Privacy Policy

This Privacy Policy applies to you if you provide your Personal Data to Teledirect to apply for employment in Teledirect. Teledirect will Process your Personal Data if you are (1) an applicant for employment or (2) an employee of Teledirect.

Please read this Privacy Policy carefully. Do not submit your Personal Data to Teledirect if you do not agree with any part of the Privacy Policy.


Definitions

Personal Data


Any data or information about you from which you may be identified or identifiable. Examples of your Personal Data: name, identification number, location data, online identifier, identification traits that are generic, cultural, etc.


Processing


Operations on Personal Data, including by automation. Examples of processing: collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, alignment, combination, erasure, destruction.


Purpose


One or more of the following acts:

1.

Consider you for future employment or continued employment

2.

Contact you

3.

Assess your suitability for employment

4.

Undertake recruiting campaigns, surveys or polls

5.

Formulate an offer of employment

6.

Manage the employment, if you are hired

7.

Provide benefits through third parties selected by Teledirect

8.

Comply with applicable law

9.

Comply with Teledirect policies

10.

Survey Teledirect employees after anonymizing your Personal Data

11.

Retain for future employment opportunities in Teledirect if you are not hired or if you leave Teledirect


Teledirect


Any one or more companies in the Teledirect Group of Companies.


Personal Data

1.

When you apply for employment, you will provide your Personal Data to Teledirect. We only collect data about you that is strictly necessary and relevant with a view to the performance of the job you are applying for.

If you fail to provide information which is necessary for us to consider your application (such as evidence of qualifications, work history, work permit, etc.), we may not be able to process your application successfully.

2.

Teledirect is the controller and processor of your Personal Data. Teledirect will Process your Personal Data for the Purpose in compliance with applicable law and this Privacy Policy as amended from time to time.

3.

Teledirect may use automated decision-making to Process your Personal Data for the Purpose. In such case, the logic of the automated decision-making as well as the criteria on which it relies will be explained to you. You will also be asked to give your prior consent.

4.

Teledirect will retain your Personal Data in electronic form.

5.

Teledirect may transfer your Personal Data out of your country of residence (including the European Economic Area) and/or disclose your Personal Data for the Purpose under conditions of confidentiality and similar levels of security safeguards as in the country of your residence to the following persons:

a.

Teledirect’s agents, contractors, third party providers and their sub-contractors that provide administrative, telecommunications, information technology, recruitment, medical and insurance services to Teledirect in any part of the world

b.

Teledirect recruitment and operations teams

c.

Teledirect clients for them to assess your suitability for their projects, in the event that the position is intended to provide services to a specific client or within the framework of a specific project. In that case, we will make sure that the client only uses your personal data in order to evaluate you for the position and that in case you are ultimately unsuccessful in obtaining this position the client will erase any of your personal data that has been provided

e.

Third party providers to do background checks on you, where background checks are not prohibited by law

f.

Persons legally entitled to have your Personal Data

All our affiliates and third-party service providers are required to comply with data protection laws and implement appropriate security measures to protect your Personal Data in line with our policies. 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 and subject to a duty of confidentiality.

In addition, we may share your Personal Data obtained through the online assessment with other entities of the Teledirect group in order to evaluating you for the position. When sharing your Personal Data with other entities in our group, we will apply the provisions of the Binding Corporate Rules (BCR) approved by the entities of our group, which are legally binding for all of them.

The BCRs are published on the external Teledirect website accessible at www.teledirectgroup.com/policies/bcr.

6.

If you refer a candidate to Teledirect, please provide the referred candidate’s written consent for Teledirect to Process his/her Personal Data for the Purpose. If the referred candidate revokes his/her consent to Processing of their Personal Data, please immediately inform Teledirect.

7.

Referred candidates must agree to the Teledirect Privacy Policy to permit Teledirect to Process their Personal Data to evaluate their application.

8.

Teledirect will retain your Personal Data if you are employed by Teledirect and for a period of 10 years after which it will be destroyed. If you are not recruited for the position that you applied for, Teledirect will retain your Personal Data for future recruitment possibilities unless you instruct us to delete your Personal Data. If you do not object to such records storage, we will keep your data for up to a maximum of two (2) years after our last professional contact.

