28 November, 2018

GDPR and integrity

The Sixth Swedish National Pension Fund (AP6) respects and protects personal integrity. However, AP6 needs to process certain personal data in order to be able to do its daily business.
Here is a brief description of how, when and why AP6 processes your personal information.

A full statement of how AP6 handles personal data is contained in the AP6 Privacy Policy.

AP6 is the Personal Data Controller for use of personal data and it is responsible for ensuring that use occurs in accordance with the applicable legislation.
For issues pertaining to AP6’s use of personal data, please contact AP6’s Data Protection Officer.


The Sixth Swedish National Pension Fund
Data Protection Officer
Köpmansgatan 32, Gothenburg
SE-411 06 Gothenburg Sweden
+46 (0)31-741 10 00

Collection and processing of personal data

Most of the personal data that AP6 processes is information that you have yourself provided to AP6, either as an individual, or as representative for an organization. Certain information may also be collected from a third party, such as from your employer when AP6 has a business connection with your employer.

AP6 collects and processes your personal data:

  • When we need to communicate with you, like when you submit a job application to AP6 or when you request information about the fund
  • When doing so is necessary to run the business, for example, when entering into a contract or to meet contract obligations
  • When AP6 has a legal obligation requiring processing of personal data
  • When it is necessary so that AP6 can pursue its interests in a legal dispute.

The types of personal data that AP6 processes are primarily:
– Name, contact information, such as email address, phone numbers, signatures (e.g. when entering into an agreement), proof of identification and information on ID cards, such as personal identity numbers (e.g. when entering into an agreement), job title (e.g. when entering into an agreement)
– Applications and information included in applications, such as CV, grades, age etc.

Legal basis for processing
AP6 is a government authority that must comply with the provisions of the Sixth National Pension Fund Act (2000:193). AP6 processes personal data that is necessary for running the business, for example, when entering into agreements. The legal basis is “processing is necessary for the performance of a task carried out in the public interest”. AP6’s operations are subject to other legislation, such as the Swedish Public Procurement Act (2016:1145) and the Archives Act (1990:782), which require AP6 to process certain personal data. The legal basis is “processing is necessary for compliance with a legal obligation”.
In certain cases, it may be necessary to process your personal data based on your “consent”, for example, when you submit a spontaneous job application to AP6 or accept cookies on AP6’s website.

On AP6’s website, www.ap6.se/en/ cookies are used to track visitor statistics. No personal data, such as the email or names of visitors is saved. If you do not want AP6 to use cookies when you visit the website, you can adjust your web browser settings to prevent this.
For more information on cookies, please visit the Swedish Post and Telecom Authority’s website: www.pts.se/en/

Data protection
In accordance with GDPR, AP6 has implemented a variety of security measure to protect your personal data from unauthorized disclosure, alteration or deletion. In the event of a security incident that could possibly have a negative impact on your personal data, AP6 would contact you with information about how we will address the matter, and what you can do, to minimize the risk of negative consequences. AP6 never uses your personal data for automated decision-making, profiling or direct marketing. Neither does AP6 sell your personal data to third parties.

Transfer of information to a third party
AP6 only transfers information to third parties if doing so is necessary for back-up purposes, due to a legal obligation or when it is necessary to run AP6’s operations.

Transfer of personal data to third countries
If it is necessary to transfer personal data to a recipient in a country outside the EU/EES, AP6 will ensure that the personal data remains protected and that the transfer occurs on a legal basis.

Storage of personal data
AP6 endeavors to never store personal data that is unnecessary. As a Swedish government authority, AP6 must comply with what is stipulated in the Archives Act (1990:782). The Archives Act requires storage of personal data contained in public documents, in certain cases, for an indefinite period of time. Certain information must also be stored in accordance with law. In such cases, the information is stored for the period of time required by law.

Your rights as a data subject
When your personal data is processed by AP6, you have certain rights as a data subject, in accordance with GDPR. If you would like to exercise any of your rights, you may submit a request in accordance with the instructions provided in AP6 Privacy Policy.

Other questions
If you have any questions about AP6’s privacy policy or how AP6’s processes your personal data, please contact AP6’s Data Protection Officer. Contact information has been provided above.