This privacy statement describes the processing of personal data related to SRV Group Plc’s General Meeting.
1. Controller and contact information
SRV Group Plc
business ID 1707186-8
P.O. Box 555, Tarvonsalmenkatu 15
FI-02601 ESPOO, FINLAND
privacy@srv.fi
Tel. +358 20 145 5200
2. Name of the register
SRV Group Plc's register of general meetings
3. The purpose and legal basis for processing personal data
The purpose of processing personal data is to enable carrying out the General Meeting of the controller in accordance with the law.
Personal data are processed only for the purposes necessary for the organisation of the General Meeting, such as to verify the identity of the registrant and their right to participate, preparing a list of participants, a list of votes and possible voting tickets, organizing any voting, and manage possible questions and requests to be heard.
The technical implementation of the registration system, General Meeting hall bookkeeping and possible advance voting and/or possible voting during the General Meeting is carried out by Innovatics Oy. The list of shareholders is maintained by Euroclear Finland Oy. Inderes Oyj is responsible for the General Meeting service in its entirety. In addition, other service providers are used when needed.
Processing of personal data is based on the legal obligations of the controller.
4. Processed personal data
The processed personal data include the shareholder’s and their possible proxy’s name, personal identity number and/or business ID, address, contact details, number of shares and votes, voting information, authentication method, basis of representation, date of registration, and possible information on aid, power of attorney, preliminary questions, and any additional information provided in connection with the registration. When participating in the General Meeting, the time of arrival and departure of each participant are recorded. For technical maintenance and monitoring of the service, log data on registration and voting, as well as the user’s IP address are also recorded.
The register contains the list of shareholders on the record date created by Euroclear Finland for the General Meeting, containing, e.g., the shareholder’s name, personal identity number/business ID, address, and number of shares.
The register contains a temporary list of shareholders created by Euroclear Finland for the General Meeting, containing information on nominee registered shareholders registered for the General Meeting and their number of shares.
5. Regular sources of data
Personal data is mainly collected from the shareholder themselves or from their representative in connection with the registration to the General Meeting. When registering via e-mail, mail or telephone, the controller or Innovatics Oy enters the registrant's personal data and advance votes into the register.
Based on the personal data provided in connection with the registration, Innovatics Oy retrieves the number of shares of the shareholder on the record date from the list of shareholders created by Euroclear Finland.
Innovatics Oy enters the voting instructions for nominee registered shareholders represented by account operators at the General Meeting into the register.
6. Disclosures and transfers of personal data
Based on the information in the register, a list of votes and a summary of the votes cast are established and attached to the minutes of the meeting. The list of votes contains information on the name of the shareholder and possible proxy and/or aid, number of the vote ticket (participant number), number of shares by share class, number of votes, basis of representation and means of attendance.
At the general meeting, in accordance with the Limited Liability Companies Act, the shareholder register is made available, which includes the names of shareholders, municipality, and the number of shares and votes according to the record date of the meeting. The list also contains information on nominee registered shareholders who are temporarily registered in the list of shareholders for the General Meeting.
7. Transfer of data to third parties and outside the EU or the European Economic Area
The data contained in the register may be shared with third parties involved in organising the General Meeting who need the registered data in their operations. Data is not disclosed for commercial purposes.
For recipients with Finnish phone numbers, text messages are sent via a Finnish service provider. For those with international numbers, text messages are sent using a Swiss service.
If it’s possible to use the right to speak virtually in the General Meeting, the right to speak will be enabled by a US service provider1. In this case, the aforementioned service provider processes the IP address and name of the person using the right to speak.
Otherwise, personal data is not transferred or disclosed outside the EU or the European Economic Area.
8. Basis for register protection
Physical material is stored in a locked room accessible only to persons entitled to the data.
Electronic material is stored in a data room that meets the requirements for the processing of personal data. The connection from the user's browser to the server is encrypted. Access to the register is limited to the employees of the controller and subcontractors who need and process data to organise the General Meeting.
9. Storage and deletion of personal data
Innovatics Oy stores personal data for a maximum of two years after the end of the General Meeting.
Euroclear Finland Oy stores personal data for a maximum of four months after the end of the General Meeting.
The minutes of the General Meeting and the list of votes attached thereto are stored permanently. It includes the names of shareholders who participated in the General Meeting, the names of potential proxies and aids, the number of shares and votes, and the numbers of the voting tickets.
Other data is destroyed when it is no longer necessary to draw up the minutes or to verify their accuracy.
10. Rights of the data subject
The data subject has the right to know the data stored about them in the register. The data subject has the right to request rectification, deletion or complementing of their data. Any request shall be addressed in writing to the address mentioned in Section 1 above.
The data subject has the right to lodge a complaint with the Data Protection Ombudsman if they have objections to the processing of personal data. The instructions are found on the website of the Data Protection Ombudsman at https://tietosuoja.fi/