Guide to Responsible Recruitment

Before starting

Before starting recruitment, check whether you are obligated to give priority to people who have previously been made redundant or laid off on financial or production-related grounds or to people with part-time employment.

In Finland recruitment is governed by, for example, the following laws

• Employment Contracts Act
• Act on the Protection of Privacy in Working Life
• Act on Equality between Women and Men
• Non-Discrimination Act
• Criminal Code

In addition, the processing of personal data must take into account the obligations laid down in data protection legislation, such as the EU’s General Data Protection Regulation (GDPR).

Planning the process

It is a good idea to start recruitment by examining the practices, instructions and resources the employer has for recruitment. The process should take into account, for example, the employer’s or a specific production’s equality and non-discrimination plan, which may set requirements for the recruitment process. We recommend defining the organisation’s recruitment practices so that they are as open, transparent and equitable as possible. Clear recruiting rules can also play a key role in terms of building a good employer image, if jobseekers consider the recruitment process open and fair.

At the beginning, it is important to consider who will participate in the recruitment process and what the division of labour will be, for example, between different departments. Allocate time for the employer and the people handling the recruitment to ensure that everyone has a clear understanding of the practices of the organisation and the project as well as sufficient competence.

After this, it is a good idea to define your needs and draw up a job description. These can be used to consider what kind of competence is desired from the applicant. It is a good idea to consider in advance how the criteria set for applicants will be assessed and measured at different stages of recruitment. Try to keep the criteria and measurement methods consistent throughout the recruitment process.

Make a written record of the policies and practical matters agreed on during the planning phase, such as the recruitment schedule, the required facilities or digital platforms, the persons participating in the process, and other essential matters.

Non-discrimination

It is also a good idea to examine the state of diversity in the organisation and to determine ways in which diversity can be promoted in the recruitment in question. For example, you can assess the current state by asking yourself what kind of perspective or competence is currently lacking in the team or working group. In addition to competence, the work community may wish to gain demographic, cognitive or experiential diversity. In addition, it is worth considering the diversity of the people handling the recruitment process and whether this can be influenced.

Also consider the job description from the perspective of non-discrimination and check whether the characteristics and requirements in it are genuinely what is needed in the job.

You can think about at least the following questions

• Have the task and its required competence been defined clearly and understandably? Even in the case of well-established professions, it is advisable to try to define the areas of responsibility and the necessary skills in this particular project.
• What kind of language proficiency is essential for the task? What is a sufficient level of proficiency for the task? How is language proficiency assessed?
• Does the job description possibly exclude some people, and if so, are those requirements genuinely based on the characteristics needed for the job?

As support for the recruitment process, you can use the checklist of Avaus, which helps identify unconscious biases and assumptions that affect recruitment.

Checklist for Unconscious Bias

Anonymous recruitment, positive action and reasonable accommodations

Equal treatment at the recruitment stage can be promoted, for example, through anonymous recruitment, in which jobseekers submit their applications without information that can be used to identify them. In partially anonymous recruitment, the applicants submit their applications normally, but a person in the organisation anonymises the applications in Excel, and the people handling the recruitment then grade these anonymised applications based on pre-defined criteria.

However, equal treatment of all people is not always sufficient to achieve real equality and achieving it may require taking into account the special needs of groups that are particularly vulnerable to discrimination. This is referred to as positive action. Different treatment of people in recruitment is permitted when it is founded on genuine and determining requirements concerning the type of occupational tasks and their performance. The different treatment also needs to be proportionate to achieve the legitimate objective.

When using anonymous recruitment or positive action, we recommend doing so systematically and mentioning it in the job advertisement.

If a person has a specific need due to a disability, the employer is required to make the necessary reasonable accommodations to enable the person with the disability to obtain the job, perform their tasks, and progress in their career. The accommodations must be appropriate and necessary based on the situation. Furthermore, the costs of the accommodations must not impose an unreasonable burden on the employer’s finances.

When assessing the reasonableness of the accommodations, the following factors are taken into account

• the needs of the person with the disability
• the size of the workplace
• the financial position of the workplace
• the nature and scope of the activities
• the estimated costs of the accommodations.

More information online

A good job advertisement provides a clear picture of the position, employer, and application process. A good job advertisement uses clear and appropriate language and does not discriminate.

It is good to include at least the following information

• tasks included in the work
• type of employment (full-time, part-time, fixed-term, etc.)
• working hours and duration of work
• competence requirements
• place of work and possible travel obligation
• deadline of application and instructions for applying
• employing organisation and contact person for further information.

We recommend providing a link to the privacy statement concerning jobseekers and the processing of their personal data in connection with the application instructions or, for example, as a link in the “Thank you” message sent by automated email.

In addition, the advertisement can introduce what the organisation does, what its work culture is like and what the applicant can gain or learn in their work. If anonymous recruitment or positive action is used, mention this in the advertisement.

