# Mega Move India Private Limited – Employee Privacy Notice
## 1. Purpose
Mega Move India Private Limited (hereinafter referred to as "Mega Move India", "we", "our", or "us") is committed to protecting the privacy, confidentiality, and security of your personal data.
This Privacy Notice ("Notice") explains how Mega Move India collects, uses, stores, processes, shares, and protects the personal data that you provide during recruitment, employment, engagement, and after the termination of your employment or association with the Company.
It is important that you read this Notice carefully to understand how and why your personal data is processed.
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## 2. Applicability
This Notice applies to all employees, former employees, trainees, consultants, contractors, temporary workers, interns, and third-party personnel associated with Mega Move India Private Limited.
The Notice also applies to all Mega Move India departments, subsidiaries, affiliates, authorized service providers, contractors, and third-party processors that process personal data on behalf of the Company.
This Notice does not form part of any employment contract, consultancy agreement, or any other service agreement. Mega Move India reserves the right to amend, modify, or update this Notice from time to time to comply with applicable laws, business requirements, and operational practices. Any material changes shall be communicated through appropriate channels.
This Privacy Notice is prepared with reference to the Digital Personal Data Protection Act, 2023 (DPDP Act), and other applicable privacy and data protection laws of the jurisdictions in which Mega Move India operates.
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## 3. Relationship
### Data Fiduciary
A Data Fiduciary means any person or organization that alone or jointly determines the purpose and means of processing personal data.
### Data Processor
A Data Processor means any person or organization that processes personal data on behalf of a Data Fiduciary.
Mega Move India Private Limited acts as the Data Fiduciary in relation to your personal data. Accordingly, the Company determines the purposes and methods of processing personal data collected from employees, applicants, contractors, and associated personnel.
The Company may process personal data for various employment-related purposes including recruitment, onboarding, workforce management, payroll administration, statutory compliance, employee welfare, performance management, training, succession planning, legal compliance, and business operations.
Processing activities may include:
* Collection
* Recording
* Organization
* Structuring
* Storage
* Adaptation
* Alteration
* Retrieval
* Consultation
* Use
* Disclosure by transmission
* Sharing
* Archiving
* Erasure
* Destruction
The personal data collected and processed shall be used solely for legitimate business, administrative, operational, contractual, legal, and regulatory purposes.
Mega Move India may retain and process your personal data during your employment, engagement, and after the conclusion of your employment relationship where required for legal, regulatory, audit, taxation, insurance, contractual, or business continuity purposes.
Where required by law or legitimate business necessity, Mega Move India may be unable to comply with requests for deletion or restriction of certain personal data. In such cases, the Company shall communicate the implications of such limitations.
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## 4. What Personal Data Do We Collect?
Mega Move India collects and processes the following categories of personal data as necessary for employment, legal compliance, contractual obligations, legitimate business interests, or with your consent where applicable.
