Last updated: August 2023
Averna Global Privacy Policy for Employees & External Contractors
As your employer, Averna is committed to protecting the privacy and security of your Personal Data during and after your employment. This Privacy Policy (“Policy”) describes the Personal Data that Averna collects about you as an employee or external worker, our privacy practices, and how you can contact us to exercise your privacy rights and choices. If you are a candidate for employment, please refer to our Candidate Privacy Policy.
We will only use your personal data in accordance with this Policy, unless otherwise required by applicable law. We are committed to ensuring that the Personal Data we collect about you is accurate, relevant, and used for limited purposes.
Averna reserves the right to update this Policy at any time and as necessary. We encourage you to review this Policy periodically.
- Definitions
“Averna”, “employer”, “we”, “our” or “us’’ means the Averna entity responsible for the collection and use of Personal Data under this Privacy Policy. The entity differs depending on your jurisdiction of employment.
“Personal Data” means any information about you as an individual. It excludes anonymous or de-identified data that is not associated with a particular individual, as well as business contact details and job title. As your employer, we may collect, store, and use the identified categories of Personal Data in Appendix A.
Depending on your relationship with Averna, “you” means “Employee” or “External worker”:
- “Employee” encompasses current and former employees of Averna.
- “External Worker” refers to workers who are not employed by Averna, but who have access to Averna’s facilities and/or its corporate network. It includes agency temporary workers, outsourced staff, contractors, and business guests.
2. Collection and Use of Personal Data
The nature of the Personal Data we process about you in the operation of our business and the purpose for its collection may change depending on your jurisdiction and your employment relationship with Averna.
If you are an Employee, your Personal Data is collected and used towards the fulfilment of your employment contract with Averna. Examples include, but are not limited to, managing your payroll and social benefits, providing you with training, and to assess your professional development. We may also process Personal Data about your dependents, beneficiaries, and other individuals associated with your employment, as required for the provision of health and insurance benefits, and other related purposes.
Averna may use Employee’s photos in marketing material including social media, company websites, and other graphic media during the employment relationship.
If you are a former Employee, Personal Data about you is processed mainly for legal compliance purposes.
If you are an External Worker, the Personal Data we process about you is limited to what is needed to manage your relationship with Averna (payment of your invoices for example), as well as your access to our facilities and information systems.
Averna will only process your Personal Data for the purposes it was collected for, or to comply with the legal obligations that apply to us as your employer. If Averna needs to process your Personal Data for a purpose that is not related to your employment with us, you will be notified, and, if required by law, we will seek your consent before proceeding. We will use your personal information without your knowledge or consent only where required by applicable law.
3. Sharing and Disclosure of Personal Data
Averna will only disclose your Personal Data to third parties in accordance with this Policy.
Averna may disclose your Personal Data to contractors, designated agents, third-party service providers, or other employees of Averna located outside of your jurisdiction that assist us in the fulfilment of your employment contract with us. For the purposes of this Policy, third-party service providers include, but are not limited to, payroll processors, pension administrators, mobility providers for work permits/visas, tax specialists, and benefits providers.
To protect your Personal Data during these transfers, Averna requires, through written contracts with our third-party service providers, the implementation of satisfactory security measures to ensure data privacy. We do not permit our third-party service providers to use your Personal Data other than for purposes or instructions explicitly given by Averna.
Averna may also disclose your Personal Data for the following additional purposes, where permitted or required by applicable law:
- Compliance with legal obligations or valid legal processes, such as judicial proceedings and court orders.
- Response to regulatory bodies.
- To seek advice from external lawyers, auditors, or other professionals.
- Safety and security purposes.
- Where it is in our legitimate interest to do so, such as to a potential buyer of Averna or to government-related agencies.
- For other purposes with your consent, where such consent is required by law.
In all cases, Averna ensures that reasonable steps are taken to limit disclosure of your Personal Data to the minimum necessary for applicable purposes and circumstances.
