Privacy policy

The present Policy of Privacy and Protection of Employees' Personal Data ("Politics") of INETUM BULGARIA Ltd aims to inform you about what personal data about our employees we process as Employers, your rights of confidentiality, and the measures for their protection, in fulfillment of our obligations under the General Regulation on the protection of personal data (Regulation (EC) 2016/679) (GDPR).

Administrator (of Personal Data) of your Personal Data is INETUM BULGARIA Ltd., UIC 202693021 (the "Company").

Definitions

In this policy the following expressions have the following meanings:

• Data Controller means the organization that determines the purposes for which and how your Personal Data is processed.
• Data Processor means a person or organization that processes your Personal Information on behalf of a Controller.
• EEA means the European Economic Area (= Member States of the European Union + Iceland, Norway and Liechtenstein).
• Personal data is any data directly related to you or allowing your identification, such as your name, telephone number, email address, etc.
• Processing means the collection, access and any type of use of your Personal Information.

The company collects the following categories of personal data for employees:

Prior to concluding an employment contract - when participating in a recruitment procedure:

• Your name, date of birth, contact details and qualifications (education, training courses and internships), previous work experience and any other information you provided in your resume or CV when applying for a job with us;
• If you contact us in writing, we keep this correspondence for the purposes of the selection procedure;

Conclusion and performance of a labor contract:

• Data about your identity, such as your name, ID, details of your identity documents, and data from the documents certifying your right to work, if applicable;
• Data about your financial identity such as bank account information, fees, wages and benefits, and if applicable, data about any voluntary deductions you request from your wages and fees;
• Information and documents about your presence, time spent on projects, training, changes in labor relations etc.;
• Information about your use of our IT systems, including your IP address, browser, web logs and other communications data and Company resources that you have access to;
• access to premises (entry door systems);
• personal data in connection with the exercise of special rights under the Labor Code (, if applicable and solely meeting the requirement stated in the applicable legislation;
• travel information (travel data, credit card information, passport number, costs incurred) for the purpose of negotiating, arranging and purchasing all travel related activities when you make these trips as an employee of the Company, if applicable.
• details of any changes and any improvements we may need to make for you at your working place;
• In some cases, we could also collect sensitive personal information (for example, your health data), if it is applicable and always complying with one of the bases mentioned in the law.

The Company collects and processes your personal data for the following purposes and on the following basis:

1. When applying for a job, we collect your personal data in order to proceed through the selection procedure for the respective open position declared by us - in order to take steps at your request prior to entering into a contract with you.

2. When starting work with us

a) for staff management and development in general- dictated by our legitimate interest in encouraging and supporting the upgrading of our employees' qualifications and development;

(b) for human resources activities (including management of work, remuneration and administration of benefits, taxes and social security payments, absences management, expenditure management and disciplinary procedures, submission of information to NRA and NSSI, filing information on health status in relation to the use of protection under Article 333 of the Labor Code) - in implementation of the concluded labor contract between us and in compliance with our legal obligations.

c) for the management of security and protection of the people - in fulfillment of our legal obligations as an employer for ensuring safe and healthy working conditions;

(d) For the security and protection of premises, systems and assets, which is dictated by our legitimate interest in protecting the assets and information we are working with;

e) to supervise your compliance with internal policies and procedures - in accordance with our internal labor contract;

f) to investigate incidents or respond to complaints in connection with the performance of your official duties - in pursuance of the concluded employment contract between us and in compliance of our legal obligations;

(g) to comply with our duty to cooperate with police, government or regulatory authorities to carry out a statutory duty;

The provision of your personal data is a necessary condition for the conclusion and / or performance of the employment contract between us. Without providing us with the relevant personal data, we will not be able to conclude and execute it.

How long do we keep your personal data?

The Company may (and in certain circumstances, depending on the type of data) have to store your data for a specified period, including after termination of your employment relationship.