If you object to such records storage, we will delete your record immediately if there is no obligation or legal right to keep the records. With this regard, we may have the legal right to archive your Personal Data for a longer period of time (corresponding to the applicable local statute of limitation) to defend ourselves in case of a dispute.

9.

Your rights and choices: In accordance with applicable data protection law and under certain circumstances, you have a right to access, rectify, delete, restrict, Personal Data as well as a right to portability, a right to object to the processing of your data, where this processing is based on our legitimate interest, and a right to withdraw your consent. Where we are relying on consent for the processing of your Personal Data, you also have the right to withdraw your consent for processing for that purpose at any time. To do so, please contact Teledirect Human Resources/Corporate Recruitment at recruitment@teledirectgroup.com or change your Personal Profile on the corporate HR system yourself. If you revoke your consent, it will adversely affect your potential or continued employment with Teledirect

10.

You may inquire how Teledirect has used or disclosed your Personal Data by writing to the Teledirect Privacy Officer at privacy@teledirectgroup.com.

11.

Teledirect may decline to allow you to access, rectify or erase some or all of your Personal Data under any of the following circumstances:

a.

Teledirect has a legal obligation or the right to deny your request.

b.

The burden or expense of providing access would be unreasonable for Teledirect.

c.

Your request is trivial, frivolous or vexatious.

d.

Your request is clearly unfounded or excessive (which means, for example, more than once in 6 months unless there is a legitimate reason.

e.

The Personal Data does not exist or cannot be found.

f.

The Personal Data is subject to legal privilege.

g.

The Personal Data would reveal confidential commercial information that could harm the competitive position of Teledirect.

h.

If it is necessary and proportionate and the Personal Data was collected, used or disclosed for the purposes of an investigation if the investigation and associated proceedings and appeals have not been completed.

i.

It could threaten the safety or physical or mental health of an individual.

j.

It could cause immediate or grave harm to an individual’s safety or physical or mental health.

k.

It could reveal the Personal Data of another individual.

l.

It could reveal the identity of an individual who has provided Personal Data and the individual providing the Personal Data does not consent to the disclosure of his/her identity. Teledirect will provide a summary of the Personal Data if it is possible to do so without revealing the Personal Data of the other individual, unless that individual consents to the disclosure of his/her identity.

m.

It could be contrary to the national interest of a friendly country.

12.

You may not rectify or erase the Personal Data that Teledirect relied upon to assess your suitability for employment. Teledirect may take appropriate legal action if you represent false information as your Personal Data.

13.

Teledirect uses cookies to track and analyze your use of the Teledirect website. By using this website, I agree to its use of cookies.


Personal Data

The following section only applies to candidates entering employment with Teledirect Telecommerce Sdn Bhd, Malaysia and who are not residents in the European Union.


Employee Personal Information Collection Statement for Corporate Benefits Purposes

1.

In this Statement,
“Personal Information” means personally identifiable data about you including information or data provided by you or other parties or from other sources, historical or existing data and/or data to be collected in the future. Such Personal Information may be subject to applicable data protection, privacy and other similar laws and may include copies and other details of identity documents, proof of address and other contact details, religious, philosophical or political affiliations, information concerning age, marital status, racial or ethnic origin, education, genetic or sexual life, physical or mental health or medical condition/diagnosis, dietary preference, commission or alleged commission of any offence or proceedings for any offence committed or alleged to have been committed, the disposal of such proceedings or the sentence of any court in such proceedings.

“Third Party Provider” means any provider chosen by Teledirect Telecommerce Malaysia Sdn Bhd from time to time to provide medical and other benefits to its employees.

2.

Personal Information you provide will be collected, used and otherwise processed by the Third Party Provider for the following purposes:

a.

client relationship management procedures between the Third Party Provider and Teledirect, including any potential conflict checks as may be required;

b.

the delivery of services or products to Teledirect and its employees by Third Party Providers;

c.

those purposes specifically provided for in any particular service or product offered by Third Party Providers

d.

conducting marketing and profiling activities of Teledirect in connection with insurance, other benefits and related services and products (including all selected third parties for the purpose of improving their services to Teledirect);

e.

credit assessments and other background checks of Teledirect employees as the Third Party Provider may determine to be necessary or appropriate;

f.

