This RPP covers what Personal Data we collect about you, how the Personal Data will be used and shared (if at all), how the Personal Data will be stored, and your rights in relation to the collection of your Personal Data during, before, or after your employment with the ENTITY. It also describes how you can access, modify, and if needed, request deletion of your Personal Data. This RPP also covers how your Personal Data is handled by our third-party data processors.
- APPLICABLE COMPANY: This RPP is applicable to the ENTITY listed above.
- ENTITY: For the purposes of this RPP, we will refer to the Company as the ENTITY, we, our, or us.
- EMPLOYEE: This RPP applies to the Personal Data of all individuals who seek to be, are, or were employed by the ENTITY. These individuals shall be referred to as Employee or Employees. When we refer directly to you, as the Employee, we’ll refer to you as you, as well as through second-person pronouns such as your and yours.
- PERSONAL DATA: “Personal Data” means information that we obtain from you in connection with your potential, current, or past employment with us that can identify you. For the purposes of this RPP, Personal Data is any information about an identifiable Employee that seeks to be, is, or was employed by the ENTITY. Personal Data does not mean any data that is anonymised or identify that cannot identify you in any way.
The best way to contact us is through our Human Resources Department via the COMMUNICATIONS OPTIONS below.
You may contact us for any questions you have about the handling and processing of your Personal Data. You may also contact us to have access to your Personal Data or any other request. If you are unsatisfied with the handling of your Personal Data, you may make a complaint with the relevant data protection authority.
COLLECTION OF PERSONAL DATA
We collect different types of Personal Data in different ways. Some of the Personal Data gathered is automatic (through technologies which give us information about you), and some of the information is given by you directly to us.
In order to ensure that we are meeting our responsibilities and duties as your employer or prospective employer, we collect, process, and maintain different types of Personal Data in regard to those individuals who seek to be, are, or were employed by us, including, but not limited to:
- Marital status, for the purpose of ascertaining and distributing benefits such as health insurance.
- Dependant status, for the purpose of ascertaining and distributing benefits such as health insurance.
- Date of birth.
- General contact information, such as address, telephone number, and email.
- Resumes that you provide and/or application(s) that you fill out and provide to us.
- Your start date.
- Your job title.
- The location where you are working.
- Any training or education programs you undertake through us
- Professional or personal references
- Company policies and employment forms signed by you.
- Payroll Information: This includes, but is not limited to, tax forms, your social security number, bank account information, additional direct deposit Information, and your photo ID. If, at any point, your payroll information changes, you will be required to fill out updated payroll forms. These forms will be kept in your file along with any previous payroll forms that you have given the ENTITY.
- Forms that contain any information relating to your personal employee benefits, health care plans, insurance policies and the like.
- Beneficiary information.
- The contact information of the individual that you list to be first notified in the event of an emergency. This includes phone numbers, addresses, and any other personally identifying information for that individual.
- Assessments, evaluations, performance reviews, training completion rates, and training scores.
- Any monetary raises, bonuses, stock information, retirement information, commissions, overtime rate, salaried rate and/or regular hourly rate.
- Any requested time off, accrued paid time off, tardiness, or requests to leave before the scheduled end of your workday.
- Grievances, including complaints made by fellow employees or clients or customers, corrective action plans for inappropriate behaviour and write-ups.
- Accolades, including recommendations, awards, or other instances of recognition for quality work.
- Letter of resignation, if received by the ENTITY.
- Letter of termination, if given by the ENTITY.
- Other personal details you voluntarily provide to us.
- Other personal details you are required to provide us as required by law or to serve the legitimate interests of the ENTITY.
USE OF PERSONAL DATA
We use the information that we collect about you to effectively run our business and to help us provide a pleasant, safe, and productive work environment for you.
We also use Personal Data to:
- Accurately process payroll.
- Enrol insurance policies.
- Manage and plan our business.
- Send out business mailings.
- Conduct employee reviews.
- Handle internal disputes or grievances.
- Analyse your qualifications.
- Manage employee stocks.
- Process any claims you bring.
- For internal accounting.
- Oversee your work.
- Put you through education or training.
- Generally, comply with applicable law.
- Manage your compliance to data privacy.
We only process your Personal Data where we are permitted by law or required to do so, including where we must process Personal Data for your employment with us, where we have a legal obligation to do so as your employer, for legitimate business purposes, to protect your vital interests, or if we have your consent to do so. We may, though, have to process your Personal Data without your consent or knowledge, but only when required to do so by law. We won’t make any decisions on the automated processing of Personal Data without your consent.
