Employee Privacy Statement
Last Updated February 20, 2019
Cygnacom Solutions (“Cygnacom”) values its commitment to protecting and respecting your privacy. This Employee Privacy Statement sets forth how we will use any personal data we collect or that you provide to us as an employee, consultant, independent contractor, intern or temporary worker.
Personal data is information that identifies you personally, either alone or in combination with other information available to us (e.g., your name or email address). More detail about the types of personal data we collect for employment purposes (“Employment Information”) is set forth below.
What Personal Data Does Cygnacom Collect for Employment Purposes?
Information you provide to us
We may collect the following personal data from you for employment purposes:
Depending on local law, we may also collect and process the following “special categories” of “sensitive personal data”:
Cygnacom may collect this information directly from you through application forms, CVs or resumes, passport or other identity documents such as your driver’s license, forms completed by you at the start of or during your employment (such as benefit nomination forms), correspondence with you or through interviews, meetings or other assessments.
Information we collect
Cygnacom may also collect personal data about you from third parties such as former employers and employment background check providers, depending on local law. Before we conduct these checks, we will inform you that we are doing so and let you know what information will be collected, from whom the information will be collected, and what we will do with the information.
How Do We Use the Employment Information We Collect?
We need to process Employment Information in order to enter into and meet our obligations under an employment contract with you. For example, to pay you in accordance with your employment contract and to administer employee benefits, pension and insurance entitlements.
In some cases, we need to process Employment Information to ensure we comply with our legal obligations. For example, we are required to check an employee’s entitlement to work, to deduct taxes, to comply with health and safety laws and to enable employees to take periods of leave to which they are entitled.
In other cases, Cygnacom has a legitimate interest in processing Employment Information before, during and after the employment relationship has concluded for one or more of the purposes set forth below:
Employment Information about health or medical conditions that is categorized as “sensitive personal data” is processed to carry out employment, social security and social protection legal obligations such as those in relation to employees with disabilities.
Where Cygnacom processes other sensitive personal data, such as information about ethnic origin, sexual orientation, religion or belief, this is done for the purpose of equal opportunity monitoring. This sensitive personal data is anonymized or is collected with the express consent of employees and consent can be withdrawn at any time. Employees are free to decide whether or not to provide such sensitive personal data and there are no consequences for failure to do so.
Does Cygnacom Share and Disclose Employment Information?
Cygnacom may share and disclose Employment Information in the following limited circumstances:
Cygnacom will never sell, rent or lease your personal data to a third party.
Keep Your Employment Information Accurate
Cygnacom will do its best to maintain accurate and up to date records with respect to Employment Information. Please notify us if your personal details change (e.g., change of address, emergency contact details, emergency contacts, dependents, beneficiaries) or if you become aware of any inaccuracies in the personal data we hold about you.
How Long Do We Retain Employment Information?
Cygnacom will retain Employment Information for as long as necessary for the purpose in which it was collected and subject to local law. Cygnacom may also retain Employment Information as necessary to comply with our legal obligations, resolve disputes, pursue legitimate business interests, conduct audits and protect or enforce our rights.
How Do We Protect Your Employment Information?
Cygnacom uses appropriate technical, organizational and administrative security measures to protect your personal data from loss, misuse, unauthorized access, disclosure, alteration, and destruction. These security measures are designed to provide a level of security appropriate to the risk of processing your personal data.
Storage and International Data Transfers
The personal data that Cygnacom collects from you may be transferred to and/or stored at a destination other than the one in which your personal data was collected. This may be necessary as our organizational structure and management teams are located across a number of offices around the globe. Certain privacy and data protection laws require data controllers to put in place safeguards to protect personal data transferred across borders. To comply with this requirement, Cygnacom has put in place agreements that include the standard contractual clauses recommended by the European Commission to provide adequate safeguards for personal data.
What Rights Do You Have With Respect to Your Employment Information?
Depending upon the applicable data protection law in your country of residency, you may have the right to ask Cygnacom for information relating to personal data about you we control and process; to correct, delete, or restrict any active processing of your personal data; and/or to obtain a copy of your personal data in a structured, machine readable format, and to ask us to share this personal data with another controller.
Additionally, you can object to the processing of your personal data in some circumstances (in particular, where we don’t need to process the information to meet a contractual or other legal requirement). These rights may be limited, for example, if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests to keep (e.g., for purposes of fraud prevention).
If Cygnacom has collected and processed your personal data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data on lawful processing grounds other than consent.
What If You Do Not Provide Employment Information?
If you do not wish to provide Employment Information that we request directly from you or with your consent from third parties, this may prevent Cygnacom from administering rights and obligations arising from the employment relationship appropriately and effectively. If you have any concerns with respect to providing specific information or providing consent for Cygnacom to contact a third party for specific information, please contact Human Resources. HR can provide you more detail about the nature and purpose of the information requested and how your failure to provide the information may impact you.
Amendments to the Employee Privacy Statement
We reserve the right to amend this Employee Privacy Statement from time to time as our business, laws, regulations and industry standards evolve.
This Employee Privacy Statement is not intended to replace other notices provided by Cygnacom in accordance with national and local laws and regulations. In the event of any conflict between this Statement and other notices required by local law, the notices required by local law will prevail. This Employee Privacy Statement applies to the processing of Employment Information by or on behalf of Cygnacom anywhere in the world.
If you have questions or concerns about this Employee Privacy Statement or our handling of your personal data, please contact us using our online form. We will do our best to answer your questions and address your concerns.