CONFIRMED BY
CEO of Keysystems LLC
____________A.A. Matrosov
___________20__
PRIVACY POLICY
regarding the processing of personal data in Keysystems
LLC
1. General provisions
1.1. Purpose of the Privacy Policy
1.1.1. This Policy regarding the processing of
personal data in Keysystems LLC (hereinafter - the Policy) is developed in
accordance with the Federal Law dated July, 27, 2006 No. 152-FZ «About Personal
Data».
1.1.2. The Policy comes into force from the moment of
its approval by General Director of Keysystems LLC.
1.1.3. The Policy is subject to revision in the course
of periodic analysis by the management of Keysystems LLC (hereinafter referred
to as the Company), as well as in cases of changes in the legislation of the
Russian Federation in the field of personal data.
1.1.4. The policy is subject to publication on the
official websites of the Company (https://www.keysystems.ru;
https://ksbusiness.info).
1.2.1. The purpose of the Policy is to ensure the
protection of the rights and freedoms of personal data subjects when their
personal data is processed by the Company.
1.3.1. For the purposes of the Policy, the following
concepts are used:
personal data – any information relating to a directly
or indirectly identified or identifiable individual (subject of personal data);
personal data permitted by the subject of
personal data for distribution – personal data, access to which by an
unlimited number of persons is provided by the subject of personal data by
giving consent to the processing of personal data permitted by the subject of
personal data for distribution in the manner prescribed by the Federal Law
"About Personal Data";
subject of personal data – an
individual who is directly or indirectly identified or identifiable using
personal data;
operator – a state body,
municipal body, legal entity or individual, independently or jointly with other
persons organizing and (or) carrying out the processing of personal data, as
well as determining the purposes of processing personal data, the composition
of personal data subject to processing, actions (operations) performed with
personal data;
processing of personal data – any
action (operation) or set of actions (operations) performed with the use of
automation tools or without the use of such tools with personal data, including
collection, recording, systematization, accumulation, storage, clarification
(updating, modification), extraction, use, transfer (distribution, provision,
access), blocking, deletion, destruction of personal data;
automated processing of personal data –
processing of personal data using computer means;
dissemination of personal data – actions
aimed at disclosing personal data to an indefinite number of persons;
provision of personal data – actions
aimed at disclosing personal data to a specific person or a specific group of
persons;
blocking of personal data –
temporary cessation of processing of personal data (except in cases where
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 personal data information system and (or) as a result of which the
physical data media with personal data are destroyed;
personal data information system – a set
of personal data contained in databases and information technologies and
technical means that ensure their processing;
confidentiality of information – a
mandatory requirement for a person who has gained access to certain information
not to transfer such information to third parties without the consent of its
owner;
cross-border transfer of personal data – transfer
of personal data to the territory of a foreign state to a foreign government
body, a foreign individual or a foreign legal entity;
threats to the security of personal data – a set
of conditions and factors that create the danger of unauthorized, including
accidental, access to personal data, which may result in the destruction,
modification, blocking, copying, provision, distribution of personal data, as
well as other illegal actions during their processing in the personal data
information system;
the level of protection of personal data is a
complex indicator characterizing the requirements, the fulfillment of which
ensures the neutralization of certain threats to the security of personal data
when they are processed in personal data information systems.
1.4.1. The provisions of the Policy apply to all
relations related to the processing of personal data carried out by the
Company:
– using automation tools, including in
information and telecommunications networks, or without using such tools, if
the processing of personal data without using such tools corresponds to the
nature of the actions (operations) performed with personal data using
automation tools, that is, it allows, in accordance with a specified algorithm,
to search for personal data recorded on a physical medium and contained in card
indexes or other systematized collections of personal data, and (or) access to
such personal data;
– without the use of automation tools.
1.4.2. This Policy should be followed by all employees
of the Company who process or have access to personal data.
2. Purposes of personal data processing
2.1. The
processing of personal data is carried out by the Company for the following
purposes:
– maintaining personnel and accounting
records;
– ensuring compliance with the labor
legislation of the Russian Federation;
– ensuring compliance with the tax
legislation of the Russian Federation;
– ensuring compliance with pension
legislation of the Russian Federation;
– ensuring compliance with the
insurance legislation of the Russian Federation;
– organization of voluntary medical
insurance;
– recruitment of personnel
(applicants) for vacant operator positions;
– ensuring the passing of
introductory, industrial or pre-graduate internship on the basis of an
agreement with an educational institution;
– organization of preliminary and
periodic medical examinations for employees;
– implementation of the loyalty
program;
– provision of corporate cellular
communication services;
– issuance and accounting of loans;
– conclusion of targeted training
agreements;
– preparation, conclusion and
execution of a civil law contract;
– ensuring access to the operator's
territory;
– maintaining a corporate portal;
– software development and provision
of services in the field of software supply; providing consulting support to software
users; conducting training courses; fulfilling the terms of contracts and
agreements; maintaining an official website; organizing access to information
about the organization's activities posted on the Internet information and
telecommunications network; providing access to information about employees'
birthdays, posted on a video panel in the lobby of the building; implementation
of other statutory tasks;
– organization of access to
information about employees of Keysystems LLC, posted on the Internet
information and telecommunications network;
– analysis of the behavioral
characteristics of users on the site;
– organization of access to
information about the partners of Keysystems LLC, posted on the Internet
information and telecommunications network;
– organization of access to
information about the employees of R.O.S.T.U. LLC, posted on the Internet
information and telecommunications network;
– establishment of feedback with the
User;
– organization of access to
information about the speakers of the event;
– maintaining a self-service portal;
– registration in the app;
– organization of the activities of
the Marketing Department.
3. Legal grounds for processing personal
data
3.1. The
following regulations and documents are the basis for the processing of
personal data in the Company:
– the Tax Code of the Russian
Federation;
– the Civil Code of the Russian
Federation;
– The Labor Code of the Russian
Federation;
– Federal Law No. 402-FZ dated
December, 6, 2011 "About Accounting";
– Federal Law No. 53-FZ dated March,
28, 1998 "About Military Duty and Military Service";
– Federal Law No. 273-FZ dated
December, 29, 2012 "About Education in the Russian Federation";
– Federal Law No. 173-FZ dated
December, 17, 2001 "About Labor Pensions in the Russian Federation";
– Federal Law No. 255-FZ dated
December, 29, 2006 "About Compulsory Social Insurance in case of Temporary
Working Disability and in connection with Maternity";
– Federal Law No. 27-FZ dated April,
01, 1996 "About Individual (Personalized) Accounting in the Compulsory
Pension Insurance System";
– Federal Law No. 165-FZ dated July,
16, 1999 "About the Fundamentals of Compulsory Social Insurance";
– Federal Law No. 181-FZ dated
November, 24, 1995 "About Social Protection of Persons with Disabilities
in the Russian Federation";
– Federal Law No. 44-FZ dated April,
05, 2013 "About the Contract System in the field of procurement of goods,
Works, and Services for State and Municipal Needs";
– Federal Law No. 31-FZ dated
February, 26, 1997 "About Mobilization Training and Mobilization in the Russian
Federation;
– Federal Law No. 63-FZ dated April,
06, 2011 "About Electronic Signature";
– Federal Law No. 400-FZ dated
December, 28, 2013 "About Insurance Pensions";
– Federal Law No. 326-FZ dated November,
29, 2010 "About Compulsory Medical Insurance in the Russian
Federation";
– Federal Law No. 167-FZ dated
December, 15, 2001 "About Compulsory Pension Insurance in the Russian
Federation";
– Federal Law No. 125-FZ dated July,
24, 1998 "About Compulsory Social Insurance against industrial Accidents
and occupational diseases";
– Federal Law No. 31-FZ dated
February, 26, 1997 "About Mobilization Training and Mobilization in the
Russian Federation;
– Federal Law No. 223-FZ dated July,
18, 2011 "About Procurement of Goods, Works, and Services by Certain Types
of Legal Entities";
– Order of the Ministry of Health of
the Russian Federation dated May, 30, 2023 No. 266n "About Approval of the
Procedure and Periodicity of pre-shift, pre-trip, post-shift, post-trip medical
examinations, medical examinations during the working day (shift) and the list
of studies included in them";
– Rosarchive Order No. 236 dated December,
20, 2019 "About Approval of the List of Standard Administrative Archival
Documents formed in the course of the activities of state bodies, local
governments and organizations, indicating the terms of their storage";
– The Charter of Keysystems Limited
Liability Company, approved by Protocol No. 50 of the general meeting of
participants dated December, 25, 2015;
– contracts concluded between the
operator and the subject of personal data;
– contracts for the assignment of
personal data processing concluded with third parties;
– contracts under which the
beneficiary or guarantor is the subject of personal data;
– consent of the personal data subject
to the processing of personal data;
– consent to the processing of
personal data authorized by the personal data subject for dissemination.
3.2. In cases
not directly provided for by the legislation of the Russian Federation that do
not comply with the Company's powers, personal data processing is carried out
with the consent of the personal data subject to the processing of his/her
personal data.
3.3. The
processing of personal data is terminated upon the reorganization or liquidation
of the Company.
4. Scope and categories of personal
data processed, categories of personal data subjects
5. Procedure and conditions of personal
data processing
5.1. Principles of personal data processing
Personal data
processing is carried out by the Company in accordance with the following
principles:
– personal data is processed on a
lawful and fair basis;
– processing of personal data is
limited to the achievement of specific, predetermined and legitimate purposes;
processing of personal data incompatible with the purposes of personal data
collection is not allowed;
– it is not allowed to combine
databases containing personal data, the processing of which is carried out for
purposes incompatible with each other;
– only personal data that meets the
purposes of their processing is subject to processing;
– the content and volume of the
personal data being processed correspond to the stated purposes of processing;
the personal data being processed are not redundant in relation to the stated
purposes of their processing;
– when processing personal data, the
accuracy of personal data, its sufficiency, and, if necessary, its relevance to
the purposes of personal data processing is ensured; the Company takes the
necessary measures or ensures their adoption to delete or clarify incomplete or
inaccurate data;
– personal data is stored in a form
that makes it possible to identify the subject of personal data, no longer than
the purposes of personal data processing require, unless the period of personal
data storage is established by federal law, an agreement to which the personal
data subject is a party, beneficiary or guarantor; the processed personal data
is subject to destruction upon achievement of the purposes of processing or in
case of loss of the need to achieve these goals, unless otherwise provided by
the Federal Law.
5.2. Conditions of personal data processing
5.2.1.
Conditions
for processing special categories of personal data
The processing of
special categories of personal data is carried out by the Company in compliance
with the following conditions:
– personal data processing is carried
out in accordance with the legislation on state social assistance, labor
legislation, pension legislation of the Russian Federation;
– the processing of personal data is
carried out in accordance with the legislation on compulsory types of
insurance, with insurance legislation;
– the processing of personal data on
criminal records may be carried out by state bodies or municipal bodies within
the limits of the powers granted to them in accordance with the legislation of
the Russian Federation, as well as by other persons in cases and in accordance
with the procedure determined in accordance with Federal Laws;
– personal data is processed on behalf
of another person.
5.2.2. Conditions for processing biometric
personal data
Information
characterizing the physiological and biological characteristics of a person, on
the basis of which it is possible to establish his/her identity (biometric
personal data) and which is used by the Company to establish the identity of
the personal data subject, is not processed by the Company.
5.2.3.
Conditions
for processing other categories of personal data
The processing of
other categories of personal data is carried out by the Company in compliance
with the following conditions:
– processing of personal data is
carried out with the consent of the personal data subject to the processing of
his/her personal data;
– processing of personal data is necessary
to achieve the goals stipulated by an international agreement of the Russian
Federation or a Law, to perform and fulfill the functions, powers and duties
assigned to the Company by the legislation of the Russian Federation;
– processing of personal data is
required for the performance of a contract to which the personal data subject
is a party or beneficiary or guarantor, as well as for the conclusion of a
contract on the initiative of the personal data subject or an agreement under
which the personal data subject will be the beneficiary or guarantor. An
agreement concluded with a personal data subject may not contain provisions
restricting the rights and freedoms of the personal data subject, establishing
cases of processing personal data of minors, unless otherwise provided for by
the legislation of the Russian Federation, as well as provisions allowing
inaction of the personal data subject as a condition for concluding the
agreement;
– processing of personal data is
necessary for the exercise of the rights and legitimate interests of the
Company or third parties, including in cases provided for by the Federal Law
"About Protection of the Rights and Legitimate Interests of Individuals
when Carrying out Activities to Repay Overdue Debts and about Amendments to the
Federal Law "About Microfinance Activities and Microfinance
Organizations", or to achieve socially significant purposes, provided that
the rights and freedoms of the personal data subject are not violated;
– personal data is processed on behalf
of another person;
– processing of personal data is
carried out with consent to the processing of personal data authorized by the
personal data subject for dissemination.
