PAF GROUP PRIVACY POLICY FOR RECRUITMENT
Ålands Penningautomatförening (Paf) and its wholly owned subsidiaries (“Paf Group”) is the Controller and therefore responsible for your personal data that Paf Group processes. Paf Group
respects your privacy and takes the protection thereof very seriously.
This Privacy Policy describes how and why Paf Group processes your personal data in connection with your application. For this reason, Paf Group encourages you to read this Privacy Policy carefully.
Collection of personal data
Paf Group collects and processes personal data submitted by you through the recruitment system Teamtailor or through other recruitment channels such as but not limited to recruitment agencies.
The categories of personal data that Paf Group collects and processes depends on what position you are applying for, if you are called for an interview, submitting an open application or otherwise signed up for the service Connect. The information collected may include, among other, your name, contact details, personal identification/social security number, education, work experience, other work related skills and other information found in your CV and/or cover letter, and other work related documents such as certificates.
During the application process, you might also be invited to partake in different tests in order for the Paf Group to assess your match with the relevant job description. Such tests may either be performed by third parties which conduct such tests on Paf Group’s behalf or by Paf Group.
Paf Group may also collect personal information from other third parties such as references and background checks if your application proceeds to an offer of employment and such are required for the position. In the event background checks are required, Paf Group will inform you accordingly.
If you give your consent, video meetings may be recorded and automatically transcribed in order to support the application process.
Processing of personal data
Your personal data is processed for the sole purpose of evaluating your application, your competence, skills and suitability, and any communication with you in the light thereof, in order to determine if you are the person for the position you have applied for. References are also processed for the purpose of evaluating you as a candidate.
Paf Group utilises 'Co-pilot', a suite of AI features within Teamtailor, which aids in daily recruiting tasks. This includes generating resume summaries and providing summaries of video meetings.
In compliance with applicable laws and regulations, we conduct background checks for specific roles. This process is an important part of our commitment to maintaining a safe and secure work environment.
Estonia: For positions based in Estonia, background checks are conducted in accordance with Estonian gaming law (§33(1)3). These checks are an essential part of our recruitment process for Estonian positions to ensure adherence to regulatory requirements.
Malta: For roles located in Malta, we require a police conduct certificate as mandated by Maltese law. This step helps us to confirm the reliability and integrity of our prospective employees in these positions.
Please note, background checks are only initiated after the candidate has been informed and the necessary consent has been obtained.
The processing of your job applications is based on Paf Group’s legitimate interest in recruiting suitable candidates for fulfilment of current and future positions within Paf Group.
If you have chosen to Connect with Paf Group, which allows you (amongst others) to subscribe information about current and future open positions at Paf Group, Paf Group will only process your personal data based on your consent.
Data retention
Paf Group will not keep your personal data longer than necessary for the purposes for which the personal data are processed.
Paf Group will keep your application, including any open application, and any other information related to your application until the recruitment process has been completed and up to two (2) years thereafter with exception of:
- If you have been invited to do a test, Paf group will only keep the test results up to 6 months after the completion of the test.
- Background checks or police conduct (Malta) will be reviewed and then erased following the finalisation of the recruitment process.
- If you have Connected with us, you can always withdraw your consent at any time and Paf Group will delete your personal data after such request.
Specifics for Estonia:
- Under Estonian gaming law (§33(1)3), annual background checks are mandatory for all new hires and existing Estonian employees. The results of these checks are retained for one year (12 months). After this period, the data is purged and replaced with the results of the latest checks.
Disclosure of personal data
Paf Group processes your personal data in the strictest confidence and only disclose your personal data as described down below. Otherwise Paf Group will only disclose your personal data to a third party if you have consented to such disclosure.
Paf will only disclose your personal data to persons authorised to process your personal data and who have undertaken to observe confidentiality or are subject to appropriate statutory confidentiality. Such persons may be employees who are directly involved in the recruitment process and third parties which assist us in the recruitment process.
Where Paf Group has engaged a subcontractor, which provides services related to the processing of personal data, such as but not limited to Teamtailor and other suppliers of IT/platform solutions, a so called processors, such subcontractors will only only process your personal data on behalf of Paf Group and in accordance with Paf Group’s written instructions.
Since Paf Group is a group of companies, your personal data is disclosed to companies within the Paf Group. The disclosure of your personal data is primarily for managing various matters, for example referring you to the right employer within the Paf Group.
Paf Group may also disclose your personal data in cases where Paf Group is required to do so by law, regulation or as a result of request from an authority, or otherwise handling any possible legal claims.
Transfer of personal data
Paf Group always strives to process your personal data within the European Union (EU) and the European Economic Area (EEA or otherwise within countries which are deemed to provide adequate level of data protection.
However, your personal data may in certain circumstances be transferred to, and processed outside the EU/EEA by a subcontractor on behalf of Paf Group. In such circumstances, Paf Group has taken the necessary and reasonable legal, technical and organisational measures to ensure that the level of data protection is comparable to and at the same level as in EU/EEA. In situations where Paf Group transfers personal data outside the EU/EEA, the transfer is primarily reliant on EU standard Contractual Clauses as adopted by the European Commission, or the EU-US Data Protection Framework.
Your rights
You are always entitled to request access to your personal data by means of an extract and how it is processed. You can also request correction of your personal data if you find that personal data Paf Group processes about you is inaccurate or incomplete.
In accordance with applicable data protection laws, you may also request that your personal data shall be deleted, the processing is restricted or object to the processing conducted by Paf Group. You may also in certain circumstances request that your personal data is transmitted in electronic format (data portability).
If the processing is based on your consent, you can always withdraw your consent by contacting us. Kindly note that a withdrawal will not affect the lawfulness of the processing prior to the withdrawal.
If you consider our processing of your personal data to be non-compliant with applicable data protection laws, you can always lodge a complaint to the Finnish Data Protection Ombudsman, www.tietosuoja.fi.
Contact information
If you have any questions or complaints regarding our processing of your personal data, or to exercise your rights, please contact us at privacy@paf.com.
Ålands Penningautomatförening
Lövdalsvägen 8
PB 214
AX-22101 Mariehamn
Åland, Finland
