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Privacy notice

Updated in October 2024

Introduction

Your privacy is important to Lääkärit Ilman Rajoja (MSF Finland), which is part of the global Médecins Sans Frontières (MSF) movement. We take the processing of your personal data seriously and we want you to know how we handle them. In this Privacy notice, you will find information on what type of data we collect and how we use it. It will also inform you on how you can take part in the technical and organizational measures put in place to secure your privacy and on how to control our access to your personal data.

Our objective is to make sure that your privacy is respected at all time and that your personal information is processed lawfully by MSF Finland. We take responsibility for how we use personal data to ensure that it is for a defined purpose only. For instance, if you are a donor, we need to record your donation. If you are a job applicant, we need some information to invite you to an interview. We are accountable to protect them from unauthorized access. We process personal data in accordance with the applicable laws, especially the EU General Data Protection Regulation (2016/679) (“GDPR”).

You are always welcome to contact us at info@laakaritilmanrajoja.fi if you have any question.

Scope

This Privacy notice applies to all those whose personal information are collected and processed by MSF Finland, for example when you:

  • Visit MSF Finland website,
  • Make a one-time donation or become a monthly supporter of MSF Finland,
  • Contact our donor services by mail, email, telephone or via our website,
  • Subscribe to our newsletter,
  • Apply for a job at MSF Finland office,
  • Offer your services as an independent subcontractor or consultant or volunteer,
  • Contact MSF Finland regarding other matters by mail, email, telephone or via our website;
  • Participate in one of our events like conferences, seminars, trainings, information and discussion events,
  • Others as may apply.

General processing of your personal data

Personal data is any information relating to an identified or identifiable living individual, also called

Data Subject. An identifiable living individual is one who can, directly or indirectly, be identified – either from the data itself or from the data in conjunction with other information that is, or is likely to come into, the possession of MSF Finland, in this case acting as Data Controller. In practice this means many types of data, for example your name, contact information, IP addresses and photos.

MSF Finland processing of your personal data may be related to our fundraising, recruitment and communication activities; and more specifically include registering, organizing, structuring, saving, correcting or changing, gathering, reading, using, sharing, limiting, deleting or destroying data.

We only register personal data that is needed for us to carry out our work, and when we can clearly motivate the need to use the data. We never retain personal data longer than necessary for the specific purpose for which the data was collected.

I am donor

If you make a one-off donation to MSF Finland, we collect, record and store your personal data in our donor system for as long as necessary, but however no longer than up to 6 calendar years after your last donation or purchase.

If you are a monthly donor to MSF Finland, we collect, record and store your data for as long as you are an active donor and for up to 6 calendar years thereafter.

Other donation methods (for example legacy gifts) may require longer retention periods. Feel free to contact us to get a detailed, catered-to-your-need answer.

What kind of personal data do we collect from a donor?

We collect, record and store your name and your contact data (address, telephone numbers, email address), date of birth, gender, language preference and for regular donors necessary invoicing details, for example bank account number, to fulfil obligations of the regular giving contract.

We register the transaction history such as time for donation, campaign, amount and payment method. We also record information about your wishes and interests and the type of donations including but not limited to one-off donation, regular donation, major donation, company donation, trust donation, honorary gift, legacy and private fundraising campaigns for MSF Finland.

How we use donor’s personal data?

Donors’ data is held in the donor register of MSF Finland.

We process your personal data for the following purposes to be able to, including but not limited to:

  • Inform you about our work and our organization,
  • Identify you as a donor and verify that you are over 18 years-old,
  • Fulfil your donation, order or request,
  • Process your payment and to process or discover any fraud,
  • Thank you for your donation and tell you about how your donation will be used,
  • Offer ways to support our medical humanitarian cause,
  • Offer efficient and reliable donor services through administration of your donor profile, handling of your requests, correcting data or sending information, for example in legacy matters or donation certificates for honorary gifts as per your request,
  • Communicate with you via mail or via our digital channels (email, text and image messages),
  • Analyze, group and collect statistics about our donors by choices, priorities and preferences to be able to customize information, ads and offers,
  • Analyze donor behavior to search for errors, maintenance, development, testing and improvement of our donor services and/or the technical platforms on which they are provided, to strengthen our communication and enhance user experience,
  • Administer the donor register (system administration) to maintain a well-functioning donor database.
Lawful basis used to process donors’ personal data
  • Fulfilment of agreement between MSF Finland and the donor
  • Donor’s consent
  • MSF Finland legal obligations
  • MSF Finland legitimate interest
How donors’ personal data is obtained
  • Directly from the donor
  • Regarding direct marketing to potential future donors, MSF Finland may use the services of external service providers. However, we store personal data only when a person makes a donation to MSF Finland and becomes an active donor.