5.2.4. Assignment of personal data
processing
5.2.4.1.
The
Company has the right to entrust the processing of personal data to another
person with the consent of the personal data subject, unless otherwise provided
by the Federal Law, on the basis of an agreement concluded with this person,
including a state or municipal contract, or by adopting a relevant act by a
state or municipal body (hereinafter referred to as the entrusting).
5.2.4.2.
The
Company, if necessary, assigns the processing of personal data of personal data
subjects. Information about the purpose of the processing order, the name and
location of the persons to whom personal data is transferred, the amount of
personal data transferred, and other information about the processing order are
provided in Appendix No. 2 to this Policy.
5.2.4.3.
The
person who processes personal data on behalf of the Company adheres to the
principles and rules of personal data processing provided for in this Policy,
respects the confidentiality of personal data, and takes the necessary measures
to ensure compliance with the obligations provided for by the Federal Law
"About Personal Data". The Company's order defines the list of
personal data, the list of actions (operations) with personal data to be
performed by the person processing personal data, the methods and purposes of
their processing, the obligation of such person to respect the confidentiality
of personal data, the requirements provided for in part 5 of Article 18 and
Article 18.1 of the Federal Law "About Personal Data", the obligation
to provide documents and other information at the request of the Company during
the period of validity of the Company's order, including before processing
personal data, confirming the taking of measures and compliance with the
requirements established in accordance with Part 3 of Article 6 of the Federal
Law "About Personal Data" in order to fulfill the Company's entrustings
to ensure the security of personal data during their processing, as well as the
requirements for the protection of processed personal data, including the
requirement to notify the Company of the cases provided for in Part 3.1 of the
Article 21 of the Federal Law "About Personal Data".
5.2.4.4.
When
assigning the processing of personal data to another person, the Company is
responsible to the personal data subject for the actions of the said person.
The person who processes personal data on behalf of the Company is responsible
to the Company.
5.2.4.5.
If the
Company entrusts the processing of personal data to a foreign individual or a
foreign legal entity, the Company and the person processing personal data on
behalf of the Company are responsible to the personal data subject for the
actions of these persons.
5.2.5. Transfer of personal data
5.2.5.1.
The
Company has the right to transfer personal data to the bodies of inquiry and
investigation and other authorized bodies on the grounds provided for by the
current legislation of the Russian Federation.
5.3. Confidentiality of personal data
5.3.1. Employees of the Company who have received
access to personal data do not disclose or distribute personal data to third
parties without the consent of the personal data subject, unless otherwise
provided by the Federal Law.
5.4. Publicly available sources of personal data
5.4.1. The Company does not create publicly available
sources of personal data.
5.5. Consent of the personal data subject to the processing of his/her
personal data
5.5.1. If it is necessary to ensure the conditions for
processing the personal data of the subject, the consent of the personal data
subject to the processing of his/her personal data may be provided.
5.5.2. The personal data subject decides on the
provision of his/her personal data and agrees to their processing freely,
voluntarily and in his/her own interest. Consent to the processing of personal
data must be specific, substantive, informed, conscious and unambiguous.
Consent to the processing of personal data may be given by the personal data
subject or his/her representative in any form that allows confirming the fact
of its receipt, unless otherwise established by the Federal Law. If consent to
the processing of personal data is obtained from a representative of the
personal data subject, the authority of this representative to give consent on
behalf of the personal data subject is verified by the Company.
5.5.3. Consent to the processing of personal data may
be revoked by the personal data subject. If the personal data subject withdraws
consent to the processing of personal data, the Company has the right to
continue processing personal data without the consent of the personal data subject
if there are grounds specified in paragraphs 2-11 of part 1 of Article 6,
paragraphs 2-10 of part 2 of Article 10 and part 2 of Article 11 of the Federal
Law "About Personal Data".
5.5.4. The Company is responsible for providing proof
of obtaining the consent of the personal data subject to the processing of his/her
personal data or proof of the existence of the grounds specified in paragraphs
2-11 of part 1 of Article 6, paragraphs 2-10 of part 2 of Article 10 and Part 2
of Article 11 of the Federal Law "About Personal Data".
5.5.5. In cases stipulated by the Federal Law,
personal data processing is carried out only with the written consent of the
personal data subject. Consent in the form of an electronic document signed
with an electronic signature in accordance with the Federal Law is considered
equivalent to a written consent on paper containing a handwritten signature of
the personal data subject. The written consent of the personal data subject to
the processing of his/her personal data must include, in particular:
1) last name,
first name, patronymic, address of the personal data subject, number of the
main identity document, information about the date of issue of the specified
document and the issuing authority;
2) last name,
first name, patronymic, address of the representative of the personal data
subject, number of the main identity document, information about the date of
issue of the specified document and the issuing authority, details of a power
of attorney or other document confirming the authority of this representative
(upon receipt of consent from the representative of the personal data subject);
3) name or last
name, first name, patronymic and address of the Company;
4) purpose of
personal data processing;
5) list of
personal data to be processed with the consent of the personal data subject;
6) name or last
name, first name, patronymic and address of the person who processes personal
data on behalf of the Company, if processing will be entrusted to such person;
7) a list of
actions with personal data for which consent is given, a general description of
the methods of personal data processing used by the Company;
8) period during
which the consent of the personal data subject is valid, as well as the method
of withdrawal, unless otherwise established by the Federal Law.;
9) signature of
the personal data subject.
5.5.6. In case of incapacity of the personal data
subject, consent to the processing of his personal data is given by the legal
representative of the personal data subject.
5.5.7. In case of death of the personal data subject,
consent to the processing of his personal data is given by the heirs of the
personal data subject, if such consent was not given by the personal data
subject during his lifetime.
5.5.8. Personal data may be obtained by the Company
from a person who is not the subject of personal data, provided that the
Company is provided with confirmation of the existence of the grounds specified
in paragraphs 2-11 of Part 1 of Article 6, paragraphs 2-10 of Part 2 of Article
10 and Part 2 of Article 11 of the Federal Law "About Personal Data".
5.6. Cross-border transfer of personal data
5.6.1. The Company carries out cross-border transfer
of personal data of personal data subjects. Information on the purpose of the
cross-border transfer, the name and location of the persons to whom personal
data is transferred, the amount of personal data transferred, and other
information about the cross-border transfer are provided in Appendix No. 3 to
this Policy.
5.7. Specifics of personal data processing authorized by the personal data
subject for dissemination.
5.7.1. The processing of personal data authorized by
the personal data subject for dissemination is carried out on the basis of the
relevant consent of the personal data subject.
5.7.2. Consent to the processing of personal data
authorized by the personal data subject for dissemination is issued separately
from other consents of the personal data subject to the processing of his
personal data.
5.7.3. The Consent contains a list of personal data
for each category of personal data specified in the consent to the processing
of personal data authorized by the personal data subject for dissemination.
5.7.4. Consent to the processing of personal data
authorized by the personal data subject for dissemination is provided directly
to the Company.
5.7.5. Silence or inaction of the personal data
subject is not considered consent to the processing of personal data authorized
by the personal data subject for dissemination.
5.7.6. In consent to the processing of personal data
authorized by the personal data subject for dissemination, the personal data
subject has the right to establish prohibitions on the transfer (other than
granting access) of this personal data by the Company to an unlimited number of
persons, as well as prohibitions on processing or conditions for processing
(other than gaining access) of this personal data to an unlimited number of
persons. The Company's refusal to establish prohibitions and conditions
provided for in Article 10.1 of the Federal Law "About Personal Data"
by the subject of personal data is not allowed.
5.7.7. The prohibitions established by the personal
data subject on the transfer (other than granting access), as well as on the
processing or conditions of processing (other than gaining access) of personal
data authorized by the personal data subject for dissemination, do not apply to
cases of personal data processing in the state, public and other public
interests defined by the legislation of the Russian Federation.
5.7.8. The transfer (dissemination, provision, access)
of personal data authorized by the personal data subject for dissemination must
be terminated at any time at the request of the personal data subject. This
requirement must include the last name, first name, patronymic (if any),
contact information (phone number, e-mail address or postal address) of the
personal data subject, as well as a list of personal data whose processing is
subject to termination. The personal data specified in this requirement may be
processed only by the Company.
5.7.9. The consent of the personal data subject to the
processing of personal data authorized by the personal data subject for
dissemination is terminated from the moment the Company receives the respective
request.
5.7.10. The requirements specified above do not apply in
the case of processing personal data for the purpose of fulfilling the
functions, powers and duties assigned by the legislation of the Russian
Federation to state bodies, municipal bodies, as well as to organizations
subordinate to these bodies.
5.7.11. Based on written consent, the Company processes
the following personal data authorized by the personal data subject for
dissemination:
– full name, date of birth, photo,
contact phone numbers, email address, position, structural unit, place of work,
information about work activity, if the subject of personal data is an employee
of Keysystems LLC;
– full name, if the subject of
personal data is a representative of the partners;
– full name, photo, place of work,
position, if the speaker of the event is the subject of personal data.
5.8. Processing of personal data carried out without the use of automation
tools
5.8.1. General provisions
5.8.1.1.
The processing of personal data contained in the
personal data information system or extracted from such a system is considered
to be carried out without the use of automation tools (non-automated) if such
actions with personal data as the use, clarification, dissemination,
destruction of personal data in relation to each of the subjects of personal
data are carried out with the direct participation of a person.
5.8.2. Features of the organization of
personal data processing carried out without the use of automation tools
5.8.2.1.
Personal data, when processed without the use of
automation tools, is separated from other information, in particular by
recording them on separate tangible personal data carriers (hereinafter
referred to as tangible media), in special sections or in the fields of forms (blanks).
5.8.2.2.
When
recording personal data on tangible media, it is not allowed to record personal
data on one tangible medium, the purposes of processing which are obviously
incompatible. For the processing of various categories of personal data carried
out without the use of automation tools, a separate physical medium is used for
each category of personal data.
d) the standard
form excludes combining fields intended for entering personal data, the
purposes of processing which are obviously incompatible.
5.8.2.5.
When
maintaining journals (registers, books) containing personal data necessary for
a single entry of a personal data subject into the territory where the Company
is located or for other similar purposes, the following conditions are met:
b)
copying of information contained in such journals (registers, books) is not
allowed;
c) personal data
of each personal data subject may be entered in such a journal (book, register)
no more than once in each case of the personal data subject's admission to the
territory where the Company is located.
5.8.2.6.
If the
purposes of processing personal data recorded on one physical medium are
incompatible, if the physical medium does not allow processing personal data
separately from other personal data recorded on the same medium, measures are
taken to ensure separate processing of personal data, in particular:
5.8.3.3.
When
storing physical media, the conditions ensuring the safety of personal data and
excluding unauthorized access to them are observed. The list of measures
necessary to ensure such conditions, the procedure for their adoption, as well
as the list of persons responsible for the implementation of these measures,
are established by the Company.
5.9.
Metric data
processing
5.9.1. General provisions
5.9.1.1.
Web
analytics tools are used on the Company's websites (Table 1) in order to
analyze the use of the Company's websites and improve its work.
Table 1. Web analytics tools
|
Website address |
Web analytics
tools |
Name and address
of the hosting organization owner |
|
https://www.keysystems.ru |
Yandex.Metrica |
Rostelecom Public Joint
Stock Company (Sinopskaya, 14A, ext.ter.of Smolninskoye municipal district, 191167,
Saint Petersburg) |
|
https://ksbusiness.info |
Yandex.Metrica |
Rostelecom Public Joint
Stock Company (Sinopskaya, 14A, ext.ter.of Smolninskoye municipal district, 191167,
Saint Petersburg) |
5.9.1.2.
The
processing of cookies is carried out by the Company in a generalized form and
is never correlated with the personal information of Users.
5.9.1.3.
On the
sites specified in clause 5.9.1.1, a warning is displayed informing users about
the processing of metric data.
5.9.1.4.
When
visiting the sites specified in clause 5.9.1.1, the user consents to the
Company to process the specified data using metric services to analyze the use,
measure and improve the performance of the Company's website. The consent is
valid from the moment it is provided and during the entire period of use of the
site by User.
5.9.1.5.
In
case of refusal to process cookies, the User must stop using the Company's
website or disable the use of cookies in the browser settings, while some
functions of the Company's website may become unavailable.
5.9.1.6. The addresses of the websites are shown in
Table 1.
6. Updating, correction, deletion and termination
of personal data, responses to requests from subjects for access to personal
data, rights of the personal data subject, duties of the operator
6.1. Rights of personal data subjects
6.1.1. The right of personal data subject
to access his/her personal data
6.1.1.1.
