PURE TRANSFER LTD
PRIVACY POLICY TO DATA SUBJECTS FOR EMPLOYMENT PURPOSES
| 1. Controller Information |
| We are Pure Transfer Ltd Reg. No. BC1247056 MSB Reg. No.: M20553159 BIC: PUTFCA82 300-1095 MCKENZIE AVE. VICTORIA BC V8P 2L5 CANADA. We can be contacted by writing to the following e-mail address: info@puretransfer.io. |
| 2. Contact details for communication on personal data protection issues |
| If you have any questions relating to this privacy policy or processing your personal data, you may contact us by using the communication channels listed in the previous paragraph (paragraph 1) or by contacting our personal data protection officer by writing to the following e-mail address: info@puretransfer.io |
| 3. General description of our personal data processing |
| The purpose of the Privacy policy is to give you a general insight into our personal data processing activities and purposes, but please note that other documents (such as the contract of employment or other internal procedures and instructions of the company) may provide additional information on the processing of your personal data. Similarly, the purpose of this Privacy policy is to provide an opportunity to introduce you with our personal data processing rules also to those persons whose data have been transmitted to us by employees. Privacy policy describes how we carry out the processing of personal data by our employees, candidates, family members of employees and others whose data may come to our disposal in relation to the purposes of processing personnel data. When starting an employment relationship, we will ensure that you have access to this Privacy policy. This is the wording of the current When starting an employment relationship. We reserve our right to make amendments and update this Privacy policy as needed. We are aware that personal data is your value and will process them in compliance with privacy requirements and in order to ensure the security of your personal data. |
| 4. For what purposes do we process your personal data and what is the legal basis for the processing of personal data? |
| We will only process your personal data for legitimate purposes defined above, including: in order to ensure the recruitment process and the exercise of the rights and obligations arising therefrom- As part of this, we shall collect a CV and the accompanying documents from applicants and public recruitment portals, if the applicant has placed his CV on these portals, we shall contact the feedback providers indicated by the applicants to collect feedback, with the consent of the applicant, maintain the applicant’s CV in order to consider the candidacy in cases of job vacancies, as well as in order to be able to defend our interests in judicial proceedings, we retain data to respond to claims and cases brought before the courts. For this purpose and the above sub-purposes we might need at least the following personal data: identifying data (e.g. applicant’s first name, surname), contact details (e.g. e-mail, telephone number), qualifications and experience (applicant’s education and past experience), people who can provide feedback and their contact details, the applicant, as well as any other information that may be relevant for the performance of the post and for the identification of the most relevant candidate. The main legal bases to be used for these purposes are: consent, as regarding the submission of a CV and the preservation of a CV; conclusion of a contract with data subjects, regarding the processing of data from applicants for whom a decision to conclude a contract of employment has been taken; enforcement of legal obligations — in certain cases, on individual types of data, where regulatory enactments lay down minimum requirements for a specific position; legitimate interests of the controller regarding the provision of evidence, in the case of alleged claims, as well as the amount of information to be requested. Concluding a contract of employment and the performance of a contract of employment – As part of this, we collect information that needs to be included in the contract of employment and its annexes; drafting the contract of employment; make your identification; check your education and evidence of qualifications; if necessary, make an electronic mail address for you, and give the username so that you can access the necessary information systems; organise records of your working time and work; perform your salary calculation and make transactions to your bank account; perform planning for the development of employee competencies and skills, organise business trips (including, airline ticket reservation/purchase, hotel and car rental reservation), in certain cases if this is the case, necessary for the performance of work duties, transfer data on your position and contact details to our partners and customers, as well as other employees; check your state of health and collect any other information necessary for your employment. The minimum amount of personal data required for the purposes mentioned above: for conclusion of the contract and personal identification (e.g. employee’s name, surname, personal identity number, residence, telephone number, e-mail), for performance of contract obligations (e.g. starting date of employment, workplace, timetable, position, employee duties) description, hours worked, contact details, salary rate, data of performance of work duties, education, health data etc. The main legal bases to be used for these purposes are: conclusion