To ensure up-to-date contact information and maintain the data quality of our donor register, MSF Finland routinely checks and updates the personal data of registered donors based on third-party and public registers.

I have subscribed to a newsletter

If you subscribe to a newsletter from MSF Finland we collect, record and store your personal data in our donor database for as long as necessary.

What kind of personal data do we collect from a newsletter subscriber?

We collect, record and store your name and your contact details such as address, telephone numbers email address, date of birth, gender and language preference. We keep activity log about how newsletter is received, opened, read, shared. We also record information on your wishes and interests.

How we use newsletter subscriber’s personal data?

Data is held in the customer register of MSF Finland.

We process your personal data for the following purposes to be able to, including but not limited to:

  • Inform you about our work and our organization,
  • Thank you for your participation and tell you about how your support is beneficial,
  • Communicate with you via mail or via our digital channels (email, text and image messages),
  • Analyze, group and collect statistics about our newsletter subscribers by choices, priorities and preferences to be able to adapt information, ads and offers,
  • Analyze newsletter subscriber behavior to search for errors, maintenance, development, testing and improvement of our donor services and our communication and user experience,
  • Administer the customer register (system administration) to maintain a well-functioning database.
Lawful basis used to process newsletter subscribers’ personal data

Subscriber’s consent.

How newsletter subscriber’s personal data is obtained?

Directly from the subscriber.

I have signed a petition or sent a support message

If you sign a petition created by MSF Finland or sent us a support message, we collect, record and store your personal data in our customer register for as long as necessary, but however no longer than up to two calendar years after you have signed the petition or sent us a support message.

What kind of personal data do we collect from the signatory of a petition?

We collect, record and store your name and your contact details: telephone number and email address only.

In general, MSF Finland does not transfer personal data to third parties unless the person has given its consent to do so, for instance when signing a petition. If you sign a petition, your first and last name are provided to the petition target as a part of the list of signatures.

How we use a petition signatory’s personal data?

Data is held in the customer register of MSF Finland for as long as necessary, up no longer than two calendar years.

We process your personal data for the purpose of advocating on specifics areas of our social mission such as for instance neglected diseases or forgotten crisis or restricted access to healthcare.

Lawful basis used to process petition signatory’s personal data

Petition signatory’s consent.

How petition signatory’s personal data is obtained?

Directly from the petition signatory.

I am a job applicant

If you apply for a position in MSF in Finland, or offer your services as an Independent Contractor, volunteer or consultant, we collect, record and store your personal data in our recruitment system up to 12 months after the end of the recruitment process, unless you withdraw your application and subsequent consent for data processing at any time prior to that.

What kind of personal data do we collect from job applicant?

We collect, record and store the following data:

  • your name and your contact details such as address, telephone number and email address,
  • your resume/CV with information about your education, training and work experience,
  • your motivation letter,
  • your photograph,
  • your grades and certificates, results from assessments, tests or tasks,
  • information provided by your references
  • and in general information you have provided as a part of the recruitment process.

In addition, you are asked to give consent for example before taking part in assessments or tests.

How we use a job applicant’s personal data?

Data is held in the recruitment system of MSF Finland.

We process your personal data for the following purposes to be able to, including but not limited to:

  • Administer your application and select candidates in the recruitment process,
  • Communicate with you via the recruitment platform and possibly also via other digital channels through email, text and image messages,
  • Collect statistics on applications to analyze behavior and patterns to be able to adapt our capacity (the statistics are aggregated data, meaning that the applicant information will not be revealed),
  • Analyze and group applications by choices, priorities and preferences to be able to adapt information, ads and offers to our applicants for the future,
  • Analyze applicant behavior to search for errors; maintain, develop, test and improve our application services, the technical platforms on which they are provided to and communication and user experience.
Lawful basis used to process job applicant’s personal data
  • Job applicant’s consent
  • MSF Finland legitimate interest
How job applicant’s personal data is obtained?
  • Directly from the job applicant
  • From reference(s) provided by the job applicant

I am applying to become an aid worker

If you are Finnish resident applying to become an aid worker with MSF, you will be recruited by MSF Sweden and your data will be processed through its recruitment platform and under its privacy notice, which can be found here.

