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Data Personal and Privacy Notice For Guardians

Safeguard Global and its affiliated entities (“Safeguard Global”, “we”, “us”) take the protection of personal data seriously. This Privacy Notice explains how personal data relating to its Guardians (“you”) and, in some cases as better detailed below, their respective dependents are processed in the context of our employment relationship and internal business operations.

For the purposes of this Privacy Notice, “Guardians” means individuals who are internal employees of Safeguard Global.

This Notice applies to Safeguard Global and reflects our commitment to processing personal data in accordance with applicable data protection laws, including the General Data Protection Regulation (EU) 2016/679 (“GDPR”), and our global privacy standards.

This Privacy Notice explains: our rule under data protection law; the categories of personal data we may process; the purpose and legal bases for such processing; how long personal data are retained; with whom personal data may be shared; and the rights available to you under applicable data protection law.

About our role under data protection law

The Safeguard Global company identified in your employment contract (or other contractual arrangements) is the independent data controller for your Personal Data made available to us. This means we are responsible for ensuring that we use your Personal Data in compliance with the applicable privacy and data protection laws.

What types of your Personal Data do we process about you?

We process personal data relating to Guardians that is collected before and during the employment relationship. This may include:

  • Identification and contact data: full name, address, phone number, email address, CPR number (personal ID), place and date of birth, photo, job history (CV), bank account information, a copy of your identification documentation (for example, a copy of your passport);
  • Employment information: job title, employment contract, previous and current salary, working hours, benefits, salary information, employment status, pension contribution amounts, attendance and absence, information related to your performance and professional development;
  • Legal compliance: tax ID, work permit/visa, pension registration, insurance details.
  • Other categories of personal data and sensitive data (only where relevant):

All of this information, and other personal information which we may collect and process, will be referred to collectively in this Information Notice as "Personal Data".

In some cases, we may also receive and process personal data relating to your dependents, beneficiaries or other individuals linked to you (for example, spouse or partner, children or other family members) where needed to provide employment benefits that you request or are entitled to under applicable law. This information will be used only for benefits administration and legal compliance purposes, and may be shared with relevant benefits providers and, where necessary for benefits administration, with the Client.

Why do we process your Personal Data and why are we allowed to do so?

We will process your Personal Data in the context of the employment relationship and internal business operations. This may also include processing personal data relating to additional services, such as accounting, administrative, and human resource management activities (including to ensure the correct performance of your employment agreement, as well as to manage its conclusion). We may also need to use your Personal Data to manage our relationships with social security and welfare institutions, as well as with tax authorities and credit institutions, in particular regarding the payment of your wages or other forms of remuneration and to comply with any legal obligations connected with the services you provide to Safeguard Global.

In some cases, we need to process your Personal Data to ensure that we can comply with our legal obligations related to your employment contract, as applicable. For example, we may be required to check your entitlement to work in a specific country, to deduct taxes from payments made to you, to comply with health and safety laws, and to enable you to take periods of leave. Depending on your role, we may need to carry out a criminal record check to ensure that you are permitted to fulfill that position.

As we need to process your Personal Data for the foregoing purposes in order to manage the performance of the contract with you, as well as to carry out our legal obligations and respect specific rights in the field of employment, social security and social protection law, we may do so without your specific consent. This information must be provided to us in order for us to lawfully formalise and properly manage our contractual arrangements with you. Failure to provide this information will prevent us from formalising or continuing our employment or other arrangements.

