Last updated: March 24, 2021
This Employee Privacy Notice (“Notice”) describes how we – IGMR Research Ltd. and our affiliates (“Intelligo”, “we”, “our” or “us”) – treat the personal data of our employees (“Employee”, “you“, or “your”).
Specifically, it describes the personal data we typically receive or collect, how and for which purposes we may use such data, where we store it and for how long we retain it, with whom we may share it, our security practices, your choices and rights regarding such data, our role as Data Controller and how to contact our privacy team if you have any concerns regarding your privacy or this Notice.
Intelligo is a global company with offices worldwide including in Israel and the US. While this Notice is intended to describe the broadest range of our data practices globally, those practices may be more limited in some jurisdictions based on the local legal requirements. For example, the laws of a particular country may limit the types of personal data we can collect or the manner in which we may process that data. In those instances, we adjust our internal policies and practices to reflect such local requirements.
Please read this Notice and make sure that you fully understand and agree to it.
1. Data Collection
We collect and receive the following categories of personal data:
Data received from you during your job application process: throughout the application and recruitment process, you may provide us (or we may otherwise have access to) personal data about you, which in typical circumstances would contain your:
- identifying information;
- contact details;
- work history, technical skills, educational background, professional certifications and registrations;
- language capabilities;
- training records;
- social media or other public activity;
- salary history and expectations.
We may collect this data directly from you, as you provide it voluntarily through your application and candidacy review process, or from other sources such as your references, placement agencies or our Service Providers (as defined in Section 5 below).
Data received from you during your employment: once you join Intelligo and during your employment with us, you may provide us additional personal data about you, such as:
- additional identifying and contact data (e.g., your profile picture, ID or Social Security Number, nationality, passport details, home address, gender, date of birth, marital status, employee ID number, residency and work permit status, military status, nationality, username and hashed password for your accounts at Intelligo);
- data concerning your immediate family members and emergency contacts you have provided (as necessary under applicable tax and benefits forms);
- data concerning your health (so we could best attend any special requirements or preferences you might have, or sick day permits);
- your religious or philosophical beliefs (to the extent necessary for us to respect your religious holidays, dietary requirements or other work-related needs);
- your bank, health and benefits providers (e.g., your bank account for depositing your salary, your selected pension or insurance providers, mobile carrier, health providers);
- data concerning your expressed preferences or requests;
- voicemails, e-mails, call and video recordings, correspondence, documents, and other work product and communications created, stored or transmitted using our networks, applications, devices, computers or communications tools;
- date of resignation or termination, reason for resignation or termination, information relating to administering termination of employment (e.g., references);
- meal orders and dietary preferences; and
- any other personal or economic data you may provide us with during or concerning your employment by Intelligo.
Data generated by Intelligo, other Intelligo employees or our Service Providers: we, other Intelligo employees or our Service Providers may create additional data about you, such as:
- job offer letters;
- data regarding your role, position and team;
- salary, benefits and stock options;
- records of work absences, vacation/paid time off;
- entitlement and requests;
- performance appraisals, letters of appreciation and commendation, and disciplinary and grievance procedures (including monitoring compliance with and enforcing our policies);
- work travel plans;
- Internal background checks;
- general video footage from Intelligo’s facilities’ CCTV security system;
- calendar events, participation in work events, and other data concerning your activities as a Intelligo employee.
Data automatically collected or generated: when you use any of Intelligo’s systems or devices, including when you connect to or use your Intelligo e-mailbox, we and our Service Providers may collect or generate technical data about you. Such data consists of connectivity, technical or aggregated usage data, such as IP address, non-identifying data regarding the device, operating system, browser version locale and language settings used, the cookies and pixels installed on such device, and the activity (clicks and other interactions) on such systems. We mostly use this data to have a better understanding of how our employees generally and typically use and engage with such systems and devices, or in order to investigate any suspected illegal activity, abuse or wrongdoing.
2. Data Uses
We may use your personal data as necessary for the performance of our agreement with you; for complying with applicable law, such as applicable labor laws, or regulations concerning data privacy and security; and based on our legitimate interests in managing the day-to-day of Intelligo’s human resources, better understanding and supporting our candidates and employees, ensuring that our employees, clients and assets are protected, and securing and enhancing Intelligo’s reputation and values.
Specifically, we will use your personal data as follows:
- To assess your skills, qualifications and overall fit to work at Intelligo;
- To set up your employee files, finalize and submit all necessary tax and governmental forms, and process your salaries and benefits;
- To authenticate your identity, and allow you access to our facilities and systems;
- To ensure an appropriate and compatible work environment for our employees;
- To respect your personal preferences and requirements, such as religious holidays, dietary or accessibility needs;
- To evaluate your work, status and performance, and manage your day-to-day activities at Intelligo;
- To enable our business continuity, during your employment and following your departure;
- To contact you with information about Intelligo, information or documents concerning your employment with us (such as your salary slips, employee forms, or any other information or documents sent to all or some of our employees).
- To enhance our security and anti-fraud measures and mitigate risks, and to create aggregated statistical or inferred data regarding our candidates and employees, for further development and improvement of our recruitment and HR processes;
- To further develop, customize and improve our HR operations, based on our employees’ common or personal preferences, experiences and difficulties;
- To contact you, or your family members, concerning work-related matters or emergencies;
- To act as permitted by, and to comply with, any legal or regulatory requirements (such as applicable labor laws), and to conduct any additional activities that may require the use of your personal data, for which we will request your specific approval in advance.
