Job Applicant Privacy Notice

This Notice describes how we process and store your personal data that you share with us while applying for a job and rights available to you, during and after your working relationship with us, in accordance with applicable privacy laws. 

Applicability 

This Notice is applicable to all job applicants. This Notice does not form a part of any contract of employment or other contract to provide services. We may update this Notice at any time, subsequent to which, a copy of the updated Notice will be uploaded on the website of the company. 

Relationship 

We are the "Data Controller" of your personal data which means that we are responsible for deciding how we process personal data about you. Processing will include collection, recording, organisation, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, erasure or destruction of your personal data. As your prospective employer, we need to process data about you for normal employment purposes including recruitment and on-boarding and conducting background check and verification.  

Your personal data that we will process  

We will process the following categories of personal data about you: 

• “Personal Details”, including your name, address and contact details, including email address and telephone number, etc. 
• “National ID Details”, including driver’s license details, passport number, etc. 
• “Current Employment Details” including information about your current level of remuneration, including benefit entitlements, etc. 
• “Previous Employment Details” including information about your previous employment history. 
• “Recruitment Information”, including copies of right to work documentation, details of your qualifications, skills, experience and employment history, past employment details etc. 
• “Background check report” including previous employment references and feedback, etc. 
• CCTV footage 
• Audio/video call recordings. 

Your duties as a Data Subject

• Comply with the provisions of all applicable laws for the time being in force while exercising rights under the provision of India’s Digital Personal Data Protection Act (2023). 
• Ensure not to impersonate another person while providing Personal Data for a specified purpose. 
• Ensure not to suppress any material information while providing Personal Data for any document, unique identifier, proof of identity or proof of address issued by the State or any of its instrumentalities. 
• Ensure not to register a false or frivolous grievance or complaint with LTTS or the Board. 
• Furnish only such information as is verifiably authentic, while exercising the right to correction or erasure under the provisions of India’s Digital Personal Data Protection Act (2023) or the rules made thereunder. 

How is your personal data collected? 

We collect your personal data including sensitive personal data through the job application, CVs or resumes, interviews, identification documents, assessments either directly from you, or sometimes indirectly through third-party service providers. We may sometimes collect additional data from a third parties such as job recruitment agencies, former employers, and background check providers. We may collect additional personal data in the course of the recruitment activity. All data collected during the recruitment process, or any additional data collected will be used and stored for performance of employment agreement (in the event we intend to employ you) as well as for complying with the legal obligations or legitimate interests. 

Purpose for processing your personal data 

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: 

• For the screening of your application 
• Throughout the interview process 
• Conducting background verification 
• Sharing offer letter, executing the employment contract post your selection, and for any other formalities required in case we hire you. 

We rely on the following lawful basis: 

• Where we need to perform a contract that we will be entering into with you. 
• Where we need to comply with a legal obligation. (For example, it is required to check your entitlement to work.) 
• Where it is necessary for our legitimate interests (or those of a third party), and your interests and fundamental rights do not override those interests. 
• Where we need to protect your interests (or someone else's interests). 
• Where it is needed in the public interest (or for official purposes). 

If you fail to provide personal data 

If you fail to provide certain personal data when requested, we may not be able to perform the recruitment activity including executing the employment contract post your selection or we may also be prevented from complying with our legal obligations (For example such as to ensure the health and safety of our workers). 

Change of Purpose 

We will use your personal data only for the purposes for which we collected it. If we need to use your personal data for an unrelated purpose, we will notify you and explain, without undue delay, the legal basis which allow us to do. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where it is required or to the extent permitted by law. 

In addition, we will also inform you about the changes in the following information by updating this Notice on our website: 

• categories of personal data provided to a third-party. 
• the method of sharing your personal data with third parties.  
• the method in which LTTS will receive your request. 
• the purpose for the person with whom personal data will be jointly utilized. 
• the name of a person responsible for controlling personal data. 

