Processing of personal data
Below you can read about how EKN processes the personal data we collect via our website ekn.se and that we otherwise manage as part of our operations.
Data protection officer (DPO)
EKN is controller for the processing of personal data carried out as part of EKN’s operations and on its website ekn.se. If you have any questions, please contact EKN’s DPO, Eva Kullberg Tideman at firstname.lastname@example.org.
What is personal data?
Personal data are all types of information that can be directly or indirectly related to a living private individual. Examples of personal data are name, identification number and e-mail address. The General Data Protection Regulation (GDPR) contains rules governing the way that personal data may be processed.
Under GDPR, all processing of personal data must be based on a lawful ground. Depending on the reason for processing personal data, EKN uses different lawful grounds.
A fundamental lawful ground for processing of personal data at EKN is that EKN performs a task in the public interest. This lawful ground is based on EKN’s remit as a public authority to promote Swedish export by insuring exporting companies, banks and purchasers in export transactions. EKN’s government remit is governed by law, EKN’s instructions and its public service agreement.
Below are some excerpts from section 2 of the EKN Instructions Ordinance (2007:1217), giving examples of when EKN carries out tasks in the public interest.
Section 2: In particular, EKN must
1. determine whether the prerequisites for granting a guarantee are met;
7. provide information about forms of guarantee offered by EKN and about the general requirements and conditions applying in order to be granted a guarantee;
8. monitor international developments within EKN’s sphere of responsibility.
Some excerpts are also given below from EKN’s public service agreement (click here to read the full agreement), illustrating when EKN performs tasks in the public interest:
- EKN should promote Swedish export by issuing guarantees.
- EKN should collaborate with other actors promoting Swedish export, and be presented as part of Sweden’s overall efforts to promote export.
- EKN should continue the initiative to increase awareness of its services among small and medium-sized enterprises.
In some cases EKN processes personal data because it has a legal obligation to do so.
In some cases EKN processes personal data on the basis of consent. Consent must be given voluntarily, and the data subject must be able to withdraw their consent at any time. Consent must be clearly distinguishable from other text and information. Consent is given in writing or orally.
In some cases where we process personal data based on the lawful ground of public interest, we also obtain consent as confirmation from those whose personal data we process.
Purpose of processing and lawful grounds
EKN processes personal data in different situations. Below are some of the reasons that we process personal data provided to us.
Purposes based on the lawful ground of public interest:
- Processing guarantee applications
- Assessment of relevant parties, e.g. guarantee-holders and purchasers
- Processing of loss claims
- Management of e-mails
- Management of purchases from suppliers
Purposes based on the lawful ground of legal obligation:
- Preservation of official documents in accordance with archive legislation
- Book-keeping legislation
Purposes based on the lawful ground of consent:
- Job applications
Purposes based on the lawful ground of public interest, where consent is obtained as confirmation that processing is to take place:
- Communication of information about EKN’s offering
- Invitations to events
- Ordering reports, etc.
Freedom of information, diarising and archiving
Since EKN is a public authority, it abides by the freedom of information provisions set out in the Freedom of the Press Ordinance (1949:105) and the Public Access to Information and Secrecy Act (2009:400), as well as the rules on diarising and archiving in the Archives Act (1990:782).
In general data in public documents received or drawn up and held at EKN will be preserved according to 3 § third subsection of the Archives Act: Government archives shall be preserved, kept in order and be attended to so that they enable:
1. the right to access public documents
2. the need for information on administration of justice and public administration, and
3. the needs of research.
In some cases deletion of documents is possible according to 10 § of the Archives Act:
Public documents can be deleted. However upon deletion it shall always be taken into consideration that the archives are part of the national heritage and the archiving material which remains shall be able to enable the fulfilment of the purposes as stated in 3 § third subsection of the Archives Act.
If there are divergent statutes on deletion of certain public documents in other laws or ordinances those will apply. (There are general decisions regarding deletion for EKN.)
As per article 5 (b) GDPR principles for preserving personal data for archiving purposes in the public interest is not considered incompatible with the initial purpose (purpose limitation).
EKN and market communication
Under our instructions (section 2 (7)) and our public service agreement (paragraph 1 (iii), EKN has been tasked with increasing public awareness of our services. Our efforts focus on people who, in their professional role, may have an interest in EKN’s operations. We therefore believe that people who read our articles, guides and standard documents, or who otherwise visit our web pages for specific communication initiatives, will wish to remain in contact with us. We therefore give you the option of registering your professional contact details.
Your contact data is stored in the Apsis marketing platform. You may withdraw your consent and unsubscribe from communications with us at any time.
As part of our marketing communication, we use Matomo, a third-party tool for statistics.
When you visit our website, a session cookie is downloaded to your computer to enhance your experience of visiting the site. A session cookie disappears when you close the page on your web browser. We use permanent cookies to store your personal user preferences when you make repeated visits to the site.
A third type of cookie may also be supplied to EKN by a third party to perform web analysis and traffic monitoring.
If you do not want cookies to be stored on your computer, you can always change your web browser settings on the web. Disabling cookies may affect your user experience.
Right of access
You have the right to request information about the personal data about you that are processed by EKN or to request a register excerpt showing the personal data. EKN provides the information in a digital format if the request is sent in a digital format.
Right to request rectification
You have the right to request rectification if EKN has processed/processes personal data about you incorrectly.
If you would like to request a register excerpt or exercise your other statutory rights, please contact our Data Protection Officer, Eva Kullberg Tideman by e-mail at: email@example.com.
If you consider that EKN’s processing of your personal data is in breach of GDPR, you have the right to complain to the Swedish Authority for Privacy Protection.
Web page last updated 26 Oct 2021