TRG Customer Solutions, Inc. d/b/a IBEX Global, and its operating groups, subsidiaries and divisions within the European Union, (the "Company") are committed to protecting the privacy and security of Personal Data and/or personal data ("Personal Data") of prospective, current and former employees ("Employees"). The Company collects, processes, and transfers Personal Data of Employees in connection with its human resources activities. The Company is s committed to complying with the EU General Data Protection Regulation , effective May 25, 2018; and all data protection laws, labor laws, and collective agreements in the countries in which it employs employees and does business regarding Employees' Personal Data . All questions, concerns, or complaints should be directed to the Company's Director of Security and Compliance by e-mail at security@ibex.co.
Definitions
"Personal data," means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person, but only to the extent such personal data pertain residents of the European Economic Area (EEA) or are otherwise subject to the GDPR.
"Personal data breach,", means any breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data transmitted, stored or otherwise processed.
"Process" or "processing" means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
"Special personal data," includes, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, data concerning health, data concerning sex life or sexual orientation of an individual, and data relating to criminal convictions and offenses.
"Criminal records data" means information about an individual's criminal convictions and offences, and information relating to criminal allegations and proceedings.
Data Privacy Principles
The Company complies with the following data privacy principles with respect to personal data:
The Purpose and Legal Basis for Processing Personal Data
The Company processes the following personal dta regarding Employees for the following purposes and based upon the following legal bases in furtherance of its human resources activities.
Recipients of Personal Data
Personal Data may be disclosed as follows:
Employee Data Subject Rights
Employees, as a data subjects, have the following rights regarding their Personal Data:
To make a subject access request, you should send the request to the Company's Director of Security and Compliance by e-mail at contactibexdigital@ibex.co. In some cases, the Company may need to ask for proof of identification before the request can be processed. The Company will inform you if it needs to verify your identity and the documents it requires.
The Company normally will respond to a request within a period of one month from the date it is received. In some cases, such as where the Company processes large amounts of an individual's personal data, it may respond within three months of the date the request is received. The Company will write to you within one month of receiving the original request to tell you if this is the case.
If an employee's access request is manifestly unfounded or excessive, the Company is not required to comply with it. Alternatively, the Company can agree to respond but will charge a fee, which will be based on the administrative cost of responding to the request. A subject access request is likely to be manifestly unfounded or excessive where it repeats a request to which the Company has already responded. If an employee submits a request that is unfounded or excessive, the Company will notify the employee that this is the case and whether or not it will respond to it.
Data Security
The Company takes the security of HR-related personal data seriously. The Company has internal policies and technical measures in place to protect personal data against loss, accidental destruction, misuse or disclosure. Such internal policies and technical measures include:
Where the Company engages third parties to Process Personal Data on its behalf, such parties are (1) required by contract to process the personal data based on the Company's written instructions, (2) are under a duty of confidentiality, and (3) are required to implement appropriate technical and organizational measures to ensure the security of the personal data.
Impact Assessments
Some of the Processing that the Company carries out may result in risks to privacy. Where Processing would result in a high risk to individual's rights and freedoms, the Company will carry out a Data Protection Impact Assessment (DPIA) to determine the necessity and proportionality of processing. The DPIA will consider the purposes for which the activity is carried out, the risks for individuals and the measures that can be put in place to mitigate those risks.
Data Breach Notification
If the Company discovers that there has been a breach of HR-related Personal Data that poses a risk to the rights and freedoms of individuals, it will report such breach to the appropriate data protection authority within 72 hours of discovery. The Company will record all data breaches regardless of their effect.
If the breach is likely to result in a high risk to the rights and freedoms of individuals, the Company will notify affected individuals that there has been a breach and provide them with information about its likely consequences and the mitigation measures it has taken.
International data transfers
The Company has certified that it complies with the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield Frameworks (Privacy Shield) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred to the U.S. from the EU and Switzerland, respectively. This certification covers the following Company entities:
To learn more about the EU-U.S. and Swiss-U.S. Privacy Shield programs, please visit http://www.privacyshield.gov. To view the Company's certification under Privacy Shield, please visit http://www.privacyshield.gov/list.
In addition to the protections provided under other sections of this Data Privacy Policy, the Company will provide the following protections for personal data transferred from the EU or Switzerland to the U.S.:
Individual responsibilities
Individuals are responsible for helping the organisation keep their personal data up to date. Individuals should let the organisation know if data provided to the organisation changes, for example if an individual moves house or changes his/her bank details.
Individuals may have access to the personal data of other individuals [and of our customers and clients] in the course of their [employment, contract, volunteer period, internship or apprenticeship]. Where this is the case, the organisation relies on individuals to help meet its data protection obligations to staff [and to customers and clients].
Individuals who have access to personal data are required:
Failing to observe these requirements may amount to a disciplinary offence, which will be dealt with under the organisation's disciplinary procedure. Significant or deliberate breaches of this policy, such as accessing employee or customer data without authorisation or a legitimate reason to do so, may constitute gross misconduct and could lead to dismissal without notice.
Training
The Company will provide training to all individuals about their data protection responsibilities as part of the induction process and at regular intervals thereafter. Individuals whose roles require regular access to personal data, or who are responsible for implementing this policy or responding to subject access requests under this policy, will receive additional training to help them understand their duties and how to comply with them.