Under the Swedish Labor Law, the information and documents shared as part of the recruitment process are kept for 24 months after the end of this process.

What kind of personal data do we collect from job applicant?

MSF Sweden shares some specific data or documents of job applicants who are Finnish residents with MSF Finland to support the recruitment process. For instance, if you are a doctor, nurse, midwife or psychologist, we store your medical license and verify it with the National Supervisory Authority for Welfare and Health (Valvira).

Lawful basis used to process job applicant’s personal data
  • Applicant’s consent
  • MSF Sweden and MSF Finland legitimate interest
How job applicant’s personal data is obtained?
  • Directly from the applicant
  • From reference(s) provided by the applicant
  • From MSF Sweden

I am an independent contractor

If you are an independent contractor/consultant with MSF Finland, we register your personal data when you sign your contract with us. In the contract, you give us consent to process your personal data in accordance with this privacy notice.

What kind of personal data do we collect from an independent contractor?

Depending on your role, the nature of your work and the length of your relationship with MSF Finland, we will collect, store and keep your data according to the Finnish Labor Law, contract specification and other legal obligation for accounting, audit and compliance purposes.

How do we use personal data of an independent contractor?

We process your personal data for the following purposes to be able to, including but not limited to:

  • Manage your contract and contact information
Lawful basis used to process personal data
  • Fulfilment of agreement between us and an independent contractor,
  • MSF Finland legal obligations
  • MSF Finland legitimate interest
How is personal data obtained?

Directly from the independent contractor.

I have another relation than those mentioned above with MSF Finland

If you have a business relation with us, or if you are a representative of a stakeholder organization or public body (e.g. media organizations, ministries, other government agencies and authorities, other NGOs and other partners) with an interest in the work of MSF, or if you participate in our external events such as conferences, seminars, trainings and information and discussion events, we register your contact details including personal data and keep it as long as needed for that specific purpose.

Some data like participant lists are normally saved for a short period of time, whereas other data like journalist contact details are saved as long as needed to keep the mutual relation, unless you specifically request us to delete your personal data.

What kind of personal data do we collect?

We collect, record and store personal data such as your name, title, organization, employer (if you act as a representative of your employer), and your contact details (address, telephone number and email address).

You may also be filmed and/or photographed when you participate in any of our events, as they often are recorded and streamed via our digital channels.

How we use personal data?

We process your personal data for the following purposes to be able to, including but not limited to:

  • Create participation lists of our events such as conferences, seminars, trainings and information and discussion evenings. Note that we do not always create participation lists of our events,
  • Disseminate information in our digital channels (stream video and/or publish photographs) from conferences, seminars, trainings and information and discussion events,
  • (Service providers or media representatives or other partners) Keep in contact with you, to provide customer support via mail, telephone or our digital channels (email, text and image messages or website),
  • (Representatives of media, ministries, authorities and other officials) Keep in contact with you to be able to provide efficient and effective communication and advocacy related to our work via mail, telephone or our digital channels (email, text and image messages or website),
  • Internal control of tenders and other.
Lawful basis used to process personal data
  • Data subject’s consent
  • Fulfilment of a contract entered with the data subject
  • MSF Finland legitimate interest
How is personal data obtained?
  • Directly from the data subject
  • From references provided by the data subject
  • From public sources
  • MSF Sweden

I visit the website(s) of MSF Finland

When you visit our website(s) we collect your personal data for statistics and analytical purpose.

What kind of personal data do we collect?

We collect traffic data, location data, web logs and other communication data, for example IP address, unique ID or IT device used, operation system and browser type.

We also use cookies, which are small text files that are saved on your IT device containing information from our digital channels. For more information about the use of cookies in our digital, see section Cookies.

MSF Finland use of lawful basis and how we process your data

The processing of personal data collected by MSF Finland is based on lawful basis for the intended purpose as defined within EU GDPR. Below are some examples. Please note that we never process your personal data longer than what is needed for the specific purpose.

