Murren Consulting Private Limited
Employee Privacy Policy
Effective date: August 13, 2024
Last updated on: September 3, 2024
1. Background
Murren Consulting Private Limited, having its registered address at 2nd floor, Valence Block, Prestige Technology Park–III, Sarjapur – Marathahalli Outer Ring Road, Kadubeesanahalli, Bengaluru–560103, and its affiliates including Sequoia Benefits and Insurance Services, LLC, with its registered address at 1850 Gateway Dr, Ste 700, San Mateo, CA 94404 USA (hereinafter collectively “Company“, “our”, “us” or “we“), is committed to protecting the privacy and security of your personal data.
This Privacy Policy describes how the Company collects and processes personal data about you and applies to current and former employees, consultants and other persons who are engaged by the Company (hereinafter “Employee“, “you” or “your“). It is important that you read and understand this policy, so you are aware of how and why we are using such personal data and what your rights are under applicable data protection law. This policy is to be read in conjunction with any other employment agreements and documents that you may enter with the Company.
You shall be bound by this Privacy Policy and the Company shall process your personal data only in accordance with this Privacy Policy, unless otherwise required or provided under law. By agreeing to the terms of this Privacy Policy, you provide your express consent to the collection, usage, disclosure, transfer and other processing of personal information by the Company per the manner described in this Privacy Policy.
This Privacy Policy will inform you about:
• The types of personal data that we collect about you;
• How we use this personal data, including how and when we share this information with third parties;
• How we store and secure this information; and
• The rights you have in relation to this personal data.
2. What personal data we may collect and process
We may collect and process the following categories of personal data during onboarding and throughout the duration of your engagement with us. We may collect this information either directly from you or indirectly from other Employees, personnel of the Company or its affiliates, or any other third parties such as service providers, former employers, credit reference agencies or government authorities.
(a) Contact Information: Contact details such as name, addresses, telephone numbers, email addresses, next of kin and emergency contact information.
(b) Identification Information: Date of birth, gender identification, marital status and dependants, photographs.
(c) Employment / Engagement Information: Start date and, if different, the date of your continuous employment, leaving date and your reason for leaving, location of employment or workplace, employment records (including job titles, work history, working hours, holidays/vacation entitlement and leave taken, training records and professional memberships), performance information, disciplinary and grievance information.
(d) Recruitment Information: Copies of right to work documentation, references and other information included in a CV/resume or cover letter or as part of the application process, information about criminal convictions and offences.
(e) IT Information: CCTV footage and other information obtained through electronic means such as swipe card records, and information about and based on your use of our computer networks and IT systems.
(f) Diversity, Equity and Inclusion: Where permitted by applicable law, information about your race or ethnicity, and sexual orientation.
(g) Official Documents: Aadhaar / National ID number / Social Security Number / Social Insurance Number and/or National Insurance number, copy of driving licence and passport, right to work documentation, visa details. If you choose to provide us with your Aadhaar information, you hereby expressly provide your consent to the collection and processing of your Aadhaar information by the Company for the purposes of identity verification and acknowledge that you provided such Aadhaar information voluntarily. Please note that this is not mandatory, and you may alternatively provide other identification documents such as passport and voter’s ID.
(h) Financial Information: Bank account details, payroll records, tax status information, salary, pension and benefits information, compensation history.
(i) Biometric and Health information: Genetic data, biometric data information about your health, including any medical condition, disability, health and sickness records.
