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INFORMATION ON THE PROCESSING OF PERSONAL DATA

With effect from 25/05/2018, all personal data are in compliance with the Regulation of the European Parliament and the Council of the European Union 2016/679 of 27 April 2016 on data protection of individuals in the processing of personal data and on the free circulation of such data, whereby Directive 95/46/EC (General Data Protection Directive - hereinafter referred to as the 'Directive') is thus suspended. The following information shall be granted in accordance with Article 13 of the Directive.

1. Identity and contact details of the operator

The Operator processing the personal data is SK-CONT s. r. o., located in Hadovce 219, 945 01 Komárno, ID no.: 36 563 731, registered in the Commercial Register of the District Court in Nitra, file no.: 39883/N, dept. Sro (GmbH) (hereinafter referred to as 'the Operator').

2. Rights of the data subject

The right of the Operator to require access to the personal data of the data subject in accordance with Article 15:

The data subject is entitled to receive confirmation from the Operator as to whether the personal data concerning him or her is being processed and, if so, to access such personal data and to receive the following information:

  1. Purpose of processing;
  2. Category of the personal data concerned;
  3. The recipient or category of recipients, to whom the personal data has been or will be provided, in particular the recipients in the third countries or international organisations;
  4. if it is possible, the assumed duration of data retention, or if it is not possible, the criteria for its determination;
  5. Existence of the right to require the Operator to correct the personal data of the data subject, or to delete or limit their processing, or to oppose the right to such processing;
  6. the right to appeal to the Board of Supervisors;
  7. if the personal data were not acquired by the data subject, any accessible information regarding their source;
  8. The existence of an automated decision, including the profiling of Article 22 para. (1) and (4) and, in such cases, at least useful information on the procedure followed, as well as the meaning and likely effects of such processing on the data subject.

If the personal data is transferred to third countries or to an international organisation, the data subject is entitled to be adequately informed about the transfer under Article 46 of the Directive.

The Operator shall provide a copy of the personal data being processed. For any additional copies requested by the data subject, the Operator may charge a reasonable fee equal to the administration costs. If the data subject has submitted the application electronically, the information will be provided in the usual electronic form, unless otherwise requested by the data subject. The right to receive a copy shall not impair the rights and freedoms of third parties.

 

The right to rectify personal data under Article 16:

The data subject is entitled to have the Operator rectify any inaccurate data concerning him/her without undue delay. With regard to the purpose of the processing, the data subject is entitled to supplement the incomplete personal data by means of a supplementary statement. 

 

The right to erasure (the right 'to be forgotten') under Article 17: 

The data subject is also entitled to have the Operator erase any personal data concerning him/her, and the Operator is obligated to erase the personal data without undue delay, where one of the following grounds is fulfilled:

  1. the personal data is no longer necessary for the purposes for which it was collected or otherwise processed;
  2. the data subject withdraws the consent, on the basis of which the processing takes place, acc. to Article 6 para. 1 a) or acc. Article 9 para. 2 a) of the Regulation, and provided that there is no other legal basis for processing;
  3. the data subject objects to the processing under Article 21 para. 1 of the Regulation and there are no prevailing legitimate reasons for such processing or the data subject objects to the processing under Article 21 para. 2 of the Regulation;
  4. the personal data was processed unlawfully;
  5. the personal data must be erased in order to comply with a legal obligation laid down in Union or Member State law applicable to the Operator;
  6. the personal data was collected in connection with the offer of information society services pursuant to Article 8 para. 1 of the Regulation;

If the Operator has published the personal data and if it is obligated to delete the personal data, with regard to the accessible technology and costs incurred for implementing the measures, it takes appropriate measures, including technical ones, to inform the Operator processing the personal data, that the data subject requires the erasure of all references to that personal data, their copies or counter-pleadings.

The right to erasure is not claimed if the processing is required for the following purposes:

  1. for exercising the right to freedom of expression and information;
  2. for the fulfilment of the statutory obligation of the processing under the Union or the Member State law applicable to the Operator, or for the performance of the public-interest task or in order to exercise of the public authority delegated to the Operator;
  3. for reasons of public interest in the public health field in accordance with Article 9 para. (2) (h) and (i), as well as Article 9 para. (3) of the Regulation;
  4. for archiving in the public interest, for scientific or historical research or for statistical purposes under Article 89 para. (1) of the Regulation, to the extent that it is apparent that the above right impedes or grossly hinders the achievement of such processing, or
  5. for the presentation, assertion or defence of legal claims.