Third Party Providers’ internal record-keeping;

g.

collection of outstanding payments from Teledirect;

h.

prevention of crime (including but not limited to fraud, money-laundering, bribery);

i.

meeting any legal or regulatory requirements relating to Third Party Providers’ provision of services and products and to make disclosure under the requirements of any applicable law, regulation, direction, court order, by-law, guideline, circular, code applicable to the Third Party Provider or its affiliates; and

j.

purposes ancillary or relating to any of the above (including but not limited to information relating to the Teledirect insurance program for research, benchmarking and statistical analysis).

3.

Third Party Providers may provide or disclose the Personal Information to their affiliates for the purposes stated in paragraph 2 above.


Collection and Disclosure

4.

Personal Information provided to Third Party Providers will generally be kept confidential but you hereby consent and authorize the Third Party Providers to collect, provide or disclose your Personal Information for the purposes stated in paragraph 2 above to:

a.

any person to whom they are compelled or required to do so under law or in response to a competent court or government agency;

b.

relevant parties arranging insurance or providing claims services or benefits administration services or wellness services such as insurance companies, health maintenance organisations, agents and service providers (including but not limited to consultants, service call centres, market research and quality assurance companies);

c.

the Third Party Providers’ affiliates;

d.

government agencies and industry regulators;

e.

the Third Party Providers’ auditors, accountants, lawyers or other financial or professional advisers; and

f.

such sub-contractors or third party service or product providers as the Third Party Provider may determine to be necessary or appropriate, in accordance with paragraph 2 and paragraph 7.

g.

Such person(s) as the Third Party Providers or Teledirect may instruct or require.

5.

You further consent to provide, and for your employer, insurer(s), health maintenance organizations, agents and/or third party service or product provider(s) to provide to the Third Party Providers, your Personal Information for the purposes set out in paragraph 2 above.

6.

Failure to provide the Personal Information may result in any of the Third Party Providers being unable to provide you with the services and/or products requested by Teledirect to be provided to you (including but not limited to covering costs for claims and bills). Failure to provide the Personal Information may result in any of the Third Party Providers being unable to provide you with the services and/or products requested by Teledirect to be provided to you (including but not limited to costs for claims and bills). The cost of any service and/or product that you obtain from such Third Party Providers or from other providers and that will not be covered by the Third Party Provider due to your failure to provide the Personal Information will not be borne by Teledirect.


Safeguards

7.

The Third Party Providers confirm that they have implemented the appropriate administrative and security safeguards and procedures in accordance with the applicable laws and regulations to prevent the unauthorized or unlawful processing of your Personal Information and the accidental loss or destruction of, or damage to, your Personal Information.


Data Transfer

8.

Where a Third Party Provider considers it necessary or appropriate for the purposes of data storage or processing or providing any service or product on our behalf to you, we may transfer your Personal Information to an affiliate or third party service or product providers within or outside the country in which the Third Party Provider is established, under conditions of confidentiality and similar levels of security safeguards.


Your Rights of Access and Correction

9.

You have the right to request access to and correction of information about you held by a Third Party Provider and you may:

a.

check whether a Third Party Provider holds or uses your Personal Information and request access to such data;

b.

request that the Third Party Provider correct any of your Personal Information that is inaccurate, incomplete or out-of-date;

c.

request that the Third Party Provider specify or explain its policies and procedures in relation to data and types of Personal Information handled by them; and

d.

communicate to the Third Party Provider your objection to the use of your Personal Information for marketing purposes whereupon they will not use your Personal Information for these purposes; and

e.

withdraw, in full or in part, your consent given previously,

f.

in each case subject to any applicable legal restrictions, contractual conditions, reasonable internal policies/procedures, a reasonable time period (in accordance with applicable laws) as well as, in the case of an access request, a reasonable fee (where permitted under applicable laws and as the Third Party Provider may notify you in writing upon receipt of your request).

10.

Written requests for access to Personal Information or correction and/or deletion of Personal Information or for information regarding policies and procedures and types of Personal Information handled by a Third Party Provider may be sent to privacy@teledirectgroup.com I have fully read and understood the terms and conditions set out in this Personal Information Collection Statement and consent to collection, use, transfer and processing of my Personal Information by any Third Party Provider selected by Teledirect in accordance with the terms of this Personal Information Collection Statement. I understand that I may obtain the names of the Third Party Providers from the Teledirect intranet or the local HR team or the Teledirect Privacy Officer under above mentioned email, once I receive a written offer for employment or have entered into employment with Teledirect Telecommerce Sdn Bhd, Malaysia.


