Issued Date: 180604

Privacy policy

1. SEM AB is Controller for the personal data

1. SEM AB is Controller for the personal data
SEM AB is responsible for the processing of personal data which is collected in association with our business. Any type of information which is directly or indirectly attributable to an identifiable living physical person is regarded as personal data.
To be able to run our business, SEM AB has to in some cases process personal data. As Controller of personal data, SEM ABs processing of that personal data must occur in accordance with The General Data Protection Regulation (GDPR).

2. What personal data does SEM AB process?

Processing includes, for example, collection, registration, storage, adaption, modification, reading, sharing, deletion or removal.
SEM AB processes personal information for employees. This includes current, former and future employees regardless of employment type, as well as contract labour.

SEM AB also processes personal data of external parties such as the contact people of clients, suppliers, authorities and other relevant external parties so that SEM AB is able to run its business.

In addition to this Privacy Policy, national laws and regulations in countries where the company operates may require processing of personal data in a way other than that specified herein. In such cases, subsidiaries and entities are expected to act in accordance with the rules applicable to their operations in addition to this Privacy Policy, Compulsory laws and regulations in places where the company operates, must always be followed and have priority in conflict or deviation from this policy.

3. Employee personal data processed by SEM AB

Personal data can be collected during the recruitment process, at the beginning of employment and on a regular basis during the employment at the company.

3.1 SEM AB may process the following personal data about the employees.
Basic personal information: Name, the personal identity number, nationality, gender, work phone number, work place address, home address, other contact details, employment number, bank and account details, operating unit, organizational position, employment date, time of employment start/end, manager role, employment rate, native country, employment time in years, worker/official which also requires other basic personal data.

Temporary/contract work:
Employer, when the company was engaged, when the company’s contract was terminated, contract type.
For the execution of work and work planning: manager, manager’ manager, job title, department, country, product line, region, location, education/skills, education level, work performance.

Personnel Management and other HR specific personal data:
Weekly working hours, daily working hours, country organization, contact information closest relatives, cost centre, job evaluation, job category, employee group, monthly salary, salary development, health information, rehabilitation, absence, manager, organizational level, staff subdivision and when necessary other relevant data for personnel management and HR-specific requirements.

Information Technology:
Personal data required to give employees access to the company’s computer systems and networks, including Internet address, work email, IP addresses and login usernames, but also other types of personal data logged while using data systems and networks.

3.2 The purposes of processing employees’ personal data
SEM AB may collect and process employees’ personal data, for example for the following purposes. The list is not exhaustive but intends to provide an overview of the company’s need to process employee personal data.
• administration and management of the company’s employment, maintenance of personnel records
• internal work management, planning and workforce management, need for and access to different resources, project staffing and resource allocation
• recruitment, skills development, career planning and development, evaluation and follow-up of work performance
• managing of benefits, payroll, remuneration, taxes and insurance
• managing of business travel, travel insurance, office transfers and other business
• provide employees with access to company internal information systems and other resources, support secure, safe and efficient use of internal information channels such as e-mail and other Internet or telephone-based services, ensuring that business critical information and the company’s other assets are secure and protected
• financial planning, reporting, creation of budget and analysis
• health and working environment
• follow up of internal policy application and other regulations, protect the company’s property, both physical and intellectual property rights, prevent fraud and other illegal activities
• manage work-related disputes and complaints, such as remuneration demands, act in accordance with other applicable legal obligations that the company may have through the employee’s employment with the company

3.3 The legal basis for processing
The legal basis for processing of personal data is justified by the employment contract. The legal basis is also justified because SEM AB is obligated by law, collective agreements or other regulations to process personal data in a certain way, e.g. in relation to the tax authority, insurance companies or the registration of working hours and so on. The legal basis may also be justified by a SEM AB interest evaluation that entitles processing to be carried out. In addition, SEM AB may process personal data based on the employee’s specific consent.

If the processing is required to fulfil an agreement or a legal obligation, the employee cannot oppose the process. If the processing occurs after an interest evaluation, an objection to the processing can be reviewed in that specific case.

3.4 How is the employees’ personal data protected and who has access to it?
SEM AB applies appropriate technical and organizational security measures to protect personal data against, for instance, loss, abuse and unauthorized access.