Fulfilment of agreement

An example of such agreement is when you donate to MSF Finland. To fulfil your donation, MSF Finland needs to register your transaction which contains some of your personal data. Another example is when you are offered an employment following the recruitment process.

In some cases, for example monthly donors or employees, the data processing takes longer, running at least the full term of the agreement and thereafter as necessary, on the grounds of statutory obligations which is a different lawful basis.

Legal obligation

An example of this is accounting (book-keeping) related to your donation. According to the Finnish accounting law, MSF Finland is required to save book-keeping records for at least 10 years, depending on the type of information.

Legitimate interest

This is based on an assessment and balancing exercise between MSF Finland interest in processing your personal data and your right to privacy and protection of your personal data.

When we process your personal information based on legitimate interest, the period of time differs for each purpose. For example, if you have donated a gift to us, we will consider you an active donor and save your personal data for as long as necessary, however no longer than six calendar years from your last donation, in our donor register. During this time, we will process your personal data to, for example, inform you about our work and ask you for new donations. If, for instance, you visit our website, we aim to not store your personal data for more than 24 months. The 24 months are based on a default calculation for troubleshooting, statistics and related factors in web context.

Consent

Consent is a lawful basis which requires proof of your explicit, freely given, specific and informed consent, which we record. If we get your consent, we process your personal data until we no longer need it or until you withdraw your consent. You can withdraw your consent at any time.

An example is for job applications through our website. When applying for a job or offering your services you tick a box “I consent” right next to where you fill in your application data. Other examples are when collecting cookies on our website. When not given in a tick box, consent may be given in writing or verbally (in a recorded format) as part of an agreement with MSF Finland.

How to withdraw your consent?

Consent can be withdrawn at any time by contacting us through any communication channels listed at the end of this notice.

For how long do we save your personal data?

Your personal data is saved for as long as it is needed for the purposes for which it was collected or as specified in this privacy notice.

When your personal data is no longer needed for the purpose for which it was collected, it is blocked from being processed for this purpose in our systems, unless we have a legal obligation under applicable laws or regulations to retain such data for a specific period of time. For the purpose of good register care we clean our systems systematically and delete old data.

We retain personal data that is processed for marketing purposes for as long as the data remains relevant for this purpose and as long as our legitimate interest remains valid, unless you object to our processing of your personal data or request removal of your personal data to which you have a right to at any time.

We retain personal data processed based on consent until it has been withdrawn or until the personal data no longer is relevant for the purpose for which it was collected.

Third parties’ processing of your personal data and information shared with other MSF entities

MSF Finland uses third party service providers to process certain personal data on our behalf.

In the case we use third party solutions such as service providers, sub-contractors and collaboration partners to improve our services or handle administration of our systems, all processing is regulated through Personal Data Processing Agreements between MSF Finland and the third-party service provider. This is to ensure that your personal data is handled in a secure way and is not shared with others. When we end third-party contracts, we make sure that your personal data is deleted from the third-party systems.

MSF is an international movement and MSF Finland shares personal data about its members, employees and service providers with other MSF entities, especially MSF Sweden. Others MSF entities may be located outside the European Union.

In addition, we use social media platforms such Facebook, X, LinkedIn, YouTube, Instagram and Google Analytics. Please see section Cookies for further information.

Security for personal data

MSF Finland endeavors to protect your personal data and has taken reasonable technical and organizational measures to secure the transmission and storage of processed personal data from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to.

To secure that personal data is processed in a secure and confidential manner, MSF Finland uses data networks with fire walls and safe passwords as per industry standard. The employees, individual contractors and service providers of MSF Finland are obliged by contract to respect the confidentiality of information they have access to and act as per MSF Finland set of policies and guidance, this privacy notice and other internal rules and regulations that concern the processing of personal data in MSF.

In the event of a possible personal data breach, MSF Finland will contact the relevant authorities and notify any individuals affected.

Your data protection rights

SiYou have several rights regarding the processing of your personal data that is described in this notice. You have the right

  • to obtain information on the processing of your personal data
  • of access to your data
  • to rectification of your data
  • to the erasure of your data and to be forgotten
  • to restrict the processing of your data
  • to data portability
  • to object to the processing of your data
  • not to be subject to a decision based solely on automated processing.

