Privacy Notice

 

1.     Introduction

Tata Steel Limited, India (hereafter referred to as TSL) is committed to protecting you and your family's personal information when you are using our services. We want our services to be safe and secure for our users. Uniform practices for collecting, using, disclosing, storing, retaining, disposing, accessing, transferring or otherwise processing such information assists TSL to process Personal Information fairly and appropriately, disclosing it and/or transferring it only under appropriate circumstances. This privacy notice relates to our use of any personal information we collect from you for providing related services.

 

This privacy notice tells you how we use your personal information collected through TSL’s applications. Please read this privacy notice before using the application/s or submitting any personal information. This notice will be updated subject to any changes in information collection, activities performed or any applicable regulations. You are encouraged to review the privacy notice whenever you visit the application/s to make sure that you understand how any personal information you provide will be used.

 

Please Note:

The privacy practices set forth in this privacy notice are for the specific application requested to use only as well as the personal information collected through non-automated / hard-copy based means. If you link to other web sites, please review those privacy policies. Additionally, kindly refer to the “Glossary” section of Data Privacy Policy for definitions of GDPR related terms.

 

2.    Purpose

The purpose of this notice is to highlight various obligations, best practices and tools that support compliance with data privacy regulations applicable to TSL in its role as both data controller as well as processor.

 

3.    Applicability

This notice applies to TSL India.

 

4.        Collection and use of information

This Data Privacy Notice describes the information that TSL collects about you; how we use and protect this information; and the choices you can make about how we use this information.

 

Information we collect

To manage the employee lifecycle activities, TSL may collect, process or store personal data relating to you and your dependents as declared by you, including but not limited to, sensitive personal data such as:

·         race or ethnicity

·         physical or mental health

·         medical history

·         legal proceedings

·         passwords

·         Aadhar number

·         PAN card number or any other government-issued identification numbers; and

·         personal financial information like bank account numbers.

 

We may collect information about you from a variety of sources but not limited to, information we collect from you directly; information we collect about you when you visit our sites, use our services, or view our online advertisements; and information we collect about you from other sources (as permitted by law). TSL has implemented organizational, physical and technical safeguards designed to protect your personal information from unauthorized access, use or disclosure.

 

How We Use This Information

TSL may engage third parties to perform services for its employees, such as payroll processing, medical insurance and annual health checks (wherever applicable). From time to time, employee welfare programmes may be organized in association with third parties. Your personal information may be collected and processed by these associated third parties for the purpose such as but not limited to employee welfare programmes, payroll processing, medical insurance and annual health checks (wherever applicable) only. In addition, personal information about your family members may be collected and processed for insurance registrations and employee welfare programmes on a voluntary basis.

In case your employment is transferred to a business unit of TSL outside Indian Territory, your personal information may be transferred as part of your personnel records to the Human Resources personnel for that business unit. The purpose of transferring your personal data outside Indian Territory is to provide continued Human Resources services to you as an employee of TSL.

During your employment, if you would like further information on the way in which TSL collects, processes and protects your personal information, please register a request with our Privacy Grievance Officer (privacy.governance@tatasteel.com). We will respond to valid requests in an appropriate timeframe.

Where we are unable to give you direct access to your personal information records for corrections and updates, please write to the concerned HR officer.

 

5.    Fairness and Purpose

TSL will collect adequate, relevant and necessary Personal Information, and will process such information fairly and lawfully for the purpose it is collected. The purpose of collection will be specified not later than at the time of data collection, or on each occasion of change of purpose.

 

6.    Accuracy of information

The information held by TSL on its applications shall be checked with you from time to time to ensure that it remains up-to-date. Should your personal circumstances change, you should notify the human resources department and update your details.

 

7.    Distribution of Information

7.1 Information Disclosure

 

TSL does not share, sell, rent, or trade personal information collected through its applications with third parties for their sole promotional purposes or as otherwise outlined in this Privacy Notice. TSL may share information with third party service providers contracted to provide services on our behalf for processing to provide your employment related services and benefits and other business purposes. These third party service providers may only use information we provide to them as requested and instructed by TSL.

          i.       TSL may disclose your Personal Information as we believe to be necessary or appropriate:

a)  under applicable law, including laws outside your country of residence;

b)  to comply with legal process;

c)   to respond to requests from public and government authorities, including public and government authorities outside your country of residence, for national security and/or law enforcement purposes;

d)  to enforce our terms and conditions; and

e)  to allow us to pursue available remedies or limit the damages that we may sustain.

         ii.       Additionally, in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings), we may transfer the Personal Information we have collected to the relevant third party.

        iii.       We may share information with governmental agencies or other companies assisting us in fraud prevention or investigation. We may do so when:

a)  permitted or required by law; or,

b)  trying to protect against or prevent actual or potential fraud or unauthorized transactions; or,

c)   Investigating fraud which has already taken place. The information is not provided to these companies for marketing purposes.

 

If TSL goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your personal information collected through our website(s) may be among the assets transferred. A prominent notice will appear on our website(s) for 30 days after any such change in ownership or control of your personal information along with the updated Privacy Policy and Notice.

