This notice contains important information regarding the processing of your personal data by G2 Travel and all other subsidiaries of the G2 Travel Group (generally referred to as G2 Travel). Please read carefully all information provided below in order to properly understand how we process your Personal Data. To facilitate the reading of this notice, we have structured the information contained in it into several distinct sections:
General information on the protection of Personal Data
As you may already know, on 25 May 2018 the General Data Protection Regulation (EU) 2016/679 (GDPR) came into force. The GDPR mandates certain requirements and obligations relating to the processing of information that can lead to an identified individual (“Personal Data”). We are committed to ensure that our Personal Data privacy and security practices are in strict compliance with the provisions of the GDPR. As part of our commitment to the rights of individuals whose Personal Data we process, we provide below the relevant information on the purpose, the legal basis and the duration for which we process your Personal Data, who we share it with, as well as on the rights you are entitled to and how you can exercise those rights.
What Personal Data do we process?
In order to conduct your recruitment process or to conclude and to ensure the performance of our labour employment agreement with you, we are obliged to process the following types of data:
- Identification data (name, surname, photograph, employee’s unique registration number, personal numeric code, series and number of identity documents, civil status certificate, driving license); – Contact details (phone number, e-mail address, home, residence); – Financial data (bank account information, payroll records, tax status information); – Data about your education and previous employment history; – Data about family members in your care; – Employment-related medical data (medical certificate for employment, regular medical exams, medical leave, disability); – Data related to working time; – Data contained in your personnel file – such as start date, performance reviews, grievances; – Information collected for the purposes of your recruitment (copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process, such as past employment records, job titles, training records, professional certifications.
During the performance of the employment contract, by virtue of our legitimate interests, as detailed below, we may process the following types of data:
- History of the use of work equipment made available to you by us, such as the list of telephone conversations, logging history and event-logging in our systems, internet browsing history from our terminals within our network); – Your image captured by the video tracking devices within our premises or during the collective events organised by us for employees and collaborators or for clients and potential clients.
How do we collect your Personal Data?
Prior to your employment: We collect Personal Data about employees through the application and recruitment process, either directly from candidates or sometimes from an employment agency or background check provider. We may also collect additional information from third parties including former employers, credit reference agencies or other background check agencies or publicly available resources (such as social networks). During your employment: We will collect Personal Data in the course of job-related activities throughout the period of you working for us.
Why do we process your Personal Data?
We have a legal obligation to process part of your Personal Data (for example, to deduct taxes, to comply with anti-money laundering and bribery regulations). Additionally, processing is necessary for:
- Conduct during your recruitment process or to conclude and perform the mutual obligations under the individual labour employment agreement concluded with you (for example, making decisions regarding recruitment, employment or termination, supporting decisions regarding promotions, salary reviews and compensation, paying your salary and so on) – Where processing is necessary for our or your legimate interests, as mentioned above, such interests may include:
o To protect the safety and integrity of the premises, equipment, technologies and systems used by us, including for the purpose of protecting the Personal Data we hold; o To prevent unauthorised access to Personal Data and information held or accessed by us; o To prevent the deterioration and theft of fixed and mobile equipment owned by us or used by us as part of our activity, as well as protecting the life and integrity of the persons using the equipment; o For the continuous improvement of the products and services offered to our customers; o To ensure the satisfaction and retention of our personnel.
We may also process Personal Data when it is needed in the public interest or in protection of our rights, such as dealing with legal disputes, including incidents at work.
How do we use sensitive Personal Data?
Information about your health: We may use particularly sensitive Personal Data about your health in the following ways:
1. We will use information relating to leave of absence, which may include sickness absence or family related leave, to comply with employment and other laws. 2. We will use information about your health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits. 3. We will use information about your health to assist with your enrolment on our appointed benefit provider, as applicable.
Information about criminal convictions and offences: We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so. Where appropriate, we will collect information about criminal convictions as part of the recruitment process or we may be notified of such information directly by you in the course of you working for us. Your consent: In some circumstances we may approach you for written consent to allow us to process certain particularly sensitive Personal Data. If we do, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that this is not a condition of your contract with u that you agree to any request for consent from us.
