Privacy Policy Privacy Notice The following applies to current and former employees, workers and contractors. This notice does not form part of any contract of employment or other contract to provide services. If you are a client, you should refer to our engagement letter and terms of business to review the nature and purposes of our data collection and processing. Definitions For the purpose of this Privacy Notice the following definitions shall apply in respect of active, former and prospective individuals: Candidates refer to individuals currently on assignment with, or using the payroll services of MDE Group, and those who have registered or engaged with us or our advertising partners with regard to potential temporary and permanent opportunities or are prospective staff Employees of MDE Group. Customers refer to individuals receiving services either paid for directly by themselves, or by their employer or another third party. Clients refer to individuals that represent an organisation who has or is seeking to use the services offered by MDE Group, and those who MDE Group engage with for potential staffing solutions. Employees refer to individuals working directly for MDE Group or its associated companies as a staff’ member of the business. External Providers includes suppliers and business groups partners who provide products or services to MDE Group and regulatory bodies or similar and refers to the individuals representing these organisations. Other Contacts refers to individuals named as next of kin, referees and similar. Third parties include third-party service providers (including contractors and designated agents) and other entities within the MDE Group Website Users refers to individuals accessing MDE Group’s website. Information Collected How we collect information As a candidate, customer or employee you have the opportunity to provide information in various ways and in different formats to suit your needs and preferences. Typically, this could include: Registration through the MDE Group website Applying for a role through MDE Group’ website or other site that utilises our job advertising partner Contacting us through our website; Submitting a CV or application direct to MDE Group or a nominated Consultant Submitting compliance criteria as part of MDE Group’s on-boarding process Submitting information in order to receive services from MDE Group Data collected by the above means includes your personal data and, if present on CVs or included on online profiles, may include other categories of data. By submitting your data to MDE Group via the above means you acknowledge the methods in which MDE Group process your data in accordance with this Privacy Notice. Along with submission of personal data directly, MDE Group collect and use data obtained from other sources available to us in our capacity as a Manpower, relocation and in country services provider. These sources may include: Clients or Candidates as part of a referral or placement scheme; Employment references; Search of online job boards such as Linked-In or other industry job sites External Providers undertaking screening, background checks or insurance services. Where information is coming via a third party, MDE Group will ensure that the Candidate, Customer or Employee has given consent to share information. Data received will be retained within the respective system and made available within MDE Group for the purpose of delivering services as a Manpower, relocation and in country services provider. What information we collect When you interact with us, either as a Candidate, Customer or employee, you may provide us with or we may obtain personal information about you, such as information regarding your: Personal contact details such as name, title, addresses, telephone numbers, and email addresses Date of birth and gender Marital status and dependants Next of kin and emergency contacts National insurance number and other tax or governmental identifiers Bank accounts, payroll and tax status Salary, annual leave, pension and benefits Start date Location of employment or workplace Driving licence (including copies thereof where we are required to hold such information for identification or insurance purposes where you are to use our vehicles); Recruitment (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process); Employment records (including job titles, work history, working hours, training records and professional memberships) Compensation history Pension and pension entitlements Performance including that generated through our appraisal systems Disciplinary and grievance information Movements though CCTV footage and other information obtained through electronic means such as swipecard and key fob records Use of our information and communications systems Image in photographic form Shareholding, option, SARS and dividend entitlement Loans made to MDE Group Using Information MDE are committed to protecting your privacy and will only use your personal information in accordance with applicable data protection legislation. We use your personal data to provide our services, maintain our records, and meet our obligations as a Manpower, relocation and in country services provider. In addition, data from you or generated during the course of our relationship is also used for the purpose of reporting, monitoring and evaluation of services. We will not ask your consent to process personal or sensitive data, however we will only ever process personal or sensitive data for the purposes defined by this Privacy Notice. In line with the conditions defined by the GDPR, we shall ensure the conditions for processing fall into one of more of the following categories: where we need to perform the contract we have entered into with you where we need to comply with a legal obligation 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. where we need to protect your interests (or someone else’s interests); and where it is needed in the public interest. We need all the categories of information in the listed in What Information. We collect primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases, we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers). The situations in which we will process your personal information are listed below; To inform you of