Logistic Coordinator TEST Tamara and Kamila
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Information notice regarding the processing of Personal Data of International Employees
in accordance with the Swiss Federal Data Protection Act (FDPA) and Regulation (UE) 2016/679 (GDPR),
if applicable
Data Controller and Contact Point
Your personal data are processed by Global Projects Services AG, Uetlibergstrasse 134a, 8045 Zürich, Switzerland (GPS or Company) as data controller and the persons or legal entities which process these data on GPS' behalf as data processors.
Employees who want to exercise their rights under the Federal Data Protection Act (FDPA) and any other applicable data protection laws, in particular the European General Data Protection Regulation (GDPR), the Federal Data Protection and Information Commissioner (FDPIC) and any other data protection authorities competent for the data processing by the Company, may contact GPS under privacygps@saipem.com.
Personal Data Processed
This Information Notice on the Processing of Personal Data of International Employees (Information Notice) applies to all personal data that you as Employee of GPS to be deployed to companies outside Switzerland (you or Employee) provide or that are collected by or on behalf of GPS in connection with your employment relationship with GPS. For the avoidance of doubt, it does not apply to any data processed for the purposes of and in relation to taxes, pension plans, social security or insurance contracts, declarations, terms applicable to them or any change thereof, information or communication relating to them, or payments made or received in relation to them, even if the Company was involved therein.
All your personal data will be processed in accordance with the FDPA, as amended, and any ordinances, guidelines and fact sheets issued thereunder by the FDPIC or any other competent public authority, and any other data protection laws and regulations that may be applicable, in particular the GDPR. The Company undertakes to process your personal data in accordance with the principles of fairness, lawfulness and transparency, in compliance with the purposes set out below and only insofar as necessary for these specified purposes. Only authorized and properly trained personnel will be allowed to process said data.
The Company will collect, record, consult and generally process your personal data, such as name, surname, address, telephone number, e-mail address, bank and payment details, qualifications, leave of absence, education, data on health issues as well as special categories of data and data relating to criminal convictions and offences, only insofar as necessary for and justified by the performance of your employment contract.
GPS will also process personal data of family members of the Employee, such as name, surname, address, telephone number, e-mail address, bank and payment details in order to conduct expatriation and/or repatriation procedures for the Employee and his/her family members and to notify family members in cases of emergency or transfer to them money when due.
Data are collected from the Employee or acquired from third parties at the time of the conclusion of the employment contract and during the course of the employment.
You are intended to be deployed to perform work for and within the organization of another Company, which will process your personal data as independent data controller. The scope and objectives of the processing of your personal data by that other Company will be governed by the letter of deployment and the data protection notices and internal regulations of that Company. This notice will apply by default where and with the appropriate modifications insofar as any issue is not covered by the data protection notice of that other Company.
When deployed to that other Company, you may be assigned to a work location where a video surveillance system is installed. The video surveillance system consists of cameras equipped with an application that exploits artificial intelligence technology, which makes it possible to report, in real time, to the person in charge of safety, behaviors, held by Employees, that do not comply with the standards placed to protect health and safety in the workplace. The personal data thus collected are anonymized upon receipt of the images and in any case within a minimum time frame.
In order to enable the operation of the automatic safety anomaly recognition system, a model is prepared using training elements constituting images (e.g., with squares drawn on the safety harness so that the model can learn to recognize the same harness). Once trained, the model will be validated against a new, previously unused dataset to evaluate its performance.
Processing will be carried out in digital and/or paper form, with methods and tools designed to ensure maximum security and confidentiality, by individuals specifically appointed for this purpose, as well as an adequate level of accuracy, robustness, and cybersecurity of the systems in accordance with the best practice.
The Company you will be deployed to may have in place a system to control physical access through video surveillance systems, where installed, in order to guarantee the safety of people and property.
That Company you will be deployed to may also have in place a system to control physical access and exit to and from that Company’s offices and work sites through a badge in order to guarantee the safety of people and property, or through a system of biometrical data if justified by special safety considerations.
