PROTECTION POLICY AND THE PROCESSING OF PERSONAL DATA
1.1 this Policy concerning the processing of personal data (hereinafter – the Policy) is made in accordance with paragraph 2 of article 18.1 of the Federal law “On personal data” № 152-FZ of 27 July 2006, as well as other normative-legal acts of the Russian Federation in the field of protection and processing of personal data and applies to all personal data (hereinafter Data) of LLC “Mega Resource” (hereinafter – LLC “Mega Resource”, the Operator, the Company) may receive from the subject of personal data, which is a party to a civil contract, as well as from the subject of personal data, consisting with the Operator in the relations regulated by labor legislation (hereinafter – the Employee).
1.2 the Operator provides protection of the processed personal data from unauthorized access and disclosure, misuse or loss in accordance with the requirements of the Federal law of July 27, 2006 № 152-FZ “on personal data”.
1.3 Policy Changes
The operator has the right to make changes to this Policy. When changes are made, the Policy header indicates the date when the revision was last updated. The new version of the Policy shall enter into force upon its posting on the website, unless otherwise provided by the new version of the Policy.
Personal data (PD) – any information relating directly or indirectly to a specific or identifiable natural person (subject of personal data). Processing of personal data – any action (operation) or a set of actions (operations) performed using automation or without the use of such means with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data. Automated processing of personal data – processing of personal data by means of computer equipment. Information system of personal data (ISPD) – a set of personal data contained in databases and ensuring their processing of information technologies and technical means. Personal data made public by the subject of personal data-PD, access of an unlimited number of persons to which is provided by the subject of personal data or at his request. Blocking of personal data-temporary termination of processing of personal data (except for cases when processing is necessary to clarify personal data). Destruction of personal data – actions as a result of which it becomes impossible to restore the content of personal data in the information system of personal data and (or) as a result of which the material carriers of personal data are destroyed. Operator-an organization, independently or jointly with other persons, organizing the processing of personal data, as well as determining the purposes of processing of personal data to be processed, actions (operations) performed with personal data. The operator is OOO “Mega Resource”
3.1 obtaining PD.
3.1.1 all PD should be received from the subject. If the subject’s PD can only be obtained from a third party, the subject must be notified or consent must be obtained from the subject.
3.1.2 the Operator shall inform the subject of the objectives, intended sources and methods of obtaining PD, the nature of the PD to be obtained, the list of actions with PD, the period during which the consent is valid, and the procedure for its withdrawal, as well as the consequences of the subject’s refusal to give written consent to their receipt.
3.1.3 Documents containing PD are created by:
– copy of original documents (passport, education document, TIN certificate, pension certificate, etc.).);
– entering information into accounting forms;
– obtaining the originals of the necessary documents (employment record, medical report, characteristics, etc.).
3.2 the Treatment of PD.
3.2.1 Processing of personal data is carried out:
– with the consent of the personal data subject to the processing of his personal data;
– in cases where the processing of personal data is necessary for the implementation and performance of the functions, powers and duties assigned by the legislation of the Russian Federation;
– in cases where the processing of personal data is carried out, the access of an unlimited number of persons to which is provided by the subject of personal data or at his request (hereinafter – personal data made publicly available by the subject of personal data).
3.2.2 Purposes of personal data processing:
– implementation of labour relations;
– implementation of civil law relations.
3.2.3 Categories of personal data subjects.
PD of the following subjects of PD are processed:
– individuals with an Operator. in labour relations;
– individuals who have resigned from the Operator;
– natural persons who are candidates for employment;
– individuals who are in civil relations with the Operator.
3.2.4 PD processed by the Operator:
– data obtained in the implementation of labor relations;
– data obtained for the selection of candidates for the job;
– data obtained in the implementation of civil law relations.
3.2.5 Processing of personal data is:
– using automation tools;
– without the use of automation.
3.3 storage of PD.
3.3.1 PD of subjects can be received, processed further and transferred for storage both on paper and in electronic form.
3.3.2 PD recorded on paper are stored in lockable cabinets or in lockable premises with limited access rights.
3.3.3 PD subjects processed using automation for different purposes, are stored in different folders.
3.3.4 it is Not allowed to store and place documents containing PD in open electronic directories (file sharing) in ISPD.
3.3.5 storage of PD in the form allowing to define the subject of PD is performed not longer, than it is required by the purposes of their processing, and they are subject to destruction upon achievement of the purposes of processing or in case of loss of need for their achievement.
