Shield GEO Privacy Policy

1. The Impact of the General Data Protection Regulation (GDPR) on Shield GEO

2. ShieldGEO Data Privacy Policy for Employees
2.1 Information We Collect and Receive From Employees
2.2 Data Storage and Processing of Employee Information
2.3 How We Use and Share Employee Information

3. ShieldGEO.com Visitor Data Privacy Policy
3.1 Information We Collect From ShieldGEO.com Visitors
3.2 How We Use Visitor Information

4. Data Security and Protection for All Data

5. Changes to this Privacy Policy

6. Contacting ShieldGEO

1. The Impact of the General Data Protection Regulation (GDPR) on Shield GEO

The GDPR went into effect on 25th May 2018 and it introduces obligations for all organisations that handle EU citizens’ personal data, regardless of where the organization is located. Penalties for non-compliance with the GDPR are severe – up to 4% of annual global turnover for a breach.

As an Employer of Record, ShieldGEO collects and processes personal data on our GEO employees, many of whom are EU citizens. ShieldGEO acts as both a data processor, from handling data given to us by the employee or end client, and a data controller, through passing data to the end client or to our local partners in the host country.

Our responsibilities under the GDPR legislation include:

1. Ensuring we only process data when we have the right to do so;
2. Notifying individuals within 72 hours of any breach; and
3. Complying with the employee’s right to have their data amended or deleted unless this is prevented by other legislation.

To this end, we ensure that the employee or client provides us with permission before we collect personal data and we also inform the recipient of their responsibilities before personal data is shared with them. We maintain a detailed record of all data processing activities that we carry out.

2. ShieldGEO Data Privacy Policy for Employees

ShieldGEO has created a Data Privacy Policy to ensure compliance with all relevant legislation concerning the data that we collect from employees, clients and site visitors and how it is used. In the policy below, “employee” refers to the employees that we help to on-board for our clients.

2.1 Information We Collect and Receive From Employees

In performing our services, ShieldGEO may collect and receive employee data. This section will outline the the personal information that we collect from the employees whom we on-board for our clients. Information will only be collected with the full consent of the party whose data is being shared and processed.  All persons authorised to process the personal data have committed themselves to confidentiality, or are under a statutory obligation of confidentiality. Employee data that we collect may include, but is not limited to the following:

• Identification Information: Name, Passport Number, Photo Identification, Driver’s License Number, Email Address and National Insurance/Social Security Number
• Demographic Information: Age and Nationality
• Employment Information: Job Description and Title, Compensation (base salary, bonuses, commissions, incremental pay raises) and Benefits
• Government Information: Visa, Immigration Status and Tax Status
• Other Information: Medical Information, Living Expenses, Spouse/Partner Career Data, Insurance Coverage, and Bank Account Details

2.2 Data Storage and Processing of Employee Information

This section outlines how ShieldGEO stores and processes employee information. ShieldGEO is committed to protecting any personal information that we hold. Employee information is stored in Salesforce and Dropbox with all confidential and sensitive information being password protected. Information on the privacy policies of Salesforce and Dropbox are available here: Salesforce (https://www.salesforce.com/au/company/privacy/), Dropbox (https://www.dropbox.com/privacy2016). Additionally, your name and email address will be shared and stored with Drip and Mailchimp, which are third party automated marketing providers that will send you ShieldGEO country guides and newsletters in line with your needs and preferences. Information on the privacy policies of Drip and Mailchimp are available here: Drip (https://www.drip.com/privacy), Mailchimp (https://mailchimp.com/legal/). If you would like to amend your personal information or remove it from our databases, please contact ShieldGEO at our email address listed below. For additional information on how ShieldGEO protects your data, please see the Data Protection and Security section below.

ShieldGEO and the client are obligated to maintain records of all processing activities carried out on behalf of the employee involving their data. This includes the following:

• The identity and contact details of the controller and processor, and where applicable, the controller’s representative;
• The purposes of the processing;
• A description of the categories of data subjects and of the categories of personal data;
• The categories of recipients to whom the personal data have been or will be disclosed including recipients in third countries or international organisations;
• Where applicable, transfers of personal data to a third country or an international organisation, including the identification of that third country or international organisation;
• Where possible, the envisaged time limits for erasure of the different categories of data; and
• Where possible, a general description of the technical and organisational security measures in place to secure data processing activities.

2.3 How We Use and Share Employee Information

ShieldGEO adopts a policy of ‘Least Privilege’ when it comes to using and sharing employee information. This means that Shield GEO will only share the personal data of employees with third parties that absolutely must have it to perform their responsibility in the provision of services to the Client and the Employee. The personal data may only be collected by Shield GEO with the employee’s consent, and/or where it is necessary for the performance of a contract to which the employee is party, and/or if it is necessary for compliance with a legal obligation to which Shield GEO is subject. Shield GEO is prohibited from using this personal information for any purpose other than to fulfil the service requirement for which the Client has engaged Shield GEO.

Shield GEO may use employee data:

• To pass onto the Local Partner in the region you will be employed. The Local Partner will use your personal information to set up and organise your payroll, work-related benefits, insurance benefits (e.g. medical insurance) and social security contributions with the relevant institutions.If applicable, the Local Partner will also use your personal information to submit an application for any working permits or visas where applicable.
• To facilitate the contract between the employee and the client. When you enter into a contract for employment with the client, we will use your personal information to facilitate the contractual relationship between yourself and the client.
• To respond to your requests, comments and questions. ShieldGEO may use your contact details to answer any questions you may have with regards to your employment.
• To provide additional information tailored to your needs. ShieldGEO may use your personal information to provide additional information that may be of interest to you including ShieldGEO country-specific articles and newsletter. 
• To meet regulatory and legal requirements.  If we receive a request for information, we may disclose your personal information if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation or legal process.