1. Purpose of the processing
Personnel administration, exercising rights and fulfilment of obligations arising from the employment contract.
Legal basis of the processing
The processing of personal data is lawful because it is necessary for the execution of the employment contract, including the Organisation and Management Model 231 and the GPS Code of Ethics (art. 6 para. 1 lit. (b) GDPR), to comply with the legal obligations to which the Controller is subject (art. 6 para. 1 lit. (c) GDPR), and for the purposes of the legitimate interests of GPS to assert or defend its rights, reputation and property or those of a third party whose interests GPS is obligated to guard (art. 6 para. 1 lit. (f) GDPR).
Retention period of data
Personal data will generally be kept for 10 years from the date of their collection or last processing, except where legal requirements, the nature of the data or their possible use for determining the rights and obligations of the parties justify a retention for up to 5 years. Where data may be relevant for any likely claims of or against the Company after that period, the data may be retained until the end of the prescription period and for the duration of the initiation or knowledge of the initiation of any possible legal action, plus the duration of any litigation or arbitration until final and binding adjudication or until settlement in full.
GPS may retain the personal data relevant for employment related diseases or bodily damages for a retention period of up to 20 years after the termination of the employment contract, or for the maximum of the practically relevant and scientifically recognised latency periods if longer, plus an appropriate additional period as set forth in the preceding paragraph.
2. Purpose of the processing
Fulfilment of regulatory obligations (e.g., the obligations of the Controller with regard to whistleblowing).
Legal basis of the processing
The processing of personal data is lawful because it is necessary to comply with the legal obligations to which the Controller is subject (art. 6 para. 1 lit. (c) GDPR), and for the purposes of the legitimate interests of GPS to assert or defend its rights or those of a third party whose interests GPS is obligated to guard (art. 6 para. 1 lit. (f) GDPR). The processing of special categories of particularly sensitive personal data is lawful because it is necessary to fulfil the obligations and exercise the rights of the Controller or Employee in the field of labor law (art. 9. para. 2 lit. (b) GDPR).
Retention period of data
Personal data will at least be retained for the period during which the Company may face negative consequences if it were not able to use these personal data as evidence.
3. Purpose of the processing
Fulfillment of regulatory obligations regarding health and safety at work.
Legal basis of the processing
The processing of personal data is lawful because it is necessary to comply with the legal obligations to which the Controller is subject (art. 6 para. 1 lit. (c) GDPR), in order to protect the vital interests of the Employee or of another natural person (art. 6 para. 1 lit. (d) GDPR) and for the purposes of the legitimate interests of GPS to defend its rights, reputation and property or those of a third party whose interests GPS is obligated to guard (art. 6 para. 1 lit. (f) GDPR). The processing of special categories of particularly sensitive personal data is lawful because it is necessary for purposes of preventive medicine or occupational medicine, and for the assessment of the Employee's ability to work by a competent health professional (art. 9 para. 2 lit. (h) GDPR).
Retention period of data
Personal data will at least be retained for the period during which the Company may face negative consequences if it were not able to use these personal data as evidence.
4. Purpose of the processing
Control of physical access and exit - through a badge - to and from the Company offices and work sites in order to guarantee the safety of people and property.
Legal basis of the processing
The processing of personal data is lawful because it is necessary to comply with the legal obligations to which GPS is subject (art. 6 para. 1 lit. (c) GDPR) and for the purposes of the legitimate interests of GPS to assert or defend its rights, reputation and property and those of a third party whose interests GPS is obligated to guard (art. 6 para. 1 lit. (f) GDPR).
Retention period of data
Personal data relating to access control by badge will be stored for a period of 5 years.
5. Purpose of the processing
Control of physical access through video surveillance systems, where installed, in order to guarantee the safety of people and property.
