Privacy Notice for Suppliers and Externals
15 July 2022, 15:00 EEST
In our privacy notice below, you can find information about how we collect, process and use the personal data. For the purpose of the EU General Data Protection Regulation 2016 (GDPR), the data controller is Fortum Corporation and its subsidiaries (“Fortum”). Information about the local country-specific controllers can be found in the Privacy notices of each country, see section “Contact information” at the end of this page.
This privacy notice describes how Fortum (Fortum Corporation and its subsidiaries, “Fortum”) processes your personal data. This notice applies to the processing of your personal data in the context of supplier and consultant relationships or when otherwise working with us as an external person. We may also provide you with additional privacy information in supplements or other notices regarding a particular system, product or service.
The provisions here are supplemented by applicable mandatory law that prevails to the extent that there is a conflict with this Notice.
2. What data does Fortum process?
Fortum collects and processes various types of personal data, where applicable, such as:
- Personal details - including your contact details (e.g. your name, phone number, and email address), demographic data (e.g. your gender, age, language, nationality, professional details), and your identification related information where needed (e.g. national ID number, passport number).
- Administrative information – such as your resumé and competences, information about previous assignments or projects where you have been involved, where applicable, the results of background checks, credit information, photographs, accident records, project time and attendance management and information about work related equipment and services that you use in connection with working with us, including, e.g. recorded and transcribed phone calls, recordings of trainings, messaging, and information you publish about yourself in internal and external channels.
- Financial data – such as your bank account information, travel and other expenses, insurance information, tax numbers.
- Online data & identifiers – data that is collected with cookies or similar technologies about your use of our internal services, your IP address, cookie ID, mobile device ID, details about browser and device, and location.
- Security data – data that is used for securing the use of our services and our premises, such as your password and login details, employee ID, security logs, facility entry logs, and CCTV camera recordings.
3. How does Fortum collect information about you?
The personal data which we process about you comes from different sources:
- You and your employer– We receive information directly from you and the company with which you are working;
- Third parties – We may receive information from third parties, such as national authorities (e.g. police and other enforcement agencies).
- Fortum Group companies, which share information for purposes mentioned below in section 6.
4. What are the purposes and legal bases for processing personal data?
We will use your personal data for predefined purposes based on contract, consent, legal obligation and legitimate interest. Typically, the legal basis for processing your data is our legitimate interest to administer our contact persons’, external persons’ or consultants’ information for work related matters. In addition, we have certain legal and contractual obligations that require us to process personal data. Consent may be used in certain specific situations.
We will use your personal data for the following purposes:
- Supplier & stakeholder relationship management
We process personal data to manage the professional relationship with our business partners. This involves contacting our stakeholders and arranging events.
- Managing work orders and assignments, evaluation, and general administration
We process personal data of external persons in order to administer their work and assignments. We provide them with work related tools, trainings and services, manage travel and expense claims and project hours, conduct contract performance evaluation, and manage insurances and payments. Personal data is also processed in contract management, for example when signing non-disclosure agreements.
- Service development & reporting
We process personal data to improve and develop our internal services. Service development is done, for example, by collecting feedback directly from you in surveys and questionnaires; by utilizing the data generated from the use of our services in analytics; and by using recorded or transcribed phone calls in certain operations for training and service quality improvement. We also have internal reporting processes that utilize personal data.
- Legal obligations
We process personal data to comply with our legal obligations, for example, to comply with tax, accounting, securities, anti-bribery, anti-money laundering, health and safety rules and other legal obligation placed on Fortum.
- Ensuring security, safety and legal rights
We use personal data to ensure the security and safety of our information, facilities, products, services, and personnel. This is done subject to local law, for example by keeping access logs and system backups, preventing attacks, monitoring system use, identifying and authenticating individuals, and monitoring access and facilities (including CCTV) and locating individuals in emergency situations. We also process personal data for defending legal rights, including preventing and investigating fraud, industrial espionage and other crime.
5. Automated decision-making
If we use automated decision-making with legal or similarly significant effects on you, we will inform you about it in advance. If such automated decision-making is not authorized by legislation, not necessary for the performance of or entering into a contract with us, we will ask for your consent.
You may always express your opinion or contest a decision based solely on automated processing, as well as request a manual decision making process instead by contacting us (see section 11. below).