Privacy Notice

This Privacy Notice applies to you if you are located in the EEA and are an employee, worker or consultant of Gascaquen Teledirect S.A (Teledirect). Teledirect is the controller and processor of your Personal Data.

We are committed to protecting the privacy and security of your Personal Data. This Privacy Notice describes how we collect and use Personal Data about you during and after your working relationship with us, in accordance with the General Data Protection Regulation (GDPR).

Please read this Privacy Notice carefully.


Data Protection Office [Manager]

We have appointed a Data Protection Officer [Manager] to oversee compliance with this Privacy Notice. If you have any questions about this Privacy Notice or how we handle your Personal Data, please contact the Data Protection Officer on DPO@teledirectgroup.com or +34 932 710 121. You have the right to make a complaint at any time to the Agencia Española de Protección de Datos (“AEPD”), the Spanish supervisory authority which we have selected to oversee our data protection issues.


Data Protection Principles

Teledirect will comply with the GDPR and other relevant data protection law. The GDPR says that the Personal Data we hold about you must be:

1.

Used lawfully, fairly and in a transparent way.

2.

Collected only for valid purposes that we have explained to you and not used in any way that is incompatible with those purposes.

3.

Relevant to the purposes we have told you about and limited only to those purposes.

4.

Accurate and kept up to date.

5.

Kept only as long as necessary for the purposes we have told you about.

6.

Kept securely.


Definitions

Group means the group of Teledirect (Teledirect) companies referred to in this policy, namely Agorae Pte Ltd (Singapore); Gascaquen Teledirect, SA (Spain); Teledirect Pte Ltd (Singapore); Teledirect Telecommerce Ltd (Philippines) Inc; Teledirect Telecommerce (Thailand) Ltd; Teledirect Telecommerce Sdn Bhd (Malaysia); KK Teledirect Japan; Agorae Information Consulting (Beijing)Co., Ltd; Teledirect Hong Kong Ltd, which together are referred to as “the Teledirect Group” or “group”. References to “our group” means references to companies in the Teledirect Group.

Personal Data means information about you which identifies you directly or indirectly. Examples of your Personal Data are: name, identification number, location data, online identifier, identification traits that are physical, physiological, genetic, mental, economic, cultural or social.

There are also "special categories" of more sensitive Personal Data which require a higher level of protection, such as information about your health or religion.

Processing means operations on Personal Data, including by automation. Examples of processing include: collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, alignment, combination, restriction, erasure, destruction.


The Kinds Of Personal Data We Will Hold About You

We will collect, store, and use the following categories of your Personal Data:

  • Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses;

  • Date of birth, country of birth and nationality;

  • Gender;

  • Marital status and dependants;

  • Next of kin and emergency contact information;

  • Bank account details, payroll records and tax status information;

  • Salary, annual leave, pension and benefits information;

  • Employment start date;

  • Employment leaving date and your reason for leaving;

  • Location of employment or workplace;

  • Copy of passport; Passport/NIE number

  • User name and password

  • Recruitment information (including copies of right to work documentation, references and other information included as part of the application process the information provided through your online assessment and (subject to your consent) the recording of your video interview);

  • Employment records (including job titles, work history, working hours, holidays, training records and professional memberships);

  • Remuneration history;

  • Performance information;

  • Disciplinary and grievance information;

  • CCTV footage and other information obtained through electronic means such as swipe card records;

  • Photographs; and

  • Results of employment status checks


We may also collect, store and use the following "special categories" of more sensitive Personal Data:

  • Information about your race or ethnicity;
  • Information about your health, including any medical condition, health and sickness records, including:
    • details of any absences (other than holidays) from work including time on statutory parental leave and sick leave; and
  • Information about criminal convictions and offences (where relevant to your role and allowed by law).

How Teledirect collects Personal Data about you

We collect Personal Data about employees, workers and contactors through the application and recruitment process, either directly from candidates or sometimes from an employment agency or background check provider.

We will collect additional Personal Data in the course of job-related activities throughout the period that you work for us.


When Teledirect will process your Personal Data.

We will only use your Personal Data as permitted by the law, most commonly:

1.