The
personal data subject has the right to receive information (hereinafter
referred to as the information requested by the subject) concerning the
processing of his personal data, including the following:
1) confirmation
of the fact of personal data processing by the Company;
2) legal grounds
and purposes of personal data processing;
3) purposes and
methods of personal data processing used by the Company;
4) name and
location of the Company, information about persons (with the exception of
employees of the Company) who have access to personal data or to whom personal
data may be disclosed on the basis of an agreement with the Company or on the
basis of the Federal Law;
5) processed
personal data related to the respective personal data subject, the source of
their receipt, unless another procedure for submitting such data is provided
for by the Federal Law;
6) terms of
personal data processing, including the terms of their storage;
7) the procedure
for the exercise by a personal data subject of the rights provided for by the
Federal Law "About Personal Data";
8) information
about a cross-border data transfer that has been carried out or is expected to
be carried out;
9) name or last
name, first name, patronymic and address of the person who processes personal
data on behalf of the Company, if the processing is or will be entrusted to
such a person;
10) information
on the ways in which the Company fulfills the obligations set forth in Article
18.1 of the Federal Law "About Personal Data";
11) other
information provided by the Federal Law "About Personal Data" or
other Federal Laws.
6.1.1.2.
The
personal data subject has the right to receive the information requested by the
subject, except in the following cases:
– the processing of personal data,
including personal data obtained as a result of operational search,
counterintelligence and intelligence activities, is carried out for the
purposes of national defense, state security and law enforcement;
– personal data is processed by the
authorities that have detained the subject of personal data on suspicion of
committing a crime or have charged the subject of personal data in a criminal
case, or have applied a preventive measure to the subject of personal data
prior to the indictment, except in cases provided for by the criminal procedure
legislation of the Russian Federation when it is allowed to familiarize the
suspect or accused with such personal data;
– personal data is processed in
accordance with the legislation on countering the legalization (laundering) of
proceeds from crime and financing of terrorism;
– the access of the personal data
subject to his personal data violates the rights and legitimate interests of
third parties;
– personal data is processed in cases
stipulated by the legislation of the Russian Federation on transport security
in order to ensure the stable and safe functioning of the transport complex,
protect the interests of individuals, society and the state in the field of
transport complex from acts of unlawful interference.
6.1.1.3.
The
personal data subject has the right to require the Company to clarify his
personal data, block or destroy them if the personal data is incomplete,
outdated, inaccurate, illegally obtained or is not necessary for the stated
purpose of processing, as well as to take legally prescribed measures to
protect his rights.
6.1.1.4.
The
information requested by the subject must be provided to the personal data
subject by the Company in an accessible form, and it must not contain personal
data related to other personal data subjects, except in cases where there are
legitimate grounds for the disclosure of such personal data.
6.1.1.5.
The requested
information is provided to the personal data subject or his representative by
the Company within ten working days from the date of the request or receipt by
the Company of the request from the personal data subject or his
representative. The specified period may be extended, but not for more than
five working days, if the Company sends a reasoned notification to the personal
data subject indicating the reasons for extending the deadline for providing
the requested information. The request must contain the number of the main
identity document of the personal data subject or his representative,
information about the date of issue of the specified document and the issuing
authority, information confirming the participation of the personal data subject
in relations with the Company (contract number, date of conclusion of the
contract, conditional verbal designation and (or) other information), or
information, otherwise confirming the fact of personal data processing by the
Company, the signature of the personal data subject or his representative
(hereinafter referred to as the information required for the request). The
request can be sent in the form of an electronic document and signed with an
electronic signature in accordance with the legislation of the Russian
Federation. The Company provides the requested information to the personal data
subject or his representative in the form in which the relevant request or
request is sent, unless otherwise specified in the request or inquiry.
6.1.1.6.
If the
information requested by the subject, as well as the personal data being
processed, has been provided to the personal data subject upon his request, the
personal data subject has the right to contact the Company again or send a
second request in order to receive the information requested by the subject and
familiarize himself with such personal data no earlier than thirty days later
(hereinafter referred to as – standardized request period) after the initial
request or sending of the initial request, unless a shorter period is
established by the Federal Law, a regulatory legal act adopted in accordance
with it, or an agreement to which the personal data subject is a party or
beneficiary or guarantor.
6.1.1.7.
The
personal data subject has the right to re-apply to the Company or send a repeat
request in order to obtain the information requested by the subject, as well as
to familiarize himself with the personal data being processed before the
expiration of the normalized request period, if such information and (or) the
personal data being processed have not been provided to him for review in full
based on the results of the review the initial request. The repeated request,
along with the information necessary for the request, must contain a
justification for sending the repeated request.
6.1.1.8.
The
Company has the right to refuse to fulfill a repeated request to a personal
data subject that does not comply with the terms of the repeated request. Such
a refusal must be motivated. The obligation to provide evidence of the validity
of the refusal to fulfill the repeated request lies with the Company.
6.1.2. The rights of personal data subjects
when processing their personal data for the purpose of promoting goods, works,
and services on the market, as well as for political campaigning purposes
6.1.2.1.
The
Company does not process personal data for the purpose of promoting goods,
works, and services on the market through direct contacts with potential
consumers via means of communication, as well as for political campaigning
purposes.
6.1.3. The rights of personal data subjects
when making decisions based solely on automated processing of their personal
data
6.1.3.1.
The
Company does not make decisions based solely on automated processing of
personal data that have legal consequences for the personal data subject or
otherwise affect his rights and legitimate interests.
6.1.4. The right to appeal against the
actions or inaction of the Company
6.1.4.1.
If the
personal data subject believes that the Company is processing his personal data
in violation of the requirements of the Federal Law "About Personal
Data" or otherwise violates his rights and freedoms, the personal data
subject has the right to appeal the actions or inaction of the Company to the
authorized body for the protection of the rights of personal data subjects or
in court.
6.1.4.2.
The personal
data subject has the right to protect his rights and legitimate interests,
including compensation for damages and (or) compensation for moral damage in
court.
6.2. Obligations of the Company
6.2.1. Obligations of the Company in collection of
personal data
6.2.1.1.
When collecting personal data, the Company
provides the personal data subject, upon his request, with the requested
information regarding the processing of his personal data in accordance with
Part 7 of Article 14 of the Federal Law "About Personal Data".
6.2.1.2. If, in
accordance with the Federal Law, the provision of personal data and (or) the
Company's consent to the processing of personal data is mandatory, the Company
explains to the personal data subject the legal consequences of refusing to
provide his personal data and (or) consent to their processing.
6.2.1.3.
If
personal data is not received from the personal data subject, the Company
provides the following information to the personal data subject prior to the
start of processing such personal data (hereinafter referred to as information
provided upon receipt of personal data not from the personal data subject):
1) name or last name, first name, patronymic and address of the
representative of the Company;
2) the purpose of personal data processing and its
legal basis;
3) list of
personal data;
4) intended users of personal data;
5) the rights of the personal data subject established
by the Federal Law "About Personal Data";
6) the source of receiving personal data.
6.2.1.4. The Company does not provide the subject with
information provided upon receipt of personal data not from the subject of
personal data, in cases where:
1) the personal data subject has been notified about
the processing of his/her personal data by the Company;
2) personal data was obtained by the Company on the
basis of the Federal Law or in connection with the execution of a contract to
which the personal data subject is a party or beneficiary or guarantor;
3) the processing of personal data authorized by the personal data subject
for dissemination is carried out in compliance with the prohibitions and
conditions provided for in Article 10.1 of the Federal Law "About Personal Data";
4) The Company processes personal data for statistical or other research
purposes, for the professional activity of a journalist, or for scientific,
literary or other creative activities, provided that the rights and legitimate
interests of the personal data subject are not violated;
5) providing the personal data subject with information provided upon
receipt of personal data not from the personal data subject violates the rights
and legitimate interests of third parties.
6.2.1.5.
When
collecting personal data, including through the Internet information and
telecommunications network, the Company ensures the recording, systematization,
accumulation, storage, clarification (updating, modification), extraction of
personal data of citizens of the Russian Federation using databases located on
the territory of the Russian Federation.
6.2.1.6.
The
location of the data processing center(s) and information about the
organization responsible for data storage are determined by the Company's
internal documents.
6.2.2. Measures
aimed at ensuring that the Company fulfills its obligations
6.2.2.1.
The
Company takes measures necessary and sufficient to ensure the fulfillment of
its duties. The Company independently determines the composition and list of
measures necessary and sufficient to ensure the fulfillment of duties, unless
otherwise provided by the Federal Laws. Such measures include, in particular:
1) appointment of a person responsible for the
organization of personal data processing;
2) the publication of Policies, local acts on the
processing of personal data, as well as local acts establishing procedures
aimed at preventing and detecting violations of the legislation of the Russian
Federation and eliminating the consequences of such violations. Such documents
and local acts may not contain provisions restricting the rights of personal
data subjects, as well as imposing powers and obligations on the Company that
are not provided for by the legislation of the Russian Federation;
3) application of legal, organizational and technical
measures to ensure the security of personal data;
4) implementation of internal control and (or) audit
of compliance of personal data processing with personal data protection
requirements, Policies, and local acts of the Company;
5) assessment of the harm that may be caused to
personal data subjects in case of violation of the Federal Law "About
Personal Data", the ratio of this harm and the measures taken by the
Company aimed at ensuring the fulfillment of obligations stipulated by the
Federal Law "About Personal Data";
6) familiarization of the Company's employees who
directly process personal data with the provisions of the legislation of the
Russian Federation on personal data, including requirements for personal data
protection, documents, Policies, local acts on personal data processing, and
(or) training of these employees.
6.2.3. Measures
to ensure the security of personal data during their processing
6.2.3.1.
When
processing personal data, the Company takes the necessary legal, organizational
and technical measures or ensures their adoption to protect personal data from
unlawful or accidental access to them, destruction, modification, blocking, copying,
provision, dissemination of personal data, as well as from other unlawful
actions in relation to personal data.
6.2.3.2.
Ensuring the security of personal data is
achieved, in particular:
1) identification of threats to the security of
personal data during their processing in personal data information systems;
2) the application of organizational and technical
measures to ensure the security of personal data during their processing in
personal data information systems necessary to meet the requirements for personal
data protection, the implementation of which ensures the levels of personal
data security established by the Government of the Russian Federation;
3) the use of information security tools that have
passed the compliance assessment procedure in accordance with the established
procedure;
4) assessment of the effectiveness of measures taken
to ensure the security of personal data prior to the commissioning of the
personal data information system;
5) taking into account the machine storage of personal
data;
6) detection of unauthorized access to personal data
and taking measures;
7) recovery of personal data modified or destroyed due
to unauthorized access to them;
8) establishing rules for access to personal data
processed in the personal data information system, as well as ensuring
registration and accounting of all actions performed with personal data in the
personal data information system;
9) control over the measures taken to ensure the
security of personal data and the level of security of personal data
information systems.
6.2.3.3.
The use and storage of biometric personal data
outside of personal data information systems may be carried out only on such
material media and with the use of such storage technology that ensures the
protection of this data from unlawful or accidental access to them, their
destruction, modification, blocking, copying, provision, dissemination.
6.2.4. The
Company's obligations when contacting the personal data subject or when
receiving a request from the personal data subject or his representative, as
well as the authorized body for the protection of the rights of personal data
subjects
6.2.4.1.
In
accordance with the established procedure, the Company informs the personal
data subject or his representative about the availability of personal data
related to the relevant personal data subject, and also provides an opportunity
to get acquainted with these personal data when contacting the personal data
subject or his representative, or within ten working days from the date of
receipt of the request from the personal data subject or his representative.
The specified period may be extended, but not for more than five working days
if the Company sends a reasoned notification to the personal data subject
indicating the reasons for extending the deadline for providing the requested
information.
6.2.4.2.
In case of refusal to provide information on the
availability of personal data about the relevant personal data subject or
personal data to the personal data subject or his representative, upon their
request or upon receipt of a request from the personal data subject or his
representative, the Company shall give a reasoned response in writing within a
period not exceeding ten working days from the date of the personal data
subject's request or his representative, or from the date of receipt of the
request from the personal data subject or his representative. The specified
period may be extended, but not for more than five working days if the Company
sends a reasoned notification to the personal data subject indicating the
reasons for extending the deadline for providing the requested information.
6.2.4.3.
The
Company provides free of charge to the personal data subject or his
representative the opportunity to get acquainted with personal data related to
this personal data subject. Within a period not exceeding seven business days
from the date on which the personal data subject or his representative provides
information confirming that the personal data is incomplete, inaccurate or
outdated, the Company makes the necessary changes to them. Within a period not
exceeding seven working days from the date of submission by the personal data
subject or his representative of information confirming that such personal data
was illegally obtained or is not necessary for the stated purpose of
processing, the Company destroys such personal data. The Company notifies the
personal data subject or his representative of the changes made and the
measures taken, and takes reasonable measures to notify third parties to whom
the personal data of this subject has been transferred.
