Super Transfer UK Ltd, its affiliates and subsidiaries place a priority on the Data Privacy of its employees, contractors, clients, prospective clients, service providers and other partners or third parties and on the importance of compliance with Data Protection and Privacy laws worldwide. Thus, Super Transfer UK Ltd has developed this Policy that outlines and explains the appropriate principles concerning collecting, processing, transferring and using an individual's Personal Data during everyday business.
In its collection, use and disclosure of Personal Data, Super Transfer UK Ltd strives to balance the needs of managing its business effectively while minimising intrusiveness and complying with local legal requirements. In some countries, additional requirements beyond this policy may be applied to comply with local legislation. Data Protection and Privacy has been and will continue to be an integral component of Super Transfer UK Ltd business practices.
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The Data Protection and Privacy principles below are the foundation of this Policy. As such, Super Transfer UK Ltd will, through appropriate management and controls on an ongoing basis, monitor implementation of and compliance with these principles. It shall be a fundamental principle with Super Transfer UK Ltd that any Personal Data shall be processed fairly, sensitively, respectfully and in accordance with this Policy and applicable local law.
Notice: Super Transfer UK Ltd will inform individuals about the purpose for which it collects Personal Data, how to contact Super Transfer UK Ltd with inquiries or complaints, and the administrative process by which the complaints will be resolved. Where appropriate, Super Transfer UK Ltd will communicate the types of third parties to which Super Transfer UK Ltd discloses Personal Data, and the choices, procedures and means Super Transfer UK Ltd offers for limiting use and disclosure of personal information will also be provided.
Choice: Subject to applicable local law and Super Transfer UK Ltd policies, general procedures and business requirements Super Transfer UK Ltd will ensure that the rights of Data Subjects, about whom Personal Data is held, can be fully exercised. This includes the right of an individual to choose how their Personal Data provided is used, whether the use of such data is incompatible with the original purpose or authorizations, or is disclosed to third parties, subject to laws requiring disclosure and consent.
Onward Transfer: Super Transfer UK Ltd will ensure that all transfers of Personal Data, whether within or outside of the Super Transfer UK Ltd group, are protected by suitable safeguards and in accordance with applicable local law. Further, unless required by court or another legal mandate, or except as discussed below, Personal Data will only be transferred outside of Super Transfer UK Ltd if the receiving party has entered into a Data Protection Agreement with Super Transfer UK Ltd or comparable safeguards are in place. Where Personal Data is transferred outside of Super Transfer UK Ltd, Super Transfer UK Ltd will ensure that any such transfer protects the legitimate interests of Data Subjects in line with this Policy and applicable local law.
Security: Super Transfer UK Ltd is committed to protecting Personal Data against unauthorized use or disclosure. To ensure the appropriate use of Personal Data, and prevent unauthorized access to such Personal Data, as well as prevent loss, alteration or destruction of Personal Data. In adherence with Data Protection and Privacy laws worldwide and internal Super Transfer UK Ltd policies, Super Transfer UK Ltd will address security at all appropriate technology infrastructure points.
Data Integrity: Super Transfer UK Ltd will collect and process appropriate Personal Data only to the extent that there is a Business Need for Personal Data, to fulfill operational needs, and/or to comply with legal requirements, including those legal requirements of the countries in which the Personal Data was collected, as applicable. Super Transfer UK Ltd will take reasonable steps to ensure that all Personal Data is relevant, accurate, complete, current, and reliable for its intended use. All Data Subjects have a responsibility to assist Super Transfer UK Ltd in this effort.
Data Retention: Super Transfer UK Ltd will not keep Personal Data for longer than is necessary for the purpose or purposes, for which it was intended, or as required by contractual agreement, by law or regulation, by other Super Transfer UK Ltd policies or, where applicable, for the appropriate statute of limitations period.
Access: Upon request, Super Transfer UK Ltd will provide individuals with access to their Personal Data and, when appropriate, allow the individuals to request that their Personal Data be corrected or updated by Super Transfer UK Ltd, as required by law or Super Transfer UK Ltd policies.