potential positions, projects or services that might be of interest to you Managing our database and keeping work-seeker records up to date Contacting you to obtain specific consent where we need it Providing work finding service for our candidates and clients Making a decision about your recruitment or appointment Determining the terms on which you work for us Checking you are legally entitled to work in the country you are applying for To request additional information that may be needed for onboarding, mobilising, or demobilising, and making applications as required including but not limited to visa applications, travel bookings and putting in place medical insurance. Paying you and, if you are an employee, deducting tax and National Insurance or Social Security contributions Legislated reporting including but not limited to HMRC Intermediary reporting and IRS tax clearance Providing benefits of employment, including flexible benefits Liaising with your pension provider Administering the contract we have entered into with you Business management and planning, including accounting and auditing Conducting performance reviews, managing performance and determining performance requirements To take references Making decisions about salary reviews and compensation Assessing qualifications for a particular job or task, including decisions about promotions Gathering evidence for possible grievance or disciplinary hearings Making decisions about your continued employment or engagement Making arrangements for the termination of our working relationship Education, training and development requirements Dealing with legal disputes involving you, or other employees, workers and contractors, including accidents at work Ascertaining your fitness to work Managing sickness absence Complying with health and safety obligations To prevent fraud To monitor your use of our information and communication systems to ensure compliance with our IT policies To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution; and to conduct data analytics studies to review and better understand employee retention and attrition rates Equal opportunities monitoring Shareholding, options and dividend details. Sensitive Data This type of information requires higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process “Sensitive Personal Data” in the following circumstances: In limited circumstances, with your explicit written consent; Where we need to carry out our legal obligations or perform a contract with you; Where it is needed in the public interest, such as for equal opportunities monitoring or in relation to our occupational pension scheme Where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards. 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. We will use your Sensitive Personal Data in the following ways: we will use information relating to your absence from work, which may include sickness absence or family-related absences, to comply with employment and other laws; we will use information about criminal convictions to comply with law and in order to determine your eligibility to undertake particular types of work; 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 provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits; 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; and We will use trade union membership information to pay trade union premiums, register the status of a protected employee and to comply with employment law obligations. We do not need your consent if we use Sensitive 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. Sharing Data Recipients of Data We may share your personal information where it is necessary to administer the working relationship, or we have a legitimate interest in so doing. Your information may be shared with the below recipients; Clients* Former Employers whom we may seek references from Payroll and pension partners Audit, legal & financial partners Other staffing companies involved in client supply chains Insurance brokers and providers Government departments or courts Immigration services providers Travel and accommodation providers Mobile telecoms providers Other service providers MDE Group have partnered with to provide the services listed in MDE Group Business Activities Benefits provision and administration IT services All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information 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 and in accordance with our instructions. Overseas Transfers MDE Group is a global organisation with a network of offices all over the world; as such we are able to offer our candidates, customers and clients a consistently high level of services where ever they are based. In order to do this we share a global CRM which contains both personal data and data about the services we are providing. The Data stored in our CRM is only accessible by authorised MDE Group staff. Due to the nature of this central database, personal data provided in one location will be accessible by all MDE offices around the world, including countries outside of the European Economic Area(‘EEA”). MDE Group take steps to ensure adequate protections are in place to ensure the security of your information. *Please note, we will always attempt to contact your before submitting your CV to a client, however, if you have previously informed us that you would like us to make an application to a specific client we will send your CV even if we have not be able to discuss the submittal with you before hand. Please ensure you provide us with details of clients that you would not want us to send your CV to upon registration, or any time after. Other Data Disclosures Data Retention MDE Group will only retain your personal data for as long as we need to in line with our legitimate interests. The duration for which we retain your personal information will differ depending on the type of information and the reason why we collected it from you. Also, different laws require us to keep certain data for longer periods of time than others. The criteria we use to determine the retention period includes: The nature of the personal data Our legal obligations Purpose of your interaction with MDE Group Whether a contract has been performed and/or cannot be performed anymore Whether you