6.2.4.4.
Upon
request of this body, the Company shall provide the necessary information to
the authorized body for the protection of the rights of personal data subjects
within ten working days from the date of receipt of such request. The specified
period may be extended, but not for more than five working days, if the Company
sends a reasoned notification to the authorized body for the protection of the
rights of personal data subjects, indicating the reasons for extending the
deadline for providing the requested information.
6.2.5. The
Company's obligations to eliminate violations of the law committed during the
processing of personal data, to clarify, block and destroy personal data
6.2.5.1.
In case of detection of unlawful processing of
personal data when contacting the personal data subject or his representative,
or at the request of the personal data subject or his representative or the
authorized body for the protection of the rights of personal data subjects, the
Company blocks the unlawfully processed personal data related to this personal
data subject, or ensures their blocking (if the processing of personal data is
carried out by another person, acting on behalf of the Company) from the moment
of such request or receipt of the specified request for the verification
period. In case of detection of inaccurate personal data when contacting a personal
data subject or his representative, or at their request or at the request of
the authorized body for the protection of the rights of personal data subjects,
the Company blocks personal data related to this personal data subject, or
ensures their blocking (if the processing of personal data is carried out by
another person acting on behalf of the Company) from the moment of such request
or receipt of the specified request for the verification period, if the
blocking of personal data does not violate the rights and legitimate interests
of the personal data subject or third parties.
6.2.5.2.
In case of confirmation of the inaccuracy of
personal data, the Company, based on information provided by the personal data
subject or his representative or the authorized body for the protection of the
rights of personal data subjects, or other necessary documents, clarifies the
personal data or ensures their clarification (if personal data is processed by
another person acting on behalf of the Company) within seven working days. days
from the date of submission of such information and removes the blocking of
personal data.
6.2.5.3.
In
case of detection of unlawful processing of personal data carried out by the
Company or a person acting on behalf of the Company, the Company, within a period
not exceeding three working days from the date of this detection, stops the
unlawful processing of personal data or ensures the termination of unlawful
processing of personal data by a person acting on behalf of the Company. If it
is impossible to ensure the legality of the processing of personal data, the
Company, within a period not exceeding ten working days from the date of
detection of the unlawful processing of personal data, destroys such personal
data or ensures their destruction. The Company notifies the personal data
subject or his representative about the elimination of violations or the
destruction of personal data, and if the request of the personal data subject
or his representative or the request of the authorized body for the protection
of the rights of personal data subjects has been sent by the authorized body
for the protection of the rights of personal data subjects, also the specified
body.
6.2.5.4.
If the
fact of unlawful or accidental transfer (provision, dissemination, access) of
personal data is established, which has resulted in a violation of the rights
of personal data subjects, the Company, from the moment such incident is
identified by the Company, the authorized body for the protection of the rights
of personal data subjects or another interested person, notifies the authorized
body for the protection of the rights of personal data subjects:
1) within twenty-four hours – about the incident, about the alleged causes
that led to the violation of the rights of personal data subjects, and the
alleged harm caused to the rights of personal data subjects, about the measures
taken to eliminate the consequences of the relevant incident, as well as about
the person authorized by the Company to interact with the authorized body for
the protection of the rights of personal data subjects, on related to the
identified incident;
2) within seventy-two hours – about the results of the internal
investigation of the identified incident, as well as about the persons whose
actions caused the identified incident (if any).
6.2.5.5.
If the purpose of personal data processing is
achieved, the Company stops processing personal data or ensures its termination
(if the processing of personal data is carried out by another person acting on
behalf of the Company) and destroys personal data or ensures their destruction
(if the processing of personal data is carried out by another person acting on
behalf of the Company) within a period not exceeding thirty days from the date
of achievement of the purpose of personal data processing, unless otherwise
provided by the contract to which the party, the beneficiary or guarantor of
which is the personal data subject, by another agreement between the Company
and the personal data subject, or if the Company is not entitled to process personal
data without the consent of the personal data subject on the grounds provided
for by the Federal Law "About Personal Data" or other Federal Laws.
6.2.5.6.
If the
personal data subject withdraws consent to the processing of his personal data,
the Company stops processing them or ensures the termination of such processing
(if the processing of personal data is carried out by another person acting on
behalf of the Company) and if the storage of personal data is no longer
required for the purposes of personal data processing, destroys the personal
data or ensures their destruction (if personal data is processed by another
person acting on behalf of the Company) on time, not exceeding thirty days from
the date of receipt of the said withdrawal, unless otherwise provided by an
agreement to which the personal data subject is a party, beneficiary or
guarantor, or by another agreement between the Company and the personal data
subject, or if the Company is not entitled to process personal data without the
consent of the personal data subject on the grounds provided for by the Federal
Law "About Personal Data " or other Federal Laws.
6.2.5.7.
If a personal data subject requests the
termination of personal data processing, the Company, within a period not
exceeding ten working days from the date of receipt of the relevant request,
terminates their processing or ensures the termination of such processing (if
such processing is carried out by the person processing personal data), except
for the cases provided for in paragraphs 2-11 of Part 1 Article 6, part 2 of
Article 10 and Part 2 of Article 11 of the Federal Law "About Personal
Data". The specified period may be extended, but not for more than five
working days if the Company sends a reasoned notification to the personal data
subject indicating the reasons for extending the deadline for providing the
requested information.
6.2.5.8.
If it is not possible to destroy personal data
within the specified period, the Company blocks such personal data or ensures
their blocking (if personal data is processed by another person acting on
behalf of the Company) and ensures the destruction of personal data within no
more than six months, unless another period is established by Federal Laws.
6.2.6. Notification
of the processing (intention to process) of personal data
6.2.6.1.
The
Company, with the exception of cases stipulated by the Federal Law "About
Personal Data", notifies the authorized body for the protection of the
rights of personal data subjects of its intention to process personal data
prior to the start of personal data processing.
6.2.6.2. The notification is sent in the form of a paper document or in the form of an electronic document and is signed by an authorized person. The notification contains the following information:
1) name
(last name, first name, patronymic), Company address;
2) purpose
of personal data processing;
3) description
of measures, including information on the availability of encryption
(cryptographic) tools and the names of these tools;
4) last
name, first name, patronymic of the individual or name of the legal entity
responsible for organizing the processing of personal data, and their contact phone
numbers, postal addresses, and email addresses;
5) date
of the beginning of personal data processing;
6) the
term or condition of termination of personal data processing;
7) information
about the presence or absence of cross-border transfer of personal data during
their processing;
8) information about the location of the
database of information containing personal data of citizens of the Russian
Federation;
9) last name, first name, patronymic of an
individual or the name of a legal entity that has access to and (or) processes
personal data contained in state and municipal information systems on the basis
of a contract;
10) information
on ensuring the security of personal data in accordance with the requirements
for the protection of personal data established by the Government of the
Russian Federation.
6.2.6.3.
In the event of a change in the specified
information, the Company, no later than the 15th day of the month
following the month in which such changes occurred, notifies the authorized
body for the protection of the rights of personal data subjects of all changes
that occurred during the specified period. In case of termination of personal
data processing, the Company notifies the authorized body for the protection of
the rights of personal data subjects within ten working days from the date of
termination of personal data processing.
6.2.7. Notification
of cross-border transfer of personal data
6.2.7.1.
Prior
to the start of cross-border transfer of personal data, the Company notifies
the authorized body for the protection of the rights of personal data subjects
of its intention to carry out cross-border transfer of personal data.
6.2.7.2.
The
notification of the cross-border transfer of personal data is sent separately
from the notification of the processing (intention to process) of personal data
provided for in Article 22 of the Federal Law "About Personal Data".
6.2.7.3. The notification is sent in the form of a paper document or in the form of an electronic document and is signed by an authorized person. The notification contains the following information:
1) name (last name, first name, patronymic),
the Company's address, as well as the date and number of the notice of intent
to process personal data previously sent by the Company in accordance with
Article 22 of the Federal Law "About
Personal Data";
2) name (last name, first name,
patronymic) the person responsible for organizing the processing of personal
data, contact phone numbers, postal addresses and email addresses;
3) the legal basis and purpose of the
cross-border transfer of personal data and further processing of the
transferred personal data;
4) categories and list of personal data
to be transferred;
5) categories of subjects of personal
data whose personal data is being transferred;
6) the list of foreign countries in
territory of which the cross-border transfer of personal data is planned;
7) the date of the Company's assessment
of compliance by authorities of foreign states, foreign individuals, and
foreign legal entities to whom the cross-border transfer of personal data is
planned, with the confidentiality of personal data and ensuring the security of
personal data during their processing.
6.2.7.4.
The
assessment of compliance by authorities of foreign states, foreign individuals,
and foreign legal entities to whom the cross-border transfer of personal data
is planned with the confidentiality of personal data and ensuring the security
of personal data during their processing is carried out by the Company on the
basis of information requested in accordance with Part 5 of Article 12 of the
Federal Law "About
Personal Data".
7. Areas of responsibility
7.1. Persons responsible for the
organization of personal data processing in organizations
7.1.1. The Company appoints a person responsible for
the organization of personal data processing.
7.1.2. The person
responsible for organizing the processing of personal data receives
instructions directly from the executive body of the organization that is the
operator and is accountable to it.
7.1.3. The Company provides the person responsible for
organizing the processing of personal data with the necessary information.
7.1.4. The person
responsible for the organization of personal data processing, in particular,
performs the following functions:
1) performs internal control over compliance by the
Company and the Company's employees with the legislation of the Russian
Federation on personal data, including requirements for personal data
protection;
2) informs the Company's employees of the provisions
of the legislation of the Russian Federation on personal data, local acts on
personal data processing and personal data protection requirements;
3) organizes the reception and processing of requests
and requests from personal data subjects or their representatives and/or
monitors the reception and processing of such requests and inquires.
7.2.
Responsibility
7.2.1. Persons guilty of violating the requirements of
the Federal Law "About Personal Data" are liable in accordance with
the legislation of the Russian Federation.
7.2.2. Moral damage caused to a personal data subject
as a result of violation of his rights, violation of the rules for processing
personal data established by the Federal Law "About Personal Data",
as well as requirements for the protection of personal data established in
accordance with the Federal Law "About Personal Data", is subject to
compensation in accordance with the legislation of the Russian Federation.
Compensation for moral damage is carried out independently of compensation for
property damage and losses incurred by the personal data subject.
8. Key results
When the goals are achieved, the following results are expected:
– ensuring the protection of the
rights and freedoms of personal data subjects during the processing of their
personal data by the Company;
– improving the overall level of
information security of the Company;
– minimization of the Company's legal
risks.
9. Coherent policies
There are no coherent policies.