MSF Finland is subject to a variety of legal and contractual obligations which may inform how we keep, store and share your data. Not all the rights can be exercised in all situations. Factors such as the basis for using your personal data influence the situation.

For more information, check the comprehensive website of the Finnish Data Protection Authority: Know your rights | Data Protection Ombudsman’s Office (tietosuoja.fi)

Exercising your data protection rights

If you wish to exercise your data protection rights or have a question about this privacy notice, please contact MSF Finland by email info@laakaritilmanrajoja.fi.

To be able to reply to your request accurately, help us by stating how you wish to exercise your data protection rights or which data you want to access. We will need to verify your identity before we can fulfil your request. If we are unable to verify your identity based on your request, we will contact you and request additional information.

MSF Finland has 30 day to reply to your request though we will do our best to contact you as soon as possible. If we are unable to fulfill your request, we will notify and provide you with the reason.

Notification of a breach (complaint)

If you consider your personal data have been implicated in a data breach, we encourage you to report this to us as soon as possible. You have the right to officially file a complaint with the Finnish data protection authority concerning our processing of your personal data: Data Protection Ombudsman.

Damages

If you have suffered damages due to a data breach as defined by the applicable legislation you have the right to compensation. You can require compensation from us directly or through a court order. A request for damages shall be done in writing to MSF Finland.

Miscelleanous

Personal data for children

As a general rule, MSF Finland does not target children for fundraising, communication, advocacy or recruitment. Thus, MSF Finland does not collect personal data about children other than if dependents accompany aid workers in the field or if MSF Finland visits schools or other similar contexts, photos may be taken with the prior written consent of the guardian.

If you are a guardian and are made aware that your child has shared any personal data with MSF Finland, we encourage you to contact us.

External links

MSF Finland may occasionally be featured in third-party channels such as job sites, blog posts and advertisements or commercials which have their own privacy and data protection policies and notices. This means that this privacy notice is not applicable to any other digital channels.

Changes to this policy

MSF Finland reserves the right to revise this privacy notice when needed. The date of the latest update appears at the top of this page.

MSF Finland contact information

For any question or to exercise your rights, you can choose to contact MSF Finland as the data controller by mail at the below address, email or phone:

Lääkärit Ilman Rajoja / MSF Finland
Association registration number 219.164 Business code 2832010-2
Kumpulantie 5, 00520 Helsinki, Finland

email: info@laakaritilmanrajoja.fi

telephone: 044 741 2000

Cookies

What are cookies?

MSF Finland uses cookies in many of our digital channels. Through these cookies, data is gathered about how you use our digital channels.

Cookies are small text files which are stored on a user’s computer holding a modest amount of data from the website. Next time you come back to the website these cookies will be read and show the website with the right settings. There are two types of cookies that we use:

A temporary session cookie which is saved in the memory of your computer during the time that you are visiting the website. This cookie disappears when you close your web browser.

A permanent cookie which stays on your computer until it is removed. This type of cookie can be removed through settings in your web browser.

Visit our website without cookies

You can reject cookies through the security settings in your web browser. If you do not accept cookies on our websites, the consequence may be that the user experience and the functionality of the website is affected.

Why are we using cookies?

The purpose with cookies is to give you as a visitor to our website access to functions and facilitate the use of our website. Cookies collect information about how you as a visitor (not as identified individual though) use our functions. We collect this information to improve the website.

Sharing function

To facilitate sharing of information from our websites in social media, we use so called plug ins. These plug ins can save third-party cookies in the web browser that makes it possible for the visitor to recommend articles on for example Facebook and Twitter.

Analysis function

The web analysis tool Google Analytics is used on our websites, and cookies register information on an aggregated level about how the visitors use the websites. The information collected is about number of page views, from where visitors access the website and number of visitors.

Remarketing

We use remarketing on our websites. This gives us an idea about the age and the sex of our visitors. This information may be used in donation campaigns to direct advertisements in Google Display Network and the advertising tools of Facebook. A third-party cookie is used for this purpose. You can change the settings for advertisements or opt-out from advertisements to avoid behaviour-based advertising from Google.

Management of google marketing

You can control Google Marketing through this link https://adssettings.google.com/authenticated.

Google analytics web browser addendums

You can reject Google Analytics web browser addendums through this link https://tools.google.com/dlpage/gaoptout

For more information about how we use your personal data, please read our Privacy Policy at the top of this page.