Privacy Policy

Vanator employees, consultants & subcontractors managed by Vanator, are granted access to data / information resources in order to facilitate their job responsibilities. Vanator employees, consultants & subcontractors must understand and agree to the Data Privacy Policy to be allowed to access to Vanator
information systems.For the purpose of this policy, the terms ‘personal data’, ‘process/processing’, ‘data controller’, ‘data processor’, ‘data subject’ shall have the same meaning as under the applicable data protection and privacy law and regulation and notably as in Directive 95/46/EC and any subsequent applicable legislation that may replace them (such as the European General Data Protection Regulation 2016/679).

I acknowledge and agree that any data including without limitation, personal data must be processed solely for the purpose for which it is provided i.e. only on behalf and in accordance with Vanator’s documented instructions.

I acknowledge and agree that at all times personal data are processed in compliance with applicable data protection and privacy regulations and ensure that its employees, contractors and/or agents comply with the relevant provisions of the applicable data protection and privacy law and regulation and with the following obligations.

Further, I understand that for the purpose of this Agreement and the Services being provided hereunder, I shall:

i. Use the highest industry standards and data controls and take technical and organizational security measures to safeguard and protect personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure, access, in particular when the processing involves
the transmission of data over a network, and against all other unlawful forms of processing.

ii. not process any client’s personal data for any purpose other than those necessary for the performance of this Agreement.

iii. Restrict access to all client’s personal data, whether stored and processed electronically or otherwise, to such of the Staffing Agency’s relevant employees and/or agents and any subcontractors engaged by the Staffing Agency who have a specific need to access client personal data, and will take reasonable steps to ensure the reliability of any individuals or entities who have access to client personal data;

iv. Promptly inform client about:
a. Any breach (actual or threatened) of data provided to the Staffing Agency and the steps it has taken to mitigate such breach.
b. Any request received directly from the data subjects concerned by client personal data without
responding to that request unless it has been expressly authorized by client to do so.
c. Any legally binding request for disclosure of client’s personal data by a law enforcement authority
unless otherwise prohibited, such as a prohibition under criminal law to preserve the confidentiality of a law enforcement investigation.

v. Destroy and/or return all data immediately upon expiry/termination of this Agreement, or earlier if the purpose for which such data is required has been fulfilled.
vi. defend, indemnify and hold harmless clients, its affiliates and its customers from and against any and all liabilities, costs, expenses (including legal expenses), damages, injury, fines, claims, losses that arise from or in respect of use or misuse of data by the Staffing Agency or otherwise attributable to any data
breach pursuant to this Agreement.

vii. not subcontract any part of the services without the prior written consent of the client and without requiring the sub-processor to sign a contract containing equivalent provisions as those set out in this provision. The Staffing Agency undertakes also to send promptly a copy of any sub-processor agreement it concludes to client.
viii. at all times allow client or its third party auditor to access to the Staffing Agency data processing facilities (or the Staffing Agency’s subcontractor’s facilities) to carry out an audit of all facilities, equipment, documents or electronic data relating to and/or used in the processing of client personal data by the Staffing Agency and verify the Staffing Agency’s confidentiality and security measures taken, provided that client shall give reasonable notice to the Staffing Agency prior to conducting such audit.