I. FRANGOS & ASSOCIATES LLC (“we”, “us” or “our” in this privacy notice) respects your personal data and commits to being transparent during the data collection and processing. We also commit to operating in compliance with the Cypriot or European Legislation in the areas of personal data processing, privacy and data security. The legislation includes, inter alia, the General Data Protection Regulation (GDPR) and the National legislation for the personal data protection. We also consider the Guidelines issued by the Office of the Commissioner for Personal Data Protection in Cyprus.
This Privacy Notice refers to the personal data of employees working for our Company and job applicants applying for the available job positions, including job candidates sending their CVs
voluntarily for consideration for future employment opportunities (hereinafter “Employees” or “Job Applicants” or “you”).
It is important that you read this privacy notice together with any other privacy notice we may provide on certain occasions when we are collecting or processing your personal data so that you are fully aware of how and why we are using your data. This privacy notice supplements any other notices and is not intended to override them.
1. Important Information
Data Controller
The data controller processing your personal data is I. FRANGOS & ASSOCIATES LLC, a duly registered limited liability company in Cyprus under registration number 236075 with its registered office at 57 Spyrou Kyprianou Avenue,Bybloserve Business Center, Larnaca 6051, Cyprus
Data Protection Officer (DPO)
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our DPO using the details set out below.
DPO Contact Details:
Name: Georgia Thoma
Email address:
dpo@frangoslaw.com
Address: 10 Patron street, 6051 Larnaca
Tel: 24812581
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Any changes to this privacy notice will be posted on our
website and where appropriate notified to you in writing.
2. What personal data do we collect about you?
Personal data is any information relating to an identified or identifiable person. We may collect, use, store and transfer different kind of personal data relating to you which we have grouped together as follows:
For employees:
- Identity Data: name, surname, ID or Passport number, date of birth, gender, domicile, nationality, tax identification number, social security number, as well as, name and surname of people that we will contact in a case of an emergency.
- Data on marital status: marital status (single, married, divorced), name and surname of spouse, number of children, children’s date of birth, as well as, name, surname and further details of other dependent members (if any)
- Contact Details: home address, email address, telephone or fax numbers, personal corporate phone number, last home address abroad (for foreign citizens), as well as, home address, telephone number and email address of persons that we will contact in a case of emergency.
- Data relating to the education, professional experience and other characteristics of the employee: qualifications, employment history, seminar attendance certifications, IT knowledge, knowledge of foreign languages, driving license, recommendation letters, fulfillment of military obligations, work permit (for foreign citizens).
- Data relating to health: medical history, health certificate, including doctor's certificate for sick leave and doctor's certificate for maternity or paternity leave.
- Financial Data: bank account details, payroll, social security’s statement, transaction history from our Company’s debit cards.
- Data relating to the use of our electronic systems: corporate email addresses, user details (usernames)
- Data relating to the contracts: employment contract, contract amendments, termination agreements (termination or resignation)
- Data collected from the security systems: records from the cameras through the Closed-circuit television (CCTV).
For job applicants:
We may collect your CV together with your job application for the available job position. These documents may contain the following personal data:
- Identity Data: name, surname, date of birth, place of birth, domicile, photo of potential employee, ID number or passport number
- Data relating to the education, expertise, and other characteristics of the employee: qualifications, employment history, seminar attendance certifications, IT knowledge, knowledge of foreign languages, driving license, recommendation letters, fulfillment of military obligations, work permit (for foreign citizens)
- Data relating to the marital status: marital status (single, married, divorced), number of children, age of children
- Contact details: home address, email address, telephone number
- Data collected from the security systems: records from the cameras through the Closed-circuit television (CCTV).
3. How do we collect your personal data?
For employees:
We collect your personal data from you. We may also use the information that you provided us during the recruitment process through your job application, CV or resume, references supplied by former employers, or in any other way.
For job applicants:
We collect your personal data during the recruitment process through your job application, CV or resume, references supplied by former employers, interviews or other forms of assessment. Your CV and/or job application may be received through third-party websites that they post our vacancies.