Where we need to perform the employment or services contract we have entered into with you.

2.

(In limited circumstances), where we have your consent.

3.

Where we need to comply with a legal obligation.

4.

Where it is necessary for our legitimate interests as your employer (or the legitimate interests of a third party) and your interests and fundamental rights do not override those interests

We may also use your Personal Data in the following situations, which are likely to be rare:

5.

Where we need to protect your interests (or someone else's interests) such as in a medical emergency in which you are incapacitated or otherwise incapable of giving consent.

6.

Where it is needed in the public interest or for official purposes.


Situations in which we will use your Personal Data:

We need all the categories of Personal Data in the list above primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases we may use your Personal Data to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests.

The purposes for which we will process your Personal Data are listed below.

  • Assessing your suitability for employment and making a decision about your recruitment or appointment;

  • Determining the terms on which you work for us;

  • Checking you are legally entitled to work in the country in which you are based;

  • Contacting you

  • Managing your employment with Teledirect, and administering the contract we enter into with you, for example,

    • Paying you and, if you are an employee or deemed an employee for tax purposes, deducting tax and any other necessary deductions;

    • Providing benefits to you through third parties selected by Teledirect

    • [Where relevant, enrolling you in a pension arrangement;

    • Liaising with the trustees or managers of a pension arrangement operated by a group company, your pension provider and any other provider of employee benefits;]

    • Conducting performance reviews, managing performance and determining performance requirements

    • Making decisions about salary reviews and compensation;

    • Assessing your qualifications for a particular job or task, including decisions about promotions

    • Assessing education, training and development requirements;

    • Monitoring your use of our information and communication systems to ensure compliance with our IT policies;

    • Ensuring network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution;

    • Dealing with legal disputes involving you, or other employees, workers and contractors, including accidents at work

    • Ascertaining your fitness to work

    • Managing sickness absence

    • Gathering evidence for possible grievance or disciplinary hearings

    • Making decisions about your continued employment or engagement

    • Making arrangements for the termination of our working relationship;

  • Preventing fraud;

  • Carrying out business management and planning, including accounting and auditing;

  • Conducting data analytics studies to review and better understand employee retention and attrition rates

  • Complying with applicable law

  • Complying with Teledirect policies

  • Undertaking recruitment campaigns, surveys or polls

  • Surveying Teledirect employees after anonymising your Personal Data

  • If you give us your consent, retaining your Personal Data for future employment opportunities in Teledirect if you leave Teledirect.

  • For the legitimate interests of Teledirect, Teledirect Group, or a third party, provided those interests are not overridden by your interests, fundamental rights and freedoms.

Some of these Purposes will overlap and there may be several grounds which justify Teledirect’s use of your Personal Data.


How We Use Particularly Sensitive Personal Data

"Special categories" of particularly sensitive Personal Data require higher levels of protection. We need to have further justification for collecting, storing and using this type of Personal Data. We may process special categories of Personal Data in the following circumstances:

1.

In limited circumstances, with your explicit written consent.

2.

Where we need to carry out our legal obligations or exercise rights in connection with your employment.

3.

Where it is needed in the public interest, such as for equal opportunities monitoring.


Our obligations as an employer

We will use your particularly sensitive Personal Data in the following ways:

  • We will use information relating to leaves of absence, which may include sickness absence or family-related absences, to comply with employment and other laws;
  • We will use information about your physical or mental 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; and

Do We Need Your Consent?

We do not need your consent if we use special categories of your Personal Data to carry out our legal obligations or exercise specific rights in the field of employment law.

In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data, in case there is a legal legitimacy for such processing. If we do so, we will provide you with full details of the information that we would like to process and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.


Information About Criminal Convictions

We will only seek information about criminal convictions if it is appropriate given the nature of the role to be performed and where we are legally able to do so. Where specifically permitted, we will carry out a criminal background check as part of the recruitment process [and give you the opportunity to comment on any conviction that is revealed. We will only retain a record of whether or not the results of any checks were satisfactory.]

We will use information about criminal convictions and offences in order to comply with applicable laws and regulations. We have in place appropriate safeguards when processing such data.


Change Of Purpose

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.


If You Fail To Provide Personal Data

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations.