3. Data Location
Your personal data may be maintained, processed, accessed and stored by Intelligo, our Service Providers and business partners in Israel the US and other jurisdictions, as necessary for the proper performance of our company and for the proper handling of your employment with us or as may be required by law.
While privacy laws may vary between jurisdictions, Intelligo, its affiliates and Service Providers engaged in processing hereunder are each committed to protect personal data in accordance with this Notice, customary industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction to which such data is transferred.
4. Data Retention
Intelligo may retain your personal data for the duration of your employment with us, and then for an additional period, as reasonably necessary to comply with our legal obligations, to resolve disputes, prevent fraud and abuse, enforce our agreements or otherwise protect our legitimate interests.
Following such period, we may retain limited copies of your data, so to allow us to maintain a registry of everyone who ever worked at Intelligo and to be able to contact them solely in this context (and such registry shall only contain such limited data as necessary for this purpose).
Note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and are free to securely delete it for any reason and at any time.
5. Data Sharing
We may share your personal data with certain third-parties, including law enforcement agencies, our Service Providers and our affiliates – but only in accordance with this Notice and as described below:
Compliance with Laws, Legal Orders and Authorities: we may disclose or allow government and law enforcement officials access to certain personal data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations, including for national security purposes. Such disclosure or access may occur with or without notice to you, if we have a good faith belief that we are legally compelled to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.
Service Providers and Business Partners: we engage selected third-party companies and individuals to perform services complementary to our own (e.g. hosting services, human resources software and service providers, data analytics services, data and cyber security services, fraud detection and prevention services, payroll and payment processing services, e-mail distribution and monitoring services, and our business, legal, financial and compliance advisors – collectively, “Service Providers“). These Service Providers may have access to your personal data, depending on each of their specific roles and purposes in facilitating and complementing our Services, and may only use it for such purposes.
Intelligo Clients and Partners: we may disclose certain personal data to our clients and partners, such as your name, position and contact details, and in some cases (if required for you to provide support or professional services on Intelligo’s behalf) additional data such as your ID and existence of a background check (if any), to those clients requiring such data for security and regulatory reasons.
Other Intelligo Employees: your fellow employees may have access to certain personal data, such as your identity, role, profile picture and contact details, as may be available to them in the internal employee directory, and additional data depending on their specific roles and responsibilities, and need for such data (e.g., payroll data may be disclosed to HR, Finance and Legal personnel, as well as to your managers, all solely on a “need to know” basis).
Protecting Rights and Safety: we may share your personal data with others, if we believe in good faith that this will help protect the rights, property or personal safety of Intelligo, yourself, any of our clients or partners, or any members of the general public.
Intelligo Group: we may share personal data internally within group, for the purposes described in this Notice. In addition, should IGMR Research Ltd. or any of its subsidiaries undergo any change in control or ownership, including by means of merger, acquisition or purchase of substantially all or part of its assets, or will be considered or found eligible for a governmental grant and/or a potential investment, personal data may be shared with the parties involved in such an event. If we believe that such event might materially affect your personal data then stored with us, we will notify you of this event and the choices you may have via e-mail or prominent notice in our internal systems typically used for such notices.
For the avoidance of doubt, Intelligo may share your personal data in additional manners, pursuant to your explicit approval, if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. We may share or otherwise use non-personal data in our sole discretion and without the need for further approval.
6. Data Security
In order to protect your personal data held with us and our Service Providers, we are using industry-standard physical, procedural and electronic security measures, including encryption where deemed appropriate. These measures provide sound industry standard security. These measures provide sound industry-standard security, confirmed also by Intelligo’s ISO/IEC 27001:2013 compliance certification. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any personal data stored with us or with any third-parties.
7. Data Subject Rights
If you wish to exercise your rights under any applicable law (including the EU General Data Protection Regulation (GDPR) or Israeli Protection of Privacy Law) to access, rectify, erase or port your personal data held with Intelligo, or to restrict or otherwise object to its processing, or to exercise any similar rights afforded to data subjects under the laws that apply to you – please contact our privacy team at email@example.com.
Please note that we may require additional information, including certain personal data, in order to authenticate and process your request. Such additional information may be then retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request), in accordance with Section 4 above. We may redact from the data which we will make available to you, any personal data related to others.
Please also note that such rights are not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal data that we hold about you. In the event that we cannot accommodate your request, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
8. Data Controller/Processor
Certain data protection laws and regulations, such as the EU GDPR, typically distinguish between two main roles for parties processing personal data: the “Data Controller”, who determines the purposes and means of processing; and the “Data Processor”, who processes the data on behalf of the Data Controller.
Intelligo is typically the Data Controller of its candidates’ and employees’ personal data, and with respect to which, assumes the responsibilities of Data Controller (solely to the extent applicable under law) and as set forth in this Notice. In such instances, our Service Providers processing such data will assume the role of Data Processors.
9. Additional Information
Updates and amendments: We may update and amend this Notice from time to time by distributing an amended version. The amended version will be effective as of the published effective date. We will provide an advance notice if any substantial changes are involved, via any of the communication means available to us. After this notice period, all amendments shall be deemed accepted by you.
Questions, concerns or complaints: If you have any comments or questions regarding our data practices or your privacy, or if you have any concerns regarding your personal data held with us, or if you wish to make a complaint about how your personal data is being processed by Intelligo, you can contact us at firstname.lastname@example.org.
Last updated: March 24, 2021