PRE-BETA DRAFT CONTENT
PILOT TESTING PURPOSES ONLY
1. About us, your data controller
The legal entity listed in your contract or offer of employment (CWT) is responsible for determining and controlling the collection and processing of your personal data. As CWT operates in many countries CWT affiliates may also process your personal data pursuant to this global policy which also serves as our global privacy NOTICE. References to ‘We’, ‘Our’ and ‘Us’ in this policy refer to CWT and where relevant CWT affiliates.
2. Your privacy is important to us
We are committed to respecting your privacy through appropriate protection and management of your personal data, also known as personal information. This policy gives notice of and describes our collection and processing of your personal data in the context of your work engagement and details how we protect and secure your data and your rights.
3. How we collect, process your personal data
We collect most of the personal data about you that we process directly from you. We may also collect personal data indirectly, such as from our management of work technology tools and/or to validate or update your work details from external (such as public) sources.
CWT will, during and after your work engagement, collect, process and make determinations regarding processing of your personal data relevant or required for your work, role, function, location, contract, benefits, which may include:
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4. Our processing activities, purposes and legal basis
Your personal data will be processed (collected, stored, used, accessed, transferred, deleted) in accordance with applicable laws and regulations, for purposes which, if relevant to your work, role, function, location, contract, benefits may include:
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Further legal basis for the processing may include our performance of a contractual obligation (including your contract, offer or related document), our legal obligations (including employment and social security), our legitimate interests (including safety and service quality management), necessity to establish or defend legal claims (including in relation to work matters), your consent, where legally required, possible.
5. How we use (access, share) and transfer your data
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In compliance with California Consumer Privacy Act (CCPA) CWT does not sell your personal information.
6. How we secure your data
CWT takes the security of your personal data seriously and all processing operations (collection, storage, use, transfer, deletion) are conducted in accordance with relevant legal obligations and technical, organisational and administrative security measures and processes and policies relating to safety, security and legal compliance. CWT implements information security protocols to protect your data processed by CWT, CWT Group Companies and external vendors. You can find further details of CWT’s comprehensive risk and security program on our company intranet.
7. Data retention, deletion
CWT stores and retains your data only for a period not exceeding that required for the purposes for which it was collected and in accordance with applicable laws, regulations and the relevant retention policy. Secure storage of your data may be carried out in limited circumstances after you leave CWT, for example for the establishment, exercise or defence of a legal claim and/or for the purposes of preserving evidence or otherwise where required by applicable laws. Upon expiry of the relevant retention period your personal data will be permanently and securely deleted. You can find further details of CWT’s retention policies on our company intranet.
8. How we protect your rights
You can generally access, update, rectify and/or correct your personal data yourself using work technology made available to you for these purposes. In limited or exceptional case your efforts were unsuccessful, you may contact your human resources manager with request to arrange on your behalf.
Subject to applicable law, you may have the right to erasure, restriction and/or objection to the processing of your personal data, change consents (if any) as well as the right to portability of your data.
In addition the following specialised privacy resources are available to you:
- Privacy Program Information: company intranet
- Data Subject Access Requests: SAR form
- Privacy Questions or Complaints: GlobalPrivacy@mycwt.com
Privacy questions or issues should be resolved directly with CWT where possible. If you are unable to resolve a privacy issue with CWT you may file a complaint with your local data protection supervisory authority or equivalent privacy regulator.
9. Further information particular to you and your work engagement
For information specific to you and your work engagement please refer to the resources below in addition to this global privacy policy:
- country specific privacy notice (if any)
- your contract, engagement terms
- local arrangements and HR resources applicable to your work, role, function, location
- CWT country and global policies.
Please check this policy and other resources, including our company intranet, regularly for further relevant information and updates