Only people within the company who in their employment need to process personal data in accordance with the above purpose will have access to it.
SEM AB may disclose personal data to personal data Processors, other companies within the corporate group or third parties as described below in accordance with applicable data protection laws.
• To recipients within the corporate group to enable global handling of personal data for the above mentioned purposes.
• To personal data Processors. SEM AB can engage personal data Processors for business purposes as part of their normal activities, such as outsourcing management of employee wages or IT operations to an external supplier. In such cases, SEM AB will require such personal data administrators to use appropriate technical and organizational security measures to protect employee personal data and that processing of employee personal data only happens in accordance with SEM AB’s instructions.
• To government authorities if SEM AB has an obligation to do so or if SEM AB needs to protect its own or third party’s rights.
• To third parties in connection with a sale or other ownership transfer as a part of SEM AB’s operations.
• To third parties in case of emergency where health and safety for an employee or other person is in danger.
• To third parties to safeguard SEM AB’s rights, such as in connection with labour dispute.
• To government and/or employer organisations for payroll statistics.
• Some recipients of employee personal data may be or have activities in a country other than where the employee’s place of employment is located. Data protection legislation may be different in such countries. SEM AB will ensure that an adequate level of protection is maintained for the processing of personal data in each transfer of personal data.

3.5 Storage and deletion times for personal data
SEM AB will process and store employee personal data for as long as necessary in relation to the purposes for which the data was collected.
Certain personal data will be deleted in connection with the termination of the employment. Other personal data will be stored for a longer period as there is a legal obligation for the company to retain personal data, e.g. in order to prepare an employment reference or to support an audit that correct tax deductions have been made, alternatively that SEM AB needs the information in order to exercise its rights. As the possibility of directing claims against SEM AB expires (statutes of limitations), the data will be deleted. SEM AB may also need to save personal data associated with specific projects and may therefore need to be retained for as long as the projects are in progress.

Some personal information may be saved for a longer time, such as employment duration until the employee has reached retirement age according to the Employment Protection Act. The data used as the basis for pension contributions may be saved for as long as the employee is alive.

4. External party personal data processed by SEM AB

4.1 SEM AB may process the following personal data regarding external parties
Personal data that SEM AB processes regarding external parties is typically name, e-mail address and telephone number, but sometimes, in order to carry out our business, we also process other personal data as well.

4.2 The purposes of processing external parties’ personal data
SEM AB mainly processes personal data from external parties in order to perform its business.

4.3 The legal basis of the processing
Often it may be the completion of an agreement, a future agreement or a termination agreement where there are still warranty commitments. It may also be that SEM AB is obliged by law or other provisions to keep personal data in a certain manner. Sometimes it may be that the individual has consented to the processing of personal data by, for example, leaving a business card.

4.4 How is the external parties’ personal data protected and who has access to it
SEM AB applies appropriate technical and organizational security measures to protect personal data against e.g. loss, abuse and unauthorized access.
Only people within the company who, as part of their employment, need to process personal data in accordance with the above purpose will have access to it.
SEM AB may disclose personal data to personal data Processors, other companies within the corporate group or third parties in accordance with applicable data protection laws.

4.5 Storage and deletion times for personal data
The personal data processed by SEM AB should be adequate and relevant in relation to the purposes of the processing. Therefore, SEM AB does not save more personal data than what is necessary, and we do not save personal data for longer than what is necessary.

5. The individuals’ right
Individuals are entitled to know free of charge what personal data SEM AB is processing about them (a so-called registry extract). A request for information about personal data is handled within one month. If it takes longer then the individual should be informed about the delay and the reason for this. Individuals may also request that incorrect personal data be corrected, deleted or request that the processing of personal data be restricted. Individuals may also in certain cases be entitled to object to SEM AB’s processing of personal data. These rights may be restricted by other provisions of data protection legislation or if such a claim would be inappropriate in an individual case, such as a dependency on an ongoing investigation of improper conduct. In cases where consent has been given to SEM AB for processing personal data, the individual may revoke this at any time. To do so, please contact us directly. The individual may have the right to share a copy of his personal data to another personal data Controller. This concerns personal data that SEM AB processes with the consent of the individual or to fulfil an agreement with the individual. The data should have been provided to SEM AB in a structured, widely used and machine-readable format. Individuals can get more information about the management of personal data via HR when it concerns the employees, or the respective business function manager when it concerns external parties.
6. Changes to the Privacy Policy
SEM AB may make changes to this Privacy Policy. At the top of the first page it is clarified when the last changes were made. If more substantial changes are made, individuals will be informed directly.
7. Contact details and complaints

SEM AB, org. nr. 556023-5748, is a Controller for the processing of your personal data.

This means that SEM AB is responsible for your personal data being processed correctly and in accordance with the current data protection legislation. If you would like to contact SEM AB, the address is Magnetgatan 1, 662 21 Åmål. You can also send an email to or call our switchboard with the phone number +46 (0)532-61 100.

Individuals who are dissatisfied with the way SEM AB manages personal data can lodge a complaint to The Swedish Data Protection Authority, which is the authority that supervises the processing of personal data. The Swedish Data Protection Authority has the phone number 08-657 61 00 and the email