When preparing a job advertisement, it is important not to use words or phrases that can be inadvertently interpreted as discriminatory. For example, a good starting point is not to advertise only for male or female applicants. However, the advertisement may be directed at a specific gender on an exceptional basis if there is a weighty and acceptable reason that the task in question specifically requires a man or a woman. For example, in casting situations, a role may be given to a person who is of the gender represented by the character.

It is a good idea to strive to communicate in a language and gender conscious manner. This may mean, for example, preparing the advertisement in several languages or avoiding gendered occupational titles when a gender-neutral option is available (e.g. foreman – foreperson, cameraman – camera operator).

Adding a diversity clause to the job advertisement is one way to promote diversity in recruitments. The advertisement can also show in other ways that the organisation appreciates diversity and makes a conscious effort to develop the workplace. Underrepresented groups can also be encouraged to apply even if the applicant does not meet all the criteria for the role.

Below is an example of a diversity clause that you can modify to describe the values of your own organisation and the diversity work you are doing:

​​”[Name of organisation] values equality and diversity in the work community. We welcome applicants from different backgrounds, such as people of different ages, different genders and members of different language, cultural or minority groups.”

More information online

The majority of vacancies in the audiovisual industry are so-called hidden jobs, which means that they are not publicly announced. The employer can recruit a person that they consider best for an open position without a public application procedure, but before hiring a person, ensure that you are not violating any statutory obligations, such as those related to previous employees that were laid off on production-related and financial grounds.

When an employer recruits an employee for a vacancy, the employer also needs to take into account the equal treatment of its employees in recruitment practices, including the flow of information on vacancies. For example, part-time and fixed-term employees must have equal opportunities to apply for a vacancy.

Using multiple publication channels for your advertisement helps ensure that it reaches potential applicants as widely as possible. Job vacancies can be advertised on various free employment service websites, such as tyotakaikille.fi and Duunitori.fi (in Finnish). There are also several popular Facebook groups for recruitment in the audiovisual industry and media. You can also make use of other social media channels, networks of different organisations, communities and educational institutions as well as mailing lists.

From the perspective of promoting diversity, it is also worthwhile to try and include networks that help you reach groups that are underrepresented in your organisation. For example, contacts with educational institutions, organisations and associations increase the opportunities to reach representatives of underrepresented groups. The audiovisual industry also organises various networking events, such as speed meetings.

When using recruitment or casting services, it is good to ensure that the service providers are aware that diversity is valued in the work community in question, and wishes in terms of the diversity of applicants can also be clearly expressed to them.

The transparency of the recruitment process has a significant impact on the applicant experience. Good communication with the applicants increases the experience of fairness and supports the employer image. It is recommended to thank the applicants once the application has been received and to indicate the schedule for the recruitment and when the applicant can expect to be contacted next. If the recruitment schedule is delayed, it is advisable to inform the applicants of this as soon as possible.

It is a good idea to prepare for assessing the applications by first drawing up a plan for the assessment criteria, which have usually already been outlined at the planning stage. The assessment can be based on, for example, a point system, assessment matrices, or a partially anonymised Excel file. Before reading the applications, you can decide, for example, how many points can be given for a particular competence or experience. Predetermined criteria help keep the assessment objective and speed up the process.

If automated decision-making, such as artificial intelligence, is used in recruitment, for example in the first stage of the evaluation of applications, the fulfilment of obligations laid down in data protection legislation concerning automated decision-making and the jobseeker’s consent must be ensured.

Once applicants have been selected for interviews, it is advisable to inform the applicants who were not selected that the selections have been made as well as explain the grounds on which the selections were made. It is also a good idea to inform the selected applicants of the number of applicants selected for interviews and to communicate the schedule for the upcoming recruitment process. If the schedule changes, it is important to communicate this proactively and inform the applicants of the new schedule.

In addition, you can elaborate on what the applicant can expect from the interview (e.g. duration, persons present in the interview and what topics will be discussed) and make note of any issues related to accessibility.

It is a good idea to prepare carefully for the interview situation, as this supports equality in interviews and decision-making and helps ensure that only permitted and necessary information is collected from the applicant. Keep in mind that the personal data collected on jobseekers is largely subject to the same privacy and data protection requirements as the processing of data related to people who are already in an employment relationship.

Using predetermined assessment criteria or matrix can help you formulate a structured set of questions for the interview. This ensures that all applicants are asked the same questions in the same order, making the interview an equal situation for all applicants and giving the interviewees equal opportunities to highlight their competence.

If possible, use more than one interviewer and take diversity into account when selecting interviewers.