4. Why do we collect and process your personal data?
We use your personal data only for the following purposes:
For employees:
- When it is necessary for performing the employment agreement. This includes, inter alia:
- ayroll and payment processing
- managing the employment relationship and providing the necessary equipment to the Employees
- ensuring the security of our premises
- When it is necessary for protecting our legitimate interests as long as the individual’s fundamental rights and freedoms do not override these interests, especially for:
- collecting and analysing personal information for statistical purposes after having taken the appropriate security measures,
- preventing and detecting security threats, frauds or other criminal or malicious activities,
- purposes of risks insurance coverage,
- exercising or defending our legal rights or for complying with court decision or orders
- controlling the access on our premises for security purposes
Closed-circuit television (CCTV) is also used for purposes of our legitimate interests,
especially for:
- the crime prevention and detection
- the security and protection of our premises
- the security of Clients and Employees
- assuring the Clients and Employees of their security thanks to the measures that have been taken and thus reducing the fear of crime
- assisting the local law enforcement authorities with the crime detection and prevention, including the fight against terrorism.
- when it is necessary for the protection of the vital interests of employees or any other physical persons. This includes, inter alia,
- managing incidents, sicknesses, accidents, injuries or cases of emergency at our premises
- contacting you or any other relevant contact person in case of emergency
- when it is necessary for complying with a legal obligation, including maintaining records, compliance checks or screening and recording (e.g. for tax purposes, for fraud and crime prevention and detection etc.). This can include sharing your personal data with third parties, such as the competent law enforcement authorities
- when it is necessary for performing a task in the public interest and this task has a clear basis in law
- When you give us your consent to process your personal data
For job applicants:
- When it is necessary in order to take steps at the job applicant’s request prior to entering into an employment contract and especially for:
- managing the recruitment process, assessing and confirming a candidate’s suitability for employment and deciding to whom to offer a job
- being able to enter into a contract with the job applicant
- being able to contact the job applicant
- when we decide not to proceed with your job application and you give us your consent to keep your personal data for consideration for future employment opportunities. In this case, you are free to withdraw your consent at any time
Special Categories of Personal Data
We do not process your personal data that belongs to the special categories of personal data (e.g. racial or ethnic origin, health data etc.),
except that:
- Processing is necessary for the fulfillment of the obligations and/or the
exercise of our Company’s and Employees’ rights according to the Social Security and Labor Law.
- Processing is necessary for the protection of the vital interests of the employees, or any other physical persons.
- Processing is necessary for the exercise of legal claims
- Processing is necessary for purposes of public interest, such as the investigation of a criminal case
- Your explicit consent for a specific purpose was given.
Automated decision making
We will not use your personal data for making any automated decisions, including the creation of profiles, i.e. making decisions by electronic means without any human intervention.
Change of purpose of processing
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, where this is required or permitted by law.
5. Who do we share your data with?
We may have to share your personal data for the purposes mentioned in this Privacy Notice with the following categories of recipients:
For employees:
- relatives in case of emergency or following your prior consent
For job applicants:
- third parties providing services to our Company, such as IT support
- regulatory bodies, law enforcement authorities, or pursuant to an order of a court or a legal obligation
- other third parties provided that such obligation is based on national or EU law.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. We will not sell your personal data, as well as, we will not allow third parties to sell the data we transfer to them.
6. How do we transfer your personal data outside the European Economic Area (EEA)?
We do not transfer any personal data to countries outside the EEA.
Nonetheless, it might be necessary to do so for the purposes mentioned in this Privacy Notice and we will take steps to ensure that your personal data receives an adequate level of protection. In case where your personal data is transferred to a service provider for processing in any country outside the EEA that is not recognized by the EU Commission as providing an adequate level of protection for personal data, we will ensure that appropriate safeguards as per the EU Commission’s standard contractual clauses or by any other appropriate safeguard as foreseen under the applicable data protection law are provided.