### Personal Details
Including but not limited to:
* Full Name
* Title
* Residential Address (Permanent and Temporary)
* Postal Code
* Telephone Numbers
* Mobile Number
* Personal Email Address
* Official Email Address
* Date of Birth
* Age
* Gender
* Nationality
* Citizenship
* Country of Residence
* Marital Status
* Marriage Certificate
* Marriage Date
* Photograph
* Signature
* Emergency Contact Information
* Languages Known
* Educational Qualifications
* Professional Certifications
* Training Records
* Skill Assessments
* Extracurricular Activities
* Nominee Information
* Dependent Information
### Family Information
Including but not limited to:
* Spouse Name
* Spouse Date of Birth
* Spouse Passport Details
* Children's Details
* Dependents' Information
* Parents' Information
* Sibling Information
* Nominee Information
### Financial Information
Including but not limited to:
* Bank Name
* Bank Account Number
* IFSC Code
* SWIFT Code
* Salary and Compensation Information
* Tax Information
* Benefit and Reimbursement Records
* Insurance Details
### National Identity Information
Including but not limited to:
* Passport Number
* Driving Licence Number
* PAN Number
* Aadhaar Number (where legally permissible)
* Tax Identification Number
* Government-Issued Identification Numbers
* Work Permit and Visa Information
### Current Employment Information
Including but not limited to:
* Designation
* Department
* Employee Code
* Compensation Details
* Incentives and Benefits
* Leave Records
* Attendance Records
* Performance Records
* Promotion History
* Disciplinary Records
### Previous Employment Information
Including but not limited to:
* Employment History
* Previous Employer Details
* Reference Information
* Referee Contact Details
* Previous Compensation Details
* Reporting Manager Information
### Recruitment Information
Including but not limited to:
* Curriculum Vitae (CV)
* Resume
* Educational Qualifications
* Skills and Competencies
* Employment History
* Reference Checks
* Right-to-Work Documentation
* Background Verification Information
* Interview Assessments
### CCTV Surveillance Data
Mega Move India may operate CCTV systems at its offices, warehouses, logistics facilities, operational yards, parking areas, and other Company premises for:
* Security Monitoring
* Asset Protection
* Fraud Prevention
* Safety Management
* Investigation of Incidents
* Compliance Requirements
CCTV footage may be recorded, retained, reviewed, and disclosed where required by law or legitimate business interests.
### Special Categories of Personal Data
Where legally permissible and necessary, Mega Move India may process certain sensitive categories of personal data.
Currently, criminal record information may be processed solely for employment screening and background verification purposes where permitted by applicable law.
Should Mega Move India process additional sensitive personal data categories during employment, employees will be appropriately informed.
Such data may include:
* Health Information
* Biometric Information
* Genetic Information
* Religious Beliefs
* Political Opinions
* Trade Union Membership
* Racial or Ethnic Origin
* Sexual Orientation
* Transgender or Intersex Status
* Social Security Information
* Financial Information
* Other Sensitive Personal Data permitted under applicable laws
### Business Purposes
Personal data may be processed for legitimate business purposes including:
* Auditing and Compliance Activities
* Fraud Detection and Prevention
* Cybersecurity and Information Security Monitoring
* Incident Investigation
* Internal Business Administration
* Service Quality Assurance
* Research and Development
* Operational Improvement Initiatives
* Risk Management Activities
* Contract Management
* Client Service Delivery
* Technology Development and Testing
* Legal and Regulatory Compliance
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## 5. How Is Personal Data Collected?
Mega Move India collects personal data through various lawful sources including:
* Employment Applications
* Recruitment Portals
* Interviews
* Employee Information Forms
* Joining Documentation
* Onboarding Processes
* Employee Self-Service Systems
* Internal HR Systems
* Payroll Systems
* Training Platforms
* Company Communication Systems
Personal data may also be collected indirectly from:
* Recruitment Agencies
* Background Verification Agencies
* Previous Employers
* Educational Institutions
* Government Authorities
* Medical Service Providers
* Credit Reference Agencies
* Insurance Providers
Additional personal data may be collected during the course of employment where necessary for legitimate business, contractual, operational, legal, regulatory, or compliance purposes.
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## 6. How We Use Personal Data
Mega Move India will process personal data only where permitted by law and for legitimate business purposes.
Personal data may be used for:
* Managing employment relationships
* Recruitment and onboarding
* Payroll administration
* Benefits administration
* Performance management
* Workforce planning
* Career development
* Succession planning
* Employee training and development
* Attendance and leave management
* Business communication
* Immigration and visa processing
* Statutory compliance
* Tax compliance
* Insurance administration
* Health and safety management
* Security management
* Information technology administration
* Network security
* Fraud prevention
* Internal audits
* Legal proceedings
* Dispute resolution
* Regulatory reporting
* Business continuity planning
* Client contractual compliance
* Reference verification
* Employee engagement initiatives
* Corporate transactions including mergers, acquisitions, restructuring, or asset transfers
Personal data may also be processed:
* To perform contractual obligations;
* To comply with legal obligations;
* To protect legitimate business interests;
* To protect vital interests of individuals;
* To support public interest obligations where applicable.
