Privacy Statement for Job Applicant Register

Data controller:
Oy Apotti Ab
Valimotie 17-19
FIN-00380 Helsinki, FINLAND

Contact information for register-related matters:
+358 (0)20 719 1850

If you have any questions about your rights as a data subject, you can also contact our data protection officer at

Privacy statement for job applicant register

The personal data stored in the job applicant register of Oy Apotti Ab is used in the recruitment process. As a rule, the data is collected from data subjects themselves when they apply for a job. With the data subject’s consent, personal data can also be collected from other sources. For more information about data protection within the job applicant register and the processing of personal data, please read this privacy statement.

1. What personal data do we collect?

The applicants themselves store the following information in the recruitment system: their contact information, date of birth and gender; information affecting selection, such as educational qualifications, work experience and language skills; and such information about their expertise, attributes and skills as is relevant to the job. If the applicant so wishes, they may attach files to the application, such as a curriculum vitae, a letter of motivation or a photograph. They may also submit contact information for references.

In addition, the applicant may, if they so wish, provide other information, e.g. in attachments to the application or during an interview.

If the applicant has applied for several jobs at Oy Apotti Ab, this fact is also stored.

Some recruitment processes include an aptitude test. The test assesses the applicant’s technical, mathematical and logical reasoning skills. If the application process for the position includes an aptitude test, this will be stated in the job advertisement.

It is also possible to subscribe to job alerts through our recruitment system by providing an email address. No personal data apart from your email address is processed when you subscribe to job alerts.

2. On what grounds do we process personal data?

Below are listed the legal grounds for processing personal data for the job applicant register, which comply with article 6 of the EU General Data Protection Regulation:
1. Consent of the data subject
2. Legitimate interest of the data controller if the process leads to an employment contract

Providing data is voluntary and the data is used for recruitment purposes. Some recruitment processes include aptitude tests as well as the data provided by the data subject. The purpose is to provide an objective assessment of the applicant’s initial status in relation to the skills needed in the job. If the recruitment process leads to the applicant being hired, the data in the job applicant register will be used for prefilling the employment contract and the data concerning the newly recruited applicant will be transferred to Oy Apotti Ab’s employee register.

3. To whom do we pass on personal data?

Personal data is mainly processed in the ReachMee recruitment system, which is supplied by ReachMee AB.

In some recruitment processes, shortlisted applicants will take an aptitude test using a system supplied by Apotti Oy Ab’s principal partner, Epic Systems Corporation.

4. To which countries do we transfer personal data?

As regards the aptitude test system owned by Epic Systems Corporation, the data subject’s name and test result will be transferred to the United States. This data transfer is based on a contract between Oy Apotti Ab and Epic Systems Corporation, drawn up using the model contract clauses approved by the European Commission. When aptitude tests are scheduled, personal data is transferred to Doodle Ag in Switzerland, where the local legislation fulfils the requirements for GDPR compliance according to the European Commission.

5. How do we protect personal data?

Data stored in the register is processed in data systems with restricted access. Using the data requires a username and password. User rights are defined on the basis of job-specific access. Job application data can be accessed by HR and by the supervisor who is hiring for the position. In addition, the staff of Apotti Oy Ab are given guidelines for dealing with personal data and protecting information pertaining to data subjects.

6. How long do we keep personal data?

The applicant’s data is deleted from the ReachMee recruitment system 24 months after the application was submitted unless the applicant renews their profile before it expires. Applicants who have registered but not submitted an application, and persons who have only subscribed to job alerts, will have their data deleted 12 months after the registration or subscription was completed.

Scheduling information will be deleted from the Doodle system within two weeks of completing the aptitude test. The results of the aptitude test are retained for the time being and are delivered to the applicant in a summarised format.

7. What are the data subject’s rights?

According to the General Data Protection Regulation, the data subject has the following rights:

  • Right to gain access to personal data
  • Right to have data rectified
  • Right to have data erased
  • Right to restrict processing
  • Right to object
  • Right to data portability

The job applicant, i. e. the data subject, has a right to withdraw their consent at any time by sending email to The data subject also has a right to file a complaint with the Data Protection Authority. You will find more information on this topic on the website of the Data Protection Ombudsman at

Please note that not all of the rights of data subjects are unlimited. If you would like to exercise your rights, please contact Please specify in your message which right you wish to exercise.

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