Personal data (GDPR) and Cookies

For us at Första AP-fonden, the personal integrity of the individuals we interact with is very important. Our goal is for them to feel secure when we process their personal data. In our role as data controller, we ensure that we comply with the applicable legislation.

Första AP-fonden is a governmental entity, which means that messages sent to us become public documents.

Privacy Notice

General

Första AP-fonden, org.nr. 802005-7538 (“AP1” or “the Fund”) respects and protects your personal integrity. We want you to feel secure when we process your personal data. With this privacy notice (“Privacy Notice”), we want to show how we ensure that your personal data is processed in accordance with applicable legislation.

Första AP-fonden manages part of the buffer capital in the income pension system. To be able to perform this task, we need to use personal data about you. This Privacy Notice applies to you if you, for example, are a contact person for a partner or contracting party to the Fund, apply for a job with us, visit our website or office, or otherwise interact with us through, for example, e-mail.

Scope

This privacy notice applies to AP1’s use of personal data within the framework of our operations in relation to those who provide personal data to us or whose personal data we receive from other sources.

Data controller and data protection officer

The Fund is the data controller for the use of your personal data and is responsible for ensuring that the use is in accordance with applicable legislation. You can find our contact details at the end of this Privacy Notice.

We have appointed a data protection officer (“the Data Protection Officer”). The Data Protection Officer’s tasks include monitoring that our use of personal data is in accordance with applicable legislation. The Data Protection Officer’s e-mail address is caroline@apriorilaw.se.

Our use of your personal data

At the Fund, we use your personal data to be able to fulfil our obligations, to inform about our operations, and to interact with you. We therefore use your personal data for the following purposes:

• Administration and fulfillment of contracts as well as to safeguard our legal interests
• Recruitment
• Communication with you, security, and provision of information

Fulfillment of our task

In the tables below, you will find more information about, among other things, why we use your personal data, which personal data we save to achieve these purposes, and how long we save your personal data. 

Purpose: Administration and fulfillment of contracts as well as to safeguard our legal interests in the event of a dispute. 

Personal data: Contact details such as name, personal identification number, phone number and email address.

Your rights: You have the right to object to the use of personal data based on performance of a task of public interest. If you object to such use, we will only continue the use if there are important reasons for the use that outweigh your interests. See below if you want to read more about which.

Purpose: Recruitment

Personal data: Contact details such as name, phone number and email address, as well as what you submit to us such as CV, cover letter, references.

Your rights: You have the right to object to the use of personal data based on performance of a task of public interest. If you object to such use, we will only continue the use if there are important reasons for the use that outweigh your interests. See below if you want to read more about which.

Purpose: Communication with you, security, and provision of information

Personal data: Contact details such as name, phone number and e-mail address, as well as other data provided in e-mails sent to us or visits to our premises.

Your rights: You have the right to object to the use of personal data based on performance of a task of public interest. If you object to such use, we will only continue the use if there are important reasons for the use that outweigh your interests. See below if you want to read more about which.

Source of your personal data

The personal data we use about you has been provided by you to us. You provide information such as contact details when you contact the Fund, for example, by sending an e-mail or submitting a job application. If you are an employee or representative of a partner, contracting party or supplier to the Fund, you provide information to us in connection with contract signing or when you otherwise interact with the Fund. When you visit our website, certain information such as cookies is collected during your visit to improve your experience.

The personal data we use about you that comes from other sources may include, for example, contact details from partners and contracting parties to perform our obligations.

Automated decision making

We do not use automated processes to make decisions that significantly affect you.

How long do we keep your personal data?

We only keep your personal data as long as needed for the purposes for which we collected the data according to this privacy notice. When we no longer need to keep your data, we remove it from our systems, databases, and backups. In the tables above, you can see how long we keep personal data about you for different purposes.

We may also need to keep your personal data for other reasons, such as to comply with legal requirements or to protect our legal interests or another important public interest.

Who do we share your personal data with?

The Fund may share your personal data with third parties, such as IT providers and companies we collaborate with to fulfill our obligations. In some cases, we may also need to disclose information at the request of authorities or to other parties in legal proceedings or similar.

The Fund is a governmental agency, which means that the Fund is subject to the principle of public access to official documents. We will not sell your personal data.

