Data protection notice for employees (O_ES_PL)

1. Data Controller

TECHNOFORM EDGE BOND SOLUTIONS POLAND Sp. z o.o. with its registered office in Skawina at ul. Za Górą 23A, 32-050 Skawina, entered into the Registry of Entrepreneurs by the District Court for Kraków-Śródmieście in Kraków, the 11th Commercial Division of the National Court Register KRS under National Court Register KRS number: 0000828941, State Statistical Number REGON: 385789087, Tax Identification Number NIP: 6762579007.

For any questions regarding data protection, feel free to contact the Data Controller in writing, with the note „Personal Data,” at the address of our registered office or via e-mail at: kontakt [at] technoform [dot] com

2. Data Collection Method

If you are one of our employees or partners, we collect your personal data primarily from you. You provide us with your personal data for purposes necessary for employment – while concluding an employment agreement, a civil law agreement, or completing any personal data form. As your employer – the cooperating entity – we have to process your personal data to contact you or properly settle any and all matters related to your employment, including for tax or national insurance purposes. Sometimes your personal data will be transferred to us by third parties, such as state authorities contacting TECHNOFORM EDGE BOND SOLUTIONS POLAND Sp. z o.o. as your employer or a cooperating entity.

In some cases, we process your personal data shared on social media (on LinkedIn or Facebook). In this case, we are acting with the purpose of verifying information provided during the recruitment process or employment and securing the legitimate economic interest of the Data Collector, depending on the nature of the position held.

We have also implemented means of workplace electronic communication surveillance (for browsers, internal messaging apps, and company e-mails). This proved to be necessary to ensure the organisation of work allowed us to take full advantage of our work time and the right use of available work tools, as well as secure the network and data of other employees and customers from unauthorised access or data leaks.

E-mail surveillance does not violate your privacy of correspondence or your other personal rights.

3. The Purpose of Processing

Your provision of personal data is obligatory within the scope set out in labour regulations (in particular, the Labour Code); outside of this scope, it is voluntary, but necessary for purposes related to commencing and continuing your employment. Not providing this personal data will prevent the Data Controller from employing you and complying with its obligations as an employer in an appropriate manner.

If you are one of our employees or partners, we use your personal data for purposes related to your employment, including tracking working time or increasing employee qualifications via training. As your employer or a cooperating entity, we have to fulfil a number of obligations – both for organising our cooperation in the right manner, as well as for HR and payroll purposes. As an employee/cooperating entity, we are also entitled to certain rights – we use your personal data to, for instance, contact you.

We also need the personal data of employees and their families to provide them with access to benefits and rights. We use your personal data to ensure you receive benefits and support in case of illness or maternity, as well as in the event of a work accident. Once again, the purpose of processing your personal data in such a case is the proper management of our employment relationship or cooperation with you and the protection of your vital interests.

We process personal data shared via social media (on LinkedIn or Facebook) to verify information provided by you during your recruitment process or employment and to secure the legitimate economic interest of the Data Controller, depending on the nature of the position held.

We may use your personal data to provide information on you to third parties, for instance, to the bank in which you apply for a loan, to an insurance company, to a healthcare service provider, or to a public authority that submitted a request for information. In such cases, your personal data will be provided for your benefit, on your request, or in connection with our legal obligations.

Data may be used on the basis of consent, e.g., to publish it on a website in relation to the appointment of a contact person for entities interested in the published commercial offers. Your personal data used for purposes related to our employment relationship or cooperation shall not be used for other purposes by TECHNOFORM EDGE BOND SOLUTIONS POLAND Sp. z o.o. without your consent. In particular, we will not process your data for marketing purposes without your express consent.

4. The Basis of Processing

4.1. Employees

The scope of data indicated in the provisions of the Labour Code, tax regulations, and social insurance regulations (Art. 6(1)(c) of GDPR); Employment agreement (Art. 6(1)(b) of GDPR); medical and health data (Art. 9(2)(b) of GDPR); protection of vital interests of the person concerned (Art. 6(1)(d) of GDPR); pursuing mutual claims arising from the Civil Code or other regulations, verifying information provided by you during your recruitment process or employment, and securing the legitimate economic interest of the Data Controller, depending on the nature of positions held (Art. 6(1)(f) of GDPR).

Outside of this scope, the consent of the employee is required (Art. 6(1)(a) of GDPR)

4.2. Partners with whom we concluded a civil law agreement

Service agreement/mandate agreement/cooperation agreement/any other agreement – e.g., concerning an internship (Art. 6(1)(b) of GDPR), legal provisions of, for instance, the Civil Code, provisions of law concerning taxes and social insurance (Art. 6(1)(c) of GDPR), pursuit of legitimate interests of the Data Controller (e.g. for the pursuit of claims or verification of information provided during the recruitment process or employment and the securing of legitimate economic interest of the Data Controller, depending on the nature of the position held) – Art. (6)(1)(f) of GDPR).

