Privacy Declaration Panama

Panama values your privacy, security and confidence. It is essential for us throughout the entire company. Therefore, Panama takes high importance to the protection and the respect towards your privacy. Panama comes in contact with different kinds of data by way of different channels. Below, to accord to the new GDPR, we will explain in detail what we’re doing to protect your privacy, how you have involvement at any moment and which controls we execute in order to comply to this declaration.

 

1. Terminology

This declaration is fully applicable on the collection, gesture, and use of your data by the entities belonging to Panama.

‘Panama’ implies the company Panama BVBA. Panama is registered in the trade register of the Chamber of Commerce under BE 0461.175.711 and legally established in Kapelanielaan 8, 9140 Temse. In the meaning of the privacy regulation Panama can in some situations be a processor and in other a controller. In the latter it means that Panama is responsible for the observance of the privacy regulation if it concerns your personal data.

‘Personal data’ is a collective noun for all information based on how a person directly or indirectly can be identified, such as the name, address, e-mail, national insurance number, information about your pay, et cetera.

‘Privacy scented information’ contains information such as medical data, data about someone’s religious conviction, race, judicial past and sexual inclination.

The concept ‘processing’ is defined as broad as possible so that as good as every adaptation of the personal data is seen as a processing of it. Think about collecting, capturing, saving, adapting, processing, consulting, using, sending, spreading, deleting, et cetera.

The ‘processor’ is the one who processes the personal data for a responsible. The ‘in order’ processing of personal data implies that the processor doesn’t fix himself the goal and the means to process the data. The processor acts corresponding the instructions of the controller and its responsibility. When the processor executes next to its orders, orders for one’s own end, he is for that part of the processing co-responsible.

The ‘agreement’ of a person concerned contains a free, specific, informed and unequivocal expression of one’s will, in which the person concerned accepts by means of a declaration of unequivocal active act the processing of personal data.

The ‘controller’ is a natural person or an artificial person, a public body, a service or another organ which alone or together with others determines the aim and the means of a processing of personal data.

‘The person concerned’ in the points of interest below, refers mainly to the customer or the user.

 

2. Which data do we collect? 

Personal data which Panama mainly collects are personal data that is necessary in order to provide a correctly execution of our services. Actually, these include (without restriction):

• We collect your name, date and place of birth, qualifications and contact details such as your address, e-mail, telephone number, gsm number, fax number, function, preferred language and all further information that you have given us by your Curriculum Vitae.
• We can also collect information that has been made public, or when you have exposed them on public/social media and from this it would be clear that you would be the right person as part of our services.
• When you contact us, we sometimes collect that conversation.
• When we employ you, we often save feedback and evaluations about you and third parties with whom you’ve been working or are working with. If you give feedback to others, we’ll often save this too.
• We can also collect information about your use of our systems such as (without any restriction) your IP address, browser, and other communication data and the means you’re using. Because of this information it will be easier to use our systems in the future.
• We also save data that we receive by third parties or out of contracts, contact forms, payment regulations, commands and so on.
• Concerning the employees of Panama, we save:

• Your nationality, a copy of your identity documents, address and if necessary copies of documents which make clear that you can work on locations where you will be employed. (visa, work permit, et cetera.)
• Information about your salary and your bank account, your Citizen Service Number, your group of tax rate, your fiscal number, deductions and eventual preconditions.
• Registrations of attendances and absences, time spend on tasks, training, promotions, researches and disciplinary affairs.
• Details about persons on your account and your near relatives (family members and close family)
• Travel information (travel data, credit card information, passport number, made costs) for the negotiation about the regulation and acquisition of all travel related affairs (such as: flight tickets, train-, hotel-, & car rent reservations) and the remuneration of travelling costs.

• For professional customers, deliverers, or companies with whom we (could) start a collaboration, we keep next to the information above also
  • Corporate data such as the VAT number and company number
  • The co-ordinates of the contact person of the judicial entity (name, function, telephone) as well as the associates and the partners in the company.

3. Why do we collect this information?

Panama collects and processes this personal data in order to complete the objectives below. Your data will not be used for other purposes without you knowing in advance and if so asking your permission.

1. To give you information about the services and other activities of Panama and in order to better fine-tune on your needs and wishes or those of your company or organisation.
2. To head to a business affair with you or your company or organisation.
3. In order to proactive propose apt candidates and profile descriptions and eventually organise job interviews.
4. To close the agreement with us in a right way and to answer to your requests and questions when you contact us. In this way we can for example send you a digital invoice or an employment contract, communicate in a proper way or send a package to the right address.
5. To invite you for events, newsletters and promo actions. You can always deregister yourself of future marketing communications.
6. To meet our judicial and fiscal obligations
7. With the start of your work at Panama
   • To comply with the employment contract
   • To execute the other HR-activities (such as task gesture, presence and absence gesture, gesture of formations and people management, cost gesture and disciplinary procedures)
   • To keep a close watch on the respecting and complying with the intern policy and procedures.
   • To research and react on incidents and complaints.
8. In order to give you the possibility to fulfill your rights and afterwards can show that we have given consequence to these rights.
9. When you no longer want to receive any of our news letters or information about our services, you can at any moment, without motivation deregister. You can do this by sending us an e-mail or by clicking on the link of deregistration in the publication e-mails.