We retain personal information as follows:

• In connection with participation in a recruitment procedure - up to 12 months after completion of the procedure, except in case we have your consent in order to retain it for longer period. After the abovementioned period we will delete or eliminate the retained the carriers which contain your personal data, except if otherwise established in a special law.
• In connection with paid taxes, labor contracts and annexes to them, unsolicited work records, financial information (including salary data), health and social insurance data, etc.) for 50 years,
• Documentation relating to accidents at work and carrying out health and safety at work instruction- 5 years from the relevant event;
• Patient papers (paper), working schedules -3 years after their issuance.

We disclose your data to the following categories of recipients:

1) To our service providers supporting staff management of the following categories:

• financial, accounting, legal and other administrative service providers who process your personal data for the management and administration of payments related to your employment relationship - remuneration, social security and tax payments, as well as for the compilation and filing of the statutory statements, declarations, notifications, notes, etc.;
• Providers of services related to the organization of business trips (missions);
• Providers of services related to the searching of job candidates, such as services which allow the employers to publish online their job openings.
• IT vendors hosting or maintaining our IT systems, including information about you, when you use these IT systems in service;
• Occupational Health Services, which processes personal data for the purposes of ensuring health and safety at work;

We require each of our suppliers to processes your personal data subject to strictly established security and confidentiality obligations, access is granted only to the data required to perform the contract activities.

2) In fulfillment of our legal obligations of assistance and accountability in certain cases we may be required to provide your personal data to the government, police, regulatory or law enforcement authorities, NSSI, NRA.

3) Insurance companies, which process your data in case you requested voluntary to have an additional health insurance.

We will not transfer your data outside the EEA except to countries where the European Commission considers it to offer you an appropriate level of protection or when there are appropriate legally established safeguards to preserve the confidentiality of your information.

What rights do you have?

1) Right to access and receive a copy of your personal data: You have the right to request confirmation that we are processing your personal data.

In such cases, we will provide you with access to your personal information and information on how we process it.

2) The right to correct your personal information: If your personal information which we are processing is inaccurate and incomplete, you may request for this information to be corrected, updated or supplemented. Please also inform us when changing your data that you know we process to keep your information up to date.

3) Right to be forgotten/ right to erasure: If we do not need to store or process the data for any other reason, you may request that we erase (part or all) of your personal information when the applicable legal conditions are fulfilled.

4) Right to restriction of the processing in case any of the conditions established when the applicable legal conditions are fulfilled.

5) Right of objection: When we process your personal data on the basis of the Company's legitimate interest, you may object to its processing.

6) Right to Complain: You have the right to complain to the data protection authority where you live or work, or where you think a problem has arisen in connection with your personal data.

In Bulgaria, the personal data protection authority is the competent authority for the protection of personal data, address 1592, Boulevard "Professor Tsvetan Lazarov" 2, Sofia, Bulgaria.

7) Right to data portability (if applicable): you have the right to receive the personal data, which you had provided to the Company, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance when the GDPR requirements are met.

8) Right to object to the processing of your personal data, when such processing is based on legitimate interest.

9) Right to restriction of processing: you have the right to require the restriction of the processing of your personal data according to the established in the GDPR and on the legal basis previewed thereof.

10) Right to withdraw your consent for the processing of your data at any time without any negative consequences, when the processing is based on consent.

If you wish to exercise your rights, ask us for assistance and / or clarification or ask us a question regarding the processing of your personal data, you can contact us by e-mail at: office.bulgaria@inetum.com

When you send us an e-mail requesting you to exercise your rights, the Company may ask you to identify yourself appropriately in order to be able to provide you with the requested assistance.

To the extent permitted by law, the Company reserves the right to audit, monitor and record the access, use and content of any data stored or processed by its IT systems.

Additional terms and conditions regarding the use of IT systems are contained in special policies for which we will duly inform you.

The Company may periodically and in its sole discretion modifies this Policy. We will duly inform you of any changes through appropriate notifications or will contact you through other communications channels.