3.4 the Destruction of the POA.
3.4.1 Destruction of the documents (carriers) containing PD is made by burning, crushing (crushing), chemical decomposition, transformation into the shapeless mass or powder. For destruction of paper documents use of the shredder is allowed.
3.4.2 PD on electronic media are destroyed by erasing or formatting the media.
3.4.3 the fact of destruction of PD is documented by the act of destruction of carriers.
3.5 transmission of PD.
3.5.1 the Operator transfers PD to third parties in the following cases:
– the subject consented to such actions – ;
– the transfer is provided for by Russian or other applicable law within the procedure established by law.
3.5.2 List of persons to whom PD is transferred.
– Pension Fund of the Russian Federation for accounting (legally);
– tax authorities of the Russian Federation (legally);
– Social insurance Fund of the Russian Federation (legally);
– territorial compulsory health insurance Fund (legally);
– insurance medical organizations for compulsory and voluntary health insurance (legally);
– banks for payroll (on the basis of the contract);
– bodies of the Ministry of internal Affairs of Russia in the cases established by the legislation;
– network organizations (under civil law contracts).
4.1 in accordance with the requirements of regulatory documents, the Operator has created a system of personal data protection (SZPD), consisting of subsystems of legal, organizational and technical protection.
4.2 the Subsystem of legal protection is a set of legal, organizational, administrative and regulatory documents that ensure the creation, operation and improvement of the FDD.
4.3 the Subsystem of organizational protection includes the organization of management structure of SZPD, allowing system, protection of information at work with employees, partners and third parties.
4.4 Subsystem of technical protection includes a set of technical, software, software and hardware that provide protection of PD.
4.5 The main PD protection measures used by the Operator are:
4.5.1 Appointment of the person responsible for processing PD, which carries out the organization of PD processing, training and instruction, internal control over compliance with the requirements for the protection of PD by the institution and its employees.
4.5.2 Identification of actual threats to the safety of PD during their processing in the ISPD and development of measures and measures to protect PD.
4.5.3 develop a policy for the processing of personal data.
4.5.4 establishing rules of access to PD processed in the ISPD, as well as ensuring the registration and accounting of all actions taken with the PD in the ISPD.
4.5.5 Establishment of individual passwords for access of employees to the information system in accordance with their work responsibilities.
4.5.6 The use of duly passed the procedure of conformity assessment of information security.
4.5 Certified anti-virus software with regularly updated databases.
4.5.8 Compliance with the conditions ensuring the safety of PD and excluding unauthorized access to them.
4.5.9 detection of unauthorized access to personal data and taking measures.
4.5.10 restoration of PD modified or destroyed due to unauthorized access to them.
4.5.11 Training of the Operator’s employees directly engaged in the processing of personal data, the provisions of the legislation of the Russian Federation on personal data, including the requirements for the protection of personal data, documents defining the Operator’s policy regarding the processing of personal data, local acts on the processing of personal data.
4.5.12 internal control and audit.
5.1 Basic rights of the subject of PD.
The subject has the right to access his / her personal data and the following information:
– confirmation of PD processing by the Operator;
– legal basis and purpose of PD processing;
– goals and methods of PD processing used by the Operator;
– the name and location of the Operator, information about persons (except employees of the Operator) who have access to PD or who can be disclosed PD on the basis of an agreement with the Operator or on the basis of Federal law;
– terms of processing of personal data, including the terms of their storage;
– the procedure for the subject of PD rights under the current legislation;
– name or surname, name, patronymic and address of the person performing PD processing on behalf of the Operator, if the processing is or will be entrusted to such person;
– appeal to the Operator and sending him requests;
– appeal against actions or omissions of the Operator.
5.2 Obligations Of The Operator.
The operator is obliged:
– when collecting PD to provide information on the processing of PD;
– in cases where PD were not received from the PD subject, notify the subject;
– in case of refusal to provide PD to the subject, the consequences of such refusal are explained;
– publish or otherwise provide unrestricted access to the document defining its policy regarding the processing of PD, to information on the requirements for the protection of PD;
– take the necessary legal, organizational and technical measures or ensure their adoption to protect PD from illegal or accidental access to them, destruction, modification, blocking, copying, provision, distribution of PD, as well as other illegal actions against PD;
– to respond to requests and appeals of PD subjects, their representatives and the authorized body for protection of PD subjects ‘ rights.