• Purpose: This Notice describes how we process your personal data, that you share while applying for a job with LTTS or during and after your working relationship with us, in accordance with the General Data Protection Regulations (“GDPR”).
• Applicability: It is applicable to all job applicants. This Notice does not form a part of any contract of employment or other contract to provide services. We may update this Notice at any time, subsequent to which, a copy of the updated Notice will be uploaded on the website of the company.
• Relationship: We are the "Data Controller" as specified under the GDPR. This means that we are responsible for deciding how we process personal data about you. As your prospective employer, we need to process data about you for normal employment purposes including recruitment and on-boarding. Processing will include collection, recording, organisation, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, erasure or destruction of your personal data. The data we hold and process will be used for management and administrative purposes only. We will keep and use it to enable us to run the business and manage our relationship with you effectively, lawfully and appropriately, and in the event you are employed with us or provide services to us, whilst you are working for us, at the time when your employment ends and after you have left us. This includes using personal data to enable us to comply with the recruitment requirements, legal requirements, to pursue our legitimate interest and protect our legal position in the event of legal proceedings. If you do not provide this data or request for the deletion of data shared, we may be unable in some circumstances to comply with our legal obligations and we will tell you about the implications of your such decision.

• Your Personal Data That We Will Process

  We will process the following categories of personal data about you:

  • “Personal Details”, including your name, address and contact details, including email address and telephone number, etc.
  • “National ID Details”, including driver’s license details, passport number, etc.
  • “Current Employment Details” including information about your current level of remuneration, including benefit entitlements, etc.
  • “Previous Employment Details” including information about your previous employment history.
  • “Recruitment Information”, including copies of right to work documentation, details of your qualifications, skills, experience and employment history, past employment details etc.
  • “Background check report” including previous employment references and feedback, etc.

  We may also process the following "special categories" of personal data:

  • Information about your health, including blood group, disability details, any medical condition, health and sickness records/certificates.
  • Criminal records.
  • Ethnic origin, religion or beliefs.

• How is Your Personal Data Collected

  We collect your personal data through the job application, CVs or resumes, interviews, identification documents, assessments either directly from you, or sometimes indirectly through third party service providers. We may sometimes collect additional data from a third party like job recruitment agencies, former employers, and background check providers. We will collect additional personal data in the course of the recruitment activity. All data collected during the recruitment process or additional data collected will be used and stored for performance of employment agreement (in the event we intend to employ you) as well as for complying with the legal obligations or legitimate interests.

• How Will We Use Personal Data 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:

  • Where we need to perform a contract that we will be entering into with you. (For example, we need to to process your data to provide you with an employment contract, to pay you in accordance with your employment contract and to administer [benefit, pension and insurance entitlements]).
  • Where we need to comply with a legal obligation. (For example, it is required to check your entitlement to work, to deduct tax, to comply with health and safety laws and to enable employees to take periods of leave to which you are entitled to in the event you are employed with us.)
  • 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. (For example we need to process your data to carry out administrative activities like issuing of laptop, access, id creation etc.)
  • Where we need to protect your interests (or someone else's interests).
  • Where it is needed in the public interest [or for official purposes].

• If You Fail To Provide Personal Data

  If you fail to provide certain personal data when requested, we may not be able to perform the recruitment activity including executing the employment contract post your selection, or we may be prevented from complying with our legal obligations (For example such as to ensure the health and safety of our workers).

• Change of Purpose

  We will only use your personal data for the purposes for which we collected it. 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 without undue delay. 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.

• Special Categories of Personal Data:

  Special categories of personal data require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal data in accordance with Articles 6 and 9 of the GDPR. We have in place an appropriate policy document and safeguards which are required by law to be maintained when processing such data. We may process special categories of personal data in the following circumstances:

  • Where we need to carry out our legal obligations or exercise rights in connection with employment.
  • Where processing is necessary for the performance of contract to which you will be a party.
  • Where processing is necessary for the purpose of legitimate interest pursued by us or third party with appropriate safeguards.
  • Where processing is necessary for the purpose of carrying out the obligations and exercising our specific rights and in the event of employment, the specific rights of the employees in fields of employment, social security and social protection law, in so far as is authorised by the Union or Member State law or a collective agreement providing appropriate safeguards for your fundamental rights and interests.
  • 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 vital interests (or some else’s interests) and you are physically or legally incapable of giving your consent, or where you have already made the information public.
  • Where processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity.

• Data Sharing

  We will be sharing your personal/ special data with the following recipients:

  • Third parties with whom we have a contractual relationship, including clients, background check vendor, vendors (law firms), etc. We require third parties to respect the security of your data and to treat it in accordance with our instructions and as per the law.
  • Our other entities for performance of employment contract. We may transfer your personal data outside the EU for processing in accordance with the Standard Contractual Clauses executed between us and our L&T Technology Services Limited, India.
  • Internal departments, including with interviewers, recruitment team, hiring managers, etc.

• Transferring Personal Data Outside the EU

  We will transfer the personal data we collect about you to India which is outside the EU in order to perform our contract with you. There does not exist an adequacy decision by the European Commission in respect of this/ these country/ countries.

  However, to ensure that your personal data does receive an adequate level of protection we have executed Standard Contractual Clauses with our L&T Technology Services Limited, India to ensure that your personal data is treated by those third parties in a way that is consistent with and which respects the EU and regional laws on data protection.

• Data Security

  We have put in place measures to protect the security of your personal data. Details of these measures are available upon request or are available on intranet.

  Third parties will only process your personal data on our instructions and they have agreed to treat the personal data confidential and to keep it secure. We do enter into specific agreements with such third parties to ensure compliance.

  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

  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 unauthorised 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.

  In some circumstances, we may anonymise your personal data so that it can no longer be associated with you, in which case we may use such data without further Notice to you. Once your data is no longer required, we will securely destroy your personal data in accordance with our Data Retention Policy.

• Data Protection Officer

  We have appointed a data protection officer (DPO) to oversee compliance with this Notice. If you have any questions about this Notice or how we handle your personal data, please contact the DPO at DPO@lnttechservices.com You have the right to make a complaint at any time to the regional supervisory authority for data protection issues.

• 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 working relationship with us.

• Rights Available To You

  Your rights in connection with personal data: Under certain circumstances, by law, you have the:

  • Right of 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.

  • Right to Rectification of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected.

  • Right to be Informed about the collection and use of personal data.

  • Right to be Forgotten will enable you to ask us to delete or remove personal data which we process about you subject to limited circumstances in accordance with the GDPR requirements.

  • Right to 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.

  • Right to 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.

  • Right of Data Portability/Transfer to another party.  

  • Right to Withdraw Consent for processing of personal data where explicit consent has been sought. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Data Processing Officer at DPO@lnttechservices.com Once we have received notification that you have withdrawn your consent, we will no longer process your data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

  • Right Related to Automated Decision Making Including Profiling. You will have a right not to be subjected to a decision based solely on automated processing including profiling. Such decisions can be made only if, they are necessary for the entry into or performance of a contract or authorized by the Union or Member State law applicable to us or based on your explicit consent.

  All the above mentioned rights can be exercised by contacting the Data Protection Officer at DPO@lnttechservices.com

• No Fee Usually Required

  You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

• Changes to this Notice

  We reserve the right to update this notice at any time, and we will provide you with a new Notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal data.

If you have any questions about this Notice, please contact The Data Protection Officer at DPO@lnttechservices.com