We also process your Personal Data to prevent fraud and ensure the security of all aspects of our business.
SPECIAL CATEGORIES OF PERSONAL DATA
We may collect certain categories of sensitive data, as defined under relevant applicable law. If you are asked for any of these categories of data, you may request the purpose for which the data is required and refuse to provide it, if desired. We collect and process the following sensitive Personal Data only through voluntary disclosure for our legitimate business purposes, including to carry out any legal obligations and responsibilities as needed and required.
- Racial origin.
- Ethnic origin.
- Religious or spiritual beliefs.
- Political opinions.
- Criminal background.
- Sexual orientation.
- Health data.
- Biometric data.
- Genetic data.
- Trade union membership.
If we collect other categories of sensitive Personal Data not described here, we will seek your prior express consent.
We only share your Personal Data when to those individuals and entities who assist in fulfilling our responsibilities within the employment relationship with you or when required to do so by applicable law (collectively, “Third-Party Service Providers”). These Third-Party Service Providers include, but are not limited to, the website in which you submitted your employment application (if applicable) security personnel companies, payroll information and pay stub viewing applications and companies, scheduling programs, processing systems, company insurance providers and others similarly situated to assist in the employment relationship.
In certain cases, we may have to disclose your Personal Data to third parties without your consent or prior knowledge. We limit that disclosure to the following circumstances.
- To protect our legal rights.
- To satisfy any Local Laws, State Laws, Federal Laws and International Laws or regulations.
- To respond to requests, such as discovery, criminal, civil, or administrative process, subpoenas, court orders, or writs from law enforcement or other governmental or legal bodies.
- To bring legal action against an Employee who has violated the law.
- In the case of any business transfer, sale, or transfer of assets of the ENTITY.
- To generally cooperate with any lawful investigation about our past, present, or potential employees.
- If we suspect any fraudulent activity within or in relation to the ENTITY, or if we have noticed any activity which may violate our ethics, guidelines, or other applicable rules.
- If you have breached any data privacy regulations.
We are based in Greece. In other words, your Personal Data may be transferred from the location in which you reside to our physical location in Greece. It may also be transferred to third parties, as described above, located in Greece and abroad. The risks of transferring data outside of your jurisdiction to Greece include the possibility of data breaches and loss. Before beginning employment, we ask you to specifically consent to the transference of your Personal Data to Greece. We will continue to process your Personal Data in the manner described herein, and if we change anything about how we handle your Personal Data, including the international transfer of your Personal Data, we will seek your explicit consent again.
DATA STORAGE AND SECURITY
We only store your Personal Data as long as it is necessary for providing you with the benefits and protections that employment with us entails or until you cease your employment with us and request deletion of your data. We may also store your Personal Data for any applicable legal record-keeping, including after the termination of your employment or for additional business purposes (e.g., maintaining our accountancy records or otherwise maintaining the safety and security of our ENTITY, for a time period permitted by applicable law).
We employ organisational and technical security measures to protect your Personal Data, such as limiting access to your Personal Data, secured networks, and encryption. We ensure that your Personal Data is protected against unauthorised access, disclosure, or destruction by utilising practices that are consistent with standards in the industry to protect your privacy.
Please note, however, that no system involving the transmission of information via the Internet or the electronic storage of data is completely secure, no matter what reasonable security measures are taken. Although we take the protection and storage of your Personal Data very seriously, and we take all reasonable steps to protect your Personal Data, we cannot be responsible for data breaches that occur outside of our reasonable control. We will, however, follow all applicable laws in the event a data breach occurs, including taking reasonable measures to mitigate any harm as well as notifying you of such breaches as soon as possible.
We the ENTITY are committed to maintaining an ongoing path to compliance at all times.
APPLICATION RETENTION PERIOD
If your application for employment is unsuccessful, the ENTITY will hold your data on file for 6 (six) months after the end of the relevant recruitment process. If you agree to allow us to keep your personal data on file, we will hold your data on file for a further 6 (six) months for consideration for future employment opportunities. At the end of that period, or once you withdraw your consent, your data is deleted or destroyed.
If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your Human Resources file (electronic and paper based) and retained during your employment. The periods for which your data will be held will be provided to you in a new privacy notice.
You may also contact us to restrict the sharing of your personal data with third-parties, in compliance with the local, state, national or other data privacy jurisdictions that you qualify in being protected under as a data subject.