Data sharing 

We will be sharing your personal data with the following recipients: 

• Third parties with whom we have a contractual relationship, including clients, background check vendor, vendors, law firms, etc. We require third parties to respect the security and confidentiality of your data and to treat it in accordance with our instructions and as mandated under applicable law.  
• Other LTTS entities for performance of employment contract. We may transfer your personal data outside the country where you belong to for processing. Such transfer and further processing shall be in accordance with applicable laws, specifically using the Standard Contractual Clauses (for EU residents) executed between us and other LTTS entities. 
• Internal departments, including with interviewers, recruitment team, hiring managers, admin team, etc. 
• We may share your personal data to a third party without obtaining your consent. In such instances, we will do so in compliance with the applicable privacy laws on data protection. 

Transnational data transfer 

LTTS may transfer the personal data transnationally depending upon the requirements for the performance of a contract with the client or required for other related activities including for our legitimate interests or for your employment purposes. To ensure that your personal data receives adequate level of protection during such transfer, and thereafter for further processing, we have executed Standard Contractual Clauses/Inter-company Agreements with our group companies, other LTTS entities, and authorized third parties to ensure that your personal data is treated by them in a way that receives the adequate degree of protection consistent with the requirements mandated by applicable data privacy laws. 

Data security 

We have put in place reasonable measures to protect the confidentiality of your personal data including any sensitive personal data shared by you. Details of these measures are available upon request. 

Third parties who are required to process your personal data personal data, does so only on our instructions and under the obligation of implementing adequate amount of security and confidentiality. We enter into specific data processing agreements with such third parties to ensure that they comply with our privacy requirements as well as the standards prescribed under applicable laws. 

Data retention 

We will only retain your personal data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. 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, and the applicable legal requirements. 

In some circumstances we may anonymize your personal data so that it can no longer be associated with you, or identify you, in which case we may use such data without further notice to you. In cases where you no longer remain an employee, worker, or contractor with us, we will still retain and securely destroy your personal data in accordance with our Data Retention Guidelines or applicable laws and regulations. 

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 working relationship with us.  

Rights available to you 

Your rights in connection with personal data: Under certain circumstances, by law, you have the: 

• Right of access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you. 
• Right to rectification of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected. 
• Right to be informed about the collection and use of personal data. 
• Right to be forgotten which enables you to ask us to delete your personal data which we hold about you. 
• Right to object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you to object to processing on this ground. 
• Right to request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you during the time we are checking or confirming its accuracy of such data.  
• Right of data portability/ transfer to another party. 
• Right to withdraw consent for processing of personal data where explicit consent has been sought. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. 
• Right related to automated decision-making including profiling. You will have a right not to be subjected to a decision based solely on automated processing including profiling. Right to nominate any other individual, who shall, in the event of death or incapacity, exercise your rights in accordance with the provisions of India’s Digital Personal Data Protection Act (2023) and the rules made thereunder² 

If you are a California resident, you have the following rights under certain circumstances: 

• Right to Know: You have the right to request from us information on the personal data about you that we have processed in the preceding 12 months. This also enables you to receive a copy of the personal data we hold about you. 
• Right to Delete: You have the right to request from us the deletion of your personal data. 
• Right to Non-Discriminate: You have the right to exercise any of the rights listed above (and any other rights under CCPA) without discrimination by us. 
• Additionally, under the CCPA, you can request LTTS to not sell your personal information to third parties. Similarly, under CCPA, LTTS is also required to inform you if LTTS sells or has sold your personal data during the last 12 months. 

Please note that none of these rights are absolute and are subject to provisions stated under applicable law. 

Data Protection Office 

We have appointed a Data Protection Officer (DPO) to oversee compliance with this Notice. If you have any questions about this Notice, or you want to know more about how we handle your personal data, or if want to exercise any of the aforesaid rights, please write to the DPO at: dpo@ltts.com.  

You have the right to make a complaint at any time to the regional supervisory authority for data protection issues.  

Apart from sending email to the aforesaid email ID, any request may be submitted by filling up the form on available on LTTS website. 

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 for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances. 

Changes to this Notice 

We reserve the right to update this Notice at any time. Please visit our website from time to time for to know about the changes in this Notice.   

Footnotes:

[1] Additional requirement from India’s Digital Personal Data Protection Act (2023)