Employee Privacy Policy

Employee Privacy Policy

Introduction

At VTS we are committed to maintaining the accuracy, confidentiality and security of your personal information. This Employee Privacy Policy describes the personal information that VTS collects from or about you, and how we use and to whom we disclose that information.

Application

VTS has adopted a series of Privacy Policies in order to address the specific privacy concerns of certain groupings of individuals and specific issues relating to the use of our website. This Employee Privacy Policy applies to the personal information of all individuals who seek to be, are, or were employed by VTS (collectively, an “employee”), unless the personal information is collected, used or disclosed while using the VTS website.  This personal information is dealt with in the VTS Website Privacy Policy.
 
If you are unsure of which Privacy Policy applies to you, please contact privacy@vts.com for more information.

Organizations Covered by this Policy

The VTS family (“VTS Family”) includes the parent company, View the Space, Inc. and its affiliated entities.

All references in this Employee Privacy Policy to “VTS”, “we”, “us”, “our” and like terms should be interpreted accordingly.

Policy of Compliance

It is VTS’s policy to comply with the privacy legislation within each jurisdiction in which we operate.  Sometimes the privacy legislation and / or an individual’s right to privacy are different from one jurisdiction to another.  This Employee Privacy Policy was developed to guide the activities of VTS. In addition, specific privacy practices may be adopted to address the specific privacy requirements of particular jurisdictions.

This Employee Privacy Policy has a limited scope and application and the rights and obligations contained in this Employee Privacy Policy may not be available to all individuals or in all jurisdictions. If you are unsure if or how this Employee Privacy Policy applies to you, please contact privacy@vts.com for more information.

What is Personal Information?

For the purposes of this Employee Privacy Policy, personal information is any information about an identifiable individual, other than the person’s business title or business contact information when used or disclosed for the purpose of business communications. Personal information does not include anonymous or non-personal information (i.e., information that cannot be associated with or tracked back to a specific individual).

What Personal Information Do We Collect?

We collect and maintain different types of personal information in respect of those individuals who seek to be, are, or were employed by us, including the personal information contained in resumes and/or applications;

  • – references and interview notes;
  • – photographs and video;
  • – letters of offer and acceptance of employment;
  • – mandatory policy acknowledgement sign-off sheets;
  • – payroll information; including but not limited to social security number and pay check deposit information;
  • – wage and benefit information;
  • – forms relating to the application for, or in respect of changes to, employee health benefits; including, short and long term disability, medical and dental care; and
  • – beneficiary and emergency contact information.

In addition to the examples listed above, personal information also includes information such as name, home address, telephone, personal email address, date of birth, employee identification number and marital status, and any other information necessary to VTS’s business purposes, which is voluntarily disclosed in the course of an employee’s application for and employment with VTS.

As a general rule, VTS collects personal information directly from you.  In most circumstances where the personal information that we collect about you is held by a third party, we will obtain your permission before we seek out this information from such sources (such permission may be given directly by you, or implied from your actions).

From time to time, we may utilize the services of third parties (including other members of the VTS Family) in our business and may also receive personal information collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.
 
Where permitted or required by applicable law or regulatory requirements, we may collect information about you without your knowledge or consent.

Why Do We Collect Personal Information?

The personal information collected is used and disclosed for our business purposes, including establishing, managing or terminating your employment relationship with VTS. Such uses include:

  • – determining eligibility for initial employment, including the verification of references and qualifications;
  • – administering pay and benefits;
  • – processing employee work-related claims (e.g. worker compensation, insurance claims, etc.)
  • – establishing training and/or development requirements;
  • – conducting performance reviews and determining performance requirements;
  • – assessing qualifications for a particular job or task;
  • – gathering evidence for disciplinary action, or termination;
  • – establishing a contact point in the event of an emergency (such as next of kin);
  • – complying with applicable labor or employment statutes;
  • – compiling directories;
  • – ensuring the security of company-held information; and
  • – such other purposes as are reasonably required by VTS.

Monitoring

The work output of VTS’s employees, whether in paper record, computer files, or in any other storage format belongs to us, and that work output, and the tools used to generate that work output, are always subject to review and monitoring by VTS.

In the course of conducting our business, we may monitor employee activities and our premises and property. Pursuant to our VTS Acceptable Use Policy, we have the capability to monitor all employees’ computer and e-mail use.

This section is not meant to suggest that all employees will in fact be monitored or their actions subject to constant surveillance. We have no duty to so monitor. It is meant to bring to your attention the fact that such monitoring may occur and may result in the collection of personal information from employees (e.g. through their use of our resources).  When using VTS equipment or resources employees should not have any expectation of privacy with respect to their use of such equipment or resources.

How Do We Use Your Personal Information?

We may use your personal information:

  • – for the purposes described in this Employee Privacy Policy; or
  • – for any additional purposes that we advise you of and where your consent is required by law we have obtained your consent in respect of the use or disclosure of your personal information.

We may use your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.

When Do We Disclose Your Personal Information?

We may share your personal information with our employees, contractors, consultants and other parties (including other members of the VTS Family) who require such information to assist us with establishing, managing or terminating our employment relationship with you, including: parties that provide products or services to us or on our behalf and parties that collaborate with us in the provision of products or services to you.  In some instances, such parties may also provide certain information technology and data processing services to us so that we may operate our business. We may share personal information with such parties both in and outside of your home jurisdiction, and as result, your personal information may be collected, used, processed, stored or disclosed in the United States of America, and in some cases, other countries.  Personal information is only transferred by us to another country, including within the VTS Family, if this is required or permitted under the applicable privacy legislation, in particular only in as far as a reasonable level of data protection is assured in the recipient country.

