Easyrecognition – Privacy Policy
Effective From 01st October, 2016
QUADMO SOLUTIONS PRIVATE LIMITED PRIVACY POLICY
Last Updated: October 01st, 2023.
DEFINITIONS
Business purposes:
The purposes for which personal data may be used by us:
Personnel, administrative, financial, regulatory, payroll and business development purposes.
Business purposes include the following:
• Compliance with our legal, regulatory and corporate governance obligations and good practice
• Gathering information as part of investigations by regulatory bodies or in connection with legal proceedings or requests
• Ensuring business policies are adhered to (such as policies covering email and internet use)
• Operational reasons, such as recording transactions, training and quality control, ensuring the confidentiality of commercially sensitive information, security vetting, credit scoring and checking
• Investigating complaints
• Checking references, ensuring safe working practices, monitoring and managing staff access to systems and facilities and staff absences, administration and assessments
• Monitoring staff conduct, disciplinary matters
• Marketing our business
• Improving services
Personal data:
Information relating to identifiable individuals, such as job applicants, current and former employees, agency, contract and other staff, clients, suppliers and marketing contacts.
Personal data we gather may include: individuals' contact details, educational background, financial and pay details, details of certificates and diplomas, education and skills, marital status, nationality, job title, and CV.
Sensitive personal data
Personal data about an individual's racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership (or non-membership), physical or mental health or condition, criminal offences, or related proceedings—any use of sensitive personal data should be strictly controlled in accordance with this policy.
SCOPE
This policy applies to all staff. You must be familiar with this policy and comply with its terms.
This policy supplements our other policies relating to internet and email use. We may supplement or amend this policy by additional policies and guidelines from time to time. Any new or modified policy will be circulated to staff before being adopted.
OUR PROCEDURES
Fair and lawful processing
We must process personal data fairly and lawfully in accordance with individuals’ rights. This generally means that we should not process personal data unless the individual whose details we are processing has consented to this happening.
The Data Protection Officer’s responsibilities:
• Keeping the management updated about data protection responsibilities, risks and issues
• Reviewing all data protection procedures and policies on a regular basis
• Arranging data protection training and advice for all staff members and those included in this policy
• Answering questions on data protection from staff, management and other stakeholders
• Responding to individuals such as clients and employees who wish to know which data is being held on them by Quadmo Solutions Private Limited.
• Checking and approving with third parties that handle the company’s data any contracts or agreement regarding data processing
RESPONSIBILITIES OF THE IT MANAGER
• Ensure all systems, services, software and equipment meet acceptable security standards
• Checking and scanning security hardware and software regularly to ensure it is functioning properly
• Researching third-party services, such as cloud services the company is considering using to store or process data
RESPONSIBILITIES OF THE MARKETING MANAGER
• Approving data protection statements attached to emails and other marketing copy
• Addressing data protection queries from clients, target audiences or media outlets
• Coordinating with the DPO to ensure all marketing initiatives adhere to data protection laws and the company’s Data Protection Policy
The processing of all data must be:
• Necessary to deliver our services
• In our legitimate interests and not unduly prejudice the individual's privacy
• In most cases this provision will apply to routine business data processing activities.
Our Terms of Business contains a Privacy Notice to clients on data protection.
The notice:
• Sets out the purposes for which we hold personal data on customers and employees
• Highlights that our work may require us to give information to third parties such as expert witnesses and other professional advisers
• Provides that customers have a right of access to the personal data that we hold about them
SENSITIVE PERSONAL DATA
In most cases where we process sensitive personal data we will require the data subject's explicit consent to do this unless exceptional circumstances apply or we are required to do this by law (e.g. to comply with legal obligations to ensure health and safety at work). Any such consent will need to clearly identify what the relevant data is, why it is being processed and to whom it will be disclosed.
ACCURACY AND RELEVANCE
We will ensure that any personal data we process is accurate, adequate, relevant and not excessive, given the purpose for which it was obtained. We will not process personal data obtained for one purpose for any unconnected purpose unless the individual concerned has agreed to this or would otherwise reasonably expect this.
Individuals may ask that we correct inaccurate personal data relating to them. If you believe that information is inaccurate, you should record the fact that the accuracy of the information is disputed and inform the DPO.
YOUR PERSONAL DATA
You must take reasonable steps to ensure that personal data we hold about you is accurate and updated as required. For example, if your personal circumstances change, please inform the Data Protection Officer so that they can update your records.
DATA SECURITY
You must keep personal data secure against loss or misuse. Where other organizations process personal data as a service on our behalf, the DPO will establish what, if any, additional specific data security arrangements need to be implemented in contracts with those third party organizations.
STORING DATA SECURELY
• In cases when data is stored on printed paper, it should be kept in a secure place where unauthorized personnel cannot access it
• Printed data should be shredded when it is no longer needed
• Data stored on a computer should be protected by strong passwords that are changed regularly. We encourage all staff to use a password manager to create and store their passwords.
• Data stored on CDs or memory sticks must be locked away securely when they are not being used. And preferably encrypted. If these media are transferred outside the facilities they must be encrypted.
• The DPO must approve any cloud used to store data.
