Version
Date
Owner
Reviewer(s)
Revision Reason
Privacy Policy of 7-Eleven Corporate Services India LLP (GCC India)
New Policy
Date Issued: April 06, 2021
Functional Area: GCC
Document No: 12-02
1. PURPOSE
1.1
To explain how 7-Eleven Corporate Services India LLP at the Global Capacity Center (“GCC “) collects, uses, and discloses information about its employees and job candidates applying for a job directly through the GCC or through a third-party contractor, sub-contractor or vendor.
2. APPLIES TO
2.1
All employees, consultants, contractors, and prospective candidates (for employment or engagement) of GCC. Individuals who provide information, including their Personal Information, as part of the recruitment process, accepting an offer of employment from GCC or otherwise engaging with GCC, are consenting to the transfer, disclosure and processing of their Personal Information as detailed in this Privacy Policy, as may be amended.
3. POLICY OVERVIEW
3.1
As part of employment or engagement at the GCC, and the related application and recruiting process, the GCC collects certain information from and about employees, consultants, contractors, and prospective candidates (for employment or engagement). Some of this information may be considered Personal Information.
4. POLICY
4.1
Information provided may include:
4.1.1
Demographic Information, such as: name, address and contact details, date of birth, gender and marital status.
4.1.2
Professional or Employment-related and Education Information, such as: CV or resume, a cover letter or other correspondence submitted with employment application, information related to one’s qualifications, skills, experience and employment history, notes taken during interviews, current and expected salary, existence of any disability for which GCC need to make reasonable accommodations, and authorization to work in India.
4.1.3
Government-Issue Identifiers and Income Tax Information, such as: personal identifiers like permanent account number (PAN), and details of income tax filed in preceding years and remuneration, etc.
4.1.4
If any employee’s or applicant’s information is submitted to GCC on behalf of another person, the person submitting the information confirms that he/she has made the employee or applicant aware of how GCC may collect, use and disclose their information, the reason the information was provided, how they can contact the GCC, the terms of this Privacy Policy and that the employee or applicant has consented to such collection, use and disclosure of their information.
4.2
Information may be collected in other ways, including:
4.2.1
From third parties, including identity verification services, credit bureaus and publicly available sources. GCC may also collect Personal Information about the employee or applicant from third parties, such as the references supplied by the employee or applicant or supplied by former employers or external recruiters.
4.2.2
GCC and the third-party service providers use technologies to collect information, including cookies. Cookies are small data files stored on a hard drive or in device memory that help to improve the recruitment process and experience and help manage our relationship with you. For information about cookies and how to disable them, see the section on Cookies below.
4.3
Information Usage:
4.3.1
GCC uses your information for a variety of business and commercial purposes, including but not limited to: processing the employee or applicant’s job application when applying for a job; providing services in relation to employment or engagement, such as payroll processing and office attendance; providing employment-related benefits and further managing the terms of the engagement or employment relationship; carving out GCC obligations and exercising specific rights in relation to employment or engagement; performing day to day activities and providing services, which are incidental to business.
4.3.2
GCC may also process the employee or applicant’s Personal Information to comply with GCC’s legal obligations, defend against legal claims or to respond to inquiries from the employees or others made on their behalf.
4.3.3
With respect to job applicants, GCC may process the employee’s Personal Information during the application and recruiting process and for keeping records of the process.
4.3.4
GCC may share employee information, including Personal Information, as follows, or as otherwise described in this Privacy Policy:
4.3.4.1
With 7-Eleven group entities and current and future parents, affiliates, subsidiaries, and other companies under common control and ownership. In relation to job applicants, GCC may share information internally during the application process, for example with managers of the department with the job opening;
4.3.4.2
With vendors, consultants and other service providers under contract who help with our business operations, such as recruitment, employment, payroll and payment processing, email distribution, statistics and research, legal and compliance services;
4.3.4.3
With law enforcement, governmental agencies or authorized third parties to comply with applicable laws and regulations, to respond to a subpoena, or otherwise pursuant to legal process. GCC may use and disclose employee’s Personal Information to establish or exercise our legal rights, to assert and defend against legal claims, or if we believe such disclosure is necessary to investigate, prevent, or take action regarding actual or suspected illegal or fraudulent activities or potential threats to the physical safety or well-being of any person;
4.3.4.4
In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company; and
4.3.4.5
With your consent or at your specific direction.
4.4
Transfer of Information to the U.S. and Other Countries: GCC’s parent company, 7-Eleven Inc., is based in the United States, and GCC may transfer to, process and store information (including Personal Information) in the U.S. and other jurisdictions outside the employee’s country of residence.
4.5
Information Security: GCC has internal policies and controls in place to protect employee information (including Personal Information) from being lost, accidentally altered or destroyed, misused or disclosed or accessed without authorization. GCC requires any third parties processing employee’s and consultant’s information to implement the same levels of protection with respect to employee data.
4.6
Data Retention: When joining the GCC India team, employee’s and consultant’s Personal Information will be transferred to the Human Resources department and retained during the employment or engagement term. Human Resources will provide you with access to the Employee Handbook containing applicable policies.
If a job applicant is not offered the position applied for, GCC (or their third-party recruitment service or service providers) may still keep an applicant’s Personal Information on file for future employment opportunities that match the applicant’s skills and experience. At the time the applicant submits their CV or resume they will be asked to consent to their Personal Information being retained for that purpose. Upon consent, at the end of that time period prescribed under GCC record retention and destruction policy (“Retention Policy”), or once the applicant withdraws their consent, their Personal Information will be deleted or destroyed pursuant to the provisions of the Retention Policy.
4.7
Additional information:
4.7.1
If a job application is submitted through an external recruiter or employment agency, that organization’s privacy policy will also apply. The job applicant is expected to review all applicable privacy policies of the organizations that may collect or otherwise process the employee or job applicant’s Personal Information in relation to the job application at the GCC.
4.7.2
Job Applicants are under no statutory or contractual obligation to provide information to GCC during the application process. However, failure to provide the information will result in GCC not able to process the job application.
4.7.3
Cookies: Most web browsers are set to accept cookies by default. Job applicants can usually choose to set their browser to remove or reject browser cookies. Removing or rejecting cookies, availability, and certain functionality may be impacted.
4.7.4
Any questions, comments or concerns about GCC Privacy Policy, should be directed to the GCC Director of Human Resources or by email at GM-GCCPrivacy@7-11.com and the GCC will endeavour to respond as expeditiously as possible. Except to the extent necessary for describing the job applicant’s grievance, please do not email any confidential, sensitive or Personal Information to this email.
4.7.5
The Privacy Policy will be reviewed regularly and updated as necessary. GCC will include the updates on this webpage. All are encouraged to check this policy each time when visiting the GCC website, to be aware of any updates or changes.
5. DEFINITIONS
5.1
Personal Information means information that reasonably identifies the employee or job applicant or their device or can reasonably be associated with the employee or job applicant
6. EXCEPTIONS
None.
7. RELATED POLICIES
7.1
Record Retention and Destruction Policy For GCC-India (12-01)
8. REVISION HISTORY
1.0
04/06/2021
Chief Privacy Officer
Compliance
New Policy
Version
1.0
Date
04/06/2021
Owner
Chief Privacy Officer
Reviewer(s)
Compliance
Revision Reason
New Policy