Privacy Notice – Renaissance Current and former Employee, Contractor and Dependents
This Privacy Notice sets out the personal data Renaissance Africa Energy Company Limited (‘Renaissance’ or ‘we’) collects from individuals who are employees, former employees, interns or individual contractors as well as dependents (‘Renaissance Staff’), the purposes as well as the rights of the Renaissance Staff.
What does this Privacy Notice cover?
This Privacy Notice provides information about personal data of Renaissance Staff processed by Renaissance.
Every individual in Renaissance is responsible for protecting personal data of their colleagues and that of our customers, business partners and suppliers.
For individuals who apply to work for Renaissance, or who attend a recruitment event or undertake an assessment with Renaissance, please refer to the Privacy Notice – Job applicant @ https://renaissanceafrica.com/data-privacy-notice-job-applicants/.
As well as this Privacy Notice, bespoke privacy notices and supplementary privacy statements may contain further information about how we process your personal data in relation to specific HR processes (such as Open Resourcing, Secondment and International Mobility programs). In those instances, such privacy notices will be communicated to you separately.
This Privacy Notice explains what personal data are processed about you, why Renaissance are processing your personal data and for which purposes, how long we hold your personal data for, how to access and update your personal data, as well as the options you have regarding your personal data and where to go for further information.
What personal data do we process about you? Collection of information
We process personal data necessary to manage the employment relationship, to engage contractors and interns and to provide benefits to certain dependents of Renaissance employees.
This includes personal home contact information, date of birth, marital status, payroll and bank account information, wage and benefit information including beneficiary information, emergency contacts, work performance information, information required to ensure you have the right to work in the country you are engaged in, as well as any other information necessary for managing the employment relationship, for engaging contractors and for providing benefits to certain dependents of Renaissance employees (such as those dependents who accompany a Renaissance employee while on an assignment outside the base country).
Sensitive personal data
We also process some special categories of personal data (’sensitive personal data’) such as data relating to an individual’s health, their racial or ethnic origin, religious or philosophical beliefs, sexual orientation, political opinions and trade union membership. We will only process such personal data where it is necessary for the purposes of complying with employment and social security laws, for the establishment, exercise or defence of claims or where necessary for the purposes of providing occupational medical advice and support, to protect the vital interests of an individual (such as in an emergency), where necessary for reasons of public health or where the individual has provided their explicit consent.
We will only process your personal data where we have a legal basis to do so.
Why do we process your personal data?
We process your personal data:
- in order to satisfy our obligations to comply with extant laws and regulations;
- for legitimate business interests (for example performance management in order to ensure we have qualified and competent personnel or for health, safety and security purposes to ensure that only authorised personnel can access certain sites or assets, litigation and defence of claims); or
- where we have your explicit consent.
Please note that as a general principle, Renaissance does not seek or rely on the consent of Renaissance Staff for processing personal data. However, there are limited circumstances when consent is required, such as if required by applicable law.
Personal data requested from Renaissance Staff are the minimum required in order to fulfil legal and/or contractual requirements and to provide opportunities to take part in programs or to provide a benefit. Failure to provide us with the information requested may negatively affect your ability to remain in employment, internship or engagement as a contractor or from participating in a program or receiving a benefit.
In those cases where processing is based on consent, you have the right to withdraw your consent at any time. This will not affect the validity of the processing prior to the withdrawal of consent. Withdrawal of consent may however impact your ability to remain employed or otherwise engaged or from participating in a program or receiving a benefit.
For what purposes do we process your personal data?
We process personal data covered by this Privacy Notice for the following purposes:
- Human Resources, personnel management, business process execution, internal management, management reporting, organisational analysis and development – including budgetary, financial and organisational planning, administration, compensation, performance management;
- Health, safety and security – including protection of Renaissance Staff’s life or health, occupational health and safety, protection of Renaissance assets and authentication of Renaissance Staff status and access rights; or
- Legal and/or regulatory compliance – including compliance with legal or regulatory requirements.
We may also process your personal data for a secondary purpose where it is closely related, such as:
- storing, deleting or anonymising your personal data;
- fraud prevention, audits, investigations, dispute resolution or insurance purposes, litigation and defence of claims; or
- statistical, historical or scientific research.
Monitoring
All activities on Renaissance IT equipment and/or when connected to the Renaissance IT network may be monitored for legitimate business purposes.
All Renaissance Staff receive an access badge which allows Renaissance to record the date, time and access points made by individuals within Renaissance premises and assets. The data from the access and security systems are used:
- for health, safety and security purposes, to prevent fraud and specifically the protection of Renaissance assets, Renaissance Staff and visitors to Renaissance premises;
- to comply with legal and regulatory requirements, specifically where there is a legal requirement to provide information to government/regulatory authorities;
- to monitor (on an aggregated basis) the number of individuals entering and working in a Renaissance premise for human resources and real estate planning; and
- in the case of contractors only (not Renaissance employees) the date and time of their entry and exit of Renaissance premises is used for the purposes of financial management and control.
