3.1. Introduction and General Data Protection Regulation
3.2. Definition: Personal Data
Personal data means information which relates to a living and identifiable natural individual, such as names, addresses, account numbers, online identifier and location data.
The data items transferred will vary from client to client. However, the personal data transferred will fall under the following categories.
|Date of birth
3.3. Sources of Personal Data and Purpose
We collect Personal Data through the following sources and below defined purpose:
|Categories||How we collect your data||Purpose and Lawful basis of Processing|
Personal Data or
Personal Information in Projects
|Directly from you while you evaluate Synoverge capabilities and/or Synoverge is providing services to you||To share our capabilities, proposals and provide our products and services to you|
Personal Data or
|Directly from you while you are sharing your service proposal and/or you are providing services to Synoverge||To share our business requirements and receive your products and services|
|Prospective Candidates||From multiple sources where you have shared your profile for employment opportunities like recruitment portals, employee referrals, recruitment agencies, networking platforms, etc.
Directly from you in case you have directly applied through the website or email
|To evaluate your candidature for suitable open positions|
|Employee Data||Directly from you during the course of your employment||To maintain employee information as required during employment period for continued employment, payroll processing.
To conduct background screening checks as per customer requirement or compliance requirements
|Visitor information||Directly from you at the time of visiting our premises||To maintain basic visitor information as required by law|
|Marketing Data, Events and Initiatives||Directly from you when you contact (or you have been contacted) or interact with any Synoverge representative, via Synoverge website or events or conferences or workshops or Surveys that you attend, by telephone, email, online portal or in person or from professional networking platforms like Linkedin, Tweeter.||To share required business information and discuss potential business opportunities|
While we do not share personal information provided to Synoverge for business purpose mentioned above, we may be required to share this information under the following circumstances. In such cases data protection officer approves dissemination of this information based due diligence.
- Legal Obligations: We may process your Personal Data, Personal Information where it is necessary in order to comply with applicable legal and/or regulatory obligations, establish, exercise or defend our legal rights or for the purpose of legal proceedings and to prevent and respond to actual or potential fraud or illegal activities.
- Other “Public Interest” Grounds: We may process your Personal Data, Personal Information (or where relevant, your Sensitive Personal Data) on other public interest grounds where it is subject to regulatory requirements where Processing is necessary by us for the performance of a task mandated by governmental authorities, regulatory authorities or any other law enforcing authorities in the public interest.
We do not use personal information provided for unsolicited emails, calls and/or messages to you.
3.4. Access, Retention and Disposal of Personal Data or Personal Information
Synoverge ensures that personal data / information access is limited to the employees / stakeholders who are engaged in business activities with you. This is assured through information security access control policy.
Synoverge retains personal data / information provided as part of its master data for varying duration as per business requirement.
- Purposes identified in this Policy for using the Personal Data/ Personal Information/ Sensitive Personal Information – we will need to keep the information for as long as is necessary for the relevant purpose; and
- Legal obligations – laws or regulation may set a minimum period for which we will have to keep your Personal Data/ Personal Information/ Sensitive Personal Information
Synoverge disposes personal data / information provided through the following means.
- Hardcopy personal data / information is disposed off using paper shredder.
- Softcopy personal data / information is removed through hard delete options from the database unless archival of personal data / information is required for specific legal / regulatory purpose.
You can communicate to concern authority to specifically request removal of your personal information from our records. We will process your request in case this doesn’t conflict with requirement to retain information as per compliance and/or regulatory and/or legal requirement.
3.5. Quality of Personal Data/ Information
We shall ensure to implement reasonable mechanism to monitor the quality of the Personal Data/ Information maintained in our systems.
- Each business unit & support function within our organisation shall take steps to assure that Processed Personal Data/ Information is complete and accurate.
- Employees can review, update and confirm on the accuracy and completeness of their Personal Data/ Information.
Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the third parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
Mr. Ritesh Dave is designated data protection officer at Synoverge. You can address your grievances regarding data protection to him on his email id email@example.com.