Job policy notice

LightKnow · 11 August 2021 at 5:52PM

Hi everyone, I know this may be odd request or question

So basically am looking at a job but for me to continue, they want me to sign a digital policy document, I have read it and I think it looks fine but can I be a pain and get someone else to read over it too? Just to make sure nothing suspicious

Super apologies in advance

WHAT IS THE PURPOSE OF THIS DOCUMENT

Tata Consultancy Services Limited (“TCS” or “we”) is committed to protecting the privacy and security of

your personal data.

This privacy notice describes how we collect and use personal data about you during and after the

candidate recruitment with us in accordance with the General Data Protection Regulation (GDPR) and

applicable privacy legislation.

This privacy notice describes how we collect and process personal data about you to assess your

suitability for employment with us. Employment opportunities exist as employment or term

contracts either directly between TCS and you or between TCS and your representative agency.

TCS is a “data controller”. This means that we are responsible for deciding how we hold and use personal

data about you. We are required under data protection legislation to notify you of the information contained

in this privacy notice.

This Privacy Notice applies to all candidates seeking employment / work placements / contracting / project

based assignments with TCS, regardless of contract type.

It is important that you read this notice, together with any other privacy notice we may provide on specific

occasions when we are collecting or processing personal data about you, so that you are aware of how and

why we are using such information.

DATA PROTECTION PRINCIPLES

We will comply with applicable data protection laws. This means that the personal data we hold about you

must be:

1. Used lawfully, fairly and in a transparent way.

2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is

incompatible with those purposes.

3. Relevant to the purposes we have told you about and limited only to those purposes.

4. Accurate and kept up to date.

5. Kept only as long as necessary for the purposes we have told you about

6. Kept securely.

THE KIND OF INFORMATION WE HOLD ABOUT YOU

Personal data means any information about an individual from which that person can be identified. It does

not include data where the identity has been removed (aka anonymous data).

There are “special categories” of sensitive personal data, which we may also collect, store and use. These

require a higher level of protection

In the context of our candidate recruitment, we may Process the below-mentioned categories of your data

through digital and paper-based systems. We collect your data in a number of ways:

• Unsolicited CVs sent directly to our HR/Recruitment seeking employment opportunities

• CVs sent to our HR/Recruitment in response to specific job advertisement(s)

• CVs sent to our HR/Recruitment by sourcing vendor companies / recruitment agencies

• CVs sent to our HR/Recruitment by existing TCS employees e.g. employee referral

• CVs received by our HR/Recruitment/Project teams through non TCS employees

• Job sites

• TCS website

• Social Media

• Placement coordinators from education institutions

Further, we may collect personal data from you, through your activities prior to, in the course of, and after

your assessment for a suitable position or from third parties (including references), and may include the

following:

• Personal information: such as name and contact information (home address, personal phone

number/s, email address and emergency contact information), date of birth, government

identification numbers, citizenship, residency, passport details, driving license, vehicle license plate

number, visa information, marital status, dependents, gender, visual images, competencies, and

other data collection permitted or required by local law

• Compensation information: such as base salary and statutory or contractual benefits, annual

salary, pay scale and range, type of employee, incentive information, equity and other

compensation program participation and salary history

Background information: such as, previous residence(s), educational qualifications, industry

certifications, training and employment background, medical and other background information

commonly used for security screenings where applicable to your role.

We may also collect, store and use the following “special categories” of sensitive personal data:

• Information about your race or ethnicity, religious beliefs and sexual orientation.

• Trade union membership, if applicable.

• Information about your health, including any medical condition, health and sickness records.

• Biometric data.

• Information about criminal convictions and offences, County Court Judgments or history of unlawful

or objectionable behaviour (not the criminal record itself),

HOW IS YOUR PERSONAL DATA COLLECTED

We collect personal data about you through websites (internet and intranet), forms and templates, emails,

other interactions, either directly from you and from third party sources, e.g. recruiters, employment agency,

job sites, training providers, back ground check companies (if applicable), etc.

HOW WE WILL USE INFORMATION ABOUT YOU

We will only use your personal data when the law allows us to. Most commonly, we will use your personal

data in the following circumstances:

1. Where we need it to assess your suitability for a role within TCS

2. Where we need to comply with a legal obligation.

3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and

fundamental rights do not override those interests.

