At RWS we may have to collect and use information about people with whom we work with. This personal information whether it be on paper, in computer records or recorded by any other means is handled and dealt with properly.
We regard the lawful and correct treatment of personal information as very important to our successful operation and to maintaining confidence between us and those with whom we carry out business. We will ensure that we treat personal information lawfully and correctly.
To this end we fully endorse and adhere to the strictest applicable data protection regulations.
The processing of personal data in manual and electronic records kept by us in connection with our human resources function as described below. It also covers our response to any data breach and other user rights.
This policy applies to the personal data of job applicants, existing and former employees, apprentices, interns, workers and self-employed contractors. These are referred to in this policy as relevant individuals.
“Personal data” is information that relates to an identifiable person who can be directly or indirectly identified from that information, for example, a person’s name, identification number, location, online identifier. It can also include pseudonymized data.
“Criminal offense data” is data which relates to an individual’s criminal convictions and offenses.
“Data processing” is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
C) DATA PROTECTION PRINCIPLES
We ensure that: processing will be fair, lawful and transparent, with data collected for specific, explicit, and legitimate purposes. Data collected will be relevant and limited to what is necessary for the purposes of processing data and will be kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay. Data is not kept for longer than is necessary for its given purpose and will be processed in a manner that ensures appropriate security of personal data including protection against unauthorized or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organization measures complying with the applicable regulations for transferring of personal data.
D) EMPLOYEE RIGHTS
You have the following rights in relation to the personal data we hold on you:
- the right to be informed about the data we hold on you and what we do with it;
- the right of access to the data we hold on you. More information on this can be found in the section headed “Access to Data” below; the right
- for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known as ‘rectification’;
- the right to have data deleted in certain circumstances. This is also known as ‘erasure’;
- the right to restrict the processing of the data;
- the right to transfer the data we hold on you to another party. This is also known as ‘portability’;
- the right to object to the inclusion of any information;
- the right to regulate any automated decision-making and profiling of personal data.
In order to protect the personal data of relevant individuals, those within our business who must process data as part of their role have been made aware of our policies on data protection.
F) LAWFUL BASES OF PROCESSING
We acknowledge that processing may be only be carried out where a lawful basis for that processing exists and we have assigned a lawful basis against each processing activity.
Where no other lawful basis applies, we may seek to rely on the employee’s consent in order to process data.
However, we recognize the high standard attached to its use. We understand that consent must be freely given, specific, informed and unambiguous. Where consent is to be sought, we will do so on a specific and individual basis where appropriate. Employees will be given clear instructions on the desired processing activity, informed of the consequences of their consent and of their clear right to withdraw consent at any time.
G) ACCESS TO DATA
As stated above, employees have a right to access the personal data that we hold on them. To exercise this right, employees should make a request to [email protected]. We will comply with the request without delay, and within one month. Those who make a request will be kept fully informed of any decision to extend the time limit.
No charge will be made for complying with a request unless the request is manifestly unfounded, excessive or repetitive, or unless a request is made for duplicate copies to be provided to parties other than the employee making the request. In these circumstances, a reasonable charge will be applied.
H) DATA DISCLOSURES
The Company may be required to disclose certain data/information to any person. The circumstances leading to such disclosures include:
any employee benefits operated by third parties;
disabled individuals – whether any reasonable adjustments are required to assist them at work;
individuals’ health data – to comply with health and safety or occupational health obligations towards the employee;
for applicable statutory purposes;
HR management and administration – to consider how an individual’s health affects his or her ability to do their job;
the smooth operation of any employee insurance policies or 401k plans;
to assist law enforcement or a relevant authority to prevent or detect crime or prosecute offenders;
or to assess or collect any tax or duty.
These kinds of disclosures will only be made when strictly necessary for the purpose.
I) DATA SECURITY
All our employees are aware that hard copy personal information should be kept in a locked filing cabinet, drawer, or safe.
Employees are aware of their roles and responsibilities when their role involves the processing of data. All employees are instructed to store files or written information of a confidential nature in a secure manner so that are only accessed by people who have a need and a right to access them and to ensure that screen locks are implemented on all PCs, laptops etc when unattended. No files or written information of a confidential nature are to be left where they can be read by unauthorized people.
Where data is computerized, it should be coded, encrypted or password protected both on a local hard drive and on a network drive that is regularly backed up. If a copy is kept on removable storage media, that media must itself be kept in a locked filing cabinet, drawer, or safe.
Employees must always use the passwords provided to access the computer system and not abuse them by passing them on to people who should not have them.
Personal data relating to employees should not be kept or transported on laptops, USB sticks, or similar devices, unless prior authorization has been received. Where personal data is recorded on any such device it should be protected by:
ensuring that data is recorded on such devices only where absolutely necessary.
using an encrypted system — a folder should be created to store the files that need extra protection and all files created or moved to this folder should be automatically encrypted.
ensuring that laptops or USB drives are not left where they can be stolen.
Failure to follow the Company’s rules on data security may be dealt with via the Company’s disciplinary procedure. Appropriate sanctions include dismissal with or without notice dependent on the severity of the failure.
J) THIRD PARTY PROCESSING
Where we engage third parties to process data on our behalf, we will ensure, via a data processing agreement with the third party, that the third party takes such measures in order to maintain the Company’s commitment to protecting data.
K) INTERNATIONAL DATA TRANSFERS
The Company may be required to transfer personal data to a country/countries outside of the US.
L) REQUIREMENT TO NOTIFY BREACHES
All data breaches will be recorded on our Data Breach Register. Where legally required, we will report a breach within 72 hours of discovery. In addition, where legally required, we will inform the individual whose data was subject to breach.
The Company keeps records of its processing activities including the purpose for the processing and retention periods in its HR Data Record. These records will be kept up to date so that they reflect current processing activities.
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