VER keeps a record of the contact persons of its partners and stakeholders for purposes such as investment of assets. Such purposes include, for example, tasks related to the management and administration of investment assets. The information concerning VER’s stakeholders and partners may also be used for sharing information on its activities and events. The processing of personal data may be based on a legal obligation, contract or consent of the data subject.
Processing of Counterparty Information
Counterparty information related to investment activities is processed for the purpose of managing and administering VER’s investment operations and for implementing VER’s risk management with regard to counterparty risk.
Processing of the Contact Register for Illiquid Investments
For the administration of VER’s illiquid investments, information concerning contact persons of funds, direct investment targets, and investment partners is processed.
Processing of Permanent and Project-Specific Insider Registers
Personal data is processed in order to fulfill statutory obligations related to maintaining insider registers.
Processing of Stakeholder and Business Partner Information
We process information relating to stakeholders and business partners, for example, for communications about VER’s operations, general communications, and possible events (name, position, email address, telephone number, address).
Processing of Telephone Records
Personal data is processed to verify and investigate trading activities conducted by VER’s investment directors and portfolio managers by telephone.
Processing of Admincontrol User Credentials
The purpose of the processing is to store access rights information for the use of the Admincontrol service by members and deputy members of VER’s Board of Directors, as well as representatives of the Finnish Financial Supervisory Authority and VER’s auditors.
CCTV Surveillance and Access Control
Personal data is processed to ensure the safety of individuals present on VER’s premises, protect VER’s property, prevent and investigate dangerous situations, threats, and criminal offences. In addition, the data may be used to identify individuals seeking access to the premises.
Processing of Job Applicant Information
Job applicants’ personal data is processed for the purpose of making recruitment decisions and hiring new employees.
Enabling Website Functionalities
On our website, we process information to enable the “send link by email” functionality.
Sanctions Screening
Personal data is processed for the purpose of conducting sanctions screening so that VER can ensure compliance with its statutory obligations (e.g., financial sanctions and requirements relating to the identification of counterparties). The processing applies to representatives of contractual counterparties and potential counterparties, such as responsible persons, shareholders, and beneficial owners. Personal data processed may include, for example, name, date of birth, nationality, and the results of sanctions screening checks.
Disclosure of Data
As a general rule, we do not disclose your personal data to third parties. The State Pension Fund of Finland (VER) discloses personal data only in accordance with statutory rights of access to information and legal rights and obligations concerning disclosure.
However, VER has entered into agreements with certain service providers who, as part of the services they provide, may process your personal data on behalf of the State Pension Fund. These service providers may also maintain their own personal data registers. Information concerning such registers is available directly from the relevant data controllers.
Transfers to Third Countries
Personal data is not transferred outside the European Union (EU) or the European Economic Area (EEA).
Protection of Data
Access rights to the processed data are restricted, and the data is available only to those who require it for the performance of their duties.
Data protection is ensured in accordance with VER’s current security policy.
Rights of the Data Subject
Under data protection legislation, you have certain rights regarding the processing of your personal data. We process your personal data to the extent necessary to facilitate the exercise of these rights. If you wish to exercise your rights, please submit your request using the contact channel specified in the section “Additional Information”.
You have the right to:
1. Access Your Data
You have the right to know what information has been collected about you. Requests should be directed to the contact specified in the “Additional Information” section.
2. Lodge a Complaint with the Supervisory Authority
You have the right to lodge a complaint with the supervisory authority, the Office of the Data Protection Ombudsman, if you believe that the processing of personal data violates applicable data protection legislation.
3. Request Rectification of Data
You have the right to request the correction of inaccurate personal data concerning you that is held in the register. Requests should be directed to the contact specified in the “Additional Information” section.
4. Request Erasure of Data
In certain circumstances, you have the right to obtain from the data controller the erasure of personal data concerning you without undue delay. Requests should be directed to the contact specified in the “Additional Information” section.
The right to erasure does not apply where the data controller has, for example, a statutory or contractual obligation to retain the data. If your request is not fulfilled, the data controller must provide a written explanation of the reasons.
5. Transfer Data from One System to Another
You have the right to receive and transfer your personal data from one system to another, provided that the processing is based on consent or a contract and is carried out by automated means. This right applies to data that you have provided to the data controller yourself. You also have the right to have your data transferred directly from one data controller to another where technically feasible. Requests should be directed to the contact specified in the “Additional Information” section.
If your request is not fulfilled, the data controller must provide a written explanation of the reasons.
6. Withdraw Consent
Where the processing of your personal data is based on your consent, you have the right to withdraw that consent at any time.
7. Object to the Processing of Your Personal Data
You have the right, on grounds relating to your particular situation, to object to the processing of your personal data where the processing is based on our legitimate interests. In such a case, we will cease processing your personal data unless we can demonstrate compelling legitimate grounds that override your rights and interests, or unless the processing is necessary for the establishment, exercise, or defence of legal claims.
8. Restrict the Processing of Your Personal Data
In certain circumstances, you have the right to request the restriction of the processing of your personal data. Where processing has been restricted, we may, in addition to storing the data, process your personal data only with your consent, for the establishment, exercise, or defence of legal claims, or to protect the rights of another person.