Legal basis of the processing
The lawfulness of processing is the compliance with a legal obligation (art. 6 para 1 lit. (f) GDPR) and the legitimate interest of GPS as the data controller (art. 6 para 1 lit. (f) GDPR). The processing of special categories of particularly sensitive personal data is lawful because it is necessary to fulfil the obligations and exercise the rights of the Controller or Employee in the field of labor law (art. 9. para. 2 lit. (b) GDPR), and to protect the vital interests of the data subject or of another natural person where the Employee is physically or legally incapable of giving consent (art. 9. para. 2 lit. (c) GDPR). The Employee will be informed about the positioning, scope and objective of recording of the video surveillance systems.
Retention period of data
Personal data relating to access control by video or use of biometrical data will generally not be stored for a period longer than seven days, unless specific circumstances require or justify a longer retention. Video recordings will be stored under special security measures which prevent any use not permitted by applicable law.
6. Purpose of the processing
Retention and use of your personal data for asserting of or defending against a right or claim of or against the Company in court, in arbitration, in conciliation procedures, or in criminal or administrative procedures.
Legal basis of the processing
The processing of personal data is lawful because it is necessary for the purposes of the legitimate interests of GPS to assert or defend its rights, reputation and property and those of a third party whose interests GPS is obligated to guard (art. 6 para. 1 lit. (f) GDPR). The processing of special categories of particularly sensitive personal data is lawful because it is necessary to establish, exercise or defend the rights of GPS in court or arbitral for administrative proceedings (art. 9 para. 2 lit. (f) GDPR).
Retention period of data
Where data are or where there are specific indications that data may be relevant for any claims of or against the Company, the data may be retained until the end of the prescription period and for the duration of the initiation or knowledge of the initiation of any possible legal action before any state court, arbitral tribunal or administrative authority, plus the duration of such legal action until final and binding adjudication or until settlement in full.
7. Purpose of the processing
Management of emergency situations affecting the Employee, including immediately notifying family members if the Employee cannot do it independently.
Legal basis of the processing
The processing of personal data is lawful because it is necessary to comply with the legal obligations to which GPS is subject (art. 6 para. 1 lit. (c) GDPR) and for the purposes of the legitimate interests of GPS in managing emergency situations that may involve its Employees (art. 6 para. 1 lit. (f) GDPR). The processing of special categories of particularly sensitive personal data is necessary to protect the vital interests of the Employee or of another natural person where the Employee is physically or legally incapable of giving consent (art. 9 para. 2 lit (c) GDPR).
Retention period of data
Personal data relating to the Employee’s family members will be kept for the duration of the employment relationship, but may be retained for a longer period if necessary for the purposes of the legitimate interests of GPS.
8. Purpose of the processing
Archiving of Company e-mail messages.
Legal basis of the processing
The processing of personal data is lawful for the purposes of the legitimate interest of GPS in having documentary evidence and/or proof in order to assert claims or defend its rights, interests and property in the event of any disputes with suppliers and/or costumers (art. 6 para 1 lit (h) GDPR.
Retention period of data
Personal data will be stored for 15 years from the date of sending/receiving each corporate message, unless there is a legitimate interest to keep them longer.
9. Purpose of the processing
Data mining activities to improve work processes.
Legal basis of the processing
The processing of personal data is lawful because it is necessary for the purposes of the legitimate interests to improve work processes and to optimize its operational processes according to a “data driven” logic (art. 6 para. 1 lit. (f) GDPR).
Retention period of data
Personal data retained for data mining purposes will be processed for the time period during which it is relevant for optimizing GPS’s operational processes.
10. Purpose of the processing
IT security management, including log management in order to detect malicious access and behavior.
Legal basis of the processing
The processing of personal data is lawful because it is necessary to comply with a legal obligation to which GPS is subject (art. 6 para. 1 lit. (c) GDPR) and for the purposes of the legitimate interests pursued by GPS in preserving the integrity of its IT system (art. 6 para. 1 lit. (f) GDPR).
Retention period of data
Personal data related to IT security management, in particular log management data, will be retained for a period of 6 months from their recording.
During the period of lawful retention, the data will be retained in accordance with standard data security, storage and backup procedures.