 

The right to restriction of processing under Article 18:

The data subject is entitled to have the Operator restrict the processing of his/her personal data, if one of the following cases applies:

  1. the data subject contested the accuracy of the personal data, for a period enabling the Operator to verify the accuracy of the personal data;
  2. the processing of the data subject's personal data is unlawful, but the data subject opposes the erasure of this data and requests the restriction of its use instead;
  3. the Operator no longer needs the personal data for the purposes of the processing, but the data subject requires it for the establishment, exercise or defence of legal claims;
  4. the data subject has objected to the processing of his/her personal data pursuant to Article 21 para. (1) of the GDPR pending the verification whether the legitimate reasons of the Operator override the legitimate reasons raised by the data subject.

If processing has been restricted in accordance with the aforementioned limitation, such personal data will be provided, with the exception of detention, only upon consent of the data subject or for the purpose of representing, asserting or defending the rights, or for the protection of the rights of another natural person or entity, or for reasons of important public interest of the Union or of the Member State.

The data subject who has obtained the restriction of processing in accordance with the aforementioned facts is informed by the Operator before the processing restriction is deleted.

 

The right to data portability under Article 20:

The authorised person is entitled to obtain personal data, which relates to him or her and which he or she has provided to the Operator, in a structured, commonly used and machine-readable format, and is entitled to transfer this data to another Operator without any hindrance from the Operator to whom the data was provided if: a) the processing is based on the consent referred to in Article 6 para. (1) (a) or Article 9 para. (2) (a) of the Regulation or on the contract referred to in Article 6 para. (1) (b) ) of the Regulation, and b) if the processing is carried out by automated means.

The data subject is entitled to have personal data transferred directly from one Operator to another, whenever technically feasible, in exercising his/her right of portability.

Article 17 of the Regulation shall not be affected by exercising the right. That right does not relate to the processing necessary to fulfil the task, which was carried out in the public interest or in exercising of the public authority delegated to the Operator. The right to data portability must not adversely affect the rights and freedoms of third parties.

 

The right to object to the processing, including objection to the profiling (where applicable) in accordance with Article 21:

The data subject is entitled, at all times, to object to the processing of his/her personal data, which is carried out pursuant to Article 6 para. (1) (e) or (f) of the Regulation, for reasons relating to his/her specific situation, including objection to profiling based on the aforementioned provisions.

The Operator may not process the personal data further, unless it proves the urgent and justified reasons for the processing, which override the interests, rights and freedoms of the data subject, or the reasons for the expulsion, assertion or defence of the legal claims. If personal data is processed for direct marketing purposes, the data subject is entitled, at all times, to object to the processing of his/her personal data for the purpose of such marketing, including the profiling to the extent that it relates to this direct marketing. If the data subject opposes processing for direct marketing, the personal data may not be processed for such purposes.

In the context of the exercising of information society services and without regard to Directive 2002/58/EC, the data subject may claim his/her right through automated means by applying technical specifications. Where personal data is processed for scientific, historical or statistical purposes under Article 89 para. (1) of the Regulation, the data subject is entitled to object to the processing of personal data, for the reasons that relate to his/her specific situation, with the exception of cases where the processing is necessary for fulfilling urgent tasks for public interest reasons.

 

The right to lodge a complaint with the supervisory authority:

The data subject is entitled to lodge a complaint with the supervisory authority, which is the Office for Personal Data Protection of the Slovak Republic.


The right to revoke consent with processing:

In the event that the legal basis for the processing of the personal data is the consent of the data subject, the latter is entitled to revoke his/her consent at any time without affecting the legality of the processing based on the consent granted prior to the revocation.

The right to withdraw consent at any time, even before the expiry of the period for which such consent has been granted, may be claimed by the data subject in the following way:

  1. via email to the address: ochranaudajov@sk-cont.sk
  2. by calling +421352901130, or
  3. by sending the written request to the address of the registered office of the Operator stating the text "GDPR - odvolanie súhlasu / revocation of consent" on the envelope.