APPENDIX No. 1
to Policy regarding the processing of personal data in Keysystems LLC
dated __ _________20__
Information about
personal data processed by Keysystems LLC
|
List of processed
personal data (PD)* |
PD processing
methods |
PD processing
period |
PD storage period |
|
Purpose of PD processing: maintaining personnel and
accounting records |
|||
|
Employees of Keysystems LLC: Other: full name; information about the name
change; TIN (INN); IIAN (SNILS); gender; date of birth; place of birth; citizenship; registration address; date of registration at the
place of residence; residential address; details of the identity
document; name of the authority that
issued the identity document; date of issue of the
identity document; contact phone numbers; email address; bank details; validity period of the power
of attorney; information about education; details of the education
document; qualification according to
the document of education; information about
postgraduate professional education; profession; job title; structural department; place of work; employee ID number; details of the employment
contract; salary amount; information about
professional development; information about
professional retraining; information contained in the
orders; information about employment
and transfers to other positions; information about foreign
language proficiency; information about annual
leaves (vacations); information about business
trips; employment record data; information about work
activity; information about work
experience; sick leaves certificate data; information about
composition of the family; marital status; information about children; information about social
benefits; information specified in the
writ of execution; information about income; information about taxes; information about insurance
premiums; direction of training or
specialty according to the document of education; relation to military duty
and military rank; information about awards (incentives),
honorary titles; information specified in the
certificate of state registration of the civil status act; driver's license details; other information strictly
necessary to achieve the purposes of personal data processing |
automated |
during the term of the
employment contract |
in accordance with the
regulations governing the storage of personal data |
|
non-automated |
during the term of the
employment contract |
in accordance with the
regulations governing the storage of personal data |
|
|
employees of organizations
belonging to Keysystems Group of companies: other: full name; information about the name
change; TIN (INN); IIAN (SNILS); date of birth; email address; place of birth; gender; citizenship; registration address; date of registration at the
place of residence; residential address; contact phone numbers; details of the identity
document; name of the authority that
issued the identity document; date of issue of the
identity document; bank details; validity period of the power
of attorney; information about education; education document details; qualification according to
the document of education; information about
postgraduate professional education; profession; job title; structural department; place of work; employee ID number; employment contract details; salary amount; information about
professional development; information about professional
retraining; information contained in the
orders; information about employment
and transfers to other positions; information about foreign
language proficiency; information about annual
leaves (vacations); information about business
trips; employment record data; information about work
activity; information about work
experience; sick leaves certificate data; information about composition
of the family; marital status; information about children; information about social
benefits; information specified in the
writ of execution; information about income; information about taxes; information about insurance premiums; relation to military duty
and military rank; information about awards (incentives),
honorary titles; information specified in the
certificate of state registration of the civil status act; driver's license details; other information strictly
necessary to achieve the purposes of personal data processing |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
non-automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
|
close relatives of employees
of Keysystems LLC: other: full name; date of birth; place of birth; information specified in the
certificate of state registration of a civil status act; degree of kinship; place of study; year of study; form of education; field of study or specialty; information specified in the
writ of execution; other information, strictly
necessary to achieve the purposes of personal data processing |
automated |
during the term of the
employee's employment contract |
in accordance with the
regulations governing the storage of personal data |
|
non-automated |
during the term of the
employee's employment contract |
in accordance with the
regulations governing the storage of personal data |
|
|
close relatives of employees
of organizations belonging to Keysystems Group of companies: other: full name; date of birth; place of birth; information specified in the
certificate of state registration of civil status act; degree of kinship; place of study; year of study; form of education; field of study or specialty; information specified in the
writ of execution; other information strictly
necessary to achieve the purposes of personal data processing |
automated |
in
accordance with the regulatory legal acts governing the processing of
personal data |
in
accordance with the regulations governing the storage of personal data |
|
non-automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
|
dismissed employees of Keysystems
LLC: other: full
name; information
about the name change; TIN
(INN); IIAN
(SNILS); date
of birth; place
of birth; gender; citizenship; registration
address; date
of registration at the place of residence; email
address; residential
address; contact
phone numbers; details
of the identity document; name
of the authority that issued the identity document; date
of issue of the identity document; bank
details; validity
period of the power of attorney; information
about education; education
document details; qualification
according to the document of education; information
about postgraduate professional education; profession; job
title; structural
department; place
of work; employee
ID number; employment
contract details; salary
amount; information
about professional development; information
about professional retraining; information
contained in the orders; information
about employment and transfers to other positions; information
about foreign language proficiency; information about annual
leaves (vacation); information about business
trips; employment record data; information about employment; work experience; sick leaves certificate data; the basis for termination of
the employment contract (dismissal); information about dismissal; information about
composition of the family; marital status; information about children; information about social
benefits; information specified in the
writ of execution; information about income; information about taxes; information about insurance
premiums; date of dismissal; direction of training or
specialty according to the education document; relation to military duty
and military rank; information about awards (incentives),
honorary titles; information specified in the
certificate of state registration of civil status act; driver's license details; other information strictly
necessary to achieve the purposes of personal data processing |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
non-automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
|
dismissed employees of
organizations belonging to Keysystems Group of companies: other: full name; information about the name
change; TIN (INN); IIAN (SNILS); Date of birth; place of birth; gender; citizenship; registration address; date of registration at the
place of residence; email address; residential address; contact phone numbers; identity document details; name of the authority that
issued the identity document; date of issue of the
identity document; bank details; validity period of the power
of attorney; information about education; education document details; qualification according to
the education document; information about
postgraduate professional education; profession; job title; structural department; place of work; employee ID number; employment contract details; salary amount; information about
professional development; information about
professional retraining; information contained in the
orders; information about employment
and transfers to other positions; information about foreign
language proficiency; information about annual
leaves (vacations); information about business
trips; employment record data; information about employment; work experience; sick leaves certificate data; basis for termination of the
employment contract (dismissal); information about dismissal; information about
composition of the family; marital status; information about children; information about social
benefits; information specified in the
writ of execution; information about income; information about taxes; information about insurance
premiums; date
of dismissal; direction
of training or specialty according to the document of education; relation
to military duty and military rank; information
about awards (incentives), honorary titles; information
specified in the certificate of state registration of civil status act; driver's
license details; other
information strictly necessary to achieve the purposes of personal data
processing |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
non-automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
|
close relatives of dismissed
employees of Keysystems LLC: other: full
name; date
of birth; place
of birth; information
specified in the certificate of state registration of civil status act; degree
of kinship; place
of study; year
of study; education
form; field
of study or specialty; information
specified in the writ of execution; other
information strictly necessary to achieve the purposes of personal data processing |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
non-automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
|
close relatives of dismissed
employees of organizations belonging to Keysystems Group of companies: other: full name; date of birth; place of birth; information specified in the
certificate of state registration of civil status act; degree of kinship; place of study; year of study; education form; field of study or specialty; information specified in the
writ of execution; other information strictly
necessary to achieve the purposes of personal data processing |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
non-automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
|
Purpose of PD processing: ensuring compliance with the
Labor Legislation of the Russian Federation |
|||
|
employees of Keysystems LLC: special: information about disability; information about criminal
record; reason for working
disability other: full name; information about the name
change; TIN (INN); IIAN (SNILS); gender; date of birth; place of birth; citizenship; registration address; date of registration at the
place of residence; residential address; registration condition; details of the identity
document; name of the authority that
issued the identity document; date of issue of the identity
document; contact phone numbers; email address; bank details; details of the power of
attorney; validity period of the power
of attorney; information about education; education document details; qualification according to
the document of education; information about
postgraduate professional education; profession; job title; structural department; place of work; employee ID number; nature, type of work; employment contract details; salary amount; information about
professional development; information about
professional retraining; information contained in the
orders; information about employment
and transfers to other positions; information about foreign
language proficiency; annual leaves (vacations)
data; business trips data; employment record data; information about employment; work experience; sick leave certificate data; information about family
composition; marital status; information about children; information about social
benefits; information specified in
writs of execution; information about income; information about taxes; information about insurance
premiums; direction of training or
specialty according to educational document; relation to military service
and military rank; information about awards (incentives),
honorary titles; information specified in the
certificate of state registration of civil status act; driver's license details; other information strictly
necessary to achieve the purposes of personal data processing |
automated |
during the term of the
employment contract |
in accordance with the
regulations governing the storage of personal data |
|
non-automated |
during the term of the
employment contract |
in accordance with the
regulations governing the storage of personal data |
|
|
employees of organizations
belonging to Keysystems Group of companies: special: information about disability; information about criminal
record; reason for working
disability other: full name; information about the name
change; TIN (INN); IIAN (SNILS); date of birth; email address; place of birth; gender; citizenship; registration address; date of registration at the
place of residence; residential address; registration condition; contact phone numbers; details of the identity
document; name of the authority that
issued the identity document; date of issue of the
identity document; bank details; details of the power of
attorney; validity period of the power
of attorney; education information; education document details; qualification according to
the document of education; information about
postgraduate professional education; profession; job title; structural department; place of work; employee ID number; nature, type of work; employment contract details; salary amount; information about professional
development; information about
professional retraining; information contained in the
orders; information about employment
and transfers to other positions; information about foreign
language proficiency; information about annual
leaves (vacations); information about business
trips; employment record data; information about
employment; work experience; sick leave certificate data; information about
composition of the family; marital status; information about children; information about social benefits; information specified in the
writ of execution; information about income; information about taxes; information about insurance
premiums; direction of training or
specialty according to the document of education; relation to military duty
and military rank; information about awards
(incentives), honorary titles; information specified in the
certificate of state registration of civil status act; driver’s license details; other information strictly
necessary to achieve the purposes of personal data processing |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
non-automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
|
close relatives of employees
of Keysystems LLC: other: full name; date of birth; place of birth; information specified in the
certificate of state registration of civil status act; degree of kinship; place of study; year of study; form of education; field of study or specialty; information specified in the
writ of execution; other information strictly
necessary to achieve the purposes of personal data processing special: disability information |
automated |
during the term of the
employee’s employment contract |
in accordance with the
regulations governing the storage of personal data |
|
non-automated |
during the term of the
employee’s employment contract |
in accordance with the
regulations governing the storage of personal data |
|
|
close relatives of employees
of organizations belonging to Keysystems Group of companies: other: full name; date of birth; place of birth; information specified in the
certificate of state registration of civil status act; degree of kinship; place of study; year of study; form of education; field of study or specialty; information specified in the
writ of execution; other information strictly
necessary to achieve the purposes of personal data processing special: disability information |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
non-automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
|
dismissed employees of Keysystems
LLC: special: disability information; information about criminal
record; reason for temporary
disability other: full name; information about changing
the name; TIN (INN); IIAN (SNILS); date of birth; place of birth; gender; citizenship; registration address; date of registration at the
place of residence; email address; residential address; registration condition; contact phone numbers; details of the identity
document; name of the authority that
issued the identity document; date of issue of the
identity document; bank details; details of the power of
attorney; validity period of the power
of attorney; education information; education document details; qualification according to
the document of education; information about postgraduate
professional education; profession; job title; structural department; place of work; employee ID number; nature, type of work; employment contract details; salary amount; information about
professional development; information about
professional retraining; information contained in the
orders; information about employment
and transfers to other positions; information about foreign
language proficiency; information about annual
leaves (vacations); information about business
trips; employment record data; information about
employment; work experience; sick leave certificate data; basis for termination of the
employment contract (dismissal); information about dismissal; information about
composition of the family; marital status; information about children; information about social
benefits; information specified in the
writ of execution; information about income; information about taxes; information about insurance
premiums; date of dismissal; direction of training or
specialty according to the document of education; relation to military duty
and military rank; information about awards
(incentives), honorary titles; information specified in the
certificate of state registration of civil status act; driver’s license details; other information strictly
necessary to achieve the purposes of personal data processing |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
non-automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
|
dismissed employees of
organizations belonging to Keysystems Group of companies: special: disability information; information about criminal
record; reason for temporary
disability other: full name; information about changing
the name; TIN (INN); IIAN (SNILS); date of birth; place of birth; gender; citizenship; registration address; date of registration at the
place of residence; email address; residential address; registration condition; contact phone numbers; details of the identity
document; name of the authority that
issued the identity document; date of issue of the
identity document; bank details; details of the power of
attorney; validity period of the power
of attorney; education information; education document details; qualification according to
the document of education; information about
postgraduate professional education; profession; job title; structural department; place of work; employee ID number; nature, type of work; employment contract details; salary amount; information about professional
development; information about
professional retraining; information contained in the
orders; information about employment
and transfers to other positions; information about foreign
language proficiency; information about annual
leaves (vacations); information about business
trips; employment record data; information about
employment; work experience; sick leave certificate data; basis for termination of the
employment contract (dismissal); information about dismissal; information about composition
of the family; marital status; information about children; information about social
benefits; information specified in the
writ of execution; information about income; information about taxes; information about insurance
premiums; date of dismissal; direction of training or
specialty according to the document of education; relation to military duty
and military rank; information about awards
(incentives), honorary titles; information specified in the
certificate of state registration of civil status act; driver’s license details; other information strictly
necessary to achieve the purposes of personal data processing |
automated |
in
accordance with the regulatory legal acts governing the processing of
personal data |
in
accordance with the regulations governing the storage of personal data |
|
non-automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
|
close relatives of dismissed