4. Cross-Border and International Data Transfers
Averna operates globally. Therefore, your Personal Data may be transferred to countries other than your own, outside of the country where your Personal Data was originally collected. These countries may have data protection requirements that are different from your country. When transferring your Personal Data across borders, Averna takes appropriate measures to comply with data privacy laws applicable to such transfers.
5. Data Security and Retention
Averna makes reasonable efforts to provide a level of security appropriate to the risk associated with the processing of your Personal Data. We maintain appropriate physical, technical, and organizational security measures designed to protect the Personal Data covered by this Policy against accidental loss and unauthorized access, use, alteration, or disclosure. Additionally, Averna ensures that access to your Personal Data is limited to employees, agents, contractors, and third parties that have a legitimate business need for such access.
Averna does not carry out profiling activities and does not make decisions regarding you by automated means.
To help us protect your Personal Data, we encourage you to keep your local Averna entity informed about changes to your Personal Data throughout your employment with us. We also encourage you to follow the recommendations laid out in our IT policy to preserve password security and to ensure that your interactions with Averna services remain secure.
Except as otherwise permitted or required by law, Averna will only retain your Personal Data for as long as necessary to fulfill collection purposes, including:
- to comply with our accounting or reporting requirements.
- to enable fraud monitoring, detection, and loss prevention activities.
- to comply with our legal obligations.
Under certain circumstances, your Personal Data may be anonymized, in which case it will no longer be associated with you. Averna reserves the right to use such anonymous and de-identified data for any legitimate business purposes without further notice to you or your consent.
Upon the termination of your employment relationship with us, your Personal Data will be retained and securely destroyed by Averna in accordance with this Policy and applicable laws.
6. Additional Data Privacy Rights
- You have the right to request access to the Personal Data that Averna collects, uses, or transfers about you, and the right to object collection or processing of your Personal Data, or request that it be restricted.
- Where you have provided your consent to the collection, use, and transfer of your Personal Data, you have the right to withdraw such consent, or any consent previously given to Averna.
- You have the right to request that Averna rectify or erase your Personal Data that is inaccurate, incomplete, or outdated.
- You have the right to data portability.
- You further have the right to request that the processing of your Personal Data be restricted. At any time, you have the right to lodge a complaint regarding the collection and use of your Personal Data by Averna.
To exercise your privacy rights, you may contact our Global Data Protection Officer (DPO) by e-mail at privacy@averna.com.
We may request specific information from you to help us confirm your identity and our ability to make your requested changes. Where your Personal Data has been destroyed, erased, or anonymized, or where we are required by law to refuse you access to your Personal Data held by Averna, you will be informed of the reasons why, subject to any legal or regulatory restrictions. At any time, you may contact our DPO for information about our retention obligations and practices.
7. Data Protection Officer
Averna has appointed a Global Data Protection Officer to ensure compliance with this Policy.
Global Data Protection Officer: Rania Hamdine (privacy@averna.com)
Appendix A
For the purposes of this Policy and depending on your jurisdiction of employment, Averna may collect the following categories of Personal Data about you:
- Personal contact details, such as name, title, address, telephone number, employment location, and email address.
- Identification details, such as gender identity, date of birth, nationality, citizenship, veteran, minority, or disability status, and home and emergency contact information.
- Photographs taken during social and company events.
- Insurance and pension enrollment, as well as maintenance information, including marital status, spouse and dependent names, addresses, and birthdates.
- Job application and background check information, including resumes, references and academic records, training, criminal records, and credit and work history.
- Mobility-related information, such as passport information, work permit information, driving records and driver’s license information.
- Compensation information, including bank account details, social security/insurance number (or the equivalent), wage, benefits, and performance history.
- Trade union membership as may be applicable.
- Employment records, including leaves of absences, accommodation needs, professional memberships, references, work history, and proof of work eligibility.
- Photographs or videos.
- Any other employee personal data necessary for the purposes of managing your employment relationship with Averna.