Enforcement and Oversight: Super Transfer UK Ltd will address complaints or disputes regarding Personal Data promptly, in an orderly fashion and courteously. Super Transfer UK Ltd will provide or, where appropriate, endeavor to provide notification to Data Subjects about how to file a complaint or inquiry and the administrative process to follow. Super Transfer UK Ltd will perform a self-assessment on a regular basis to verify that this Policy is communicated, prominently displayed, implemented, and accessible. Super Transfer UK Ltd will cooperate with the relevant Data Protection Authorities in the investigation and resolution of complaints relating to this Policy. Super Transfer UK Ltd will seek, in a timely manner as practicable, to comply in good faith with the advice of these authorities.
Training and Audit: Super Transfer UK Ltd will provide appropriate training to all relevant staff handling and dealing with the Processing of Personal Data so that any such processing will be carried out in accordance with this Policy and applicable law. Super Transfer UK Ltd will further ensure that Data Protection and Privacy is subject to periodic audit.
We may transfer your data outside the European Economic Area (the "EEA").
Some of those countries have a European Commission adequacy decision, which means they are considered to offer an adequate level of data protection. Other countries do not have the same level of legal protection as countries in the EEA, or with an adequacy decision. If we do transfer your data in this way, we will take steps to ensure that it is protected to the same levels that apply in the EEA. This may include, for example, ensuring that the organisation receiving the data is registered with the EU-US Privacy Shield (in the case of transfers to the USA), or that we use the EU's model contractual clauses.
Super Transfer UK Ltd entities and all non- Super Transfer UK Ltd entities (e.g., agents, contractors, outsource service providers and processors) accessing or processing Personal Data are required to comply with this Policy with respect to such Personal Data.
The Data Officer is primarily responsible for adopting, implementing, and maintaining this Policy.
The responsibility for the implementation of the Policy lies with every employee and manager, whether the Personal Data is in the form of manual records, computer data or arises from communication with employees and Data Subjects both online (electronic) or off line (manual records). Implementation requirements will include the development of notice and consent forms to provide to managers and Data Subjects where required by applicable laws. Employees, agents, contractors and their employees are individually responsible for providing/maintaining accurate information and for protecting the personal information that Super Transfer UK Ltd has about any individual in support of the implementation of this Policy. Employees who violate this Policy or applicable legal requirements are subject to discipline, up to and including termination of employment, dependent on the severity of the violation. Agents or contractors or their employees who violate this Policy or applicable legal requirements are subject to termination and/or other contractual penalties. Employees, agents and contractors should also be aware that if they knowingly or recklessly obtain or divulge Personal Data without Super Transfer UK Ltd consent, they may be committing a criminal offence.
Human Resources will address any complaints or disputes regarding Personal Data promptly and courteously, and will follow all applicable laws to respond to the complaint. This includes inquiries from Data Subjects, employee councils, management sponsors, or regulatory authorities.
A responsible person designated by management will handle investigations regarding non-compliance with this Policy. All investigations will be handled under the legal requirements of the geographic area where the investigation is taking place.
The Data Officer is responsible for maintaining and safeguarding Personal Data, and for ensuring that access to such Personal Data is restricted to persons who have a job-related "need to know" or who have documented access rights. Covered entities may have access to Personal Data on a business related need to know for purposes generally compatible with the collection of the Personal Data.
Data Subjects may review the contents of any files as requested pursuant to the access principles detailed above and subject to other Super Transfer UK Ltd policies. All Data Subjects must authenticate themselves based on online or offline standards (i.e., pass codes) set by Super Transfer UK Ltd before gaining access. Data Subject may request a copy of documents, but under no circumstances will an individual be allowed to remove any documents from the file or be allowed to remove the original file from Super Transfer UK Ltd. Certain confidential files, such as investigative files, will not be accessible to Data Subjects, in particular employees.
Regarding any requests for information concerning an Super Transfer UK Ltd employee's status which may be received from non-Super Transfer UK Ltd entities, only members of the human resources department are authorized to release any information and this will be restricted to confirmation of current employment including the employee's name, the most recent job title and the dates of Super Transfer UK Ltd employment. Additional information will not be provided without the employee's authorization.
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If you have any questions regarding this notice, or any questions relating to data protection or privacy, you can contact us at firstname.lastname@example.org
Super Transfer UK Ltd may from time to time amend this Policy to reflect changes in any applicable legislation. Super Transfer UK Ltd will notify Data Subjects of such amendments as soon as reasonably practicable.