of a contract;; enforcement of legal obligations, regarding the information to be reflected in the contract of employment and qualification requirements. performance of the duties of the controller and enforcement of rights in the field of employment, regarding processing of specific categories (health data) data. fulfilment of the requirements regarding employment specified in regulatory enactments or fulfilment of the requirements specified in other regulatory enactments – In the framework of this purpose, we would need to comply with both the provisions of the labour law, binding regulations issued by the state authorities, the requirements of the accounting regulation and other regulatory enactments. In some cases, we should also provide them with relevant information regarding you (e.g. the state revenue service, labour inspectorate, auditors, investigating authorities, courts, supervising bodies) on the basis of the rights of state institutions specified in regulatory enactments. The minimum amount of personal data required for the following purposes: for employment and enforcement of statutory requirements: identification of the person (given name, surname, personal identity number, personal identity records), contact information (residence, telephone number, e-mail), position, any information requested by national authorities concerning you, in order to ensure regulatory health examinations (health data, information on the compulsory health check, data related to the performance of work duties (working time records, information regarding amounts of personal income tax paid, travel orders), information about children, family status to ensure that additional vacation days, information justifying absence, etc. The main legal bases to be used for these purposes are: enforcement of legal obligations; performance of the duties of the controller and enforcement of rights in the field of employment, as regards the processing of specific categories of data (health data). ensuring the conditions of employees – As part of this, we could provide you with a variety of “social benefits”, such as additional holidays on the various events of your life, granting benefits, giving gifts, organising events, providing health insurance, awarding premiums, we could also gather information to improve the working environment, identifying the best employees, we could inform other colleagues about your anniversaries, your absence, and publish pictures/videos of events organized by employer. We need the minimum amount of personal data for the following purposes: benefits, information needed for insurance (including family members), your anniversary, photo, photographs and videos from events, in some cases assessment of the worker’s ability to work/ensuring an appropriate working environment. The main legal bases to be used for these purposes are: the consent of the data subject; legitimate interests of the controller, such as publishing photographs from events, improving the social conditions of employees; performance of the duties of the controller and enforcement of rights in the field of employment, regarding the processing of specific categories of data (health data) e) Prevention of security threats and other important legitimate interests of us or third parties Within the framework of this purpose, we would need to conduct video surveillance of our territory, premises and other properties, use personal data processors to ensure various functions, if necessary, exchange information within the group of companies, use the rights granted in regulatory acts to ensure our legitimate interests, enumerate working hours, ensure employees access to certain premises and information systems, control the protection of your trade secrets and personal data of customers, check the fulfillment of the employee’s duties, in certain cases, if necessary, transfer information about you to cooperation partners or customers, or potential customers, so that we can provide our services and your work is related to the provision of these services, as well as we should retain data to protect ourselves in cases of employee claims against us, etc. For this purpose, we may need to process at least the following personal data: data in video recordings, data recorded in access control systems. The main legal bases to be used to achieve these purposes are: – The controller’s legitimate interests. |
| 5. Who could access your personal data? |
| We shall take appropriate measures to process your personal data in accordance with the applicable law and to ensure that your personal data is not accessed by third parties who do not have the appropriate legal basis for the processing of your personal data. Your personal data could be accessed as needed: our employees or directly authorised persons who are required to carry out their duties or tasks; personal data processors according to their services and only to the required extent, including auditors, tax issues/accounting and legal advisers, websites, information system developers/technical providers, other processors contracted to process personal data on our behalf; supervising and law enforcement authorities, upon written substantiated request or in the cases and in accordance with the procedures specified in law; other third parties, carefully assessing whether such data transfer has an appropriate legal basis, such as auditors, courts. |
| 6. What partners do we choose in the processing of personal data? |