Automated Decision-Making

Teledirect may use automated decision-making to process your Personal Data for the purposes set out above. Teledirect will only take a decision based solely on automated processing which has a significant impact upon you,

  • if we notify you of the decision and give you [21] days to request a person to reconsider the decision

  • where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights

  • in limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights

    We will only make an automated decision on the basis of any particularly sensitive Personal Data if we have your explicit written consent and it is justified in the public interest, and we have put in place appropriate measures to safeguard your rights.

    You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.


Data Sharing
Why might you share my Personal Data with third parties?

We will share your Personal Data with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.


Which third-party service providers process my Personal Data?

"Third parties" includes third-party service providers (including contractors and designated agents) and other entities within our group.

The following third-party service providers process Personal Data about you for the following purposes:

Third party Activity carried out for Teledirect Spain
Edenred España S.A Management of company benefits
Programas Educativos ARVA S.L.1 (Expanish) Management of company benefits
DIR Corporate Gym Management of company benefits
IURIS Laboral Rambla S.L Management of payroll
Mapfre / Sanitas Management of company benefits
WeWork Building access

How secure is my information with third-party service providers and other entities in our group?

All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your Personal Data in line with our policies. 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.


When might you share my Personal Data with other entities in the group?

We may share your Personal Data with other entities in our group as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, for system maintenance support and hosting of data.

When sharing your Personal Data with other entities in our group, we will apply the provisions of the Binding Corporate Rules (BCR) approved by the entities of our group, which are legally binding for all of them.

The objective of the BCRs is to provide adequate protection for the transfers and processing of Personal Data by Teledirect staff and entities in the Teledirect Group, its companies, subsidiaries, affiliates and any other entity under its ownership or control.

The BCRs explain how this commitment is implemented by the Teledirect Group throughout its operations. They specifically set out Teledirect’s approach to transfers of Personal Data between entities in the Teledirect Group and apply to Teledirect’s operations worldwide.

The BCRs are communicated to all Teledirect employees and are published on the external Teledirect website accessible at www.teledirectgroup.com/policies/bcr.


What about other third parties?

We may share your Personal Data with other third parties, for example in the context of the possible sale or restructuring of the business. In this situation we will, so far as possible, share anonymised data with the other parties before the transaction completes. Once the transaction is completed, we will share your Personal Data with the other parties if and to the extent required under the terms of the transaction.

We may also need to share your Personal Data with a regulator or to otherwise comply with the law. This may include government authorities, disclosures to stock exchange regulators and disclosures to shareholders such as directors' remuneration reporting requirements.


Transferring information outside the EEA

Teledirect may transfer your Personal Data out of your country of residence (including the European Economic Area) and/or disclose your Personal Data for the purposes explained above under conditions of confidentiality and similar levels of security safeguards as in the country of your residence to the following persons:

  • Teledirect recruitment, administration and operations teams.

  • Teledirect clients for them to assess your suitability for their projects and to administer access to their systems and email, where necessary.

  • Teledirect’s agents, contractors, third party providers and their sub-contractors that provide administrative, telecommunications, information technology, recruitment, medical and insurance services to Teledirect in any part of the world.

  • Third party providers to do background checks on you, where background checks are not prohibited by law.

  • Persons legally entitled to have your Personal Data.

We have put in place the following appropriate measures to ensure that your Personal Data is treated in a way that is consistent with and which respects data protection law under the GDPR:

  • For international transfers within the organisation, we have put in place Binding Corporate Rules. These are internal rules to allow us to transfer data to various branches, outstations and offices within the organisation regardless of which country they are based in and ensure that a high standard of data protection will be observed within our group.

  • For international transfers to third-parties in countries which have not been deemed to provide an adequate level of data protection, we will put in place data protection clauses in the contracts between us and those third parties. This will ensure that those third parties observe the same high standards of data protection as we do.

If you require further information about these protective measures, you can request it from our [Data Protection Officer].


Data Retention

We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements, unless you have withdrawn the consent on which the processing is based, and the use of the data is not based on another legal basis. We will retain your Personal Data during your employment with Teledirect and for a period of 10 years, after which it will be securely destroyed. Unless it is needed to prove the commission of acts against individuals, property, or facilities, CCTV footage is retained for a maximum of one month, after which it is deleted.