employees of Keysystems LLC: other: full name; date of birth; place of birth; information specified in the
certificate of state registration of civil status act; degree of kinship; place of study; year of study; form of education; field of study or specialty; information specified in the
writ of execution; other information strictly
necessary to achieve the purposes of personal data processing special: disability information |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
non-automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
|
close relatives of dismissed
employees of organizations belonging to Keysystems Group of companies: other: full name; date of birth; place of birth; information specified in the
certificate of state registration of civil status act; degree of kinship; place of study; year of study; form of education; field of study or specialty; information specified in the
writ of execution; other information strictly
necessary to achieve the purposes of personal data processing special: disability information |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
non-automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
|
Purpose of PD processing: ensuring compliance with the
Tax Legislation of the Russian Federation |
|||
|
employees of Keysystems LLC: other: full name; TIN (INN); IIAN (SNILS); gender; date of birth; place of birth; citizenship; registration address; date of registration at the
place of residence; details of the identity
document; name of the authority that
issued the identity document; date of issue of the
identity document; information about income; information about taxes; information about insurance
premiums; information about deductions; other information strictly
necessary to achieve the purposes of personal data processing |
automated |
during the term of the
employment contract |
in
accordance with the regulations governing the storage of personal data |
|
non-automated |
during the term of the
employment contract |
in
accordance with the regulations governing the storage of personal data |
|
|
employees of organizations
belonging to Keysystems Group of companies: other: full name; TIN (INN); IIAN (SNILS); date of birth; place of birth; gender; citizenship; registration address; date of registration at the
place of residence; details of the identity
document; name of the authority that
issued the identity document; date of issue of the
identity document; information about income; information about taxes; information about insurance
premiums; information about
deductions; other information strictly
necessary to achieve the purposes of personal data processing |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
non-automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
|
close relatives of employees
of Keysystems LLC: other: full name; date of birth; information specified in the
certificate of state registration of civil status act; degree of kinship; other information strictly
necessary to achieve the purposes of personal data processing |
automated |
during the term of the
employee’s employment contract |
in accordance with the
regulations governing the storage of personal data |
|
non-automated |
during the term of the
employee’s employment contract |
in accordance with the
regulations governing the storage of personal data |
|
|
close relatives of employees
of organizations belonging to Keysystems Group of companies: other: full name; date of birth; information specified in the
certificate of state registration of civil status act; degree of kinship; other information strictly
necessary to achieve the purposes of personal data processing |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
non-automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
|
dismissed employees of Keysystems
LLC: other: full name; TIN (INN); IIAN (SNILS); date of birth; place of birth; gender; citizenship; registration address; date of registration at the
place of residence; details of the identity document; name of the authority that
issued the identity document; date of issue of the
identity document; information about income; information about taxes; information about insurance
premiums; information about
deductions; other information strictly necessary
to achieve the purposes of personal data processing |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
non-automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
|
dismissed employees of
organizations belonging to Keysystems Group of companies: other: full name; TIN (INN); IIAN (SNILS); date of birth; place of birth; gender; citizenship; registration address; date of registration at the
place of residence; details of the identity
document; name of the authority that
issued the identity document; date of issue of the
identity document; information about income; information about taxes; information about insurance
premiums; information about
deductions; other information strictly
necessary to achieve the purposes of personal data processing |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
non-automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
|
close relatives of dismissed
employees of Keysystems LLC: other: full name; date of birth; information specified in the
certificate of state registration of civil status act; degree of kinship; other information strictly
necessary to achieve the purposes of personal data processing |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
non-automated |
in
accordance with the regulatory legal acts governing the processing of
personal data |
in
accordance with the regulations governing the storage of personal data |
|
|
close relatives of dismissed
employees of organizations belonging to Keysystems Group of companies: other: full name; date of birth; information specified in the
certificate of state registration of civil status act; degree of kinship; other information strictly
necessary to achieve the purposes of personal data processing |
automated |
in
accordance with the regulatory legal acts governing the processing of
personal data |
in
accordance with the regulations governing the storage of personal data |
|
non-automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
|
Purpose of PD processing: ensuring compliance with Pension
Legislation of the Russian Federation |
|||
|
employees of Keysystems LLC: other: full name; IIAN (SNILS); date of birth; job title; nature, type of work; date of employment; transfer date; date of dismissal; other information strictly
necessary to achieve the purposes of personal data processing |
automated |
during the term of the
employment contract |
in accordance with the
regulations governing the storage of personal data |
|
non-automated |
during the term of the
employment contract |
in accordance with the
regulations governing the storage of personal data |
|
|
employees
of organizations belonging to Keysystems Group of companies: other: full
name; IIAN
(SNILS); date
of birth; job
title; nature,
type of work; date
of employment; transfer
date; date
of dismissal; other
information strictly necessary to achieve the purposes of personal data
processing |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
non-automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
|
dismissed employees of Keysystems
LLC: other: full name; IIAN (SNILS); date of birth; job title; nature, type of work; date of employment; transfer date; date of dismissal; other information strictly
necessary to achieve the purposes of personal data processing |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
non-automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
|
dismissed employees of
organizations belonging to Keysystems Group of companies: other: full name; IIAN (SNILS); date of birth; job title; nature, type of work; date of employment; transfer date; date of dismissal; other information strictly
necessary to achieve the purposes of personal data processing |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
non-automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
|
Purpose of PD processing: ensuring compliance with the
Insurance Legislation of the Russian Federation |
|||
|
employees of Keysystems LLC: other: full name; TIN (INN); IIAN (SNILS); date of birth; details of the identity
document; name of the authority that
issued the identity document; date of issue of the
identity document; bank details; work experience; sick leave certificate data; information specified in the
certificate of state registration of civil status act; banking details, date of
issue of the certificate of state registration of civil status act; banking details, date of
issue of the certificate of state registration of civil status act; other information strictly
necessary to achieve the purposes of personal data processing special: reason for temporary
disability |
automated |
during the term of the employment
contract |
in accordance with the
regulations governing the storage of personal data |
|
non-automated |
during the term of the
employment contract |
in accordance with the
regulations governing the storage of personal data |
|
|
employees
of organizations belonging to Keysystems Group of companies: other: full
name; TIN
(INN); IIAN
(SNILS); date
of birth; details
of the identity document; name
of the authority that issued the identity document; date
of issue of the identity document; bank
details; work
experience; sick
leave certificate data; information
specified in the certificate of state registration of civil status act; banking
details, date of issue of the certificate of state registration of civil
status act; banking
details, date of issue of the certificate of state registration of civil
status act; other
information strictly necessary to achieve the purposes of personal data
processing special: reason
for temporary disability |
automated |
in accordance with the regulatory
legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
non-automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
|
close relatives of employees
of Keysystems LLC: other: full
name; IIAN
(SNILS); date
of birth; information
specified in the certificate of state registration of civil status act; details
of the identity document; name
of the authority that issued the identity document; date
of issue of the identity document; place
of work; job
title; banking
details, date of issue of the certificate of state registration of civil
status act; banking
details, date of issue of the certificate of state registration of civil
status act; period
of work at the current place of work; other
information strictly necessary to achieve the purposes of personal data
processing |
automated |
during the term of the
employee’s employment contract |
in accordance with the
regulations governing the storage of personal data |
|
non-automated |
during the term of the
employee’s employment contract |
in accordance with the
regulations governing the storage of personal data |
|
|
close relatives of employees
of organizations belonging to Keysystems Group of companies: other: full
name; IIAN
(SNILS); date
of birth; information
specified in the certificate of state registration of civil status act; details
of the identity document; name
of the authority that issued the identity document; date
of issue of the identity document; place
of work; job
title; banking
details, date of issue of the certificate of state registration of civil
status act; banking
details, date of issue of the certificate of state registration of civil
status act; period
of work at the current place of work; other
information strictly necessary to achieve the purposes of personal data
processing |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
non-automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
|
dismissed employees of Keysystems
LLC: other: full name; TIN (INN); IIAN (SNILS); date of birth; details of the identity
document; name of the authority that
issued the identity document; date of issue of the
identity document; bank details; work experience; sick leave certificate data; date of dismissal; information specified in the
certificate of state registration of civil status act; banking details, date of
issue of the certificate of state registration of civil status act; banking details, date of
issue of the certificate of state registration of civil status act; other information strictly
necessary to achieve the purposes of personal data processing special: reason for temporary
disability |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
non-automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
|
dismissed employees of
organizations belonging to Keysystems Group of companies: other: full name; TIN (INN); IIAN (SNILS); date of birth; details of the identity
document; name of the authority that
issued the identity document; date of issue of the
identity document; bank details; work experience; sick leave certificate data; date of dismissal; information specified in the
certificate of state registration of civil status act; banking details, date of
issue of the certificate of state registration of civil status act; banking details, date of
issue of the certificate of state registration of civil status act; other information strictly necessary
to achieve the purposes of personal data processing special: reason for temporary
disability |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
non-automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
|
close relatives of dismissed
employees of Keysystems LLC: other: full name; IIAN (SNILS); date of birth; information specified in the
certificate of state registration of civil status act; details of the identity
document; name of the authority that
issued the identity document; date of issue of the
identity document; place of work; job title; banking details, date of
issue of the certificate of state registration of civil status act; banking details, date of
issue of the certificate of state registration of civil status act; period of work at the
current place of work; other information strictly
necessary to achieve the purposes of personal data processing |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
non-automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
|
close relatives of dismissed
employees of organizations belonging to Keysystems Group of companies: other: full name; IIAN (SNILS); date of birth; information specified in the
certificate of state registration of civil status act; details of the identity document; name of the authority that
issued the identity document; date of issue of the
identity document; place of work; job title; banking details, date of
issue of the certificate of state registration of civil status act; banking details, date of
issue of the certificate of state registration of civil status act; period of work at the
current place of work; other information strictly
necessary to achieve the purposes of personal data processing |
automated |
in
accordance with the regulatory legal acts governing the processing of
personal data |
in
accordance with the regulations governing the storage of personal data |
|
non-automated |
in
accordance with the regulatory legal acts governing the processing of
personal data |
in
accordance with the regulations governing the storage of personal data |
|
|
Purpose of PD processing: organization of Voluntary Medical
Insurance |
|||
|
employees of Keysystems LLC: other: full name; date of birth; registration address; contact phone numbers; job title; place of work; other information strictly
necessary to achieve the purposes of personal data processing |
automated |
during the term of the
employment contract |
in accordance with the
regulations governing the storage of personal data |
|
non-automated |
during the term of the
employment contract |
in accordance with the
regulations governing the storage of personal data |
|
|
close relatives of employees
of Keysystems LLC: other: full
name; date
of birth; information
specified in the certificate of state registration of civil status act; gender; details
of the identity document; name
of the authority that issued the identity document; date
of issue of the identity document; residential
address; other
information strictly necessary to achieve the purposes of personal data processing |
non-automated |
during the term of the
employee’s employment contract |
in accordance with the
regulations governing the storage of personal data |
|
Purpose of PD processing: recruitment of personnel
(applicants) for vacant operator positions |
|||
|
individuals who are job
candidates (applicants): other: full name; photo; date of birth; gender; information about foreign
language proficiency; education information; residential address; work experience; marital status; contact phone numbers; email address; place of work; information about employment; availability of a driver’s
license; driver’s license category; citizenship; other information strictly
necessary to achieve the purposes of personal data processing |
automated |
in accordance with the regulatory
legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
non-automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
|
Purpose of PD processing: provision of introductory,
industrial or pre-graduate internship on the basis of an agreement with an
educational institution |
|||
|
students undergoing internship: other: full name; TIN (INN); IIAN (SNILS); date of birth; place of study; year of study; field of study or specialty; details of the identity
document; name of the authority that
issued the identity document; date of issue of the
identity document; registration address; date of registration at the
place of residence; residential address; email address; faculty; dates of internship; terms of internship; information specified in the
review of the head of the internship about the intern's work (at the end of
the internship); other information strictly
necessary to achieve the purposes of personal data processing |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
non-automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
|
Purpose of PD processing: organization of preliminary
and periodic medical examinations for employees |
|||
|
employees of Keysystems LLC: other: full name; gender; date of birth; profession; job title; structural department; place of work; medical examination report; other information strictly
necessary to achieve the purposes of personal data processing |
non-automated |
during the term of the
employment contract |
in accordance with the
regulations governing the storage of personal data |
|
Purpose of PD processing: implementation of the Loyalty
Program |
|||
|
employees of Keysystems LLC: other: full name; TIN (INN); employee status; details of the identity
document; name of the authority that
issued the identity document; date of issue of the
identity document; information about loyalty
program bonus points; job title; employee ID number; work experience; date of employment; international passport
details; name of the authority that
issued the international passport; date of issue of the
international passport; other information strictly
necessary to achieve the purposes of personal data processing |
automated |
during the term of the
employment contract |
in accordance with the
regulations governing the storage of personal data |
|
close
relatives of employees of Keysystems LLC: other: full
name; information
specified in the certificate of state registration of civil status act; details
of the identity document; name
of the authority that issued the identity document; date
of issue of the identity document; international
passport details; name
of the authority that issued the international passport; date
of issue of the international passport; other
information strictly necessary to achieve the purposes of personal data
processing |
automated |
during
the term of the employee’s employment contract |
in
accordance with the regulations governing the storage of personal data |
|
Purpose of PD processing: provision of corporate mobile
communication services |
|||
|
employees of Keysystems LLC: other: full name; date of birth; registration address; details of the identity
document; name of the authority that
issued the identity document; date of issue of the
identity document; contact phone numbers; other information strictly
necessary to achieve the purposes of personal data processing |
automated |
during the term of the
employment contract |
in accordance with the
regulations governing the storage of personal data |
|
non-automated |
during the term of the
employment contract |
in accordance with the
regulations governing the storage of personal data |
|
|
Purpose of PD processing: issuance and accounting of
loans |
|||
|
employees of Keysystems LLC: other: full name; TIN (INN); IIAN (SNILS); date of birth; place of birth; citizenship; registration address; details of the identity
document; name of the authority that
issued the identity document; date of issue of the
identity document; contact phone numbers; bank details; job title; structural department; place of work; loan amount; loan term; loan interest rate; information about loans; information required to
obtain a loan for the purchase of secondary housing and housing in a building
under construction (in the case of obtaining a loan); other information strictly
necessary to achieve the purposes of personal data processing |
automated |
during the term of the loan
agreement |
in accordance with the