We may also use your personal data in the following situations, which are likely to be rare:

1. Where we need to protect your interests (or someone else’s interests).

2. Where it is needed in the public interest or for official purposes.

Situations in which we will use your personal data

We need all the categories of information in the list above primarily to allow us to perform an assessment

of your suitability for a role within TCS and to enable us to comply with legal obligations. In some cases,

we may use your personal data to pursue legitimate interests of our own or those of third parties, provided

your interests and fundamental rights do not override those interests. The situations in which we will process

your personal data are listed below:

• Making a decision about your recruitment or appointment, e.g. determining the terms on which

you work for us, checking whether you are legally entitled to work in the country of

employment.

• Paying you and, if you are an employee, deducting tax and social security contributions, liaising

with your pension provider and other benefits providers, making decisions about salary reviews

and compensation.

• Administering the contract we may enter with you

• Business management and planning, including accounting and auditing.

• Assessing qualifications for a particular job or task, including decisions about promotions.

• Education, training and development requirements.

• Complying with health and safety obligations.

• To prevent fraud.

• To ensure network and information security, including preventing unauthorized access to our

computer and electronic communications systems and preventing malicious software

distribution.

• To conduct data analytics studies to review and better understand employee retention and

attrition rates.

• Equal opportunities monitoring.

If you fail to provide personal data

If you fail to provide certain information when requested, we may not be able to perform the assessment

and therefore may not be able to continue with the assessment process or we may be prevented from

complying with our legal obligations, such as to ensure the health and safety of our visitors, employees and

contractors.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably

consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the

legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance

with the above rules, where this is required or permitted by law.

HOW WE USE PARTICULARLY SENSITIVE PERSONAL DATA

”Special categories” of particularly sensitive personal data require higher levels of protection. We need to

have further justification for collecting, storing and using this type of personal data. We may process special

categories of personal data in the following circumstances:

1. In limited circumstances, with your explicit written consent.

2. Where we need to carry out our legal obligations or exercise rights in relation to your engagement with

us. We have in place an appropriate policy document and safeguards which we are required by law to

maintain when processing such data.

3. Where it is needed in the public interest, such as for equal opportunities monitoring or in relation to our

occupational pension scheme. We have in place an appropriate policy document and safeguards which we

are required by law to maintain when processing such data.

Less commonly, we may process this type of information where it is needed in relation to legal claims or

where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving

your consent, or where you have already made the information public.

Our obligations as a Data Controller

We will use your particularly sensitive personal data in the following ways:

• We will use information about your physical or mental health, or disability status, to ensure your

health and safety in the workplace and to assess your fitness to work, to assess what appropriate

workplace adjustments we may need to make.

• We will use information about your race or national or ethnic origin, religious, philosophical or moral

beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring

and reporting

• We will use trade union membership information (if applicable) to pay trade union premiums,

register the status of a protected employee and to comply with employment law obligations, if and

to the extent necessary.

• To maintain access to sensitive areas of operations or sensitive systems, such as premises and

storage facilities, which are subject to access control using biometric data (such as a finger print).

• To determine and validate access to premises using CCTV.

Do we need your consent?

We do not need your consent if we use special categories of your personal data in accordance with our

written policy to carry out our legal obligations or exercise specific rights in the field of employment law. In

limited circumstances, we may approach you for your written consent to allow us to process certain

particularly sensitive data. If we do so, we will provide you with full details of the information that we would

like and the reason we need it, so that you can carefully consider whether you wish to consent. You should

be aware that it is not a condition of your contract with us that you agree to any request for consent from

us.

BACKGROUND INFORMATION

We may only use information relating to criminal convictions where the law allows us to do so. This will

usually be where such processing is necessary to carry out our obligations and provided we do so in line

with our data protection policy or applicable local policies.

Less commonly, we may use information relating to criminal convictions where it is necessary in relation to

legal claims, where it is necessary to protect your interests (or someone else’s interests) and you are not

capable of giving your consent, or where you have already made the information public.

We envisage that we will hold information about criminal convictions.

We will only collect information about criminal convictions if it is appropriate given the nature of your role

and where we are legally able to do so. Where appropriate, we will collect information about criminal

convictions as part of the recruitment and onboarding process or we may be notified of such information

directly by you.