Employee Personal Use Of Company Equipment Or Devices
  • Email and other computer files are provided by Teledirect as a working tool and must be used for working purposes only.

  • Use of computer facilities for personal reasons is strictly prohibited (personal use may be permitted subject to approval).

  • All computer passwords and codes must be available to Teledirect at all times.

  • No employee may add unauthorized or pirated software or files to any machine owned by Teledirect.

  • To avoid viruses, employees may not use computer files or software brought from home or other sources on the business computer. Likewise, the installation by employees of computer programs, or private or non-company mail accounts is strictly forbidden.

  • Software or other business information on the computer should not be copied and taken from the business premises without permission.

  • The copying, reproduction, distribution and use for specific purposes of Teledirect’s database, as well as any other computer and document support, is expressly prohibited.

  • Teledirect reserves the right to enter, search, and monitor the computer files or email of any employee, without advance notice, for business purposes such as investigating theft, disclosure of confidential business information, personal abuse or illicit use of the system or monitoring fulfilment of job responsibilities. In any event, this search will be carried out in working hours and in the presence of the work council, if any, and respecting the guarantees established in the applicable labor legislation.

  • The breach of these rules by employees will determine the use by the Company of the additional means it considers appropriate to restrict the misuse, as well as the application of the disciplinary regime that may apply.


Your Rights In Relation To Your Personal Data

1.

By law, you have the right to:

  • Request access to your Personal Data (commonly known as a "data subject access request"). This enables you to receive a copy of the Personal Data we hold about you, know how your data is processed and to check that Teledirect is lawfully processing it;

  • Request correction of the Personal Data that Teledirect holds about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;

  • Request erasure of your Personal Data. This enables you to ask Teledirect to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below);

  • Under certain circumstances, object to processing of your Personal Data where Teledirect is relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. [You also have the right to object where we are processing your Personal Data for direct marketing purposes, for which you must have given your prior consent];

  • Under certain circumstances, request Teledirect to restrict processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it; and

  • Request the transfer of your Personal Data to another party.

  • In case you consider that your rights have not been properly addressed, you could file a claim with the supervisory authority, the Agencia Española de Protección de Datos (AEPD) through its website: https://sedeagpd.gob.es/sede-electronica-web/vistas/formNuevaReclamacion/claim.jsf.

If you want to review, verify, correct or request erasure of your Personal Data, object to the processing of your Personal Data, or request us to transfer a copy of your Personal Data to another party, please contact [our Data Protection Officer in writing]. [To do so, please contact [Teledirect Human Resources/Corporate Recruitment at recruitment@teledirectgroup.com]. [You can also update certain Personal Data by changing your Personal Profile on the corporate HR system yourself.]

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.


What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that your Personal Data is not disclosed to any person who has no right to receive it.

2.

Teledirect may decline to allow you to access, rectify or erase some or all of your Personal Data under any of the following circumstances:

  • Teledirect has a legal obligation or the right to deny your request.

  • If your request is clearly unfounded or excessive (which means, for example, more than once in 6 months unless there is a legitimate reason); Teledirect can demonstrate that it is not in a position to identify you. [The Personal Data does not exist or cannot be found.]

  • If it is necessary and proportionate and the Personal Data was collected, used or disclosed for the purposes of

    • preventing, detecting, investigating and prosecuting criminal offences and execution of criminal penalties

    • establishing, exercising or defending a legal claim, prospective legal claim, legal proceedings or prospective legal proceedings

    • an investigation [if the investigation and associated proceedings and appeals have not been completed.]

  • If exercising those rights would be likely to cause serious harm to your safety or physical or mental health (for as long that is the case).

  • If providing information to you could reveal the Personal Data of another individual, Teledirect will provide a summary of the Personal Data if it is possible to do so without revealing the Personal Data of the other individual, unless that individual consents to the disclosure of his/her identity.

3.

You may not rectify or erase the Personal Data that Teledirect relied upon to assess your suitability for employment. Teledirect may take appropriate legal action if you represent false information as your Personal Data.


Right To Withdraw Consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your Personal Data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our Data Protection Officer. Once we have received notice that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.


Data Security

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from our Data Protection Officer.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.


Changes To This Privacy Notice

We reserve the right to update this Privacy Notice at any time, and we will 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.



Last updated in July 2019

Click OK
to start the call
Cancel OK