Where required under contractual commitments, Mega Move India may share employee profiles, certifications, qualifications, security clearances, or background verification status with customers, clients, project owners, regulatory authorities, or other authorized parties.
Mega Move India maintains retention schedules to ensure personal data is retained only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, enforce agreements, and satisfy regulatory requirements.
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## 7. If You Fail to Provide Personal Data
Where the provision of personal data is required by law, contract, regulatory obligation, or legitimate business necessity, failure to provide such information may prevent Mega Move India from:
* Processing your employment application;
* Establishing or continuing employment;
* Administering compensation and benefits;
* Complying with legal obligations;
* Providing requested services or support;
* Meeting contractual requirements;
* Maintaining workplace safety and security.
In such circumstances, Mega Move India may be unable to provide certain services, benefits, employment opportunities, or contractual arrangements.
## 8. Change of Purpose
Mega Move India Private Limited will use your personal data only for the purposes for which it was originally collected.
If we reasonably consider it necessary to use your personal data for a purpose that is different from the purpose for which it was originally collected, we will assess whether such use is compatible with the original purpose and permitted under applicable law.
Where required by law, we will notify you of the new purpose and explain the legal basis that permits such processing before any further processing takes place.
### Document Control
| Document Title | Employee Privacy Notice |
| ---------------- | ---------------------------- |
| Document ID | MMI-PRIV-001 |
| Version | 1.0 |
| Effective Date | [Insert Date] |
| Approval Date | [Insert Date] |
| Policy Owner | Human Resources Department |
| Approved By | Managing Director |
| Review Frequency | Annual or as required by law |
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## 9. Data Sharing
Mega Move India may share your personal data with authorized recipients where necessary for employment administration, business operations, legal compliance, contractual obligations, and legitimate business interests.
Prior to engaging third-party service providers, Mega Move India undertakes appropriate due diligence to assess their privacy, confidentiality, security, and compliance standards. Where required, Data Processing Agreements (DPAs), confidentiality agreements, and cross-border data transfer safeguards are executed to ensure adequate protection of personal data.
We may share your personal data with:
### Internal Departments
Your personal data may be disclosed only to authorized personnel and departments that require access for legitimate business purposes, including but not limited to:
* Human Resources
* Payroll and Accounts
* Finance and Taxation
* Legal and Compliance
* Information Technology
* Administration
* Recruitment Teams
* Reporting Managers
* Senior Management
Examples include sharing visa-related information with immigration coordinators, payroll information with finance teams, and training records with learning and development personnel.
### Group Companies and Affiliates
Mega Move India may share personal data with its group companies, subsidiaries, affiliates, branch offices, and representative offices where required for:
* Employment administration
* Business operations
* Client servicing
* Project execution
* Compliance obligations
Such transfers shall be conducted in accordance with applicable privacy laws and contractual safeguards.
### Third-Party Service Providers
We may share personal data with authorized service providers including:
* Background verification agencies
* Recruitment consultants and employment agencies
* Payroll processing providers
* Insurance providers
* Medical and health service providers
* Travel agencies and transportation providers
* Pension and employee benefit providers
* Cloud hosting providers
* IT infrastructure and cybersecurity service providers
* Document storage providers
* Communication service providers
* Training and psychometric assessment providers
* Auditors and accounting firms
### Professional Advisors
We may share personal data with:
* Legal advisors
* Chartered accountants
* Auditors
* Consultants
* Compliance professionals
where necessary to obtain professional advice or fulfill legal obligations.
### Government and Regulatory Authorities
Personal data may be disclosed to:
* Government departments
* Regulatory authorities
* Customs authorities
* Immigration authorities
* Tax authorities
* Law enforcement agencies
* Courts and tribunals
where disclosure is required by law, regulation, court order, or official request.
### Corporate Transactions
In the event of:
* Merger
* Acquisition
* Joint Venture
* Business Restructuring
* Sale of Assets
* Corporate Reorganization
personal data may be shared with potential buyers, investors, lenders, advisors, or successors, subject to appropriate confidentiality obligations.
