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Supplier Representative Privacy Notice
 

This version was published, and is valid from, 2023/09/01
 

This notice provides information on processing of personal data of its suppliers and their representatives by a company which is part of the Volvo Group(“Privacy Notice”). If you are, or have been, employed or engaged by a company, that is a supplier or a potential supplier of a Volvo Group company, we may process personal data about you.

For the purpose of this notice, the “Volvo Group” means AB Volvo (publ.) and entities directly or indirectly controlled by AB Volvo, including but not limited to entities belonging to any of the Volvo Group’s principal Business Areas and Truck Divisions (as may exist from time to time) such as Volvo Trucks, Volvo Buses, Volvo Construction Equipment, Renault Trucks, Arquus, Volvo Penta, Mack Trucks, Volvo Financial Services, Volvo Group Connected 

Solutions, Volvo Technology, Volvo Group Purchasing, Volvo Group Real Estate, Volvo Treasury, Volvo Information Technology, Volvo Group Trucks Operations, Volvo Autonomous Solutions and Volvo Energy.

This Privacy Notice does not apply for consultants that are engaged by the Volvo Group. The processing of personal data of consultants is covered by the Consultant Privacy Notice.

This Privacy Notice applies only when a company which is part of the Volvo Group is collecting or otherwise processing personal data for its own purposes (i.e., when a company of the Volvo Group (either alone or in common with other entities) is a controller and therefore determines the purposes for which and the manner in which any personal data is processed).

This Privacy Notice does not apply when a company of the Volvo Group is collecting or otherwise processing personal data on behalf of another company, such as Volvo Group’s independent dealers, importers, suppliers, and customers.

In addition to this Privacy Notice, some systems, applications, and processes of a company of the Volvo Group may contain their own privacy notices, which provide additional details about what specific personal data is collected and how it is stored, used, and transferred.

 

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The Volvo Group company that you or your employer may be supplying, are supplying or have been supplying with products and/or services (below referred to as “Volvo”) is the controller of the personal data that Volvo obtains from you and the other sources described below.

“Controller” means that it is Volvo that decides on the purpose and means for the processing of your personal data. Volvo is responsible for the processing of your personal data under applicable data privacy laws and regulations.

 

If you have questions regarding the processing of your personal data, please contact the Volvo Group Privacy Officer at gpo.office@volvo.com or by post or phone at:

AB Volvo,
Att: Group Privacy Office, Dept AA14100, VGHQ
SE-405 08
Göteborg, Sweden 
+46 (0)31 66 00 00

For the purposes of this Privacy Notice, “personal data” is any information about a specific individual or that identifies or may identify a specific individual. In other words, it is any piece of information than can be linked to you.

For the purposes of this Privacy Notice, the term "process” or “processing” means any use of personal data, including but not limited to the collection, recording, organization, storing, adaptation, alteration, transferring, making available, blocking, deletion or destruction of personal data.

Legal ground

Volvo may process your personal data based on any one or more of the following legal grounds, see also further details below.

 

  • Contractual obligation Volvo may process your data if such processing is necessary to fulfil a contractual obligation towards you e.g. to fulfill the terms and conditions of a contract for the provision of products and/or services signed with you or your employer.
  • Legal obligation. Volvo may process your personal data if such processing is necessary to comply with a legal obligation, e.g. to comply with court orders and legal reporting requirements.
  • Legitimate interests. Volvo may process your personal data if such processing is necessary for the purposes of a legitimate interest pursued by Volvo or a third party. It is generally considered to be in Volvo’s legitimate interest to manage its daily operations according to lawful and fair business practices, including managing its relationships with its suppliers in order to perform contract(s) to which you or your employer is a party and/or to take steps necessary prior to entering into a contract with you or your employer. As an example, Volvo will need to know your preferred language, to be able to communicate properly with you in day to day activities.

    Where it is stated herein that Volvo relies on its legitimate interests for a given processing purpose, Volvo is of the opinion that its legitimate interests are not overridden by your interests, rights or freedoms given (i) the transparency Volvo provides on the processing activity, (ii) Volvo’s privacy by design approach, (iii) Volvo’s regular privacy review and (iv) the rights you have in relation to the processing activity. If you wish to obtain further information on this balancing test approach, please contact the Volvo Group Privacy Officer via the contact details set out above.

  • Vital interests. Volvo may process your personal data to protect the vital interest of you and others if Volvo has valid reasons to believe that such processing of your personal data may prevent or reduce any significant potential harm to you or others.
  • Consent. In exceptional cases or if no other legal ground can be applied, Volvo may ask for your explicit consent to process certain personal data. Such consent is your choice and is entirely voluntary.

Volvo may process the following categories of data which, in itself or in combination with other data, may constitute personal data and for the general purposes stated in Table 1 below.

Volvo will not necessarily process all the data listed below about you, and some of the purposes for processing will overlap and there may be several purposes which justify our use of your personal data.