Questions and Complaints
Questions or complaints regarding the processing of your Personal Data should be directed to your local HR representative. Additionally, complaints may be submitted pursuant to grievance procedures under applicable trade union contracts. If the inquiry cannot be answered or the complaint is not resolved locally, please direct the matter to our Director of Security and Compliance by e-mail at contactibexdigital@ibex.co
EU employees also have the right to lodge a complaint with the local or national data protection authority in the jurisdiction where you work. A listing of the EU Data Protection Authorities ("DPAs") is located at: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm
Data Privacy is Important to Us
Please be assured that your privacy is of utmost importance to us. We comply with all applicable data privacy laws including the General Data Protection Regulation regarding personal data collected and processed concerning residents of the European Union and European Economic Area.
The specific practices outlined in this privacy statement apply to privacy practices and procedures maintained by or on behalf of ibex. and its affiliates. Some of our web pages contain links to web sites outside ibex. Please be aware that when you follow a link to another site, you are then subject to the privacy policies of the new site.
What Personal Data We Collect and Process
The Company collects business contact and financial information from our business customers and vendors. We collect personal contact information, purchase information, and customer experience information from individuals who purchase products and services from our business customers.
How and Why We Process Personal Data
The Company processes personal information for the following purposes:
Interaction with Children
We do not collect personal data of and our websites do not target or provide content to children under the age of 16.
Cookies
Cookies are small files that web servers place on a user's hard drive. The Company does not use "persistent cookies" or any other persistent tracking methods to collect personal information about visitors to its websites. Cookies serve several functions:
To protect your privacy, be sure to close your browser completely after you have finished conducting business with a website that does use cookies. If you are concerned about the potential use of the information gathered from your computer or mobile device by cookies, you can set your browser to prompt you before it accepts a cookie. Most Internet browsers have settings that let you identify and/or reject cookies. Before collecting personally identifiable information, we will prominently disclose why we are requesting the information; how it will be used; how long it may be retained; under what conditions, and with whom, it may be shared.
We Also Collect and Use Non-Personal Data
In addition to personal information, we collect and store non-personal (such as search engine queries and anonymous survey responses) to help us better understand and meet the needs of our visitors. We may share non-personal information with others, including the public, in aggregated form (for instance, in a list of our most popular search engine queries), in partial or edited form (such as in a report summarizing responses to a questionnaire), or verbatim (for example, in a complete listing of survey responses).
Data Subject Rights of EU Residents
EU residents have the following rights regarding their personal data:
To make a subject access request, you should send the request to James Ferrato, Chief Information Officer, jim.ferrato@ibex.co. In some cases, the Company may need to ask for proof of identification before the request can be processed. The Company will inform you if it needs to verify your identity and the documents it requires. The Company normally will respond to a request within a period of one month from the date it is received. In some cases, such as where the Company processes large amounts of an individual's personal data, it may respond within three months of the date the request is received. The Company will write to you within one month of receiving the original request to tell you if this is the case.
International data transfers
The Company has certified that it complies with the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield Frameworks (Privacy Shield) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred to the U.S. from the EU and Switzerland, respectively. This certification covers the following Company entities:
To learn more about the EU-U.S. and Swiss-U.S. Privacy Shield programs, please visit http://www.privacyshield.gov. To view the Company's certification under Privacy Shield, please visit http://www.privacyshield.gov/list.In addition to the protections provided under other sections of this Data Privacy Policy, the Company will provide the following protections for personal data transferred from the EU or Switzerland to the U.S.:
Privacy Rights of California Residents
Pursuant to Californian Civil Code Section 1798.83, California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to our Director of Security and Compliance by e-mail at security@ibex.co
Data Security
The Company takes the security of personal data seriously. The Company has internal policies and technical measures in place to protect personal data against loss, accidental destruction, misuse or disclosure. Such internal policies and technical measures include:
For site security purposes and to ensure that this service remains available to all users, this computer system employs software programs to monitor network traffic to identify unauthorized attempts to upload or change information, or otherwise cause damage to the information on our websites. Unauthorized attempts to upload information or change information on this service are strictly prohibited and may be punishable under the Computer Fraud and Abuse Act of 1986.
The Company retains personal information only for the period of time necessary to meet the purposes for which it was collected, to fulfil the legitimate business interests of the Company, and to comply with any data retention laws or legal requirements. For example,
When the Company engages third parties to process personal data on its behalf, such third parties are required by contract to process the personal data based on the Company's written instructions, are under a duty of confidentiality, and are required to implement appropriate technical and organizational measures to ensure the security of the personal data.
When the Company shares personal information of EU residents with affiliated companies, vendors, and business customers located outside of the EU, such as the U.S., the Company uses appropriate safeguards such as standard contract clauses to protect the personal information.
Changes to Our Privacy Policy
It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we handle personal information, we will provide notice of the changes on the website home page.
Questions and Concerns
Any questions or concerns regarding how the Company processes personal information should be directed to our Director of Security and Compliance by e-mail at security@ibex.co. EU residents also have the right to lodge a complaint with the local or national data protection authority in the jurisdiction where they reside. A listing of the EU Data Protection Authorities ("DPAs") is located at: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm. Dispute resolution: If for some reason you believe this site has not adhered to these principles, please notify James Ferrato, Chief Information Officer, at jim.ferrato@ibex.co. If our web pages are not fully in compliance with our stated policies, they will be corrected.
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We've updated our privacy policy to comply with Europe's General Data Protection Regulation (GDPR), the EU-U.S. Privacy Shield, and the Swiss-U.S. Privacy Shield. View our HR Data Privacy Policy and Non-HR Data Privacy Policy to learn more about these changes.