regulations governing the storage of personal data |
|
non-automated |
during the term of the loan
agreement |
in accordance with the
regulations governing the storage of personal data |
|
|
borrowers: other: full name; TIN (INN); IIAN (SNILS); date of birth; place of birth; citizenship; registration address; contact phone numbers; details of the identity
document; name of the authority that
issued the identity document; date of issue of the identity
document; bank details; job title; structural department; place of work; loan amount; loan terms; loan interest rate; information about loans; information required to
obtain a loan for the purchase of secondary housing and housing in a building
under construction (in the case of obtaining a loan); other information strictly
necessary to achieve the purposes of personal data processing |
automated |
during the term of the loan
agreement |
in accordance with the
regulations governing the storage of personal data |
|
non-automated |
during the term of the loan
agreement |
in accordance with the
regulations governing the storage of personal data |
|
|
Purpose of PD processing: conclusion of targeted
training contracts |
|||
|
individuals with whom a
targeted training contract has been concluded: other: full
name; TIN
(INN); IIAN
(SNILS); details
of the identity document; name
of the authority that issued the identity document; date
of issue of the identity document; registration
address; residential
address; contact
phone numbers; email
address; bank
account details; place
of study; faculty; field
of study or specialty; other
information strictly necessary to achieve the purposes of personal data
processing |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
non-automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
|
legal representatives of
individuals with whom a targeted training agreement has been concluded: other: full name; TIN (INN); IIAN (SNILS); details of the identity
document; name of the authority that
issued the identity document; date of issue of the
identity document; registration address; residential address; contact phone numbers; email address; other information strictly
necessary to achieve the purposes of personal data processing |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
non-automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
|
Purpose of PD processing: preparation, conclusion and
execution of a civil law contract |
|||
|
persons who are in a civil
and legal relationship with Keysystems LLC: other: full
name; TIN
(INN); IIAN
(SNILS); gender; contact
phone numbers; date
of birth; email
address; place
of birth; citizenship; registration
address; details
of the identity document; name
of the authority that issued the identity document; date
of issue of the identity document; bank
details; details
of the civil law contract; date
of registration at the place of residence; other
information strictly necessary to achieve the purposes of personal data
processing |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
non-automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
|
persons who have civil
relations with organizations belonging to Keysystems Group of companies: other: full name; TIN (INN); IIAN (SNILS); date of birth; gender; contact phone numbers; place of birth; email address; citizenship; registration address; details of the identity
document; name of the authority that
issued the identity document; date of issue of the identity
document; bank details; details of the civil law
contract; date of registration at the
place of residence; other information strictly
necessary to achieve the purposes of personal data processing |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
non-automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
|
counterparties
(representatives of counterparties and individual entrepreneurs): other: full name; TIN (INN); date of birth; gender; place of birth; contact phone numbers; email address; bank details; registration address; details of the identity
document; name of the authority that
issued the identity document; date of issue of the
identity document; payment amount; place of work; job title; other information strictly
necessary to achieve the purposes of personal data processing |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
non-automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
|
Purpose of PD processing: ensuring access to the
operator's territory |
|||
|
employees of Keysystems LLC: other: full name; photo; job title; employee ID number; other information strictly
necessary to achieve the purposes of personal data processing |
automated |
during the term of the
employment contract |
in accordance with the
regulations governing the storage of personal data |
|
non-automated |
during the term of the
employment contract |
in accordance with the
regulations governing the storage of personal data |
|
|
employees of organizations
belonging to Keysystems Group of companies: other: full name; photo; job title; employee ID number; other information strictly
necessary to achieve the purposes of personal data processing |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
non-automated |
in
accordance with the regulatory legal acts governing the processing of
personal data |
in
accordance with the regulations governing the storage of personal data |
|
|
visitors: other: full
name; type
of identity document; other
information strictly necessary to achieve the purposes of personal data
processing |
non-automated |
in
accordance with the regulatory legal acts governing the processing of
personal data |
in
accordance with the regulations governing the storage of personal data |
|
Purpose of PD processing: maintaining a corporate
portal |
|||
|
employees of Keysystems LLC: other: full name; date of birth; photo; registration condition; contact phone numbers; email address; job title; structural department; place of work; employee ID number; date of employment; information about absences; end term according to the
registration condition; other information strictly
necessary to achieve the purposes of personal data processing |
automated |
during the term of the employment
contract |
in accordance with the
regulations governing the storage of personal data |
|
employees of organizations
belonging to Keysystems Group of companies: other: full name; date of birth; email address; registration condition; contact phone numbers; photo; job title; structural department; place of work; employee ID number; date of employment; information
about absences; end
term according to the registration condition; other
information strictly necessary to achieve the purposes of personal data
processing |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
Purpose of PD processing: software development and
provision of services in the field of software supply; provision of
consulting support to software users; conducting training courses; fulfilling
the terms of contracts and agreements; maintaining an official website;
organizing access to information about the organization's activities posted
on the Internet information and telecommunications network; providing access
to information about employees' birthdays posted on a video panel in the
lobby of the building; implementing other statutory tasks |
|||
|
employees of Keysystems LLC: other: full
name; information
about changing the name; TIN
(INN); gender; date
of birth; photo; registration
address; date
of employment; details
of orders; residential
address; details
of the identity document; name
of the authority that issued the identity document; date
of issue of the identity document; contact
phone numbers; email
address; bank
details; details
of the power of attorney; validity
period of the power of attorney; education
information; job
title; structural
department; place
of work; employee
ID number; information
about employment and transfers to other positions; information
about business trips; information
about employment; other
information strictly necessary to achieve the purposes of personal data
processing |
automated |
during the term of the
employment contract |
in accordance with the
regulations governing the storage of personal data |
|
employees of organizations
belonging to Keysystems Group of companies: other: full name; information about changing
the name; TIN (INN); date of birth; email address; gender; registration address; details of orders; residential address; contact phone numbers; details of the identity
document; name of the authority that
issued the identity document; date of issue of the
identity document; photo; bank details; details of the power of
attorney; validity period of the power
of attorney; education information; job title; structural department; place of work; employee ID number; information about employment
and transfers to other positions; information about business
trips; other information strictly
necessary to achieve the purposes of personal data processing |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the regulations
governing the storage of personal data |
|
persons who are in a civil
and legal relationship with Keysystems LLC: other: full name; information about changing
the name; TIN (INN); gender; contact phone numbers; date
of birth; email
address; place
of work; residential
address; structural
department; registration
address; job
title; details
of the identity document; name
of the authority that issued the identity document; date
of issue of the identity document; photo; bank
details; details
of the power of attorney; validity
period of the power of attorney; other
information strictly necessary to achieve the purposes of personal data
processing |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
persons who have civil
relations with organizations belonging to Keysystems Group of companies: other: full
name; information
about changing the name; TIN
(INN); date
of birth; gender; contact
phone numbers; email
address; residential
address; place
of work; registration
address; structural
department; details
of the identity document; job
title; name
of the authority that issued the identity document; date
of issue of the identity document; photo; bank
details; details
of the power of attorney; validity
period of the power of attorney; other
information strictly necessary to achieve the purposes of personal data
processing |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
counterparties
(representatives of counterparties and individual entrepreneurs): other: full name; information about changing
the name; TIN (INN); date of birth; gender; place of birth; essence of the appeal; citizenship; contact phone numbers; email address; bank details; registration address; details of the identity
document; name of the authority that
issued the identity document; date of issue of the
identity document; place of work; structural department; job title; other information strictly
necessary to achieve the purposes of personal data processing |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
non-automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
|
partners’ representatives: other: address; full name; information about changing
the name; TIN (INN); date of birth; gender; place of birth; citizenship; contact phone numbers; email address; registration address; details of the identity
document; name of the authority that
issued the identity document; date of issue of the
identity document; bank details; place of work; structural department; job title; other information strictly
necessary to achieve the purposes of personal data processing |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
non-automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
|
persons to whom an
electronic digital signature has been issued: other: full
name; TIN
(INN); IIAN
(SNILS); date
of birth; gender; place
of birth; citizenship; contact
phone numbers; email
address; registration
address; details
of the identity document; name
of the authority that issued the identity document; date
of issue of the identity document; place
of work; structural
department; job
title; bank
details; photo |
non-automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
students
of the courses conducted by Keysystems LLC: other: full
name; contact
phone numbers; email
address; year
of study; field
of study or specialty; place
of study; other
information strictly necessary to achieve the purposes of personal data
processing |
automated |
in
accordance with the regulatory legal acts governing the processing of
personal data |
in
accordance with the regulations governing the storage of personal data |
|
non-automated |
in
accordance with the regulatory legal acts governing the processing of
personal data |
in
accordance with the regulations governing the storage of personal data |
|
|
persons taking advanced
training courses: other: full name; information about changing
the name; contact phone numbers; email address; place of work; structural department; job title; education information; other information strictly
necessary to achieve the purposes of personal data processing |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
non-automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
|
persons who filled out the
feedback form and (or) registered on the self-service portal of Keysystems website,
forum users: other: full name; contact phone numbers; email address; place of work; structural department; job title; information contained in the
message |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
website visitors: other: information collected
through metric programs |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
mobile application users: other: full name; photo; contact phone numbers; email address; place of work; job title |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
Purpose of PD processing: organization of access to
information about employees of Keysystems LLC, hosted in the Internet |
|||
|
employees of Keysystems LLC: other: full name; photo; contact phone numbers; email address; job title; structural department; place of work; information about work
experience |
automated |
during the term of the
employment contract |
in accordance with the
regulations governing the storage of personal data |
|
Purpose of PD processing: analysis of the behavioral
characteristics of users on the website |
|||
|
website visitors: other: information collected
through metric programs |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
Purpose of PD processing: organization of access to
information about the partners of Keysystems LLC, posted on the Internet |
|||
|
partners’ representatives: other: full name |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
Purpose of PD processing: organization of access to
information about employees of R.O.S.T.U. LLC, posted on the Internet |
|||
|
employees of R.O.S.T.U. LLC: other: full name; photo; contact phone numbers; email address; place of work; job title |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
Purpose of PD processing: establishing of feedback
with User |
|||
|
persons who filled out the
feedback form: other: full name; contact phone numbers; email address; place of work; job title; region; country; other information contained
in the request |
automated |
in accordance with the regulatory
legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
Purpose of PD processing: organization of access to
information about the event speakers |
|||
|
Event speakers: other: full name; photo; place of work; job title |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
Purpose of PD processing: maintaining the self-service
portal |
|||
|
event speakers: other: full name |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
users of the self-service portal: other: full
name; contact
phone numbers; place
of work; job
title; region |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
persons who left the appeal: other: last name, first name,
patronymic; region; other information contained
in the appeal |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
Purpose of PD processing: registration in the
application |
|||
|
mobile application users: other: full name; date of birth; city/region; contact phone numbers; email address; place of work; job title; other information strictly
necessary to achieve the purposes of personal data processing |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
Purpose of PD processing: organization of the Marketing
Department's activities |
|||
|
employees of Keysystems LLC: other: full name; contact phone numbers; email address; job title; structural department |
automated |
during the term of the
employment contract |
in accordance with the
regulations governing the storage of personal data |
|
counterparties
(representatives of counterparties and individual entrepreneurs): other: full name; TIN (INN); contact phone numbers; email address; place of work; job title |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
|
event participants: other: full name; contact phone numbers; email address; place of work; job title |
automated |
in accordance with the
regulatory legal acts governing the processing of personal data |
in accordance with the
regulations governing the storage of personal data |
*PD – personal data
APPENDIX No. 2
to Policy regarding the processing of personal data in Keysystems LLC
dated __ _________20__
Information about the
order for the processing of personal data carried out by Keysystems LLC
|
Name and location
of the person to whom the PD are transferred * |
List of PD |
|
Purpose of
receiving PD processing: issuance of a bank card,
payroll and other payments |
|
|
Sberbank of Russia PJSC (Vavilova
Str., 19, 117312, Moscow) |
employees
of Keysystems LLC: other categories of PD: full name; date of birth; details
of the identity document; name of the authority that issued the identity
document; date of issue of the identity document; registration address; bank
details; payment amount |
|
Gazprombank JSC (Nametkina
Str., 16, build. 1, 117420, Moscow) |
employees
of Keysystems LLC: other categories of PD: full name; date of birth; details
of the identity document; name of the authority that issued the identity
document; date of issue of the identity document; registration address; bank
details; payment amount |
|
VTB bank JSC (Degtyarnyy
Lane, 11А, 191144, Saint Petersburg) |
employees
of Keysystems LLC: other categories of PD: full name; date of birth; details
of the identity document; name of the authority that issued the identity
document; date of issue of the identity document; registration address; bank
details; payment amount |
|
Purpose of
receiving PD processing: implementation of the
voluntary health insurance program |
|
|
ENERGOGARANT Insurance Joint
Stock Company (Sadovnicheskaya Embankment, 23, 115035, Moscow) |
employees
of Keysystems LLC: other categories of PD: full name; date of birth; place
of work; details of the identity document; name of the authority that issued
the identity document; date of issue of the identity document; job title; registration
address; contact phone numbers |
|
employees
of organizations belonging to Keysystmes Group of companies: other categories of PD: full name; date of birth; details
of the identity document; name of the authority that issued the identity
document; date of issue of the identity document; registration address; contact
phone numbers; place of work; job title |
|
|
AlfaStrakhovanie
JSC (Nizhegorodskaya Str., 4, office 13, 428000, Cheboksary, the Chuvash
Republic) |
employees of Keysystems LLC: other
categories of PD: full
name; date of birth; address; contact phone numbers |
|
Purpose
of receiving PD processing: provision
of corporate mobile communication services |
|
|
VimpelCom
PJSC (8th of March Str., 10, build. 14, 127083, Moscow) |
employees of Keysystems LLC: other
categories of PD: full
name; date of birth; details of the identity document; name of the authority
that issued the identity document; date of issue of the identity document; job
title; registration address; contact phone numbers; IIAN (SNILS) |
|
Purpose
of receiving PD processing: conducting
preliminary and periodic medical examinations |
|
|
Budgetary
institution of the Chuvash Republic called Republican Narcological Dispensary
of the Ministry of Health of the Chuvash Republic (Pirogova Str., 6, 428015, Cheboksary,
the Chuvash Republic) |
employees of Keysystems LLC: other
categories of PD: full
name; date of birth; place of work; structural department; job title; gender |
|
Budgetary
institution of the Chuvash Republic called Republican Psychiatric Hospital of
the Ministry of Health of the Chuvash Republic (Pirogova Str., 6, 428015, Cheboksary,
the Chuvash Republic) |
employees of Keysystems LLC: other
categories of PD: full
name; date of birth; place of work; structural department; job title; gender |
|
Budgetary
institution of the Chuvash Republic called City Clinical Hospital No. 1 of
the Ministry of Health of the Chuvash Republic (Traktotostroiteley Ave., 46, 428028,
Cheboksary, the Chuvash Republic) |
employees of Keysystems LLC: other
categories of PD: full
name; date of birth; place of work; structural department; job title; gender |
|
Primary
trade union organization of the budgetary institution of the Chuvash Republic
called First Cheboksary City Hospital named after Petr N. Osipov, Honored
Doctor of the RSFSR of the Ministry of Health of the Chuvash Republic (K.
