Updated: January 2019
1. Data processor
Name: Odum Oy, 0224529-8
Address: Hitsaajankatu 22, 00810 Helsinki
Contact information: email@example.com
Name: Henri Rautamo, data protection officer
Address: Hitsaajankatu 22, 00810 Helsinki
3. Name of the data file system
4. Purpose of processing personal data
Personal information is collected from users to evaluate and improve their well-being. No personal information is ever shared with supervisors, company management, colleagues or authorities.
In addition, AlvinOne may produce anonymised group level reports for the employer of the users who is a customer of AlvinOne Business Services. In these reports all identifiable personal information is removed and reports are only created for groups comprising 20 persons or more so that individuals cannot be identified when reporting single health factors. The AlvinOne Health Index may be reported on group-level for groups comprising 10 or more persons. The Group AlvinOne Health Index consists of the average of the Personal AlvinOne Health Indices in the group. The Personal AlvinOne Health index consists of the average of the scores in each of the ten health factors AlvinOne analyses. This means that even in a group comprising at least 10 persons individuals cannot be identified.
Email addresses are used to individualise users and to communicate with users when needed. Such occasions include sending a confirmation email when registering to use AlvinOne, sending reminders and other content agreed upon in co-operation with the employer of the user. Date of birth and the user’s sex are used to calculate the user’s results.
The information is stored in the data file until for the time being and as long as the employer of the user has a valid contract with AlvinOne. If the contract ends all personal information is erased within six months of the contract expiry. If the employer notifies the data controller of the termination of employment of a user the user’s personal information is erased within one month of the notice.
If the users grants permission to use the data they have entered into AlvinOne it may also be used anonymously in research as the company develops the methods used in the data analysis processes of their product. In this case all identifiable personal information is removed so that individuals cannot be identified.
5. File’s data content
Name, sex, email address, employer, date of response and responses to questions regarding the user’s well-being and health.
6. Regular data sources
The data the user voluntarily provides while using AlvinOne, such as personal data and information about the user’s health and well-being.
7. Disclosure and regular data transfers
Data is not regularly transferred.
8. Disclosure and data transfers outside the EU or the EEA
Information is not transferred outside the European Union or European Economic Area.
9. File protection policy
The data is saved and stored in a protected and secure data system. If necessary designated healthcare professionals can be granted access to process personal information and AlvinOne results.
If agreed upon separately by expressed written consent between AlvinOne and the User, designated healthcare professionals can be granted access to the information as a part of the user’s occupational healthcare, i.e. as a part of a health exam. Logging into the system takes place by using a personal user ID and password and an SMS confirmation. Healthcare professionals have restricted read-only access to information that’s relevant to treat the user. No individual personal information is ever shared with supervisors, company management, colleagues or authorities.
All data communication is strongly encrypted and stored in a secured data center. The advanced security solutions of the data center meet the existing requirements. The system collects user-specific logs of all actions and changes to the data and the times of their occurrence. The data file is backed up regularly.
10. Privacy requests
Users have the right to review all personal information stored in the system. Privacy requests shall be submitted by email to the following address: firstname.lastname@example.org.
11. Correction requests
Users have the right to make changes to incorrect personal information stored in the system. Correction requests shall be submitted by email to the following address: email@example.com.
12. Other rights
Users have the right to request removal of all personal information stored in the system. Removal requests are always fulfilled as soon as possible but at the latest within one month of the request. Removal requests shall be submitted by email to the following address: firstname.lastname@example.org.
The data file is not used for direct advertising, sales, other direct marketing, market research or polling.