3. How we may use your personal data
We will process your personal data for the purposes identified below:
| Categories of personal data | Purpose for Processing |
| Contact Information, Identification Information, Employment Information, IT Information, Diversity, Equity, and Inclusion Data, Biometric and Health Information, Financial Information, other Sensitive Information |
To administer human resource functions including: (i) conducting onboarding and providing access to Company documents and systems; (ii) conducting performance reviews, managing performance, monitoring workplace and business related activities, and determining performance requirements; (iii) talent management and succession planning – including, assessing qualifications for a particular job or task, and decisions about promotions; (iv) managing annual leave; (v) making decisions about your continued employment or engagement; (vi) education, training and development requirements; (vii) administering business travel arrangements; (viii) managing internal directories and organizational charts, and social and cultural activities directly implemented by the Company; (ix) contacting your emergency contacts in case of an emergency; and (x) dealing with disciplinary action, termination, and retirement. |
|
Contact Information, Identification Information, Financial Information, Biometric and Health information
|
To administer obligations under the terms of engagement including: (i) Paying you and, if you are an employee or deemed employee for tax purposes, and deducting tax; (ii) inviting you to participate in any share plans operated by the Company; (iii) enrolling you in a pension arrangement in accordance with our statutory automatic enrolment duties; (iv) liaising with the trustees or managers of a pension arrangement operated by the Company, your pension provider, and any other provider of benefits; (v) making decisions about salary reviews and compensation; and (vi) the payment of benefits such as bonuses and car allowances. |
| Contact Information, Employment Information, IT Information | To manage communications including authorizing, granting, and administering access to or use of Company systems, facilities, devices, and records including management of email accounts. |
| Contact Information, IT Information, Employment Information |
To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution. To monitor your use of our computer networks and communication systems to ensure compliance with our IT policies. |
| Contact Information, Identification Information, Employment Information, Financial Information | For business management and planning, including accounting and auditing. |
| Contact Information, Identification Information, Employment Information, Recruitment Information |
To investigate and resolve complaints, grievances, disciplinary hearings, or misconduct. To prepare for and act in relation to enquiries, investigations, legal disputes, or proceedings, including by governmental, administrative, judicial, or regulatory authorities. |
| Contact Information, Identification Information | For marketing and business development purposes including, posting such personal data on the Company’s social media pages. |
| Contact Information, Identification Information, Employment Information, Biometric and Health Information, Financial Information | To ensure health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits including, maternity pay, sick pay, pensions and permanent health insurance. |
| Contact Information, Employment Information, Diversity, Equity, and Inclusion Data | To conduct meaningful equal opportunities monitoring and reporting. |
4. How we may disclose and transfer your personal data
The Company may share your personal data under the following circumstances, to the categories of entities identified below:
• Your information may be disclosed or transferred to our corporate affiliates, including our parent company, affiliates and subsidiaries in connection with your engagement with us, to the extent applicable.
• You information may be disclosed in connection with any business reorganisation or Company restructuring exercise.
• Your information may be disclosed or transferred to vendors, service providers and other third-party entities engaged by the Company, for the purposes of payroll, pension administration, benefits’ provision and administration, car lease and hire services, monitoring and assessment, IT services and other services.
• Your information may be disclosed and transferred for regular reporting activities on company performance.
• Your information may be disclosed and transferred to government agencies, regulators enforcement authorities, adjudicatory bodies and other such entities respond to law enforcement requests or where required to be provided under applicable laws, court orders, or government regulations.
• Your information may be disclosed and transferred to third parties such as auditors, accountants and legal advisors.
5. How we protect and store your personal data
We have put in place reasonable and appropriate security measures in order to prevent unauthorised or unlawful processing of your personal data and prevent accidental loss, damage or destruction of your personal data, in accordance with applicable data protection laws.
We will retain your personal data for as long as necessary to fulfil the specified purposes for which we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We will cease processing and delete your data when you withdraw your consent or request us to erase your data, unless retention is permitted or required by law.
In some circumstances we may continue to use your data in an anonymised form so that it can no longer be associated with you.
6. Your rights in relation to your personal data
You have the right to (a) access and review the information about the processing of your information; (b) seek correction, completion, updating or erasure of your information; (c) have your grievances resolved; and (d) nominate another individual to exercise your rights in case of your death or incapacity.
For exercising any of the abovementioned rights, please contact our Grievance Officer. Any such communication must be in writing.
If you have given your consent for the processing of your information for specific purposes, you can withdraw this consent at any time by writing to the Grievance Officer. In some cases, if we are not allowed to process your information, this may affect your engagement with the Company and our ability to fulfil our obligations under your employment agreement.
7. Acceptable Use and Systems Monitoring Policy
The Company’s Acceptable Use and Systems Monitoring Policy is incorporated herein by reference and can be found in ADP.
8. Translation
This Privacy Policy has been drafted in English and translations may be provided in other languages upon your request.
9. Grievance Officer
If you have any questions or grievances regarding this Privacy Policy or how we handle your personal data, please contact the Grievance Officer whose details have been provided below:
Grievance Officer: Shruti Yallatti
Contact Details: Shruti.Yallatti@sequoia.com