Data controller

Momentous Oy, Mannerheiminaukio 1 A, FI-00100 Helsinki, Finland
Business ID 2443137-4

Name of the register

Register that contains data on private persons participating in the execute search and management development assignments and data on contact persons of client organisations

Momentous Oy (hereinafter referred to as “Momentous”) processes personal data in accordance with the relevant national and international provisions and the provisions and principles of the European Union’s General Data Protection Regulation. Momentous is part of Bravedo Oy.

This privacy statement describes how Momentous processes the personal data of private persons participating in the execute search and management development assignments and the personal data on contact persons of client organisations in its operation.

Objectives of processing personal data

By collecting and processing personal data, Momentous enables effective matching of job applicants with client companies’ vacancies. For that purpose, Momentous collects data on suitable candidates and persons registered as job applicants, the collected data serving their appointment to vacancies at Momentous’s client companies. We collect data on the contact persons of employers to carry out the assignment in question.

We also process personal data in the development services of the acting management of the client organisation, which include suitability tests, self-assessments and interviews.

Data subjects have the right to the protection of their personal data. Their personal data are processed only in accordance with legal processing criteria and in a transparent manner.

Purpose of the register, the legal ground and the origin of the data

Personal data are processed to carry out executive search and management development assignments given by Momentous’s client companies and to manage, maintain and develop client relationships; to develop the business activities and services of Momentous, and to carry out market research and candidate communication, candidate and client feedback surveys and the compilation of statistics. We collect personal data only for the above-mentioned purposes.

The information in our personal data files is mainly obtained from the data subjects by telephone, e-mail, at meetings or customer events.

Personal data are collected principally for an ongoing recruitment assignment given by a client company. Personal data are used and stored in connection with other assignments only with the consent of the data subject.

When applicants submit their application to the assignment-specific search, they also express their consent to the processing of their personal data in the said recruitment. If they wish their data to be processes in other recruitment processes as well, we will ask them to give a separate consent.

The processing of personal data of those who have submitted an open application is based on the applicant’s consent to use their data in the execute search recruitments of Momentous’s client companies.

As initial assessment, we may also collect personal data of executive search candidates from the data sources and registers kept by third parties, such as public companies or authorities, based on a legitimate interest. Initial assessment means in executive searches that persons suitable for open job are surveyed from the labour market. Information collected include, besides contact information, also information on work history and education. After the initial assessment, we will contact the executive search candidate within a reasonable period and ask for their consent to participate in the executive search assignment and the processing of personal data.

In the development services of the acting management of the client organisation, the processing of personal data is based on the data subject’s consent, and the personal data comes directly from the material, interviews and suitability tests of the person in question We use and store the personal data only for that purpose.

What data do we process?

The data processed in the register include the following information necessary for the purpose of the register:

  • basic personal details, such as the candidate’s name, contact details (address, e-mail address, telephone number), gender and date of birth
  • specific information related to the candidates necessary for evaluating their suitability for the vacancy, such as education, profession and specialist knowledge
  • information concerning personal assessments and suitability tests of the candidate
  • information related to the candidates’ previous or current employment, such as their employers, the start date and duration of employment and job descriptions
  • information concerning the candidate’s job search, such as job preferences, desired salary, preferred location of the job and possible commencement and termination information regarding the job
  • the name, title and contact details (address, e-mail address, telephone number) of the contact persons of the client organisation
  • information on the client organisation required for the client relationship, such as order details, information on meetings, possible direct marketing permissions and prohibitions as well as other communication between the parties and possible recordings of telephone conversations and meetings
  • information related to the service, such as information on which client companies the controller has sent an overview of the candidate.
Personal data retention period

Data subjects’ personal data are retained for two (2) years from submitting the application or from the date of obtaining the subject’s permission to continue retaining the data. With the consent of the data subject, data may also be processed in connection with other possible recruitment assignments conducted for client companies.

In the development services of the acting management of the client organisation, the participants’ personal data are retained until the assignment is deemed completed, however, for the maximum of one (1) year from the commencement of the assignment.

We also retain personal data for fulfilling and enabling the burden of proof in legal actions relating to equal treatment. Primarily, Momentous’s client company acting as the employer has the burden of proof on equal decision-making, but Momentous may, however, have a burden of proof as the expert organisation relating to the decision-making.

If the candidate is selected for the job of the client company, we will retain the data, according to Momentous’s contractual obligations, as long as the person is employed by the said company, however, for the maximum of five (5) years. Then the data to be retained are the name, company and job title.

The personal data of the client organisation and its contact persons are retained for as long as is necessary for the purpose of their collection. Personal data are erased when the data necessary for managing the client relationship or marketing measures have become obsolete.

Disclosure of data

In connection with an executive search process, candidates’ personal data stored in the register are disclosed to Momentous’s client organisations with the data subject’s consent. Data on candidates are always stored confidentially and the information provided by the candidates in their applications is never disclosed to parties outside of the executive search process.

In the development services of the acting management of the client organisation, personal data on candidates are only disclosed, subject to consent, to the client company who ordered the service.

In accordance with and as obligated by the legislation in force, personal data stored in the register can also be disclosed to authorities who have a legal right to obtain information from the register. We do not disclose personal data stored in the register to other than the above-mentioned parties without the data subject’s separate consent.

Personal data are mainly stored on our service providers’ servers located in EU and EEA countries and protected in accordance with the general practices of the field. Momentous’s service providers that operate in the United States adhere to Privacy Shield principles when transferring personal data from the EEA countries. Besides the United States, Momentous does transfer information outside the EEA countries. Please read the Privacy Shield principles.

Automated decision-making and profiling

Momentous does not use personal data for automated decision-making or profiling.

Protection of the register

Electronic data are collected into databases that are protected by firewalls, passwords, user authentication and other means of data security. Possible manual databases are located in locked and guarded premises and unnecessary manual and electronic data are safely disposed of in accordance with Momentous’s practices agreed on the disposal process and by appointed responsible persons. Only employees with the right to process the data as part of their duties and with a personal user ID and password to the system are entitled to use the system containing personal data.

Rights of the data subject

Data subjects have a legal right to

  • request access to their personal data from the controller
  • request the rectification, erasure or restriction of processing of their data
  • object, in certain cases, to the processing of their personal data
  • transmit, in certain cases, the data to another system and
  • cancel their consent at any time without this having any effect on the legality of the processing carried out before the consent was cancelled if it was based on the data subject’s consent.

If you want to request access to your data, rectification of incorrect information or erasure of your data, or you have any questions about your rights or this privacy statement, please contact us personally or in writing at

In addition, the data subjects have the right to make a complaint to the Office of the Data Protection Ombudsman (the data protection agency) if they consider that their legal rights have been violated. The Data Protection Ombudsman’s contact information is available here.

(Updated 27th November 2019)