11. Purpose of the processing
In case you are assigned to a work location where a video surveillance system is installed in the workplace, whereby indicated by the specific signs showing the presence of the cameras:
Legal basis of the processing
The legal basis that legitimizes the processing of personal data for the stated purposes is the legitimate interest of the Data Controller, pursuant to Art. 6(1)(f) GDPR, in order to ensure a high level of safety in critical workplaces to protect the lives and physical integrity of workers and of whom, in various capacities, attend critical workplaces.
Retention period of data
Video recordings will be stored for 24 hours after recording, unless specific circumstances justify a longer recording.
In case of a "safe/unsafe" report, anonymized frames recorded by video surveillance cameras shall be retained for 30 days or any longer period justified by specific circumstances. Frames will not be anonymized if relevant because of the behaviour of individual Employees.
Anonymized frames recorded by video surveillance cameras can be retained for 3 months after image detection.
Once the retention period has elapsed the data will be destroyed or made anonymous in accordance with GPS' standard erasure and backup procedures.
Way of processing and provision of data
The processing of personal data will be carried out on digital, paper and other media, using methods and tools that are appropriate with regard to the state of the art, the nature and the extent of the data processing and the risk of the processing for the Employee's personality or fundamental rights, so as to comply with the protection regulations, in particular those regarding security and confidentiality, by persons chosen, instructed and supervised so that they are able to guarantee compliance with the employment contract, this Information Notice, and the applicable data protection regulations.
Where the processing of your personal data and those of your family members is necessary for the commencement and continuation of the employment relationship, in particular for the performance of the employment contract and for compliance with legal obligations, a refusal to provide these data may make it impossible to commence or continue working for the Company.
Where the processing of personal data is necessary for the fulfillment of certain post-termination obligations of GPS, in particular to fulfill legal obligations, a refusal of processing of certain data or restriction of disclosure to third parties will make it impossible for GPS to fulfill certain obligations towards you or in your favour.
Recipients and data transfer
The Company may transfer personal data to other parties for the purposes set out above, for example:
Administrative authorities, courts and arbitral tribunals to whom disclosure of personal data is required by law or necessary for the purposes of the legitimate interests of GPS or a third party. These subjects will process the data in their capacity as independent data controllers.
Personal data are transferred to third parties only under contractual or otherwise binding conditions that the data may only be used for the specific purposes for which they are transferred and not for any purposes for which GPS could not process them.
GPS may transfer personal data to any country outside Switzerland where any other Saipem Group companies have their seat or registered office or any establishment, or anywhere in the world also to any country where no other Saipem Group Company is present.
Personal data will only be transferred to countries outside Switzerland and the EU if data privacy is guaranteed by adequacy decisions by the Federal Council (or the European Commission under the GDPR), by data protection provisions of a contract between the controller or the processor and its contracting party, by standard model clauses or on the basis of binding corporate rules.
Data Subjects rights
You have the right to ask GPS as the data controller for access to your personal data, and for rectification, erasure and hand-over of your personal data in a structured, commonly used and machine-readable (portable) format, completion of incomplete personal data, restriction of processing in the cases provided for by art. 18 GDPR, as well as the right to object to any processing that does not comply with the applicable laws, or for reasons related to your particular situation in cases where data processing is necessary for the purposes of the legitimate interests of GPS as the data controller or a third party, explicitly stating which interests or fundamental rights and freedoms of yours requiring protection of personal data override the legitimate interests of GPS or the third party, or restriction of disclosure to third parties that is not in compliance with the applicable laws and this Information Notice. In addition, only in case the data are processed on the basis of your consent, you may revoke your consent at any time with effect for the future.
The right to update or supplement, as well as the right to rectify personal data cannot be exercised where the intrinsic nature of the data processed makes this unreasonable or practically impossible, such as images recorded in the course of video surveillance.
These rights may be exercised at any time, against GPS as the data controller, by sending a specific request in writing to the e-mail address privacygps@saipem.com. You can also write to GPS at the address given in the letterhead above.
