PRIVACY NOTICE FOR EMPLOYEES

We at SoftGroup AD (we, SoftGroup) understand the importance of the confidentiality and protection of your personal data and are committed to processing this personal data in compliance with the applicable legal requirements and established standards and principles.

As your employer, we collect your personal data as follows:

1.Identity card data – three names, personal identification number, address and identity card number. We use this data for the purpose of managing human resources and for the performance of the employment contract concluded between us and of our obligations as an employer imposed by the legislation, including for declaring data on the employment relationship to state authorities such as the National Revenue Agency (NRA), the National Social Security Institute (NSSI), the Labor Inspectorate and the National Employment Agency. We keep this data until the termination of the company in view of our legal obligations to provide information to the NSSI.

2.Personal and work phone number and e-mail address for contact – we use your work phone numbers and e-mail only for business contact with you until the termination of the employment relationship and then until the completion of current tasks and fulfilment of obligations. Personal phone numbers are only used in exceptional cases where we need to contact you urgently on a business matter and we cannot reach you on your work phone. We do not exclude the possibility that even after your employment with us is terminated, your personal phone numbers that you have given to your colleagues will continue to be kept from them for the purpose of personal contacts with you, but this is not something that we can control.

3.Amount of remuneration – we store your remuneration data for the purpose of managing human resources and fulfilling legal obligations to declare information to state authorities, as well as our obligations to pay salaries. The data are stored until the termination of the company’s activity and the handing over of the pay-roll books to the NSSI or until the expiry of the terms set in the Bulgarian legislation.

4.Bank details (IBAN) – we process the details of your bank accounts for the purpose of financial and accounting and the fulfilment of our obligations to pay salaries. The data is stored until termination of the employment relationship or until payment of all obligations under it.

5.Data on your health status (hospital records, documents from Work Capability Assessment Commission, card for preliminary medical examination/medical certificates for commencement of work, when required) – we process this data for the purpose of human resource management and for fulfilling our obligations under the labour law and social security (such as establishing the preconditions for using a leave due to sickness, pregnancy and childbirth or vocational rehabilitation), as well as to ensure healthy and safe working conditions. Data about your health condition is also processed in connection with the contract concluded by us for additional health insurance. We store the data only for the periods specified in the Bulgarian legislation (to date – for hospital records – 3 years from January 1 of the year following the year in which they were issued).

6.Data on acquired educational degree/s – we process data from your qualification or education diplomas to establish whether you meet the requirements for filling the relevant position. The data is stored until the termination of the employment relationship.

7.Data on acquired work experience – we store your labour book/s (with consent given in a signed declaration to store the labour book in the work records with the employer). We process data about your work experience to determine whether you meet the requirements for holding the relevant position, as well as to determine additional remuneration due under the applicable labour legislation. We store the data until termination of the employment relationship and/or until payment of all obligations under it.

8.Video surveillance data – to protect our legitimate interests for ensuring the security of the company’s premises and our employees and visitors, we collect video surveillance data of certain parts of the company’s offices (the entrance common part). We do not carry out individual video surveillance for the purpose of monitoring the work of each of you, although it is possible that parts of the workplaces you use may be covered by video surveillance equipment. Recordings are stored for no longer than 2 months after recording.

9.Your photos – we collect these data for the purpose of identifying you as our employee (by placing them in your internal business card in the company’s system, access card), and after termination of the employment relationship we delete them. With your consent, which is withdrawable at any time, we may use (including by placing on our website and company social media profiles) other photos of you, taken at company events (teambuilding , company parties and the like), as well as your photos for the company website or brochures. In using your photos, we will in no way allow damage to your dignity and honour.

We at SoftGroup do not use programs for automated processing of your personal data and decision-making, including for your profiling.

Third parties to whom we may provide your personal data

We can disclose and provide your personal data to the competent state authorities in accordance with the law and in cases where there is a corresponding obligation to provide them. Except for these cases, we may provide your personal data to third parties as follows:

1.Identity card data (e.g. three names and personal number where necessary) – (a) to airlines or other carriers and/or hotel service providers while sending you on business trips or other events in your capacity as our employees; (b) to service providers such as accountants, banks, additional health insurance, cards for sports services and occupational medicine, (c) to companies organizing company events and (d) to private bailiffs, for protecting the legitimate interests of SoftGroup, if compulsory collection of your debts is needed.

2.Names, telephone and e-mail address – to third parties, suppliers or customers of SoftGroup, for execution and management of contracts between the company and such third parties, when your work duties are related to this. We will under no circumstances provide your personal phone numbers to our customers and suppliers, but we cannot restrict you from doing so if you deem it necessary.

3.Remuneration amount, bank details (IBAN), health status data (hospital records, documents from Work Capability Assessment Commission – of accounting service providers for the purpose of human resources management and financial and accounting activities.

4.Health status data – of service providers such as occupational medicine service and additional health insurance.

5.Others – after notifying you and obtaining consent where applicable.

SoftGroup does not intend to provide your personal data to persons or organizations outside the territory of the European Union. If this becomes necessary in exceptional cases, we will notify you and take the necessary protective measures.

Your rights

According to the provisions of the General Data Protection Regulation (EU 2016/679) applicable from 25.05.2018, and subject to the prerequisites defined in the Regulation, you have the right:

• Right of access – you have the right to request a copy of the information we keep about you.
• Right to rectification – you have the right to request the rectification of data we keep about you that is inaccurate or incomplete.
• Right to erasure (“to be forgotten”) – in certain circumstances, you can request that the data we store about you be deleted from our records.
• Right to restriction of processing – if certain conditions apply, you have the right to request restriction of processing.
• Right to portability – you have the right to have the data we store about you transferred to you or to another organization, in cases where such data is processed automatically and based on your consent or contract.
• Right to withdraw consent – You have the right to withdraw your consent for personal data processing at any time, as easily as it was given. Effect of withdrawn consent going forward.
• Right to object – you have the right to object to certain types of processing, such as any processing of your personal data that is based on SoftGroup’s legitimate interests. In this case, we will cease the processing, unless there are compelling legitimate grounds for the processing that take precedence over your personal interests, rights and freedoms.
• Right to appeal – You have the right to appeal to a supervisory authority and to the court.

In case you have questions regarding the processing of your personal data or wish to exercise your respective rights, you can contact:

Mrs. Teodora Marcheva
Information security manager
Email: Teodora.Marcheva@softgroup.eu or office@softgroup.eu
Phone: 088 8715444 or 02 8799577

If you believe that we are processing your personal data illegally, you have the right to file a complaint with the Commission for Personal Data Protection (CPDP), address: Sofia 1592, Prof. Tsvetan Lazarov Blvd. No. 2, e-mail: kzld@cpdp.bg, website: www.cpdp.bg