LocalTapiola Pirkanmaa Mutual Insurance Company
LocalTapiola Pohjanmaa Mutual Insurance Company - LokalTapiola Österbotten Ömsesidigt Försäkringsbolag
LocalTapiola Pohjoinen Mutual Insurance Company
LocalTapiola Pääkaupunkiseutu Mutual Insurance Company - LokalTapiola Huvudstadsregionen Ömsesidigt Försäkringsbolag
LocalTapiola Savo Mutual Insurance Company
LocalTapiola Savo-Karjala Mutual Insurance Company
LocalTapiola Uusimaa Mutual Insurance Company - LokalTapiola Nyland Ömsesidigt Försäkringsbolag
LocalTapiola Varsinais-Suomi Mutual Insurance Company
LocalTapiola Vellamo Mutual Insurance company
I CONSENT,
I have read and expressly consent to the processing of my personal information as described in sections 3 and 4 above.