have exercised your right to erasure Whether your data is no longer considered to be up to date In line with our staffing expertise and knowledge of the industry by country, sector and job role. Personal data we no longer need to keep is archived, destroyed or deleted securely. Transactional data relating to our services and contractual obligations will be retained for an extended period in line with legal or business requirements. MDE Group will not sell your personal data In certain circumstances personal data may be disclosed to third parties in order to comply with a legal obligation or to assist in the prevention and detection of crime and for law enforcement purposes without the consent of the individual concerned. Under these circumstances MDE Group will use reasonable endeavours to check the request is legitimate before disclosing requested data. If MDE Group is involved in any transactional process regarding its ownership your personal data may be disclosed subject to strict confidentiality obligations and anonymisation where possible. MDE Website Data Cookies Your data is collected by MDE Group when you visit our website; this data is collected through Cookies in order to monitor our website usage and efficiency. There are different types of cookies available to organisations; the ones used by MDE Group are fully explained in our Cookie Policy. In summary these are: Performance cookies; Used to collect information about how the website is used. These cookies do not collect data on the individual visitor. Functionality cookies; Used to customise your visit and provide you with access to the services you select. These cookies do not track your browsing activity on other websites. Advertising & remarketing cookies; Used to collect anonymous data about interests and demographics of users to the website and improve experiences overall. These cookies do not identify you or give MDE Group access to your computer or mobile device. You can choose to enable or disable cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept cookies but this can be changed. For further details, please consult the help menu in your internet browser. Log Files We use IP addresses to analyse trends, administer the site, track users’ movements, and to gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information. Links to external websites The Company’s website may contain links to other external websites. Please be aware that the Company is not responsible for the privacy practices of such other sites. When you leave our site we encourage you to read the privacy statements of each and every website that collects personally identifiable information. This privacy statement applies solely to information collected by the Company’s website. Keeping your information safe Your personal data is important to you and important to MDE Group; in fact it is vital to the success of our business relationship. We shall therefore ensure that when processing information on your behalf your personal data is treated with respect and that every effort is made to ensure that the confidentiality, integrity and availability of data held on our systems, within data centres and as part of our service provision to you, is fully protected. We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. We have implemented 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. Additionally you should take all reasonable steps to keep your personal information held on out IT systems secure, including choosing a secure password for your accounts and not disclosing your passwords to anybody else. You should use a unique password for every account. If you share a device with others we recommend that you do not select the “remember my details” function when that option is offered. Your Rights Please be aware that you have the following data protection rights: The right to be informed about the personal data the Company processes on you; The right of access to the personal data the Company processes on you; The right to rectification of your personal data; The right to erasure of your personal data in certain circumstances; The right to restrict processing of your personal data; The right to data portability in certain circumstances; The right to object to the processing of your personal data that was based on a public or legitimate interest; The right not to be subjected to automated decision making and profiling; and The right to withdraw consent at any time. Where you have consented to the Company processing your personal data and sensitive personal data you have the right to withdraw that consent at any time by contacting our data protection team by sending an email to: globalprivacy@MDE-group.com Please note that if you withdraw your consent to further processing that does not affect any processing done prior to the withdrawal of that consent, or which is done according to another legal basis. There may be circumstances where the Company will still need to process your data for legal or official reasons. Where this is the case, we will tell you and we will restrict the data to only what is necessary for those specific reasons. If you believe that any of your data that the Company processes is incorrect or incomplete, please contact us using the details above and we will take reasonable steps to check its accuracy and correct it where necessary. You can also contact us using the above details if you want us to restrict the type or amount of data we process for you, access your personal data or exercise any of the other rights listed above. Changes to this Privacy Notice. We will update this privacy statement from time to time. We will post any changes on the statement with revision dates. If we make any material changes, we will notify you. Queries or Complaints If you wish to complain about this privacy notice or any of the procedures set out in it please contact our data protection team by sending an email to: globalprivacy@MDE-group.com NAVIGATION MDE GROUP MDE GROUP SERVICES JOB SEEKER ABOUT MDE GROUP EMPLOYER WORLDWIDE OFFICES MDE connects employers and employees all over the world. Good to Great. Telephone +47 51 20 10 00 Mail post@mde-group.com MDE Emergency Phone +47 408 09 000 MDE Stavanger AS Kontorveien 15 4033 Stavanger Delivering expertise PRIVACY POLICY