Data ethics policy

Scope

It is essential for Velliv that our customers and the world at large can rest assured that we will manage and store their personal data securely. In other words, ethically responsible use of data is a key priority of ours. This means that we focus on the interface between technology and data use, on the one side, and the values and norms of the society in which we operate, on the other, as well as on safeguarding our customers' rights and interests.

The purpose of this policy is to illustrate how we work with ethics in relation to data use and also to set the framework for the ethical data practices that we strive for in further digitisation. The policy supplements Velliv's Data Protection Policy, which sets out the overall requirements for how we manage personal data, and Velliv's Information Security Policy, which describes how we take care of customers' data, including relevant security standards for data storage, access control and data transmission.

The data ethics policy thus defines Velliv's overall objectives for the work we do on data ethics, as well as the methods and processes we use to achieve these objectives. The policy underpins the company's business model, values and vision.

The policy applies to data about customers, employees, partners, suppliers and distributors collected by Velliv from external sources, as well as data that we create ourselves through the use and development of technology. Data includes structured as well as unstructured data such as emails or other data without an identifiable structure.

Data processing forms an integral part of the processes associated with Velliv's core mission, which is to create financial security for customers throughout their lives by providing pension savings, life insurance products and pension advisory services. Velliv processes data for the purpose of establishing and managing agreements with customers as well as fulfilling our obligations towards customers, co-insured individuals and beneficiaries. In addition, we use data for marketing purposes to the extent that our customers have consented to the use of data for marketing purposes. Finally, we process data for recruitment, employment and human resource development purposes and for the development of new processes and technology to improve customer experience and optimise administrative processes. We are the controller of the personal data we process.

This data ethics policy applies to all managers and employees at Velliv. Our managers are particularly responsible for leading by example and for ensuring that all employees within their area of responsibility have read and understand the policy and that they abide by it.