How long do we retain your Personal Data?
In general, your Personal Data is processed for the duration necessary to fulfil the purposes we collect it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. For example, if you are an employee, we may retain your Personal Data for the duration of your labour employment agreement and store it for an additional period, in accordance with our general retention policy. Additional periods may be necessary to enable us to protect the rights conferred to us by the law for the period fiscal statute of limitation. However, we do not undertake to keep these data for the entire period mentioned above and we may delete or anonymise your Personal Data earlier if we do not have a legal obligation to keep them. We may set different retention periods for different aspects of your Personal Data, in order to determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use of disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
To whom do we disclose your Personal data?
We do not sell, transfer, disclose or allow access to your Personal Data to third parties not related to its activity. Where required by law, necessary to administer the working relationship with you or where we have another legitimate interest in doing so, we may have to share your Personal Data with third parties, including thirdparty service providers and other entities in the Company group. We require third-parties to respect the security of your Personal Data and treat it in accordance with the law. In order to achieve the goals described above, we may disclose your Personal Data to our suppliers of products and services, namely:
- providers of services and products involved in managing the work relationship between you and us – such as health care providers, health and safety at work, legal, tax or financial advisors, payment service providers, banks, suppliers of telecommunication services, travel agencies etc. – IT service providers assisting us or other entities in our group for the operation and maintenance of our systems and equipment;
We may also provide your contact details to any contractual partner to enable them to contact you in connection with the performance of the contract concluded by them with us. In all the cases described above, the disclosure of your Personal Data is limited to the Personal Data strictly necessary for the achievement of each purpose and is performed on the basis of a contract with the recipients of the data whereby they commit themselves to use the data solely for the purpose for which they were entrusted, to observe the obligation of confidentiality and to ensure the security of data, as well as to comply with all the provisions of the legislation in force regarding the protection of personal data.
Transferring Personal Data outside the EU?
We may transfer your Personal Data outside the EU; if we do you can expect a similar degree of protection in respect of your Personal Data. In cases where the entities in the group or the contractual partners to whom we disclose your Personal Data in the situations described above are located outside the European Economic Area, the disclosure shall be done only when the European Commission has confirmed an adequate level of protection for the respective country or if adequate protection measures have been implemented (for instance the application of standard EU contractual clauses). We may also disclose your Personal Data to public authorities, on the basis and within the limits of the legal provisions and as a result of requests expressly made by them. All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your Personal Data. We do not allow our third-party service providers to use your Personal Data for their own purposes. We only permit them to process your Personal Data for specified purposes and in accordance with our instructions.
What rights do you have and how can you exercise them?
The entry into force of the GDPR will ensure the following rights you which you may exercise free of charge:
- To be informed whether we process your Personal Data and what data is processed; – To request correction of processed data, if it is incorrect or incomplete; – To oppose to processing and to restrict the processing of your Personal Data for justified and legitimate reasons relating to your situation and only if the processing of such data is not a legal obligation for us or is not essential for the performance of the individual labour agreement; – To ask for the deletion of your Personal Data, except where the law forbids deletion or if the data is essential for the performance of the individual labour agreement. – To ask to receive your Personal Data in a structured commonly used and machine-readable format and to transmit the data to another party. As noted above, the exercising of these rights may be subject to regulatory requirements or our legitimate interests.
You may exercise the above rights by emailing your request to the Data Protection Officer at group level, Florin Marcu at [email protected] To protect your personal data and your interests, we may request additional information to identify you.
Protecting the privacy of your Personal Data
When processing your Personal Data, we use technical and organisational measures to ensure the confidentiality, availability and accuracy of your data. Personal data that benefits from special protection (personal identifiers, health data or data related family members, financial data) are processed under restrictive conditions and in accordance with the legal provisions applicable to this type of data, and we employ appropriate technical and organizational measures to protect them. However, no information security system is infallible. That is why we are working continuously to ensure that our security measures are kept at the highest level and we commit ourselves to inform you on time of any security incidents that could pose a significant risk to your rights.
Changes to this privacy notice
We reserve the right to update this privacy notice at any time and provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your Personal Data.