 

7.2     Cross-Border Data Transfers

When conducting business, working on Company projects, or implementing new processes or systems, an operation may require the transfer of personal information to other entities or third parties that are located outside of the TSL operation’s country of business. While permissible data transfer mechanisms are defined by applicable law or regulation, examples include:

              i.    a data transfer agreement with the party who will access or obtain the personal information;

             ii.   notice to and/or approval from a country’s local data protection authority; or

           iii.    notice to and/or consent from the data subjects whose data is to be transferred.

 

8.    Consent and Control

8.1 Consent

Consent is often referred to as an individual’s choice to “opt-in” or “opt-out” of the Company’s use of personal information and is usually obtained by a “check box” or signature confirming the individual understands and agrees to the processing of their personal information. At times, express written consent from the individual may be required based on the information processing activity. TSL receives consent from individuals prior to:

          i.    collecting, using, or processing their personal information, including sensitive personal information, in certain ways or sharing the individual’s personal information with any third party;

         ii.   transferring the individual’s personal information outside of the individual’s country of residence

        iii.   using or placing web cookies on an individual’s computer or other electronic devices.

 

8.2 Control of your information

TSL also provides individuals with the right to control their personal information, which includes the right to access, modify, erase, restrict, transmit, or object to certain uses of their information and for withdrawal of earlier given consent to the notice.

 

You may request to review, correct, update, suppress, or otherwise modify any of your Personal Information that you have previously provided to us through any of our applications, or object to the use or processing of such Personal Information by us. You have the ability to update your profile and related Personal Information at any time. To change this information, kindly refer to the privacy contact information mentioned within Section 14 “Privacy Contact Information” of this notice. If you have questions about your account or are having trouble accessing your account, you can reach out by emailing at privacy.governance@tatasteel.com and request help with your account. If you have privacy concerns regarding access to or the correction of your Personal Information, please contact us at privacy contact information mentioned within Section 14 “Privacy Contact Information” of this notice.

 

In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information that you have provided to us suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information that you have provided to us.

 

While the majority of questions and issues related to access can be handled quickly, complex requests may take more research and time. In such cases, issues will be addressed, or you will be contacted regarding the nature of the problem and appropriate next steps, within 30 days.

 

9.    Data Storage

Your personal information is stored on our applications which may be accessible by third party vendors (wherever applicable). For further information on data storage please contact us at privacy contact information mentioned within Section 14 “Privacy Contact Information” of this notice.

 

TSL may transfer your information from various applications to other HR systems, etc. (based on requirement of business operations at TSL) and store the same.

 

10. Commitment to data security

Your personally identifiable information is kept secure. Only authorized employees, business partners, clients, vendors and other third party providers (who have agreed to keep information secure and confidential) have access to this information.

TSL ensures that our supplier employs industry standard security measures to ensure the security of information through legally binding terms and conditions. However, users of our applications are responsible for maintaining the security of any password, user ID, or other form of authentication involved in obtaining access to password protected or secure areas of any websites. Access to and use of password protected and/or secure area of TSL’s applications is restricted to authorized users only. Unauthorized access to such areas is prohibited and may lead to criminal prosecution.

 

Use of cookies

We and our partners use various technologies to collect and store information when you visit TSL’s applications, and this may include using cookies or similar technologies to identify your browser or device. We also use these technologies to collect and store information when you interact with services we offer to our partners. You can configure your browser to refuse cookies, or to warn you before a cookie is placed. If you disable cookies, some parts of our websites may not function properly or at all.

 

11. Retention and Disposal

TSL provides individuals with the right to control their personal information, which includes the right to access, modify, erase, restrict, transmit, or object to certain uses of their information

 

We will retain your personal information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services, contact us at privacy contact information mentioned within Section 14 “Privacy Contact Information” of this notice. We will respond to your request to access or delete your information within 30 days. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

 

12. Vendor Obligations

TSL’s Vendors being the service provider for TSL’s applications and therein being the custodian of information will be liable for management of the following:

1.   security of the personal information

2.   appropriate retention and disposal of personal information

3.   appropriate storage of personal information

      Please read the privacy policy for further information.

 

13. Your Consent

Please refer to end of this notice for providing your consent.  Your consent to personal data collection and processing may be revoked by notifying us via our contact page. For users below the age of 16, the consent should be provided by the holder of parental responsibility of the child.

 

Please note, in case you choose not to provide us with the consent or withdraw the consent at any given point of time, we shall not be able to provision the services as detailed in section 4 of this notice.

 

14. Privacy Contact Information

If you have any questions regarding our Privacy Statement or if you need to update, change or remove information, you can do so by contacting regular mail addressed to privacy.governance@tatasteel.com

 

 

Declaration:

To the extent necessary to provide Human Resources services to me as an employee of TSL, I hereby authorize TSL to:

a) Obtain from me personal information related to me which could, for example, include my residential address, personal telephone number, date of birth, physical disabilities and medical history;

b) Disclose limited personal information to third parties authorized under contract with TSL to perform identified services on behalf of TSL or as may be required by law;

c) Transfer to, process and store my personal information outside Indian Territory with equivalent protection; and

d) Retain adequate documentation of the personal information records in line with applicable laws and lawful business requirements after termination of employment with TSL.

 

If I provide TSL with personal data relating to my family members or dependents, I hereby represent that I have explicitly informed them of the potential processing and disclosure of their personal data and have obtained necessary consents from those family members / dependents to enable TSL to process their personal information.