When we share personal information with such parties we typically require that they only use or disclose such personal information in a manner consistent with the use and disclosure provisions of this Employee Privacy Policy.

In addition, personal information may be disclosed or transferred to another party (including to another member of the VTS Family outside of your home jurisdiction) in the event of a change in ownership of, or a grant of a security interest in, all or a part of VTS through, for example, an asset or share sale, or some other form of business combination, merger or joint venture, provided that such party is bound by appropriate agreements or obligations and required to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this Employee Privacy Policy, unless you consent otherwise.

Further, your personal information may be disclosed:

  • – as permitted or required by applicable law or regulatory requirements.  In such a case, we will endeavor to not disclose more personal information than is required under the circumstances;
  • – to comply with valid legal processes such as search warrants, subpoenas or court orders;
  • – as part of VTS’s regular reporting activities to other members of the VTS Family (including outside of your home jurisdiction);
  • – to protect the rights and property of VTS;
  • – during emergency situations or where necessary to protect the safety of a person or group of persons;
  • – where the personal information is publicly available; or
  • – with your consent where such consent is required by law.

Notification and Consent

Privacy laws do not generally require VTS to obtain your consent for the collection, use or disclosure of personal information for the purpose of establishing, managing or terminating your employment relationship.  In addition, we may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.

To the extent that your consent is required, we will assume, unless you advise us otherwise, that you have consented to VTS collecting, using and disclosing your personal information for the purposes stated above (including any other purposes stated or reasonably implied at the time such personal information was provided to us).

Where your consent was required for our collection, use or disclosure of your personal information, you may, at any time, subject to legal or contractual restrictions and reasonable notice, withdraw your consent.  All communications with respect to such withdrawal or variation of consent should be in writing and addressed to privacy@vts.com.

How is Your Personal Information Protected?

VTS endeavors to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to protect your personal information from loss and unauthorized access, copying, use, modification or disclosure.

How Long is Your Personal Information Retained?

Except as otherwise permitted or required by applicable law or regulatory requirements, VTS endeavors to retain your personal information only for as long as it believes is necessary to fulfill the purposes for which the personal information was collected (including, for the purpose of meeting any legal, accounting or other reporting requirements or obligations). We may, instead of destroying or erasing your personal information, make it anonymous such that it cannot be associated with or tracked back to you.

Updating Your Personal Information

It is important that the information contained in our records is both accurate and current.  If your personal information happens to change during the course of your employment, please keep us informed of such changes.

In some circumstances we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.

Access to Your Personal Information

You can ask to see the personal information that we hold about you.  If you want to review, verify or correct your personal information, please contact privacy@vts.com. Please note that any such communication must be in writing.

When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. We may charge you a fee to access your personal information; however, we will advise you of any fee in advance.  If you require assistance in preparing your request, please contact privacy@vts.com.

Your right to access the personal information that we hold about you is not absolute.  There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.

In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.

Privacy Shield Principles

VTS complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States.  VTS has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms in this Employee Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

For further information regarding:

  • – the type or identity of third parties to which VTS discloses personal information, and the purposes for which it does so;
  • – your right to access your personal data;
  • – the choices and means VTS offers you for limiting the use and disclosure of your personal data;
  • – VTS being subject to the investigatory and enforcement powers of the Federal Trade Commission;
  • – the possibility, under certain conditions, for you to invoke binding arbitration;
  • – the requirement for VTS to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements; and
  • – VTS’s liability in cases of onward transfers to third parties;

Please refer to VTS’s Privacy Shield Policy located at http://www.vts.com/privacy-shield-policy.

In compliance with the Privacy Shield Principles, VTS commits to resolve complaints about our collection or use of your personal information.  EU individuals with inquiries or complaints regarding our Employee Privacy Policy should first contact VTS at privacy@vts.com

VTS has further committed to cooperate with EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU in the context of the employment relationship.  If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU DPAs for more information or to file a complaint.  The services of EU DPAs are provided at no cost to you.

Inquiries or Concerns?

If you have any questions about this Employee Privacy Policy or concerns about how we manage your personal information, please contact privacy@vts.com.  We will endeavor to answer your questions and advise you of any steps taken to address the issues raised by you.

Revisions to this Privacy Policy

VTS may from time to time make changes to this Employee Privacy Policy to reflect changes in its legal or regulatory obligations or in the manner in which we deal with your personal information.  We will communicate any revised version of this Employee Privacy Policy.  Any changes to this Employee Privacy Policy will be effective from the time they are communicated, provided that any change that relates to why we collect, use or disclose your personal information will not apply to you, where your consent is required to such collection, use or disclosure, until we have obtained your consent to such change.  This Employee Privacy Policy was last reviewed on February 21, 2017.

Interpretation of this Privacy Policy

Any interpretation associated with this Employee Privacy Policy will be made by VTS.  This Employee Privacy Policy includes examples but is not intended to be restricted in its application to such examples, therefore where the word ‘including’ is used, it shall mean ‘including without limitation.

This Employee Privacy Policy does not create or confer upon any individual any rights, or impose upon VTS any rights or obligations outside of, or in addition to, any rights or obligations imposed by the privacy laws applicable to such individual’s personal information. Should there be, in a specific case, any inconsistency between this Employee Privacy Policy and such privacy laws, this Employee Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.

 

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