4. On the base of which foundation do we process your data?

When you work with Panama, the processing of personal data for all named aims is based on foundations such as the (pre)contractual relations and all the thereon allied judicial obligations. When we conclude or negotiate an agreement with you or your company or organisation we need certain information of you or the persons concerned in order to deliver and negotiate a suitable offer and to prepare and execute that agreement properly.

In case you don’t want your personal data to be processed, it is not possible for us to head to or execute a service. Within the execution of an agreement for recruitment and selection we will communicate the contact details to our candidates (of your company or the persons indicated) in order so they could be able to know to whom they will need to turn when they present themselves or when they start or execute their job.

We process your personal data only on the base of other foundations when you agree on it (another foundation). For example, when you assign for the receiving of marketing communication and news by e-mails.

 

5. Terms 

• Term of storage

Panama storages your personal data as long as it’s necessary for the execution of our aims and the observance of our judicial obligations.

• Term to comply with a demand

Every person concerned has the right to reassign its agreement, to stay informed about the objectives of how its data is processed, to adapt its data, transfer or remove the data or to have a look into the data. If an employee is confronted with one of the demands mentioned above by a person concerned, we will as fast as possible comply with this demand. Furthermore, this demand will be answered within a period of 1 month.

 

6. Data transferred to a third party 

Only if necessary for the execution of the objectives above as the existing agreement between us or for the complying with the judicial obligation, Panama can transfer your personal data to a third party. If we do this, we will have a contract with the processors so that your data will be handled with confidence and in a safe way. In this way the processor will never use your data on one’s own end and your data will need to be removed as soon as the processor had completed the assignment.

• To our suppliers

We can for example hire a supplier to execute administrative and operational activities to help with the agreement. Between the supplier and Panama there will always be a processing agreement closed. The supplier(s) are obligated to respect the contractual and other judicial obligations going about your data and your privacy. Those only have access to the data which are necessary for the execution of their activities.

• To our customers/ possible employers

We distribute your data with customers who offer jobs/ activities in which you can be interested or who think your profile is interesting. They’re obligated to follow the obligations concerning your contract and secrecy with regard to your data, as well as to us as you.

• We can distribute your data with the government, the police, supervisors or maintenances of law and order.

If Panama in a discretionary way, believes that they’re judicial obligatory, or they have the right to this or by means of caution.

• In no possible way will Panama sell or rent your data to other companies or persons who don’t belong to Panama.

 

7. Protection of your data        

The personal data has to be protected from access by unauthorized persons, lost or destruction. Panama assures a confidential processing of the personal details. The employee assures that the data that he will come in contact with will be saved and processed in a secure way. The employees do this by means of physique, administrative and technologic measures:

• Secured storage of information

All personal data is gestured by Panama. This data can be transferred within the entities of Panama. Within Panama the data is only accessible for the responsible persons who need to have access in order to execute their tasks.

The employees make sure that the data is saved in a safe way. When the employee obtains data, this will be saved on Nomadesk, which is secured with a password.  We can however not garuantee that there might ever in time be an unauthorised access.

• Cookies and SSL-certificate

Panama collects data when you visit a website of Panama or click on an e-mail. This happens because of the cookies. Cookies are little files of text which are automatically punt on your webpage on the computer from you as a visitor.

For more information about the use of cookies, you can read the cookie policy.
You can disable the cookies via the settings of your web browser, but it might be possible that because of this the website doesn’t operate correctly anymore. Our website is also secured with an SSL-certificate. In this way the website is protected against pirates who want to collect sensible information.

• Check-list

Every quarter the responsible will read over a check-list with every employee. In this way there will be seen on a regular base if the taken measures still comply with the requirements of the GDPR.

8. Your rights? 

GDPR has the aim to give the citizens control of their personal data and contains therefore a number of obligations focused on the protection of the rights of the individual:

• Approval

You have the right to give your approval for processing and transferring your data. You also have the right to withdraw this approval.

• Information

You have the right to be informed about the objectives what your data is collected and processed for and who has access to your data.

• Access & Rectification

You have the right to have access about which personal information is registered and to adjust or complete it when some of the information is wrong.

• The right to be forgotten

You have the right to ask us to stop processing your data (or restrict) or to delete the data entirely or partially.

• Right of objection

You have the right to lodge an objection against the processing of your personal data by Panama.

• Data portability

You have the right to receive the information that has been processed and saved in a portable and readable format or to let it transfer to another controller.

Panama who collects your data, is responsible for this data. Panama will warn you if the protection of this data is not respected or in case of lost.

If you’re worried about the way which your data is processed, you can firstly contact Panama. Secondly you can make an appeal to the Commission for protection of private life: Rue de la Presse 35, 1000 Brussel, Tel 02 274 48 00 or commissie@privacycommission.be

To execute these rights, you need to direct a clear demand to Panama in which is clearly mentioned what you desire to know, to correct or to remove your data. This demand has to be signed and dated and has to include a copy of your identity card. If you want us to remove the data, you also need to motivate this specifically. Unfortunately, Panama can’t assist you with the execution of your rights towards the personal data which Panama isn’t responsible for. When you’ve coped with all the conditions, Panama will as fast as possible comply with your demand and contact you about it.

If you have any further questions or remarks about this Privacy Declaration or you need more information about how we are protecting your personal data, send us an e-mail to info@panamagroup.be.

For diverse reasons Panama can improve, complete, or modify this Privacy Declaration. The most actual version can always be consulted on our websites.

(Version 28 May 2018)