DT Global has issued this Global Privacy Notice (“Privacy Notice”) to provide you working on behalf of the Company and its subsidiaries and affiliates (collectively with DT Global, “DT Global” or the “Company”) with notice about how DT Global collects, uses, and processes your information.
We will only process your personal information in accordance with this Privacy Notice unless otherwise required by applicable law. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and processed for limited purposes.
Personal Information: any information relating to an identified, or an identifiable, natural person.
Process or Processing: any operation or set of operations that are performed upon Personal Information, whether by automatic means or otherwise. This includes the collection, recording, organization, storage, updating or modification, retrieval, consultation, use, disclosure by transmission, dissemination or making available in any other form, linking, alignment or combination, blocking, erasure or destruction of Personal Information.
Sensitive Personal Information: is defined by local law and may include Personal Information relating to an individual’s racial or ethnic origin, political opinions, religious or political beliefs, sexual orientation, trade-union membership, information specifying health or medical conditions, sex life, social security number, or criminal records.
This Policy does not cover data rendered anonymous. Data is rendered anonymous if individual persons are no longer identifiable.
The information collected by DT Global about you varies based on the requirements of a particular job position or salary grade, what is appropriate to evaluate and compensate you in an applicable jurisdiction, and what may be required to adhere to applicable employment law or other applicable laws, to ensure the quality of our products and services, and provide a safe workplace for you.
The following are the general categories and some examples of the categories of personal information collected and maintained by DT Global:
Examples of person Information
Purposes for Processing Personal Information
DT Global processes personal information to manage business operations, payroll administration, accounting and auditing, assessing qualifications for a particular job or task, you, business and safety and security purposes. These principal purposes include:
As a global company, DT Global transfers your personal information to the United States and to other jurisdictions in order to meet our business and legal requirements. The applicable legal protections in such jurisdictions may not be the same as those afforded in your own jurisdiction.
DT Global may need to collect Sensitive Personal Information. Where required under applicable local law, such Personal Information will only be processed with your consent. Where required by applicable local law or the EU-U.S. Privacy Shield, consent to transfers or uses of Sensitive Personal Information will be opt-in.
As noted above, DT Global may disclose Personal Information to entities located in the United States and other jurisdictions in order to meet our business and legal requirements. The applicable legal protections in such jurisdictions may not be the same as those afforded in your own jurisdiction. DT Global may be required to disclose Personal Information in response to lawful requests by public authorities, including meeting national security or law enforcement requirements.
Security and Confidentiality
DT Global takes reasonable and appropriate steps to protect Personal Information against unauthorized access, loss, misuse, disclosure, alteration, destruction and other Processing of Personal Information. These measures take into account the sensitivity of the Processing operation concerned and of the Personal Information concerned, and the risks involved.
DT Global will restrict access to Personal Information to those employees, agents and contractors of DT Global who have a legitimate business need for such access.
Communications and network security controls have been put in place requiring authentication to access computer systems, networks, and other resources. Safeguards are in place to alert DT Global when an actual or suspected unauthorized access takes place. Use of such computer resources is subject to the Electronic Communications Policy, which is not superseded by this Privacy Notice.
Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, as required to satisfy any legal, accounting, or reporting obligations, or as necessary to resolve disputes. To determine the appropriate retention period for personal information, we consider our statutory obligations, the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes we process your personal information for, and whether we can achieve those purposes through other means. We specify the retention periods for your personal information in our records management retention schedules.
Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent. Once you are no longer providing services to us, we will retain and securely destroy your personal data in accordance with our policies and applicable laws and regulations.
You will be provided access to your own Personal Information as required by and in accordance with applicable law. Requests for access, and in general, all data protection related requests, may be made to the local or regional data protection officer, if applicable, or to the local Human Resources department.
We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
You have a responsibility to assist DT Global in keeping the Personal Information DT Global maintains about you accurate, complete and current. If any Personal Information is inaccurate or incomplete, you may request that the Personal Information be corrected or completed. DT Global will correct or delete Personal Information as required by applicable law. You may also request to correct, amend, or delete Personal Information that has been processed in violation of the EU-U.S. Privacy Shield Principles.
Where you have provided your consent to the collection, processing, or transfer of your personal information, you may have the legal right to withdraw your consent. To withdraw your consent, if applicable, contact us at Belen.Nebreda@aecom.com
EU-U.S. Privacy Shield
DT Global complies with the EU-U.S. Privacy Shield Framework (“Privacy Shield”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information transferred from the European Union to the United States. DT Global has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov.
DT Global’s participation in the Privacy Shield applies to all Personal Information that is transferred from the European Union, the European Economic Area, and Switzerland to the United States. DT Global will comply with the Privacy Shield Principles in respect of such Personal Information.
DT Global’s accountability for Personal Information that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, DT Global remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless DT Global proves that it is not responsible for the event giving rise to the damage.
If you have a Privacy Shield-related (or general privacy-related) question, we encourage you to contact us at GC lawyer. As explained in the Privacy Shield Principles, a binding arbitration option will be made available to you in order to address residual complaints not resolved by any other means. DT Global is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
Other Important Information
This Privacy Notice is effective on July 1, 2019
Privacy laws and guidelines are part of a constantly changing environment. DT Global reserves the right, at its discretion, to change, modify, add, or remove portions of this Privacy Notice or any supplemental privacy notice at any time. Any material change to this Privacy Notice will be provided to you. Any questions regarding this Privacy Notice should be addressed to your local Human Resources department, or to our General Counsel at GeneralCounsel@dt-global.com.