3. ShieldGEO.com Visitor Data Privacy Policy

Thank you for visiting ShieldGEO.com. The ShieldGEO.com privacy policy explains what data we collect from you, why it is collected and how we use it when you visit our website at www.shieldgeo.com. It also outlines the specific ways we use and disclose the information that is collected. Any information we collect from you will be used only as described in this Privacy Policy and in the “How We Process and Use Visitor Information” section below. By using or accessing our site or services, you are accepting the practices described in this Privacy Policy.

3.1 Information We Collect From ShieldGEO.com Visitors

ShieldGEO may collect and receive Personal Data, Company Data and Other Information when you subscribe to our newsletter, send us an enquiry or subscribe to our articles via our website. The data is collected in various ways:

• Personal Information. ShieldGEO may collect personal information including your name, company, phone number and email address when you contact us, register for our newsletter or download our country guides.
• Company Information. ShieldGEO may collect information about your company including the number of assignees you wish to employ, their nationalities, their expected remuneration and any work-related benefits when you contact us to make an inquiry.
• Other Information. All Other Information that we collect is used in a non-identifiable way and is not shared with third parties. Other information can include:
• Cookie Information and Third Parties. ShieldGEO uses third party FullStory software to collect cookie information. Cookies are small text files that websites send to computers or other Internet-connected devices to uniquely identify the browser or to store information or settings in the browser. ShieldGEO may collect information on your use of our site including the pages visited, links clicked, non-sensitive text entered and mouse movements. In addition, we also receive more commonly collected information such as the referring URL, browser, operating system, and Internet Protocol (“IP”) address. Additional information on FullStory’s privacy policy can be found here (https://www.fullstory.com/legal/privacy/). Our purpose in collecting this information is to better understand how ShieldGEO visitors use our site. If you would not like ShieldGEO to collect cookie information, please disable cookies in your browser. We use cookies for the following purposes:
• Security. We use cookies to enable and support our security features.
• Marketing. We may use cookies to help us deliver our marketing strategies and track their performance.
• Analytics and Research. Analytics cookies anonymously remember the type of device used when you visit our website. They keep track of browsing patterns and help us to build a profile of how our readers are navigating our website. This allows us to understand and improve our services.

3.2 How We Use Visitor Information

This section describes how ShieldGEO may process and use the information that we collect from our site visitors. Any information we collect from our visitors will only be used in accordance with this section. ShieldGEO uses visitor information in furtherance of our legitimate interests in operating our website and business. More specifically, ShieldGEO uses visitor information:

• To respond to your requests, comments and questions. If you contact us, we may use your personal information and company information to respond.
• To send emails and other communications. We may contact you to inform you about any changes to our services or substantial changes to our Privacy Policies. These communications are considered part of the services and you may not opt out of them. In addition, we may send you newsletters and country guides in line with how you have chosen to subscribe. Your personal information is shared with Drip which is a third party automated marketing provider that will send you country guides in line with your needs and preferences. These are marketing messages and you can control whether you receive them. Information on Drip’s privacy policy can be found here (https://www.drip.com/privacy). Additionally, the email addresses of our newsletter subscribers are stored in Mailchimp which is a third party marketing automation platform. Information on Mailchimp’s privacy policy can be found here (https://mailchimp.com/legal/). If you wish to stop receiving our newsletter or country guides, please unsubscribe in the link provided in your email.
• To personalise your experience. Through collecting personal and company information from our visitors, ShieldGEO can send out informative materials in line with your needs.  
• To optimise and improve our website. ShieldGEO uses Other Information to identify which parts of our website are most engaging to our visitors. The information helps us to implement changes and improvements to our website. We also use cookies to build a profile of how our readings are navigating our website.
• To understand the needs of our customers.

4. Data Security and Protection for All Data

This section outlines the data security and protection measures that ShieldGEO employs to protect both employee information and website visitor information. ShieldGEO exercises great care to protect all information that we hold. This includes using firewalls, multi-factor authentication and internal phishing penetration testing as well as password protection for confidential and sensitive information. Much of the information that we hold is stored in Salesforce which contains added security and protection measures of its own. Additional information on Salesforce’s privacy policy can be found here (https://www.salesforce.com/au/company/privacy/).

Internally, ShieldGEO restricts access to personal information to employees or parties who need access to the information in order to perform their jobs. Limited access is granted and employees who are granted this access are committed to maintaining confidentiality.

As a ShieldGeo.com site visitor, it is important for you to protect against unauthorized access to your password and to your computer. No security measures are perfect and we cannot promise to be able to withstand security threats in all circumstances.

5. Changes to this Privacy Policy

ShieldGEO may change our Privacy Policies from time to time. Laws, regulations and industry standards evolve, which may make those changes necessary, or we may make changes to our business. We will update any changes to this page. If we make changes that significantly alter your privacy rights, ShieldGEO will notify you via email. If you disagree with the changes to the Privacy Policies, you should contact us to request the removal of the collected information that is under our control. 

This policy was last updated on 13 May 2019.

6. Contacting ShieldGEO

Please feel free to contact ShieldGEO if you have any questions about this Privacy Policy or ShieldGEO’s practices. You may contact us at [email protected] or at our mailing address below:

ShieldGEO

Level 15, 5 Martin Place

Sydney, NSW, 2000

Australia