6. How long does Fortum store the personal data?
This varies country by country depending on the local laws. We delete or de-identify personal data when it is no longer necessary for the purposes it was collected for. For information on how long we hold your personal data for, please contact us (see section 11, below) for more information on the specific retention times.
7. Who can access your personal data?
Where applicable, we may share your personal data with:
Fortum Group companies - Our Group companies may use your personal data for the purposes defined in this notice, based on our legitimate interest, to the extent permitted by applicable law. This includes sharing of personal data with the Uniper Group, that processes personal data in accordance with its own privacy notice, in connection with Fortum-Uniper cooperation, common projects and business activities.
Your employer – We may share your personal data for the purposes defined in this notice with the company with which you are legally employed by, based on our legitimate interest, to the extent permitted by applicable law.
Authorized third parties - We may share your personal data with authorized third parties, based on our legitimate interest, to the extent permitted by applicable law. In such cases Fortum will ensure there is a genuine need to share your personal data. Authorized third parties include, for example, Fortum’s customers, travel agencies, banks, telecom operators, insurance scheme providers, auditors, professional advisors, external legal counsels, actuaries, medical practitioners, trustees or other third-party suppliers.
Our subcontractors - We use subcontractors to provide us services. Such subcontractors may have access to your personal information and process it on our behalf, but they are not allowed to use the personal data for any other purpose than to provide the service agreed with us. We ensure that the processing of personal data by our subcontractors is done in accordance with this notice through appropriate contractual arrangements. Typical service providers that process personal data include for example IT software and service providers
Mergers and acquisitions - If we decide to sell, merge or otherwise reorganize our businesses, this may involve us disclosing personal data to prospective or actual purchasers and their advisers.
Authorities, legal proceedings and law. We will disclose your data to certain competent authorities, such as government agencies responsible for tax collection, statistical information or to the police other law enforcement agencies, to the extent required under mandatory law. We may also disclose your personal data in relation to legal proceedings or at the request of an authority on the basis of applicable law, or court order or in connection with a trial or authority process, or as otherwise required or permitted by law.
8. Does Fortum transfer personal data to third countries?
Fortum is a global company that has affiliates, business processes, management structures and technical systems that cross national borders. This means that your data may be transferred to countries other than the one where you are located, including also outside of the European Economic Area. We use appropriate safeguards, such as the standard contractual clauses provided by the European Commission, for these transfers to protect your data. You can obtain more information about the transfers by contacting us (see section 11, below).
10. Your rights and how to exercise them
Below you can see the list of your rights regarding personal data that we process about you. If you have any questions about your rights or want to exercise them, please contact us (see section 11. below). Please note that some of the rights may not be applicable, for example, if the data cannot be connected to you.
Right to access personal data – You have the right to be informed about the processing that we do and to request a copy of your personal data.
Right to correct personal data – You can ask for the information about you to be corrected if it is not accurate or if it needs to be updated.
Right to data portability – You may obtain and reuse the personal data you have once provided us. We can provide a selected set of the data delivered in a machine readable format, where the basis of processing has been either a contract or consent.
Right to deletion - We will delete the data at your request, if it is no longer legitimately needed.
Right to withdraw your consent – If you have given a consent for data processing, you are always entitled to withdraw your consent.
Right to object to the processing – You have the right to object to the processing of your personal data based on Fortum’s legitimate interests, such as developing our products and services, and other purposes explained in sections 3 and 6 above. We may reject your request if there is a compelling reason for us to continue the processing.
Right to restrict the processing - In certain circumstances you have the right to have the processing restricted.
If we do not take action in accordance with your request, we will inform you of the reasons. If you are not satisfied with our response or with the way we handle personal data, please let us know. You can also always contact your national data protection authority.
11. Changes to this privacy notice
Fortum reserves the right to amend this Privacy Notice. Possible amendments to the Privacy Notice will be notified on this site, or by communicating directly to you.
12. Controller of your personal data and contact details
Fortum has appointed a Data Protection Officer, whom you may contact by using the contact details give in this chapter.
The controller of your personal data is typically the local Fortum company with which the company you work for is conducting business. You may find the contact details to local Fortum companies below. If you want to exercise your rights or have any queries about the processing of your personal data, kindly contact the customer service of the local company.
To contact Fortum Corporation and to address any further questions and comments regarding your privacy, including contact with the Data protection officer by using the privacy contact form, or in writing to the address below:
Data Protection Officer
Keilalahdentie 2-4, 02150 Espoo