Further to the above, we also may process your Personal Data:

  1. to monitor the activities of persons who are authorised to process Personal Data, as described in Safeguard Global’s Policy on IT Tools, available on the Workday HR system or as timely delivered to employees in another form. In certain cases, the Data Controller will be able to access your professional e-mail account (namesurname@safeguardglobal.com) and your local or shared drives (e.g. OneDrive), as specified in Safeguard Global’s Policy on IT Tools;
  2. for network security purposes, as well as to prevent and combat cybercrime, while respecting applicable legislation on employee protection and not allowing, in any case, for remote monitoring of employees' work activities;
  3. for security and anti-fraud purposes, in order to protect Safeguard Global’s goods and properties, as well as Safeguard Global’s reputation;
  4. quality assurance, business analytics and performance assessment purposes;
  5. to address data subject requests in accordance with applicable privacy/data protection laws. This may involve running searches (in accordance with Safeguard Global's Policy on IT Tools) in employees' professional e-mail accounts, local or shared drives, and records of other corporate collaboration tools to identify messages/documents pertaining to a specific data subject.

For the purposes described in a), b), c) and e) above, the processing is needed to comply with Safeguard Global’s legal obligations or to protect Safeguard Global’s legitimate interests in safeguarding the rights and freedoms of individuals, as well as the integrity of company assets and of the persons who perform their duties towards the Safeguard Global;

For the purposes described in d) above, the processing is performed in Safeguard Global’s legitimate interests in ensuring the quality of services provided to customers and the effectiveness of business operations. In some cases, the processing of your Personal Data for these purposes may also be carried out based on your consent.

Additionally, at your request, Personal Data you share with us may be processed in order to assist you in applying for tax / social security and/or other employment benefits in compliance with local employment laws which you may be entitled to as an employee, as applicable. This may include, where relevant, personal data relating to your dependents or other beneficiaries (for example, spouse, partner, or children) where needed to administer those benefits. This processing is carried out in compliance with our legal obligations under labour and tax regulations. Furthermore, we will only collect those Personal Data which are legally required in order to assist you in applying for the requested benefits. You may choose not to provide Personal Data to us for this purpose. However, if you do not provide such information, we may not be able to assist you in applying for the intended benefits.

Furthermore, if you consent, some of your Personal Data (e.g., photographs or recorded images of you, taken during special events which may be organised by Safeguard Global) may be published on Safeguard Global’s website (www.safeguardglobal.com) and / or on Safeguard Global’s official social media pages (e.g., Twitter, LinkedIn) or used internally during company meetings. Your consent for these purposes is requested within the Security & Compliance course you need to complete when you join Safeguard Global, and will serve as the legal basis on which Safeguard Global may process your Personal Data, if you choose to provide it. Providing this consent is entirely optional. Please note that you may withdraw your consent at any time. If you choose not to consent, this processing will not be carried out, with no consequence to you.

If you are or become a member of Safeguard Global’s Board of Directors, some of your Personal Data may need to be disclosed, as required by the applicable law. The legal basis relied on for this processing is the fulfilment of a legal obligation to which Safeguard Global is subject.

What you need to know about providing information about someone else

Please note that when you decide to provide Personal Data about your family members, dependents, beneficiaries or next-of-kin to us (for example, for benefits administration), you confirm to us that you are duly authorized by those persons to share their information with us and, where necessary, with our partners or suppliers (for instance, because you have obtained consent from them or, where the Personal Data concerns children, because you are their parent or legal guardian). This also means that you may be held responsible for any complaints or claims brought against us, where the use of those Personal Data for the purpose of applying for these benefits was not duly authorised. If you are not authorized to provide such information, please do not provide it to us and contact our Data Protection Officer (DPO) by writing to dpo@safeguardglobal.com for guidance.

Where do we receive your Personal Data from?

We may receive information about you from:

  1. You or your representative;
  2. Previous companies you worked for (your references);
  3. Social security and welfare organisations, insurance companies, credit institutions and any other companies which may be engaged for human resource management (including training and background screening);
  4. Public entities, bodies or authorities;
  5. Third-party providers involved in payroll, benefits, insurance, training, or other employment-related services, where applicable;
  6. Our affiliate companies, where permitted under applicable privacy/data protection laws.

Who may receive your Personal Data?