| We shall take appropriate measures to ensure that your personal data is processed, protected and transmitted to data controllers in accordance with the applicable legislation. We are carefully selecting personal data processors and evaluating its necessity and the amount of data to be transferred when making the data available. The transfer of data to processors shall be subject to the requirements of the confidentiality and reliable processing of personal data. |
| 7. Are your personal data sent to countries outside the European Union (EU) or the European Economic Area (EEA)? |
| We could transfer the data to the United Kingdom, which by the decision of the European Commission is recognized as a country that provides appropriate to the European Union level of data protection. |
| 8. How long will we keep your personal data? |
| Your personal data is stored for as long as their storage is required for appropriate purposes for the processing of personal data, as well as in accordance with the applicable law. When assessing the length of the storage of personal data, we take into account existing regulatory requirements, aspects of contractual performance, your instructions (e.g. in the case of consent), and our legitimate interests. If your personal data is no longer needed for the purposes specified, we will either permanently make them anonymous, delete them, or destroy them. |
| 9. What are your rights as a data subject with regard to the processing of your personal data? |
| If there are changes in personal data that you have provided to us, such as changes in the communication address, changing the telephone number or e-mail, please contact us and provide us with the relevant data so that we can achieve the relevant purposes of processing personal data. Your right to access and correct your personal data In accordance with the provisions of the General Data Protection Regulation, you have the right to have access to your personal data at our disposal, to request their rectification, erasure, processing limitation, to object the processing of your data, as well as to the right to portability of data in the cases and procedures set out in the General Data Protection Regulation. We respect your right to access and control your personal data, so if we receive your request, we will respond to it within the time limits laid down in the regulatory framework (usually not later than one month if there is no specific request that takes longer time to prepare the answer), and if it is possible, we will correct or delete your respective data. You may obtain information or exercise other rights as a data subject in one of the following ways: by submitting an appropriate application, sending it to us by post to the following address: 300-1095 MCKENZIE AVE. VICTORIA BC V8P 2L5 CANADA; when submitting an appropriate application, sending it to our e-mail: writing to the following e-mail address: info@puretransfer.io, it is recommended that it be signed with a secure electronic signature. Upon receipt of your submission, we will evaluate the content and the possibility of identifying you, and, depending on the situation, we reserve the possibility of asking you to further identify yourself in order to ensure the security and disclosure of your data to the person concerned. Withdrawal of consent If the processing of your personal data is based on your consent, you have the right to withdraw it at any time and we will no longer process your personal data processed on the basis of your consent. However, we are informed that the withdrawal of consent cannot affect the processing of personal data which is necessary for the fulfilment of the requirements of regulatory enactments or which is based on a contract, our legitimate interests or other legal bases for the lawful processing of data provided for in regulatory enactments. You may also object to the processing of your personal data if the processing of personal data is based on a legitimate interest. |
| 10. Where can you file a complaint relating to the processing of personal data? |
| If you have any questions or objections relating to the processing of your personal data by us, we shall ask you to address us first. If, however, you believe that we have not been able to resolve the issue with each other and you believe that we are violating your right to the protection of personal data, you have the right to file a complaint with the data protection supervisory authorities. |
| 11. Why do you have to give us your personal data? |
| Above all, we are collecting your information for the purpose of carrying out the recruitment process, fulfilling our binding legal obligations and pursuing our legitimate interests. In these cases, it is necessary for us to obtain certain information for the purposes involved, so that failure to provide such information may endanger commencement of employment relationships. If the data are not required, but their submission could help to improve your employment conditions, we will point out that the provision of data is voluntary |
| 12. How do we get your personal data? |
| We can get your personal data in one of the following ways: from your application and CV to a job vacancy or job or placement of practice for search purposes; in the process of entering into a mutual contract, by obtaining data from you; from you, if you submit any submissions, e-mails or call us; where appropriate, result from medical examinations. |
| 13. Is your personal data used to make automated decisions? |
| We do not use your data to make automated decisions. |