3. The purpose and legal basis of personal data processing

The Operator processes your personal data for the following purposes:



  1. Staff and wage agenda

    The purpose of the personal data processing is the drafting and concluding of the employment contract or the agreement on the work except employment, evidence of employment documents, payroll, contributions, fulfilment of the obligations to state agencies, evidence of attendance, training certificates, the issued assignments and authorities, proof of provided occupational safety equipment, property or facility, conclusion of material liability agreements, proof of cash handover, employee benefits, proof of damage caused to employer's property by staff, boarding provision, copying of documents required for employment or similar relationship, as well as the fulfilment of other contractual and legal obligations (Act No. 311/2001 of the Code of Law, Labour Code, Law No. 580/2004 of the Health Insurance Code, Law No. 461/2003 of the Social Insurance Code, Law No. 595/2003 of the Law on Income Tax, Law No. 43/2004 of the Law on Old Age Insurance, Law No. 650/2004 Law on Supplementary Pension Insurance, Law No 5/2004 of the Law on Employment, Law No. 462/2003 of the Law on Compensation for Temporary Incapacity of the Employee, Act No. 152/1994 of the Social Fund Law and Law No. 124 / 2006 of the Code of Safety and Health and Safety).

    The basis of the processing is the fulfilment of the legal duty within the meaning of Art. 6 para. (1) (c) of the Regulation and the employment contract or the agreement within the meaning of Art. 6 para. (1) (b) of the Regulation, concluded with the data subject pursuant to the General Terms and Conditions of Purchase.

    The data subject is obligated to provide his/her personal data to the extent required; failure to fulfil this obligation renders the conclusion of the employment contract or similar contract impossible.

    The recipients of the personal data are:

    Health insurance, social insurance, tax office, supplementary pension funds, pension administration companies, agencies for social affairs and family issues, statistical matters, guard service, education agencies and trainers, subject for medical services, health report and assessment of occupational fitness, subject for safety and health at work, subjects for postal services, subjects for document archiving, subjects for the development, administration and support of information technologies, subjects for external audits, telecommunication service providers, society on whose servers the personal data is stored, clients of the employer, suppliers of the employer, organs of the public authority, lawyers and, in well-founded cases, courts, law enforcement agencies and executors.

    Period of retention of personal data in the employee's personal file is:

    The period limited to the employment relationship and 70 years of service (also a previous one), duration of the retention of the time slips regarding the holidays and spare leave is 3 years, duration of retention of medical accompanying documents is 1 year. Other documents will be kept for 5 to 10 years in accordance with the period determined by the pertinent law. The personal data is neither an object of profiling nor one of decision-making based on automated processing.

     

  2. Proof of job applicants

    The purpose of the personal data processing is to serve as proof of job applicants for the purpose of evaluating their job profile in the recruitment and selection of employees and for the use of the assessment of their suitability for the positions to be filled in the future.

    The legal basis of personal data processing is the consent of the data subject within the meaning of Article 6 para. (1) (a) of the Regulation.

    The retention period of the personal data is 3 years from the date of the approval or from the moment of the revocation of the consent.

    The Operator does not provide the personal data processed for this purpose to any recipients. The personal data is neither an object of profiling nor one of decision-making based on automated processing.


  3. Photo and image acquisition - internal communication  

    The purpose of the processing of the personal data is the presentation of the company by means of internal communication accessible to the employees of the company. The legal basis of personal data processing is the consent of the data subject within the meaning of Article 6 para. (1) (a) of the Regulation. The personal data will be maintained for the duration of the employment relationship or until it has been revoked by the employee.

    The Operator does not provide the personal data processed for this purpose to any recipients. The personal data is neither an object of profiling nor one of decision-making based on automated processing.


  4. Photo and image acquisition – external communication

    Personal data is processed for the presentation of the company by means of external communication accessible to the public. The legal basis of personal data processing is the consent of the data subject within the meaning of Article 6 para. (1) (a) of the Regulation.

    The personal data will be maintained for the duration of the employment relationship or until it has been revoked by the employee.

    The Operator does not provide the personal data processed for this purpose to any recipients. The personal data is neither an object of profiling nor one of decision-making based on automated processing.


  5. Safety

    The purpose of processing the personal data is the proof of entry of the third-party natural persons into the premises of the Operator, monitoring of the premises of the Operator by means of the camera system and check of the staff attendance by making a photo of them entering the premises.

    The legal basis of personal data processing is the legitimate interest on the part of the Operator or third parties within the meaning of Article 6 para. (1) (f) of the Regulation. The legitimate interest of the Operator or third parties is the right to property protection, the right to health protection of natural persons, the right to control the entry of natural persons into the premises of the Operator and the right to control the attendance of employees and to derive responsibilities under the employment law.