Good practices for organising a job interview

• Reserve enough time and a quiet space for the interviews.
• Plan the interview questions in advance and ensure that they reflect the content of the job advertisement and job description. Make sure that you only ask for information that is relevant and necessary for the task. The employer is not allowed to collect information on the applicant that is not relevant to the performance of the task.
• Make sure that the interview questions are clear and understandable to people of different backgrounds. Having a structured question framework supports achieving this, helps interviewers remain more objective, and facilitates comparisons between applicants.
• You can also make notes during the interview to use for assessment later. However, make sure that you only record information that is relevant to recruitment. Notes concerning the jobseeker may be part of a personal data register in accordance with data protection legislation. Under the GDPR, the data subject has the right to access information pertaining to them.

Any questions asked during a job interview must relate to information that is relevant to the job in question. They must not be offensive or otherwise intrusive. The applicant has the right to refuse to answer unnecessary questions and to be given justifications for the necessity of the questions. By planning the interview questions in advance you can ensure that they are relevant.

The employer must not ask the applicant for personal information that is not relevant to the performance of the work, such as questions related to age, family, religion, political opinion, sexual orientation, parenthood, childcare arrangements, or military or non-military service. In addition, a jobseeker may not be asked for information on their state of health or credit information, and a drug test can only be demanded if the work concerns special situations as specified in the Act on the Protection of Privacy in Working Life.

We recommend avoiding, for example, the following kinds of questions

• Do you have children? Are you planning to have children?
• Are you in a relationship?
• Where are you from? Where is your family from?
• Do you have any underlying medical conditions? Do you take any regular medication?
• Do you have a driving licence? (with the exception of tasks where a driving licence is essential for the work)
• Have you done any military or non-military service? (with the exception of tasks related to national defence)
• Do you use alcohol?
• Are you a member of a trade union?
• What religion do you represent?
• Are you a member of a political party?

A jobseeker may refuse to answer questions that they consider to be irrelevant to the task and require the employer to provide information and justifications on the necessity of the questions. In other words, the employer must be able to demonstrate that the interview only deals with characteristics or personal matters that are critical for the performance of the task. However, asking, for example, an applicant for a TV series scriptwriter position whether they have performed military service is not allowed even if the TV series takes place in a military setting.

If the applicant themself raises a topic that the interviewer should not ask about or that is not related to the current task, it is best to try to redirect the discussion to topics relevant to the task as soon as possible. It is also not recommended to write down any irrelevant personal data provided by the applicant.

In some cases, enquiring about personal characteristics may be essential for the job. For example, the physical performance requirements of the work may require that the applicant’s physical condition is examined during recruitment. Questions related to physical disabilities or restrictions can be formulated, for example, by describing what kinds of physical tasks are included in the work and asking whether the applicant is able to handle them and if there are any accommodations they would need.

After the interviews, applicants are assessed against pre-defined criteria using, for example, an assessment matrix. If there were multiple interviewers, it is recommended that they first write down their assessments independently after the interview situation. This way everyone’s views can be heard and the consensus bias avoided.

After making the selection, it is a good idea to stop for a while to challenge your own thinking and prejudices to ensure that there is no discrimination. Which factors have influenced the decision and are the criteria relevant to the performance of the task? The objectivity of the selection is increased if there are at least two or more people evaluating the fulfilment of the criteria for each applicant.

The primary source of information about an applicant is always the applicant themself. Acquiring information from other sources can only be done with the written consent of the applicant. Information should not be obtained by googling the applicant or by browsing their social media accounts. The up-to-dateness, accuracy and relevance of information obtained this way can be called into question. A LinkedIn profile may be considered an exception if the applicant has shared it in their application.

In the final stages of the recruitment process, there is often a desire to call a person that the applicant has given as a reference to confirm the views that have arisen from discussions with the applicant. When an applicant has indicated a reference and given their consent to the employer to contact them, the employer may do so. This means that you should not contact, for example, a former employer without the applicant’s consent. Keep in mind that the views of the person making the recommendation are the opinion of an outsider.

Example questions for a person given as reference

• How do you know the applicant and how long did you work together?
• What kinds of tasks did the applicant perform during your work together and what were their areas of responsibility?
• How did the applicant’s relevant skills become apparent during your work together?
• What were the applicant’s strengths or possible development areas in the previous job?
• What kind of leadership would enable the applicant to reach their full professional potential or make them perform well in their work?
• What kinds of activities or leadership would prevent the applicant from performing well in their work or achieving their full professional potential?
• We have interviewed the applicant for position X, which requires competence Y. How do you see the applicant fitting in with the role in question?

It is a good idea to personally contact those applicants that were not selected, especially if they were interviewed, to explain the reasons for the selection and offer them an opportunity to receive feedback.

Once the recruitment has been completed, we recommend saving any related documentation in a location designated by the organisation in accordance with its practices on the processing and storage of personal data. If an applicant suspects discrimination in recruitment, the employer may be obligated to provide an account of their actions, such as information on the selection criteria, the education and training of the selected applicant, their work and other experience, and other clearly demonstrable factors and merits that influenced the selection. In order to prevent discrimination claims, the selection should be justified on the basis of objective criteria, which is why we recommend paying attention to documenting the recruitment process.