### Restrictions on Use by Recipients
Any third party receiving personal data from Mega Move India:
1. Shall only process such information for the purposes authorized by Mega Move India.
2. Shall comply with applicable privacy, confidentiality, and information security requirements.
3. Shall implement appropriate technical and organizational safeguards to protect personal data.
4. Shall not sell, rent, disclose, or otherwise use personal data for unauthorized purposes.
Mega Move India does not sell or rent employee personal data to third parties.
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## 10. Transnational Data Transfer
Mega Move India may transfer personal data across national borders where necessary for:
* Employment administration
* International assignments
* Visa and immigration processing
* Client project requirements
* Global business operations
* Group company administration
Whenever personal data is transferred outside the jurisdiction in which it was collected, Mega Move India will ensure appropriate safeguards are implemented to protect such data.
Such safeguards may include:
* Standard Contractual Clauses (SCCs)
* Data Processing Agreements (DPAs)
* Intra-Group Data Transfer Agreements
* Contractual confidentiality obligations
* Other legally recognized transfer mechanisms
Mega Move India shall take reasonable steps to ensure that transferred personal data continues to receive a level of protection consistent with applicable data protection laws.
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## 11. Data Protection
Mega Move India is committed to protecting personal data through appropriate technical, physical, and organizational security measures.
The Company has established policies, procedures, controls, and security practices designed to prevent accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or unauthorized access to personal data.
Security measures may include:
### Technical Controls
* Role-based access controls
* Password protection mechanisms
* Multi-factor authentication
* Encryption of sensitive data
* Secure network architecture
* Firewall protection
* Endpoint security solutions
* Data backup and recovery systems
* Cybersecurity monitoring
* Vulnerability assessments and testing
### Organizational Controls
* Confidentiality agreements
* Employee privacy awareness training
* Information security policies
* Vendor security assessments
* Access authorization procedures
* Incident reporting and response procedures
* Periodic compliance reviews
### Physical Controls
* Secured office premises
* Visitor access controls
* CCTV surveillance systems
* Secure document storage
* Restricted access areas
Where personal data is processed by third-party service providers, Mega Move India requires such providers to maintain appropriate technical and organizational safeguards and comply with confidentiality obligations.
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## 12. Data Retention
Mega Move India retains personal data only for as long as necessary to fulfill the purposes for which it was collected, including legal, regulatory, contractual, tax, audit, insurance, and business continuity requirements.
When determining retention periods, the Company considers:
* Nature and sensitivity of personal data
* Purpose of processing
* Legal and regulatory requirements
* Statutory limitation periods
* Potential legal claims
* Business and operational requirements
Indicative retention periods may include:
| Record Type | Retention Period |
| ------------------------------- | ---------------------------------------------------------------- |
| Recruitment Records | Up to 3 Years |
| Employee Personnel Files | Duration of Employment + 7 Years |
| Payroll Records | 8 Years or as required by law |
| Tax Records | As prescribed under applicable tax laws |
| Training Records | Duration of Employment + 3 Years |
| CCTV Footage | 30 to 180 Days unless required for investigation |
| Background Verification Records | Duration of Employment + 3 Years |
| Legal and Litigation Records | Until conclusion of proceedings and statutory limitation periods |
Where retention is no longer required, personal data shall be securely deleted, anonymized, archived, or destroyed in accordance with Company policies and applicable legal requirements.
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## 13. Data Subject Rights
Subject to applicable law, employees and other individuals whose personal data is processed by Mega Move India may have the following rights:
* Right to access personal data
* Right to request correction of inaccurate information
* Right to request updating of incomplete information
* Right to withdraw consent where processing is based on consent
* Right to request deletion of personal data where legally permissible
* Right to object to certain processing activities
* Right to seek grievance redressal
* Right to nominate another person to exercise rights in the event of death or incapacity, where permitted under applicable law
Requests regarding personal data may be submitted to the Human Resources Department or the designated Grievance Officer.
Mega Move India will review and respond to such requests in accordance with applicable legal requirements and timelines.