Table 1 – Categories, Purpose and Legal Ground for Processing 

Categories of Personal Data

Purposes of Processing

Legal Ground for Processing

 

Contact data, such as name, e-mail and telephone number

  • Enabling contacts with suppliers, private dealer or private importer
  • Enabling the purchase of products and services
  • Enable and follow up the application to grants or public subsidies
  • Promotional communications and marketing purposes, such as the sending of our periodic newsletter/magazines, information on our purchasing initiatives, invitations to events organized by Volvo or from third-party companies with whom we collaborate
  • Handling of reports in the whistleblowing channel
  • Perform supplier screening to detection, reporting, handling and prevention of fraud and crime
  • Prevent and detect corruption and conflicts of interests
  • Handling of warranty claims

 

  • Contractual obligation (to manage contractual obligations)

 

  • Legitimate interest (to manage  supplier relationships)

 

 

Organizational data, such as name of employer, job position, place of work and country

 


  • Handling of reports in the whistleblowing channel
  • Handling of potential or confirmed conflict of interests
  • Perform supplier screening to detect, report, handle and prevent fraud and crime
  • Prevent and detect corruption and conflicts of interests
  • Handling of warranty claims

 

  • Legitimate interest (to manage  supplier relationships)

 

 

Individual data, such as preferred language, photo, clothing size and food preferences

 

  • Enabling the provision of personalized services (such as merchandise products in the right size or providing you food meeting your preferences when being invited to a Volvo organized event)

 

 

  • Legitimate interest (to manage supplier relationship)

  • Consent (when deemed necessary)

 

 

 

IT-related data, such as user-ID, passwords, log-in details as well as data and logs about your use of Volvo’s IT equipment, application or services

 

 

  • Enabling the use of Volvo’s  supplier portal as well as other supplier related applications and systems

 

 

 

 

  • Contractual obligation (to provide agreed services and information)
  • Legitimate interest (to manage supplier user access to systems, data protection and cyber security in general)

 

 

Image material, such as video footage that is being recorded on a Volvo Group company closed-circuit television system (“CCTV”) installed on the applicable Volvo Group company premises or other video and related security/monitoring systems whether on Volvo Group premises or not but to which we have a legitimate purpose in viewing / accessing

 

 

  • Manage safety and security at Volvo Group facilities
  • Developing and/or refining the production process
  • Efficiency improvement

 

 

  • Legitimate interest (to maintain security and safety, prevent fraud or theft; and (where applicable) to assist with regulatory compliance)

 


Financial data, such as credit or payment information and bank account details (sole traders only)

 

 

  • Enabling payment of products and services
  • Prevent and handle supplier financial distress and insolvency

 

  • Contractual obligation (to manage payments)

 

 

 

Contractual data, such as purchase orders, contracts and other agreements between you and Volvo (sole traders only)

 

 

  • Enabling supplier contract management services
  • Enabling the handling of warranty claims and product liability issues
  • Enable and follow up the application to grants or public subsidies

 

 

  • Contractual obligation (to manage contractual obligations)

 

 

Screening and sanctions related data including adverse media reports, presence on sanction lists, watchlists, political exposure, ultimate beneficial owners of the supplier’s company, crime and fraud related data

  • Perform supplier screening to detect, report, handle and prevent fraud and crime
  • Prevent and detect corruption and conflicts of interests
  • Handling of reports in the whistleblowing channel
  • Perform sanction screening for export control requirements

 

 

 

Specifically about special categories of personal data

It is specifically noted that some aspects of health and safety data may be regarded as special categories of personal data under applicable data privacy laws and shall be handled with extra 

care and require additional protective measures. Volvo will only process special categories of personal data if Volvo has a legal obligation or a legitimate business need to process such data. In such cases, Volvo will inform you and (if required by law to do so) seek your explicit consent to process such data. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

Specifically about CCTV monitoring

Volvo may use CCTV monitoring (as defined above) where permitted by law. CCTV monitoring is generally used to control and prevent unauthorized access to Volvo’s premises and equipment, however in some countries it may also be used for the purpose to ensure compliance with health and safety guidelines and procedures and for overall production improvement purposes. CCTV images and recordings are securely stored and only accessible on a need-to-know basis (for example, investigate an incident).

Specifically about automated decision-making

Volvo does not regularly and systematically perform automated decision making producing a legal effect concerning individuals or that would have a similarly significant effect. In the event you are interacting with a Volvo company that is performing such automated decision making you should receive a specific notice that outlines the details of the automated decision making. 

Volvo will primarily obtain your personal data from yourself or the company you work for.

Some personal data might also be automatically generated from Volvo’s IT-system, including any applicable supplier management systems, or equivalent, for example when creating your user-id to Volvo systems.

Except for certain information that is required by law or according to contractual obligations, your decision to provide any personal data to Volvo is voluntary.

However, please note that it is necessary for Volvo to process certain personal data to interact with its suppliers for business purposes. Not providing personal data may potentially hinder the purchase of products and services from you or your employer..