    The retention period of the personal data in the case of proof of entry of the external natural persons into the premises of the Operator is 3 years; in the case of video recordings from the monitoring system, 6 days; and in case of control of employee attendances, 1 month.

    The recipient of the personal data is the contracted security service, which ensures the protection, monitoring and control of entry into the premises of the Operator, in justified cases, the recipients of the personal data can be courts and law enforcement agencies. The personal data is neither an object of profiling nor one of decision-making based on automated processing.


  6. Accounting and business agenda

    Personal data is processed for accounting purposes, in order to fulfil legal obligations of the Operator arising from the pertinent regulations (Act No. 431/2002 of the Code of Practice on Accounting, Act No. 222/2004 of the Law on VAT Law No. 595/2003 of the Law Collection on Income Tax, Law No. 40/1964 of the Collection, Civil Code, Law No. 311/2001 of the Code of Labour Code and Law No. 18/2018 of the Collection of Laws relating to Personal Data Protection).

    The legal basis for the processing of personal data, including the provision of it to third parties, is the fulfilment of the legal duty within the meaning of Art. 6 para. 1 c) of the Regulation.

    The retention period of the personal data is 10 years.

    The recipients of the personal data are subjects for information technology, public authorities, parent companies, tax consultants, accounting consultants and auditors. The personal data is neither an object of profiling nor one of decision-making based on automated processing.

     

  7. Registry management

    The purpose of the processing of the personal data is the administration of the registry for the purpose of fulfilling the legal obligations of the Operator (Act no. 395/2002 of the Collection of Laws relating to Archives and Acts and Law no. 305/2013 of the Collection of Laws relating to the Electronic Form of the Effectiveness of Public Authorities).

    The legal basis of personal data processing is the fulfilment of the legal obligation within the meaning of Art. 6 para. (1) (c) of the Regulation. The provision of personal data is the legal duty of the data subject.

    The recipients of the personal data are subjects that ensure the development, management and support of the information technology, the external audit ensuring entities, the telecommunications service providers, the company on whose servers the personal data has been stored.

    The retention periods are determined by special regulations. The personal data is neither an object of profiling nor one of decision-making based on automated processing.


  8. Notice of socially adverse activity

    The purpose of the processing of the personal data is the evidence of criminal or other unlawful activity for the purpose of fulfilling the obligations of the Operator arising from Act No. 307/2014 of the Code of Law on some of the measures related to the reporting of the illegal activity.

    The legal basis of personal data processing is the fulfilment of the legal obligation within the meaning of Art. 6 para. (1) (c) of the Regulation.

    The retention period for personal data is 3 years.

    The recipients of the personal data may in justified cases be the courts or law enforcement authorities. The personal data is neither an object of profiling nor one of decision-making based on automated processing.


  9. Contracts with natural persons

    Personal data is processed for concluding contracts with natural persons.

    The legal basis of personal data processing is the performance of the contract within the meaning of Article 6 para. (1) (b) of the Regulation.

    The retention period for the personal data is 10 years following the expiry of the relationship with a natural person.

    The recipients of the personal data are information technology suppliers and IT administrators, external auditors, telecommunications service providers, suppliers of external data storage agencies and, in justified cases, law enforcement authorities. The personal data is neither an object of profiling nor one of decision-making based on automated processing.


  10. Proof of received and sent mail, as well as electronic mail

The purpose of the processing of the personal data is the verification of the recipient and sender as well as the content of the received and sent mail.

The legal basis of personal data processing is the legitimate interest on the part of the Operator or third parties within the meaning of Article 6 para. (1) (f) of the Regulation. 

The legitimate interest of the Operator is the proof of the intercepted and dispatched business communication related to the Operator's activity arising from the business purpose of a company.

The retention period is 5 years in the case of paper mail and the employment term in the case of electronic mail. The Operator does not provide the personal data processed for this purpose to any recipients. The personal data is neither an object of profiling nor one of decision-making based on automated processing.

4. Current recipient list of personal data

The following entities are the recipients of personal data to be processed:

  • SECURITAS SK s. r. o.
  • ABS Moča s.r.o.
  • BIOMETRIC, spol. s r. o.
  • Cronon AG
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