1. Introduction

This Privacy Notice explains how the SGCS collects information from you when you:

1. Apply for a job with a SGCS company;
   1. Join SGCS as an employee or contractor;
   1. Use our products or services;
   1. Download documents from us or subscribe for alerts or newsletters;
   1. Attend one of our events, or an event hosted at our premises;
   1. Visit or register to use www.bidvestnoonan.com (our “Website”)

SGCS will process (collect, store and use) the information you provide in a manner compatible with the General Data Protection Regulation (GDPR).

• KEY PRINCIPLES

• Who are we?

SGCS is a market leading provider of strategically outsourced services. Our services range from cleaning and security to building services and facilities management. We employ more than 25,000 highly trained people and operate throughout the Abuja and Nigeria. We are a values-led and highly accredited business.

The Data Protection Officer is responsible for ensuring that this notice is made available to data subjects prior to SGCS collecting/processing their personal data.

All Employees of SGCS who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their data is secured, if required.

• Information we collect and use

This may include:

• Information contained in your CV or job application such as your name, address, educational details, private and corporate e-mail address and phone number;
• Information contained in any documents that you send to any of us for identity verification purposes such as your passport or driving licence;
• Financial information, compliance documentation and references verifying your qualifications and experience and your right to work in the Abuja and Nigeria
• Information contained in insurance claim forms
• GPS tracking on company owned vehicles
• Invoicing and billing information
• Marketing preferences

• Purposes for collection, use and retention

To meet our regulatory and legal obligations, we collect some of your personal information, verify it, keep it up to date through regular checks, and delete it once we no longer have to keep it. If you do not provide the information we need, or help us keep it up to date, we may not be able to provide you with our services or employment opportunities.

The personal data we collect will be used for:

Employment law and practice including:

• Recruitment, vetting and screening
• Pay, tax and pension
• Health and safety
• Transfer of Undertaking Regulations compliance
• Rostering
• Training
• Vehicle locating
• Next of kin contact
• Insurance claims handling

Client service: To carry our obligations arising from any client service contracts

Our legal basis for processing for the personal data:

• Personal data: contractual performance, legitimate interest, legal obligation, consent (marketing only)
• Special category data: Employer rights and obligations, legal claims

Any legitimate interests pursued by us, or third parties we use, are as follows:

• Next of kin
• Medical reports
• GPS tracking on company owned vehicles
• Documents to assess identity verification

The special categories of personal data concerned are:

• Health data
• Racial and ethnic origin
• Religion
• Trade union membership

• Consent

Consent is required for Bidvest Noonan to process personal data for direct marketing purposes, but it must be explicitly given. Where we are asking for your consent, we will always tell you why and how the information will be used.

You may withdraw consent at any time to receiving marketing material. Please email your usual contact in SGCS or contact info@sgcs.com.ng

• Disclosure

SGCS may pass on your personal data to third parties in order to comply with our obligations as an employer or to provide services to you. The reasons we transfer your personal data to third parties may include the following:

• Issuing payslips and postal service
• GPS tracking of company owned vehicles
• Management of leased company vehicles
• Banking
• Pension and health insurance
• Insurance companies for both insuring of staff and claims handling with respect to employees or members of the public
• Legal firms and consultants for employment related matters
• Third parties who enable the completion of pre-engagement screening checks e.g. DBS, Garda vetting

Where the third party is a data controller, they have the same obligations under Data Protection law to protect your data, as we do.

Where the third party is a data processor, we require that these third parties provide a sufficient guarantee that the necessary safeguards and controls have been implemented to ensure there is no impact on your data rights and freedoms.

We also have to share information with third parties to meet any applicable law, regulation or lawful request.

• Retention period

To continue to address the legitimate purpose for which the data was originally collected the retention period for insurance and employment purposes is 10 years. All other data is only retained for as long as necessary to fulfill its purposes or as  long as is required under law.

• Your rights as a data subject

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
• Right to judicial review: if Bidvest Noonan refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.

• How can I find out the personal data that the organization holds about me?

SGCS will advise you of the information being collected and the purposes for which it is being retained when we collect personal data about you.

SGCS, at your request, can also confirm what information we hold about you and how it is being processed. If Bidvest Noonan does hold personal data about you, you can request the following information:

• Identity and the contact details of the person or organisation that has determined how and why to process your data.
• Contact details of the data protection officer, where applicable.
• The purpose of the processing as well as the legal basis for processing.
• If the processing is based on the legitimate interests of Bidvest Noonan or a third party, information about those interests.
• The categories of personal data collected, stored and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.
• How long the data will be stored.
• Details of your rights to correct, erase, restrict or object to such processing.
• Information about your right to withdraw consent at any time.
• How to lodge a complaint with the supervisory authority.
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
• The source of personal data if it wasn’t collected directly from you.
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

What forms of ID will I need to provide in order to access this?

SGCS accepts the following forms of ID when information on your personal data is requested:

Two forms of ID from the following:

• Passport
• Drivers licence
• Birth Certificate
• Utility bill (from last 3 months)

5. COMPLAINTS

In the event that you wish to make a complaint about how your personal data is being processed by  SGCS (or third parties), or how your complaint has been handled, you have the right to lodge a complaint directly with SGCS’s Data Protection Officer and/or the relevant supervisory authority.

A current version of this document is available to all stakeholders and members of staff on the SGCS website and a link to it is provided on our corporate email.

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