We are allowed to use your personal data in this way to carry out our obligations with relevant stakeholders.

We have in place an appropriate policy and safeguards which we are required by law to maintain when

processing such data.

LightKnow · 11 August 2021 at 5:54PM

DATA SHARING

We may have to share your data with third parties, including third-party service providers, TCS clients and

other entities in the group. We require third parties to respect the security of your data and to treat it in

accordance with the law. We may transfer your personal data outside the EU/EEA. If we do, you can expect

a similar degree of protection in respect of your personal data.

Why might you share my personal data with third parties?

We will share your personal data with third parties where required by law, where it is necessary to administer

the recruitment process or where we have another legitimate interest in doing so.

Which third-party service providers process my personal data?

”Third parties” includes third-party service providers (including contractors and designated agents) and

other entities within our group (including clients of TCS where individuals engaged by TCS are expected or

required to work with or for that client). The following activities are carried out by third-party service

providers: Security screening, education and identification verification and suitability for the role.

How secure is my information with third-party service providers and other entities in our group?

All our third-party service providers and other entities in the group are required to take appropriate security

measures to protect your personal data in line with our policies. We do not allow our third-party service

providers to use your personal data for their own purposes. We only permit them to process your personal

data for specified purposes.

When might you share my personal data with other entities in the group?

We will share your personal data with other entities in our group, with regards to workforce allocation, role

assignment and the recruitment process

What about other third parties?

We may share your personal data with other third parties. We may also need to share your personal data

with a regulator or to otherwise comply with the law.

Transferring information outside the EU/EEA

We may transfer the personal data we collect about you to countries outside the EU/EEA in order to conduct

the assessment of your application and suitability: for example UK, India, Australia, USA and other TCS

entities in LATAM or APAC. Currently, India, Australia, the USA and other countries in LATAM and APAC

where TCS has presence are not deemed by the European Commission to be ‘adequate’ data transfer

countries. This means that the countries to which we transfer your data are not currently recognised as

providing an adequate level of protection for your personal data. As such, to ensure that your personal data

does receive an adequate level of protection when transferred to these countries, we have put in place data

transfer agreements based on EU Model Clauses. These model clauses are an agreement between TCS

and any third party outside of the EU/EEA or any TCS facility outside the EU/EEA to which we transfer your

personal data which require those third parties to treat your personal data in a way that is consistent with

EU/EEA laws on data protection. This includes implementing adequate physical and organizational security

measures to protect your personal data. TCS will not transfer your data outside of the EU/EEA without

having the EU Model Clauses in place to protect it.

DATA SECURITY

We have put in place measures to protect the security of your information.

Third parties will only process your personal data on our instructions and where they have agreed to treat

the information confidentially and to keep it secure.

We have put in place appropriate technical, organizational and security measures to prevent your personal

data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In

addition, we limit access to your personal data to those employees, agents, contractors and other third

parties who have a business need to know. They will only process your personal data on our instructions

and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and

any applicable regulator of a suspected breach where we are legally required to do so.

DATA RETENTION

How long will you use my information for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for,

including for the purposes of satisfying any legal, accounting, or reporting requirements to determine the

appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the

personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the

purposes for which we process your personal data and whether we can achieve those purposes through

other means, and the applicable legal requirements.

If your application is successful, we will retain all the data collected during the recruitment phase for the

duration of your employment. In some cases we will retain elements of the personal data for an additional

period no longer than seven years after the end of your engagement with TCS

If your application is unsuccessful, we will erase all the personal data collected during the recruitment

phase after a period of six months after you have been unsuccessful in your application for a role with

TCS.

DATA SUBJECT RIGHTS

Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed

if your personal data changes during your relationship with us.

Your rights in connection with personal data

Under certain circumstances, by law you have the right to:

• Request access to your personal data (commonly known as a “data subject access request”).

This enables you to receive a copy of the personal data we hold about you and to check that we

are lawfully processing it.

• Request correction of the personal data that we hold about you. This enables you to have any

incomplete or inaccurate information we hold about you corrected.

• Request erasure of your personal data. This enables you to ask us to delete or remove personal

data where there is no good reason for us continuing to process it. You also have the right to ask

us to delete or remove your personal data where you have exercised your right to object to

processing (see below).