Ivanova Str., 14, 428018, Cheboksary, the Chuvash Republic) |
employees
of Keysystems LLC: other categories of PD: full name; date of birth; place
of work; structural department; job title; gender |
|
Purpose of
receiving PD processing: fulfillment of the terms of
the loan contract |
|
|
Sberbank of Russia PJSC (Vavilova
Str., 19, 117312, Moscow) |
employees
of Keysystems LLC: other categories of PD: full name; date of birth; details
of the identity document; name of the authority that issued the identity
document; date of issue of the identity document; TIN (INN); place of birth; registration
address; IIAN (SNILS); bank details; loan amount |
|
borrowers: other categories of PD: full name; date of birth; details
of the identity document; name of the authority that issued the identity
document; date of issue of the identity document; TIN (INN); place of birth; registration
address; IIAN (SNILS); loan amount |
|
|
Gazprombank JSC (Nametkina
Str., 16, build. 1, 117420, Moscow) |
employees
of Keysystems LLC: other categories of PD: full name; date of birth; details
of the identity document; name of the authority that issued the identity
document; date of issue of the identity document; TIN (INN); place of birth; registration
address; IIAN (SNILS); bank details; loan amount |
|
borrowers: other categories of PD: full name; date of birth; details
of the identity document; name of the authority that issued the identity document;
date of issue of the identity document; TIN (INN); place of birth; registration
address; IIAN (SNILS); bank details; loan amount |
|
|
VTB bank JSC (Degtyarnyy
Lane, 11A, 191144, Saint Petersburg) |
employees of Keysystems LLC: other
categories of PD: full
name; date of birth; details of the identity document; name of the authority
that issued the identity document; date of issue of the identity document; TIN
(INN); place of birth; registration address; IIAN (SNILS); bank details; loan
amount |
|
borrowers: other
categories of PD: full
name; TIN (INN); IIAN (SNILS); date of birth; place of birth; details of the
identity document; name of the authority that issued the identity document; date
of issue of the identity document; registration address; bank details; loan
amount |
|
|
Purpose of
receiving PD processing: printing business cards |
|
|
NN Press Printing House LLC
(Mashinostroiteley driveway, 1, build. С, 428022, Cheboksary, the Chuvash Republic) |
employees
of Keysystems LLC: other categories of PD: full name; contact phone
numbers; email address; place of work; structural department; job title |
|
Purpose of
receiving PD processing: booking/purchase of hotel
rooms and transportation tickets for business trips |
|
|
Keysystems Tour LLC (M. Gorky
Ave., 18b, 428000, Cheboksary, the Chuvash Republic) |
employees
of Keysystems LLC: other categories of PD: full name; gender; date of
birth; details of the identity document; contact phone numbers; email address |
|
Purpose of
receiving PD processing: administration of the
official website |
|
|
Rostelecom PJSC (Sinopskaya
Embankment, 14A, 191167, intracity territory of a federal city of Smolninskoye
Municipal District, Saint Petersburg) |
employees
of Keysystems LLC: other categories of PD: full name; photo; contact
phone numbers; email address; place of work; structural department; job
title; information about employment record |
|
partners’ representatives: other
categories of PD: full
name |
|
|
website visitors: other
categories of PD: information
collected through metric programs |
|
|
persons who filled out the feedback
form: other
categories of PD: full
name; contact phone numbers; email address; place of work; job title; country;
region |
|
|
Purpose of
receiving PD processing: reporting to regulatory authorities |
|
|
SKB Kontur Production
Company JSC (Narodnaya Volya Str., 19A, 620144, Ekaterinburg, Sverdlovsk
region) |
employees
of Keysystems LLC: other categories of PD: full
name; TIN (INN); IIAN (SNILS); gender; date of birth; citizenship; details of
the identity document; name of the authority that issued the identity
document; date of issue of the identity document; structural department; job
title; date of employment; transfer date; date of dismissal; details of
orders; information specified in the certificate of state registration of
civil status act; information about income; information about taxes; information
about insurance premiums; information about deductions |
|
persons
who have civil relations with Keysystems LLC: other categories of PD: full name; TIN (INN); IIAN
(SNILS); gender; date of birth; citizenship; details of the identity document;
name of the authority that issued the identity document; date of issue of the
identity document |
|
|
Purpose of
receiving PD processing: transfer of commission for
work performed (services rendered) |
|
|
Sberbank of Russia PJSC (Vavilova
Str., 19, 117312, Moscow) |
persons
who have civil relations with Keysystems LLC: other categories of PD: full name; bank details; payment
amount |
|
Gazprombank JSC (Nametkina
Str., 16, build. 1, 117420, Moscow) |
persons
who have civil relations with Keysystems LLC: other categories of PD: full name; bank details; payment
amount |
|
VTB bank JSC (Degtyarnyy
Lane, 11A, 191144, Saint Petersburg) |
persons
who have civil relations with Keysystems LLC: other categories of PD: full name; bank details; payment
amount |
|
Purpose of
receiving PD processing: transfer of the scholarship |
|
|
Sberbank of Russia PJSC (Vavilova
Str., 19, 117312, Moscow) |
individuals
with whom a targeted training contract has been concluded: other categories of PD: full name; bank details; payment
amount |
|
Gazprombank JSC (Nametkina
Str., 16, build. 1, 117420, Moscow) |
individuals
with whom a targeted training contract has been concluded: other categories of PD: full name; bank details; payment
amount |
|
VTB bank JSC (Degtyarnyy
Lane, 11A, 191144, Saint Petersburg) |
individuals
with whom a targeted training contract has been concluded: other categories of PD: full name; bank details; payment
amount |
*PD – personal data.
APPENDIX No. 3
to Policy regarding the processing of personal data in Keysystems LLC
dated __ _________20__
Information about the
cross-border transfer of personal data carried out by Keysystems LLC
|
Name and location
of the person to whom the personal data are transferred* |
List of PD
transferred |
Legal basis of
cross-border transfer |
Methods of PD processing |
Actions for PD processing |
|
Purpose of cross-border transfer of PD: organization of business trips
for employees of the Organization |
||||
|
Somon Air LLC (Mirzo
Mastongulova Str., 40, Tajikistan, 734012, г. Dushanbe) |
employees of Keysystems LLC: other categories of PD: full name; gender; date of
birth; citizenship; details of the identity document; contact phone numbers; email
address; structural department; job title; international passport details |
- presence of consent of the
subject of personal data to the processing of his/her personal data (consent
of the subject of personal data to the processing of personal data) |
automated and non-automated |
Collection, Recording,
Systematization, Accumulation, Storage, Clarification (updating, changing),
Extraction, Use, Transfer (provision, access), Blocking, Deletion,
Termination |
|
Nebuchadnezzar FZ‑LLC (103104, 103&104,
First Floor, Building 14, Dubai Internet City, Dubai, United Arab Emirates) |
employees of Keysystems LLC: other categories of PD: full name; gender; date of
birth; citizenship; details of the identity document; passport details; information
specified in the certificate of state registration of civil status act; contact
phone numbers; email address |
- presence of consent of the
subject of personal data to the processing of his/her personal data (consent
of the subject of personal data to the processing of personal data) |
automated and non-automated |
Collection, Recording,
Systematization, Accumulation, Storage, Clarification (updating, changing),
Extraction, Use, Transfer (provision, access), Blocking, Deletion,
Termination |
|
Belavia JSC (Nemiga Str., 14A,
220004, Minsk, Belarus) |
employees of Keysystems LLC: other categories of PD: full name; gender; date of
birth; citizenship; details of the identity document; contact phone numbers; email
address; passport details; information specified in the certificate of state
registration of the civil status act |
- presence of consent of the
subject of personal data to the processing of his/her personal data (consent
of the subject of personal data to the processing of personal data) |
automated and non-automated |
Collection, Recording,
Systematization, Accumulation, Storage, Clarification (updating, changing),
Extraction, Use, Transfer (provision, access), Blocking, Deletion,
Termination |
|
Purpose of cross-border transfer of PD: Organization's participation in procurement |
||||
|
Republican Unitary
Enterprise called Information and Computing Center of the Ministry of Finance
of the Republic of Belarus (Kalvaryiskaya Str., 17, 220004, Minsk, Belarus) |
employees of Keysystems LLC: other categories of PD: full name; profession; place
of work; job title; education information; professional experience; other
information necessary to achieve the purpose of personal data processing |
- presence of consent of the
subject of personal data to the processing of his/her personal data (consent
of the subject of personal data to the processing of personal data) |
automated and non-automated |
Collection, Recording, Systematization,
Accumulation, Storage, Clarification (updating, changing), Extraction, Use,
Transfer (provision, access), Blocking, Deletion, Termination |
|
Purpose of cross-border transfer of PD: Organization's participation
in the international investment conference |
||||
|
Ministry of industry and
Advanced Technology (000000, Muhaisnah, Muhaisanah 2, Dubai, United Arab
Emirates) |
employees of Keysystems LLC: other categories of PD: full name; contact phone
numbers; email address; place of work; job title; country; photo; details of
the identity document special categories of PD: nationality |
- presence of consent of the
subject of personal data to the processing of his/her personal data (consent
of the subject of personal data to the processing of personal data) |
automated and non-automated |
Collection, Recording,
Systematization, Accumulation, Storage, Clarification (updating, changing),
Extraction, Use, Transfer (provision, access), Blocking, Deletion,
Termination |
*PD – personal data.
INTRODUCTION PAGE
with the Policy
regarding the processing of personal data in Keysystems LLC
|
No. |
Full name |
Job title |
Date |
Signature |
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