Most of our premises and assets are equipped with surveillance cameras (CCTV). Where surveillance cameras are used, they will be identified. Surveillance cameras are used for health, safety and security specifically the protection of Renaissance assets, Renaissance staff and visitors to Renaissance premises. All images are routinely deleted unless there has been a health, safety or security incident, suspected or actual criminal activity, in which case they may be viewed by internal Renaissance investigation teams and externally if legally required or permitted by law enforcement or other government authority.
Screening
In order to comply with legal and regulatory obligations, to protect Renaissance’s assets and employees/contractors and specifically to ensure that Renaissance can comply with trade control, anti-money laundering and/or bribery and corruption laws, economic sanctions and other regulatory requirements, we carry out screening on all employees and contractors on a periodic basis. This screening takes place against publicly available, or government issued sanctions lists and is compared with information held about you by Renaissance (for example from the Conflict of Interest register).
Any personal data collected through the screening will not involve profiling or automated decision making regarding suitability for continued employment, internship or engagement as a contractor.
Who is responsible for any personal data collected?
The Renaissance Africa Energy Company Limited, Renaissance Industrial Area, Port Harcourt, Rivers State, Nigeria, will be responsible for processing your personal data, either solely or jointly with its affiliates, associates and partners.
In the case of individual contractors, the company within the Renaissance Group that has contracted your services solely or jointly with its affiliates, associates and partners and your external contracting/employing company/agency.
Who will we share the personal data with?
Your personal data are exclusively processed for the purposes referred to above and will only be shared on a strict need to know basis with:
- Other companies within Renaissance Group including affiliates, associates and partners which may be located outside of your location;
- Authorized third party agents, service providers, external auditors and/or subcontractors of Renaissance; and
- A competent public authority, government, regulatory or fiscal agency where it is necessary to comply with a legal or regulatory obligation to which the relevant Renaissance company/companies is subject to or as permitted by applicable law; or
- Any person to whom Renaissance proposes to transfer any of its rights and/or duties.
Your personal data may be transferred outside of your country, subject to appropriate safeguards.
Transfers of your personal data to other countries
Where your personal data have been transferred to companies within Renaissance Group, affiliates, associates and partners and/or to authorized third parties located outside of your country we take organizational, contractual and legal measures to ensure that your personal data are exclusively processed for the purposes mentioned above and that adequate levels of protection have been implemented in order to safeguard your personal data. These measures include the Renaissance approved transfer mechanisms for transfers to third parties as well as any additional local legal requirements.
Renaissance is committed to safeguarding your personal data.
Security of your personal data
We have implemented technology and policies with the objective of protecting your privacy from unauthorised access and improper use and will update these measures as new technology becomes available, as appropriate.
Renaissance only holds your personal data for a defined period of time.
How long do we hold your personal data for?
All information, including personal data, is managed in line with the Renaissance standards for Information and Records Management and securely deleted once no longer required for a legitimate business purpose or for a legal/regulatory purpose.
With some exceptions required to comply with local legal requirements:
- information contained within personnel files is held for no longer than 10 years once your employment has terminated;
- information relating to retirement benefits are held for no longer than 99 years from the commencement of employment;
- any personal data gathered as part of the screening against publicly available or government issued sanctions lists and media sources are held for no longer than 15 years after they were first gathered;
- the names, date, time and access points for all individuals entering Renaissance premises are held for 3 years from each access;
- where an individual has been dismissed or had their contract terminated due to serious misconduct, including breaching the Renaissance Life Saving Rules or breaching the Renaissance Code of Conduct, that information is held for up to 30 years post termination.
In all cases information may be held for (a) a longer period of time where there is a legal or regulatory reason to do so (in which case it will be deleted once no longer required for the legal or regulatory purpose) or (b) a shorter period where you object to the processing of the personal data and there is no longer a legitimate business purpose to retain it.
Your rights in relation to your personal data
We aim to keep our information about you as accurate as possible. You can request:
- access to your personal data;
- correction or deletion of your personal data (but only where they are no longer required for a legitimate business purpose);
- that the processing of your personal data is restricted; and/or
- that you receive personal data that you have provided to Renaissance, in a structured, digital form to be transmitted to another party, if this is technically feasible.
For those individuals who have access to Success Factor, you can access your personal data through: SuccessFactors: Home
Alternatively, please contact your HR adviser. If you are a contractor, you should speak with your external contracting/employing company/agency. For former employees or dependents, please contact dpo@renaissanceafrica.com
Who can you contact if you have a query, concern or compliant about your personal data?
If you have any issues, queries or complaints regarding the processing of your personal data please contact dpo@renaissanceafrica.com
If you are unsatisfied with the handling of your personal data by Renaissance, then you have the right to lodge a complaint to the Nigeria Data Protection Commission (NDPC), whose address is No.12 DR Clement Isong Street, Abuja.. Please visit https://ndpc.gov.ng/ for more information.
Changes to this Privacy Notice
This Privacy Notice may be changed over time. You are advised to regularly review this Privacy Notice for possible changes.