• Object to processing of your personal data where we are relying on a legitimate interest (or

those of a third party) and there is something about your particular situation which makes you want

to object to processing on this ground. You also have the right to object where we are processing

your personal data for direct marketing purposes.

• Request the restriction of processing of your personal data. This enables you to ask us to

suspend the processing of personal data about you, for example if you want us to establish its

accuracy or the reason for processing it.

• Request the transfer of your personal data to another party.

lincroft1710 · 12 August 2021 at 5:55PM

I think your posts will be too long for anybody to bother reading

74jax · 12 August 2021 at 6:15PM

There's no way I'm reading that 😂.

Maybe which part do you want to query? That might be easier?

LightKnow · 12 August 2021 at 7:10PM

sorry I know it long, It was hard to pick parts but I tried to take part out it.

TCS is a “data controller”. This means that we are responsible for deciding how we hold and use personal

Further, we may collect personal data from you, through your activities prior to, in the course of, and after

your assessment for a suitable position or from third parties (including references), and may include the

following:

• Personal information: such as name and contact information (home address, personal phone

number/s, email address and emergency contact information), date of birth, government

identification numbers, citizenship, residency, passport details, driving license, vehicle license plate

number, visa information, marital status, dependents, gender, visual images, competencies, and

other data collection permitted or required by local law

• Compensation information: such as base salary and statutory or contractual benefits, annual

salary, pay scale and range, type of employee, incentive information, equity and other

compensation program participation and salary history

Background information: such as, previous residence(s), educational qualifications, industry

certifications, training and employment background, medical and other background information

commonly used for security screenings where applicable to your role.

We may also collect, store and use the following “special categories” of sensitive personal data:

• Information about your race or ethnicity, religious beliefs and sexual orientation.

• Trade union membership, if applicable.

• Information about your health, including any medical condition, health and sickness records.

• Biometric data.

• Information about criminal convictions and offences, County Court Judgments or history of unlawful

or objectionable behaviour (not the criminal record itself),

of your suitability for a role within TCS and to enable us to comply with legal obligations. In some cases,

we may use your personal data to pursue legitimate interests of our own or those of third parties, provided

your interests and fundamental rights do not override those interests. The situations in which we will process

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably

consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the

legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance

with the above rules, where this is required or permitted by law.

HOW WE USE PARTICULARLY SENSITIVE PERSONAL DATA

”Special categories” of particularly sensitive personal data require higher levels of protection. We need to

have further justification for collecting, storing and using this type of personal data. We may process special

categories of personal data in the following circumstances:

1. In limited circumstances, with your explicit written consent.

2. Where we need to carry out our legal obligations or exercise rights in relation to your engagement with

us. We have in place an appropriate policy document and safeguards which we are required by law to

maintain when processing such data.

3. Where it is needed in the public interest, such as for equal opportunities monitoring or in relation to our

occupational pension scheme. We have in place an appropriate policy document and safeguards which we

are required by law to maintain when processing such data.

Less commonly, we may process this type of information where it is needed in relation to legal claims or

where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving

your consent, or where you have already made the information public.

Our obligations as a Data Controller

We will use your particularly sensitive personal data in the following ways:

• We will use information about your physical or mental health, or disability status, to ensure your

health and safety in the workplace and to assess your fitness to work, to assess what appropriate

workplace adjustments we may need to make.

• We will use information about your race or national or ethnic origin, religious, philosophical or moral

beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring

and reporting

Jillanddy · 12 August 2021 at 8:51PM

I also lost the will to live on the shorter version. Nobody is going to help here. If you are that bothered, I think you need a lawyer.

Manxman_in_exile · 12 August 2021 at 10:07PM

I didn't need to get past the first line - Tata's grammar is appalling and that would be enough for me to bin them...

LightKnow said:

...
Tata Consultancy Services Limited (“TCS” or “we”) is committed to protecting the privacy and security of
your personal data.

"... we is.. "? Are they singular or plural? Do they even know? Honestly - if they can't be bothered to sell themselves...

LightKnow · 13 August 2021 at 11:47AM

Thanks, I understand it is far to long, There this one part am not understanding? Is this kinda generic for companies ?

Transferring information outside the EU/EEA