Where do we use your personal data?

The Fund strives to always process your personal data within the EU/EEA. In some cases, we may transfer your personal data to a country outside the EU/EEA. If personal data is transferred to such a country, we will ensure that the personal data continues to be protected and that the transfer is carried out legally.

Our responsibilities for your rights

The Fund, as the data controller, is responsible for ensuring that your personal data is used in accordance with the law and that your rights are upheld. You can contact us at any time if you wish to exercise your rights. You will find the Fund’s contact details at the bottom of this privacy notice.

The Fund is obliged to respond to your request to exercise your rights within one month from when you contacted us. If your request is complicated or if there are a large number of requests, we have the right to extend the time by two more months. If we believe that we cannot do what you want us to do, we are obliged to inform you within one month from receiving your request why we cannot do what you want us to do and inform you that you have the right to complain to the supervisory authority.

All information, communication, and all actions we take are free of charge for you. However, if your request regarding your rights is manifestly unfounded or unreasonable, we have the right to charge an administrative fee to provide you with the information or carry out the requested action or refuse to comply with your request.

Your right to access, rectification, erasure and restriction

You have the right to request the following from the Fund:

Access to your personal data. This means that you have the right to request a record of our use of your personal data. You also have the right to receive a copy of the personal data we use free of charge. For any additional copies, we have the right to charge an administrative fee. If you make a request electronically, e.g., via e-mail, we will provide the information in a commonly used electronic format.

Rectification of your personal data. Upon your request or on our own initiative, we will correct, anonymize, delete or supplement data that we find to be incorrect, incomplete or misleading. You also have the right to provide us with additional data if something relevant is missing.

Erasure of your personal data. You have the right to request that we delete your personal data if there is no longer an acceptable reason for us to use it. Erasure should therefore occur if:

• the personal data is no longer needed for the purpose we collected them for
• we use your data based on your consent and you withdraw it
• you object to our use of your data based on a balance of interests and we do not have compelling interests that outweigh your interests and rights
• we have used the personal data unlawfully
• we have a legal obligation to delete the personal data

However, there may be legal requirements or other compelling reasons that mean we cannot immediately delete your personal data. We will then stop using your personal data for purposes other than complying with the legislation or as necessary for another compelling reason.

Restriction of use. This means that we temporarily limit the use of your data. You have the right to request restriction when:

• you believe your data is incorrect and you have requested rectification according to Rectification of your personal data, while we investigate the accuracy of the data
• the use is unlawful and you do not want the data to be deleted
• we, as the data controller, no longer need the personal data for our purposes of use, but you need it to establish, assert or defend a legal claim
• you have objected to the use, pending verification of whether our compelling interests outweigh yours

The Fund will take all reasonable steps to notify anyone who has received personal data according to the above sections if we have corrected, deleted or restricted access to your personal data after you have requested us to do so. Upon your request, we will inform you of whom we have disclosed personal data to.

Your right to object to use

Du har rätt att invända mot sådan användning av dina personuppgifter som vi gör med stöd av allmänt intresse. Om du invänder mot sådan användning kommer vi enbart att fortsätta användningen om vi har viktiga skäl till att fortsätta användningen som väger tyngre än dina intressen.

Your right to withdraw consent

For use where we rely on your consent as the legal basis, you can withdraw your consent at any time by contacting us. You will find our contact details at the bottom of this privacy notice. If you withdraw your consent, it may be possible that you cannot use our services as intended.

Your right to data portability

You have the right to data portability. This means the right to obtain some of your personal data in a structured, commonly used and machine-readable format and to transfer this data to another data controller. You only have the right to data portability when the use of your personal data is automated and we base our use on your consent or on an agreement between you and us.

Your right to complain to the supervisory authority

You have the right to file any complaints about our use of your personal data with the Swedish Authority for Privacy Protection.

We protect your data

You should always feel safe when you provide your personal data to us. The Fund has therefore taken appropriate security measures to protect your personal data against unauthorized access, alteration and deletion. If security incidents occur that may significantly affect you or your personal data, such as when there is a risk of fraud or identity theft, we will contact you and inform you of what you can do to minimize the risk.

Cookies

A cookie is a piece of information stored on your computer.