Outside of this scope, we process your personal data based on your consent, i.e., pursuant to Art. 6(1)(a) of GDPR. In such a case, you have the right to revoke your consent, which does not affect the effectiveness of data processing carried out up to the revocation.

5. Data Retention Period

The entire period of cooperation or employment, as well as the statutory retention period or document and information archiving period, no longer than ten (10) years from the termination of the employment relationship – Art. 125a(4a) of the Act of December 17, 1998, on retirement pensions and Social Insurance Fund pensions (uniform text: Dz. U. of 2020, item 53).

If proceedings are initiated before a court of any public authority, the documents may be retained for the entire duration of the proceedings until they are finally concluded; however, it may not be retained for longer than three (3) years from the date on which the enforcement proceedings are finally concluded, provided that the entire debt has been collected. Data related to the performance of OHS activities and employee training is processed throughout the duration of your agreement.

The Data Collector will remove your data within one (1) year from the end of the data processing period.

6. Personal Data Recipients

The recipients of your personal data will consist of employees and partners of the Data Controller responsible for HR and payroll of the Employer, as well as entities providing accounting, HR, payroll, legal, IT, and hosting services to the Data Controller.

Recipients of your personal data, solely within the required scope, may also include other members of the TECHNOFORM Group, as well as employees and contractors of TECHNOFORM EDGE BOND SOLUTIONS POLAND Sp. z o.o. responsible for operating its website, hosting services providers, entities providing photographic and graphic services related to editing photographs, and other entities processing personal data based on relevant agreements on behalf of TECHNOFORM EDGE BOND SOLUTIONS POLAND Sp. z o.o., as well as owners of social media platforms (such as LinkedIn, Facebook, Instagram, YouTube), on the basis of rules concerning the processing of data received by these entities.

The Data Controller ensures that your personal data is provided to entities complying with the necessary data protection standards only, in accordance with the GDPR requirements.

7. Your rights

The person concerned has the following rights in regard to our processing of personal data:

right to access their personal data – you can submit a request for information to us at any time concerning the scope and rules of processing of your personal data;
right to data rectification – at any time, you can request us to rectify or update your data if it is incorrect or outdated. For the avoidance of doubt, TECHNOFORM EDGE BOND SOLUTIONS POLAND Sp. z o.o. may approach you with a request to provide information enabling the identification of your personal data and confirm the change or update of your data;
right to restriction of processing – if the scope of your personal data we process for a given procedure is too broad, you may request us to restrict the scope of processing. Provided that your request does not contradict the legal requirements we have to comply with, or if it is unnecessary for the implementation of the agreement, we will restrict the processing of your personal data to the required minimum or cease to process your data;
right of erasure (right to be forgotten) – if we process your personal data without a legal basis or process it, even though it is no longer necessary for the purposes of its collection – you have the right to request the erasure of your personal data from our databases and systems. We will honour your request if there exists no other legitimate interest for the processing of your personal data or obligation to continue processing your personal data. In each case, we will attempt to honour your request to the fullest extent possible, and if this is not possible, we will try to modify your data so that it can no longer be attributed to you (as part of so-called pseudonymization):
right to data portability – in the cases where we process your personal data on the basis of consent or in relation to the performance of an Agreement, and the processing is done by automated means (e.g. in an IT system), we will export your data processed by us, on your request, to a separate file in a common format to allow you to transfer it to a different data controller.

The rights indicated above may be exercised by notifying the Data Controller in writing at the address of our registered office with the note „Personal Data” or via e-mail at: kontakt [at] technoform [dot] com

8. The Right to Object

In addition to the above, you have the right to object to the processing of your data. If the scope of your personal data processed by us on the basis of public interest or legal interest of TECHNOFORM EDGE BOND SOLUTIONS POLAND Sp. z o.o. or any other third party is too broad (inadequately so), you have the right to request the restriction of the processing of your personal data. You have the same right if, at any time, you decide that you do not want us to process your personal data for the purposes of direct marketing. After you raise your objection, we will no longer process your data in this scope and for this purpose unless it is necessary due to the existence of any other important legitimate bases for our processing of your personal data, overriding your interests, rights, and freedoms; or to establish, pursue, or defend our claims.

9. The Right to Lodge a Complaint

If we have violated the rules of processing your personal data, you are entitled to lodge a complaint directly with a supervisory authority – the President of the Personal Data Protection Office.

When exercising this right, it is necessary to provide a full description of the situation and indicate which action violates, in your opinion, your rights or freedoms. The complaint should be lodged directly with the supervisory authority.

10. The Rules of Processing

Taking into consideration that the Data Controller – TECHNOFORM EDGE BOND SOLUTIONS POLAND Sp. z o.o. – prioritizes the proper performance of all its duties under GDPR and the regulations included in Polish legislation and the implementation of rules described in external documents concerning the protection of personal data, we request that your read the content of the Privacy Policy available at www.technoform.com, which includes relevant information on the methods, purposes, and bases of our processing of personal data and indicates your rights in relation to personal data processing. The Privacy Policy is also available at the registered office of the Data Controller (ul. Za Górą 23A, 32-050 Skawina).