Privacy policy

Key terms

Data controller

The legal entity that alone, or together with others, determines the purposes and means of the processing of personal data.

Data processor

The party that processes personal data on behalf of the data controller.

Personal data

Personal data is any information relating to an identified or identifiable natural person, and which directly or indirectly can identify that person. Examples are name, contact details, identification numbers, location data, a CV or other record of qualifications, online profiles or other factors specific to a person’s identity.

Processing of personal data

Any operation or set of operations performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Legal basis

For Incluso to store and process personal data there has to be a legal basis for doing so. The following four legal bases under the GDPR are the ones relevant to our business.

Contract

You, or the organisation you represent, have entered into an agreement with us or are about to. We may process your personal data in order to fulfil the terms of that agreement.

Consent

You have given us your permission to process your personal data for specific purposes that you have been clearly informed about. You can withdraw your consent at any time, and we then have to stop that processing.

Legal obligation

As a company we have to process your personal data in order to comply with laws and regulations.

Legitimate interest

Incluso may process personal data without the data subject’s consent if the controller’s interests outweigh those of the data subject and the processing is necessary for the purpose in question. Central to this is that the risk of infringing the individual’s privacy is very small.

Incluso processes personal data for several groups of stakeholders. The following describes whose personal data we process, why we process it and on which legal basis.

Employees

Employees at Incluso enter into an agreement with us as their employer. In that relationship we are required to process a number of personal data in order to comply with the legislation that employers in Sweden have to follow. The legal basis for processing employee data is therefore Contract. The legal basis for the data we keep for longer than an ongoing or recently ended employment requires is Legal obligation.

• Name
• Address and other contact details
• Personal identity number
• Bank account number
• Salary, pension and any benefits
• Gender
• Employment history
• Trade union membership
• Photographs
• Family circumstances, for example next of kin as an emergency contact
• Information linked to performance reviews and completed courses

If you are employed as a consultant we share certain personal data with our clients, so that they can give you access to IT systems and to their premises.

If you work at the Incluso office your contact details may be shared with consultants, clients, candidates, suppliers and other stakeholders who have contact with the role you hold at Incluso.

We share your personal data with the third-party suppliers we engage to perform services on our behalf (for example payroll and accounting services) where this is required in order to administer your employment. In that context these suppliers act as data processors and may not use your personal data for any purpose other than the service they deliver to Incluso. Your personal data may also be disclosed where required by law.

When your employment with us ends, the personal data that is no longer needed is erased; the rest is retained.

Candidates

In order to deliver Incluso’s services within recruitment, staffing, coaching and similar, we use a third-party supplier (Teamtailor). Through that platform we process personal data for individuals who have consented to being stored in Teamtailor. Personal data for candidates applying for employment at Incluso itself is processed in the same system.

The platform provides information about this privacy policy, and consent to our processing of the individual’s personal data is obtained at registration. That consent is the legal basis for our processing of personal data in this category. Individuals who register a profile with us without doing so in connection with a specific recruitment or staffing assignment are also regarded as candidates once registered, rather than as prospective candidates under the section below.

• Name
• Address and other contact details
• Professional and academic title
• CV or other record of qualifications
• Link to and information from a LinkedIn profile or other relevant third party
• Competence-based suitability for a role, as established through interviews, email and telephone contact
• Coordination number, personal identity number and international ID numbers — the identity of final candidates may need to be verified
• Photograph

Incluso AB is the controller of the personal information you submit in your application through the recruitment system. Teamtailor is the data processor in relation to that system.

Use of your personal information in Teamtailor

Your personal information is collected only on the basis of your voluntary consent, and is processed and used solely in connection with:

• current or future recruitment processes where you may be a relevant candidate
• current or future consultancy assignments where you may be relevant for a particular assignment

As part of the recruitment process we may also seek additional information about you from the internet, including social media. We may also share your personal information with public and legal authorities if we are obliged to disclose it to them. You can withdraw your consent at any time.