• Servers containing personal data must be kept in a secure location, away from general office space.
• Data should be regularly backed up in line with the company’s backup procedures.
• Data should never be saved directly to mobile devices such as laptops, tablets or smartphones.
• All servers containing sensitive data must be approved and protected by security software and strong firewall.
DATA RETENTION
We must retain personal data for no longer than is necessary. What is necessary will depend on the circumstances of each case, taking into account the reasons that the personal data was obtained, but should be determined in a manner consistent with our data retention guidelines.
TRANSFERRING DATA INTERNATIONALLY
There are restrictions on international transfers of personal data. You must not transfer personal data anywhere outside India without first consulting the Data Protection Officer.
TRAINING
All staff will receive training on this policy. New joiners will receive training as part of the induction process. Further training will be provided at least every two years or whenever there is a substantial change in the law or our policy and procedure.
Training is provided through an in-house seminar on a regular basis.
It will cover:
• The law relating to data protection
• Our data protection and related policies and procedures.
Completion of training is compulsory.
What information is being collected? The core of the personal data is provided by our customers via secure data transfers. This includes Name, Corporate: Email, Address, direct manager, years of service, data of employment, date of termination, The data subject may provide delivery addresses, payment information and transactional choices (goods selected)
In some rare cases we have the data subject birthday.
We collect web traffic for quality and aggregate analytics, Infrastructure planning.
Who is collecting it? Who is collecting it? Quadmo Solutions Private Limited and its affiliates programs (Easyrecognition)
How is it collected? Data transfer from customers, and subject data via web forms, email, phone calls, letters
Why is it being collected? The Data is collected only in the sole purpose of fulfilling the contract on employee recognition with our customers. (Loyalty), Training, recognition coaching & consulting.
Who will it be shared with? The minimal required data will be shared with suppliers for shipping, drop ship, payment card services.
Retention period All financial records are retained for seven (7) years. Data subject recognition data are retained for periods required for the proper usability of the application on a customer by customer basis.
CONDITIONS FOR PROCESSING
We will ensure any use of personal data is justified using at least one of the conditions for processing, and this will be specifically documented. All staff who are responsible for processing personal data will be aware of the conditions for processing. The conditions for processing will be available to data subjects in the form of a privacy notice.
JUSTIFICATION FOR PERSONAL DATA
We will process personal data in compliance with all six data protection principles.
We will document the additional justification for the processing of sensitive data and will ensure any biometric and genetic data is considered sensitive.
CONSENT
The data that we collect is subject to active consent by the data subject. This consent can be revoked at any time.
DATA PORTABILITY
Upon request, a data subject should have the right to receive a copy of their data in a structured format. These requests should be processed within one month, provided there is no undue burden and it does not compromise the privacy of other individuals. A data subject may also request that their data is transferred directly to another system. This must be done for free.
RIGHT TO BE FORGOTTEN
A data subject may request that any information held on them is deleted or removed, and any third parties who process or use that data must also comply with the request. An erasure request can only be refused if an exemption applies.
PRIVACY BY DESIGN AND DEFAULT
Privacy by design is an approach to projects that promote privacy and data protection compliance from the start. The DPO will be responsible for conducting Privacy Impact Assessments and ensuring that all IT projects commence with a privacy plan.
When relevant, and when it does not have a negative impact on the data subject, privacy settings will be set to the most private by default.
DATA AUDIT AND REGISTER
Regular data audits to manage and mitigate risks will inform the data register. This contains information on what data is held, where it is stored, how it is used, who is responsible and any further regulations or retention timescales that may be relevant.
REPORTING BREACHES
All members of staff have an obligation to report actual or potential data protection compliance failures. This allows us to:
• Investigate the failure and take remedial steps if necessary
• Maintain a register of compliance failures
• Notify the Supervisory Authority (SA) of any compliance failures that are material either in their own right or as part of a pattern of failures
MONITORING
Everyone must observe this policy. The DPO has overall responsibility for this policy. They will monitor it regularly to make sure it is being adhered to.
CONSEQUENCES OF FAILING TO COMPLY
We take compliance with this policy very seriously. Failure to comply puts both you and the organization at risk.
The importance of this policy means that failure to comply with any requirement may lead to disciplinary action under our procedures which may result in dismissal. A solicitor in breach of Data Protection responsibility under the law or the Code of Conduct may be struck off.
If you have any questions or concerns about anything in this policy, do not hesitate to contact the DPO.
Cookie Policy
Quadmo Solutions Private Limited may use "cookies" to track your preferences and activities on the Easyrecognition website. Cookies are small data files transferred to your computer’s hard-drive by a website.
They keep a record of your preferences making your subsequent visits to the site more efficient. Cookies may store a variety of information, including, the number of times that you access a site, your registration information and the number of times that you view a particular page or other item on the site.
The use of cookies is a common practice adopted by most major sites to better serve their clients. Most browsers are designed to accept cookies, but they can be easily modified to block cookies; see your browser’s help files for details on how to block cookies, how to know when you have received cookies and how to disable cookies completely.
You should note, however, that without cookies, some of the website’s functions will not be available, and the user will lose some of the benefits of the site.