Your personal data may be shared with other Volvo Group companies and with certain categories of third parties (as further detailed below), which may involve transferring your personal data to other countries.

Sharing of personal data within the Volvo Group

The Volvo Group is a global organization with offices and operations throughout the world, and your personal data may be transferred or be accessible internationally throughout the Volvo Group’s global business and between its various entities and affiliates.

Any transfers of your personal data to other Volvo Group companies (including transfers from within the EU/EEA to outside the EU/EEA) will be governed by an intercompany agreement based on EU approved Standard Contractual Clauses or such other mechanisms as have been recognized or approved by the relevant authorities from time to time.

Such agreement reflects the standards contained in European data privacy laws (including the EU General Data Protection Regulation). Having this agreement in place means that all Volvo Group entities must comply with the same internal rules. It also means that your rights stay the same no matter where your data are processed by Volvo Group.

Sharing of personal data with third parties outside of the Volvo Group

In addition to the sharing of personal data between Volvo Group companies as set out above, Volvo may also share your personal data with certain categories of third parties, including:

  • Business partners, such as Volvo Group’s suppliers and service providers in connection with their provision of products and services to the Volvo Group, such as IT service providers.
  • Professional advisors,> such as insurers, lawyers and other professional advisors in connection with insurance claims, audits and the receipt of advisory services.
  • Counterparties and their advisors, in connection with merger and acquisition projects.
  • Emergency service providers, such as the police, fire brigade, ambulance and roadside assistance to protect the vital interest of you and other such as in connection with emergency assistance.
  • Governmental authorities, 
    In the field of law enforcement,: regulatory authorities and other public and judicial bodies in connection with legal obligations such as court orders or legal reporting requirements or if considered necessary in exceptional cases to protect the vital interest of you or others.
    Public authorities in charge of export control and customs

Any third party service providers and professional advisors to whom your personal data are disclosed, are expected and required to protect the confidentiality and security of your personal data and may only use your personal data in compliance with applicable data privacy laws and regulations.

Further, in the event any Volvo Group company that is located within the EU/EEA transfers personal data to external third parties that are located outside of the EU/EEA the relevant Volvo Group company will satisfy itself that there are appropriate safeguards in place which provide adequate levels of protection of your personal data as required by applicable data privacy laws (including the EU General Data Protection Regulation). For example, this may include the use of EU approved Standard Contractual Clauses or such other mechanism as have been recognized or approved by the relevant authorities from time to time.

If you have questions about how Volvo will share your personal data, please contact the VOLVO Group Privacy Officer via the contact details set out above.

Volvo utilizes appropriate and reasonable legal, technical and organizational security measures, including information technology security and physical security measures, to adequately protect personal data.

These measures are appropriate to the risks posed by the processing of personal data and to the sensitivity of the personal data and take into account the requirements of applicable local law. In addition, the measures are continuously improved in line with the development of available security products and services.

Volvo requires all persons to abide by applicable security policies related to personal data when using Volvo systems.

Volvo will keep your personal data as long as required to fulfill its legal rights and obligations taking into account for example the contractual term and the warranty periods. After that Volvo will only process your personal data for such time as may be required to comply with local legal obligations or to satisfy any legal requirements in the event of an actual, threatened or anticipated dispute or claim.

You may be entitled, where provided for under applicable data privacy laws and regulations, to:

  • Request access to the personal data Volvo process about you: this right entitles you to know whether we hold personal data about you and, if we do, to obtain information on and a copy of the specific pieces and categories of personal data.
  • Request a rectification of your personal data: this right entitles you to have your personal data corrected if it is inaccurate or incomplete.
  • Object to the processing of your personal data: this right entitles you to request that Volvo no longer processes your personal data.
  • Request the erasure or deletion of your personal data: this right entitles you to request the erasure or deletion of your personal data, including where such personal data would no longer be necessary to achieve the purposes.
  • Request the restriction of the processing of your personal data: this right entitles you to request that Volvo processes your personal data only in limited circumstances, including with your consent.
  • Request portability of your personal data: this right entitles you to receive a copy (in a portable and, if technically feasible, readily usable format) of your personal data, or request Volvo to transmit such personal data to another data controller.

 In the event that our processing of your personal data or part thereof is based on your consent, to withdraw at any time your consent, in which case Volvo will cease any further processing activities of your personal data or the relevant part thereof (however such withdrawal will not affect the legality of the data processing activities prior to the withdrawal).

Please note that Volvo may not always be obliged to comply with a request of deletion, restriction, objection or data portability. Assessment may be made on a case by case basis of Volvo’s legal obligations and the exception to such rights.

You also have the right to lodge any complaints you may have regarding Volvo’s processing of your personal data to a supervisory authority. For more information about these rights and how to exercise them, please contact the Volvo Group Privacy Officer via the contact details set out above.

Volvo encourages the periodic review of this Privacy Notice to stay aware of any changes to it.

We reserve the right to amend this Privacy Notice as needed. When we do, we will note near the top of this Privacy Notice the date that any such changes are made and/or when they become effective.