If you are assessed as relevant for a role or a staffing assignment, your personal data may be presented to the client.

You always have the right to access the personal information we process about you, and to request that it be corrected where needed.

Prospective candidates

In order to contact you as a prospective candidate about relevant career opportunities and other relevant communication, Incluso collects personal data through its own network and through external searches with third parties, and stores it in Incluso’s candidate system. The legal basis for this processing is Incluso’s legitimate interest in being able to find suitable individuals as prospective candidates for what Incluso judges to be relevant recruitment or staffing processes, and in being able to contact you about future career opportunities. Prospective candidates who consent to Incluso registering their profile in Teamtailor are regarded as candidates under the section above once registered.

• Name
• Address and other contact details
• Professional and academic title
• Link to and information from a LinkedIn profile or other relevant third party
• CV or other record of qualifications
• Competence-based suitability for a role, as established through email and telephone contact, for example
• Photograph

You always have the right to access the personal information we process about you, and to request that it be corrected where needed.

Clients and prospective clients

So that Incluso can maintain and develop its business relationships, its services and new business relationships, the company collects personal data for potential contacts through its own network, public registers, websites and other third parties. The processing rests either on the legal basis Contract, for personal data linked to clients with whom Incluso has an ongoing collaboration governed by an agreement, or on Incluso’s legitimate interest in establishing and developing business relationships and in developing its services, products and systems. Contract or legitimate interest is therefore the legal basis for processing personal data in this category.

• Name
• Address and other contact details
• Professional and academic title
• Link to and information from a LinkedIn profile or other relevant third party
• Any correspondence between the individual and Incluso
• Personal identity number (for sole traders)

Suppliers

The personal data we process about our suppliers is the data we need in order to maintain our professional relationship. It may concern account managers, support functions, service staff, finance departments or other key people. The legal basis for processing personal data in this category is Contract.

• Name
• Contact details
• Professional title
• Other personal data you have shared with us in our communication

Others

This group covers people who cannot be placed in any of the groups above. It may for instance be people (such as sales representatives) from organisations that are not yet suppliers, individuals in professional networks, media contacts and referees.

• Name
• Contact details
• Professional title
• Other personal data you have shared with us in our communication

The legal basis for processing personal data for this group varies with the reason for our contact. As a starting point we use the company’s legitimate interest as the legal basis. When we note that a particular processing activity falls within one of the other groups, the legal basis changes to the one that applies to that group.

Incluso as data processor

Where Incluso is a data processor for an external organisation, the processing is carried out in accordance with this policy, unless otherwise stated in a data processing agreement between Incluso and the controller.

In Incluso’s assignments as a supplier of recruitment services we are, as a rule, the data controller, and the processing is carried out in accordance with this policy. Where we handle individual steps in a client’s recruitment process, the client is to be regarded as the controller and Incluso as the processor. This matters, because a processor may not use the personal data for any purpose other than the assignment at hand.

Where we share personal data with third-party suppliers who perform services on our behalf (for example payroll and accounting services), those suppliers act as data processors and may not use your personal data for any purpose other than the service they deliver to Incluso. This is governed by agreement.

Rectification and erasure of personal data

All personal data we process must be accurate and up to date for the purpose for which it is processed. Personal data that is incorrect or irrelevant is to be rectified or erased. You have the right to request that we correct inaccurate data and erase data that is no longer necessary for the purpose it was collected for, provided there is no legal requirement to continue processing it.

Access to your data

As data controller, Incluso is obliged to provide a copy of the personal data we process about you. You have the right to obtain confirmation as to whether we process personal data concerning you and, if so, to access that data.

Data controller

Incluso AB (559002-3213, Gamla Brogatan 32, 111 20 Stockholm) is the controller for the processing of your personal data. If you have any questions about how your personal data is processed, email privacy@incluso.se. This privacy policy may be adjusted in the future, and we therefore recommend that you read our terms regularly.