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.
1. Definitions
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.
2. Privacy Notice
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
- General Information- Name, date of birth, residence address, passport number and holder, national ID number, telephone, e-mail, and professional experience record.
- Remuneration- Salary, salary grade, bank account numbers, job title
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:
- Human Resources and Personnel Management: DT Global uses information as appropriate to maintain a workforce for DT Global. Some examples are: recruiting, salary calculation and payment, administering labor agreements, managing careers and development, evaluating your performance, training, complying with applicable legal requirements, sharing data with Company affiliates and communicating with you and your representative(s).
- Business Process Execution and Management: DT Global uses information to run its operations. Some examples are: workforce structuring and restructuring, project management and proposals, managing DT Global assets, hotlines, and employee directories, and business travel management.
- Safety and Security: DT Global uses information as appropriate to ensure the safety and protection of DT Global employees, resources, and workplaces. Some examples are: protecting occupational health and safety, conducting investigations, recording and monitoring network activity for the purpose of identifying, predicting, and preventing the entry of malicious activity onto or the release of information from DT Global network and computing resources.
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.
5. Disclosures
- Affiliates: DT Global entities share information among DT Global subsidiaries and affiliates for the purposes described in this Privacy Notice where consistent with applicable legal requirements.
- Third Party Agents and Contractors: At times, DT Global entities may decide to share Personal Information to selected affiliated or third-party agents and contractors to perform services on their behalf.
- OtherThirdParties: DT Global entities disclose certain Personal Information to other third parties: (1) where required by law or legal process (e.g. to tax and social security authorities); (2) where DT Global determines it is lawful and appropriate to perform under an employment or labor agreement or otherwise consistent with the nature of the employment or other relationship; (3) to protect DT Global’s legal rights (e.g., to defend a litigation suit or pursuant to a government investigation or inquiry) or to protect Company employees, resources, and workplaces; or (4) in an emergency where the health or security of you or other person or entity is at stake.
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.
6. 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 our computer resources is subject to the DT Global Code of Business Ethics and Conduct and any applicable electronic communications polices, which are not superseded by this Privacy Notice.
7. Data Retention
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.
8. Your Rights
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.
DT Global commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or
complaints regarding DT Global’s Privacy policy should contact the DT Global Ethics Hotline or [email protected].
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.
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 [email protected].
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 [email protected].