Your Personal Data may be shared with the following categories of recipients (“Recipients”):

  1. Persons authorised by us to process Personal Data, who have signed a confidentiality agreement in compliance with applicable data protection laws (for example, certain of our employees in our Human Resources/Administration departments, system administrators who may have access to Personal Data during the performance of their duties);
  2. Payroll processing companies, consultants, intermediaries, subcontractors, social security and welfare organizations, trade unions, credit institutions and any other entities which may be engaged for accounting, administrative and technical maintenance purposes;
  3. Benefits providers (such as insurers, pension funds, health plans) and, where applicable, occupational health providers;
  4. Companies engaged for financial, tax, accounting, administrative and technical maintenance purposes (including IT service providers);
  5. Public transport companies and airlines for travel management purposes;
  6. Public authorities, bodies or entities to which Personal Data must be communicated under the applicable law or under binding orders from competent authorities;
  7. Our Clients, to the extent necessary for Safeguard Global to provide its services; and
  8. Our affiliate companies, where permitted under applicable privacy/data protection laws.

Will your Personal Data be transferred abroad?

Your Personal Data may be transferred to Recipients located in various different countries. We have implemented appropriate safeguards to ensure the lawfulness and security of these Personal Data transfers according to applicable data protection laws. With respect to data transfers outside of the EU/EEA, we may rely on adequacy decisions from the European Commission, written agreements (including standard contractual clauses adopted by the European Commission), or other safeguards or conditions considered adequate to the transfer at hand. Upon written request to privacy@safeguardglobal.com you can receive further information on international data transfers and can obtain a copy of the appropriate safeguards that we have put in place in order for the transfer to lawfully take place.

For how long may we keep your Personal Data?

Your Personal Data will be kept for the time necessary to manage the employment relationship (or other arrangement with you), the conclusion of your employment relationship, as well as for any additional and relevant periods established by applicable legislation, including any applicable statutory periods for claims related to our arrangements.

Your Privacy Rights

As a data subject, you are entitled to exercise the following rights with regard to the processing of your Personal Data, at any time:

  • Access your Personal Data (and/or obtain a copy of those Personal Data), as well as information on the processing of your Personal Data;
  • Correct or update your Personal Data, where it may be inaccurate or incomplete;
  • Request the erasure of your Personal Data, where you feel that the processing is unnecessary or otherwise unlawful;
  • Request the restriction of the processing of your Personal Data, where you feel that the Personal Data processed is inaccurate, or that the processing is unnecessary or unlawful, as well as where you have objected to the processing;
  • Request a copy of the Personal Data you provided to us in a structured, commonly used and machine-readable format, as well as request the transmission of those Personal Data to another data controller;
  • Object to the processing of your Personal Data, based on relevant grounds related to your particular situation, which you believe must prevent us from processing your Personal Data for a given purpose;
  • Lodge a complaint with the competent Supervisory Authority;
  • Withdraw your consent to processing, where your consent serves as the legal basis for processing. This will not affect the lawfulness of processing carried out prior to your withdrawal.

If you are in the EEA, these rights are described in Articles 15 to 22 GDPR. Similar rights may apply under other data protection laws.

How to exercise your Privacy Rights

Requests to exercise any of the above rights must be sent in writing:

  • By using the DSAR form available on the Safeguard Global website.
  • to us at the following address: privacy@safeguardglobal.com
  • to the Legal Team, to the attention of the Privacy lawyer at: LeonardoMorais@safeguardglobal.com

At any time, you can contact privacy@safeguardglobal.com if you have any questions arising from this Information Notice or regarding your Personal Data. You can also:

  • Contact our Data Protection Officer (DPO) by writing to dpo@safeguardglobal.com
  • Contact the competent Supervisory Authority (in the Member State of your habitual residence, place of work or place of the alleged infringement) whose contact details are available here (for UK click here), if you believe that the processing of your Personal Data that we, or the Client, carry out is unlawful.