You are aware that a deletion, hand-over, restriction of processing or of disclosure to third parties or revocation of your consent for processing of your personal data may mean that you can no longer hold the position you currently hold, or that your employment with GPS must be terminated.
You also have the right to lodge a complaint with the FDPIC or any other competent supervisory authority and to use other means of protection, as provided by the FDPA and other applicable laws.
INFORMATION NOTICE ACKNOWLEDGEMENT
I hereby acknowledge that I have read and understood the Information Notice on the processing of Personal Data of International Employees.
This Information Notice on data processing is available on the GPS website at www.gpsag.ch.
Types of Data collected
Among the Personal Information collected by this Site through the contact form and the form for spontaneous applications there are: Cookies, Usage Data, Email, Password, Name, Surname.
Other Personal Data collected may be indicated in other sections of this privacy policy or through informative texts displayed together with the collection of the Data.
Personal Data is entered voluntarily by the User.
Any use of Cookies - or other tracking tools - by this Site, unless otherwise specified, has the purpose of identifying the User and recording the related preferences for purposes strictly related to the provision of the service requested by the User.
Failure to provide the User with some Personal Data may prevent this Site from providing its services.
The User assumes the responsibility of the Personal Data of third parties published or shared through this Site and guarantees to have the right to communicate or disseminate them, freeing the Owner from any liability to third parties.
Purposes of the processing of collected data
The Data concerning the User is collected to allow the Owner to provide its services, as well as for the following purposes: Analytics, Contacting the User, Optimizing and distributing traffic.
The types of Personal Data used for each purpose are indicated above.
Communication and dissemination of data
The data collected using cookies may be processed by employees and collaborators of nCore HR, as persons in charge and responsible for data processing.
The list of data is constantly updated and is available upon request by sending a communication to the address below or an e-mail to ----
The data collected using cookies will not be disclosed.
Your rights
At any time you can request information on the processing of your personal data, obtain the update, correction or integration of the same, as well as obtaining the cancellation, transformation into anonymous form or blocking of data processed in violation of the law and oppose the processing of You according to the provisions of art. 7 of Legislative Decree no. 196/2003 reported in full at the end of this policy.
To exercise your rights you can contact the Data Controller by sending a written notice to the address below or an e-mail to ----
Owner and manager of the treatment
Holder of the treatment is ----
Internal manager of the treatment is ----
Last updated: July 2015
Art. 7 D.Lgs 196/2003. Rights attributed to the interested party.
The interested party has the right to obtain confirmation of the existence or not of personal data concerning him, even if not yet registered, and their communication in intelligible form.
The interested party has the right to obtain the indication:
the origin of personal data;
of the purposes and methods of processing;
of the logic applied in case of treatment carried out with the aid of electronic instruments;
of the identifying details of the holder, of the responsible and of the designated representative according to article 5, paragraph 2;
the subjects or the categories of subjects to whom the personal data may be communicated or who can learn about them as appointed representative in the territory of the State, managers or agents.
The interested party has the right to obtain:
updating, rectification or, when interested, integration of data;
the cancellation, transformation into anonymous form or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed;
the attestation that the operations referred to in letters a) and b) have been brought to the attention, also with regard to their content, of those to whom the data have been communicated or disseminated, except in the case in which this fulfillment proves impossible o involves a use of means manifestly disproportionate to the protected right.
The interested party has the right to object, in whole or in part:
for legitimate reasons, the processing of personal data concerning him, even if pertinent to the purpose of the collection;
to the processing of personal data concerning him for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication.
Changes to this information
The Data Controller reserves the right to make changes to this privacy statement at any time by giving notice to Users on this page. Please therefore consult this page often, referring to the date of the last modification indicated at the bottom. In case of non-acceptance of the changes made to this statement, the User is required to cease using this Site and may request the Data Controller to remove his Personal Data. Unless otherwise specified, the previous privacy policy will continue to apply to Personal Data collected until then.
Information on this privacy policy
The Data Controller is responsible for the privacy policy.
Last updated: July 2015