7. What security measures do we take?
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
- Site Access Control: unauthorized persons are not allowed to have access to areas within our premises whereby personal data are processed and in case that the provision of access to such persons is necessary, they do not remain unattended.
- System Access Control: only authorized persons have access to data processing systems.
- Data Access Control: authorized persons with access to data processing system have access only to the data they are authorized to access and are bound by confidentiality.
- Transfer Control: personal data are only transferred in prescribed manner and under certain circumstances.
- Disclosure Control: we always ascertain and check where and to whom data can be transferred by means of data transmission facilities.
- Order Control: personal data of a data subject is processed in strict accordance with the data subject’s instructions and the appropriate law.
- Availability Control: personal data is protected against accidental destruction or loss as all data is backed up.
- Breach Control: procedures to deal with any suspected personal data breach and for the notification of any applicable regulator or an affected data subject of a breach have been laid down.
Our security measures are audited regularly by external security experts in order to maintain our security level to international standards and to ensure that personal data is handled in a secure way.
8. How long do we keep your personal data?
We will only retain your personal data for the period necessary to fulfil the purposes described in this Privacy Notice.
For employees:
The personal data of employees are kept for two (2) years after the termination of the employment contract
. It is possible however, that the personal data of the employees will be kept for longer in the following circumstances:
- for audit or tax purposes
- till the period that claims against us can be issued before courts or other prosecution authorities so that we will be able to defend its legal rights
- in case of litigation, till the court proceedings or enforcement measures are carried out.
As for the CCTV records, they are retained for a period of one (1) month from the recording date. However, we may have to retain this data for a longer period, such as for defending our legal rights before courts or other enforcement authorities.
For job applicants:
The personal data of the Job Applicants are kept for up to one (1) month from the completion of the recruitment process. If their application is unsuccessful and they give us their consent for considering their candidature for future jobs, their personal data will be retained for one (1) more year. CVs that are sent voluntarily may also be kept for one (1) year for consideration for future employment opportunities.
In general, to determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, as well as, the applicable legal requirements.
Under some circumstances, you can ask us to delete your data. See below to read more about your right to erasure.
9. What are your rights?
You have the following rights regarding your personal data:
Right of Access: You have the right to access to your personal data. You can ask for a copy of the personal data we hold about you. There are situations where we may deny your request, for example, if making the information available to you would reveal personal data about another person, or if we are legally prevented from disclosing such information.
Right to Rectification: It is our objective to keep your personal data accurate, current and complete. You have the right to request the correction of any incomplete or inaccurate data we hold about you, though we may need to verify the accuracy of the new data you provide to us.
Right to Erasure: You have the right to ask us to delete your personal data where there is no reason to continue processing it. You also have the right to ask us to delete your personal data where you have successfully exercised your right to object to the processing, where we may have processed your data unlawfully or where we need to delete your personal data to comply with the law. Note, however, that we may not always be able to comply with your request for deletion for specific legal reasons for which we will notify you, as appropriate, at the time of your request.
Right to Object: You have the right to object to the processing of your personal data when we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds which override your rights and freedoms. You also have the right to object when we are processing your personal data for direct marketing purposes.
Right to Restrict Processing: You have the right to ask us to suspend the processing of your personal data in the following cases: (a) if you want us to establish the data’s accuracy, (b) when our use of the data is unlawful but you do not want us to erase it (c) when you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims, or (d) if you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Right to Data Portability: You have the right to request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.
Right to Withdraw Your Consent: You have the right to withdraw your consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before the withdrawal of consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the abovementioned rights, please contact us at
dpo@frangoslaw.com.
Right to file a complaint
You have the right to lodge a complaint with the Office of Cyprus Commissioner for Personal Data Protection.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What do we need from you?
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that your personal data is not disclosed to any other person. We may also contact you to ask for further information in relation to your request.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complicated or you have made more requests. In this case, we will notify you.
We recommend that you visit our website often in order to keep updated with the changes in our Privacy Notice. For previous versions of our Privacy Notice, please contact us at
dpo@frangoslaw.com.
Updated 15.04.2020