Protection of Whistleblowers - Imlitex Holdings

Employees Personal Data Processing in IMLITEX HOLDINGS Companies’ Group

Companies belonging to the Imlitex Holdings, UAB group of companies, where personnel management services are provided centrally to all companies of the group of companies by UAB Imlitex Service Center, are subject to the same procedures and standards for the processing and protection of employees' personal data. Personal data of the Company's employees are processed:

For the purpose of concluding, executing and accounting employment contracts in accordance with the GDPR Art. 6 Para 1 Item (b) the following employee data are processed: personal code, name, surname, date of birth, place of residence, telephone number, e-mail, social security number, curriculum vitae data, copies of the documents that justify CV facts (diplomas, certificates, statements, etc.), amount of salary, amounts and types of taxes paid, amount and type of social benefits, amounts and type of claim recoveries as per enforcement orders, information on health status, bank account number, the data on the family members (dates of birth of the children). The term of processing these data is defined by the legislation applicable in the Republic of Lithuania;
For the purpose of enforcing other agreements between the employer and the employees pursuant to the GDPR Art. 6 Para 1 Items (a) and (b) the following data are processed: accumulation of pensions, life and health insurance, execution of loan agreements, professional development, etc. The term of processing these data is defined by the legislation applicable in the Republic of Lithuania;
For the purposes of work-related electronic communication (e-mail and publicly available contact information) and communication with the employee during working hours on the basis of the employer's legitimate interest in accordance with the GDPR Art. 6 Para 1 Item (f) and as per the employee consent in line with the GDPR Art. 6 Para 1 Item (a) the contact details and images of employees are processed. On the basis of GDPR Art. 6 Item (f) the name and surname of the employee are used for making his/her work e-mail address, and the name, surname, position, telephone number, e-mail address are processed in the Contacts sections on the websites. Based on the employee's consent (GDPR Art. 6 Para 1 Item (a)), his/her image might be processed in the websites Contacts. Electronic mailbox data is stored for 3 years after the termination of the employment relationship, other data is destroyed within 5 working days after the end of the employment relationship;
Due to the legitimate interest of the employer (based on the GDPR Art. 6 Para 1 Item (f)) to contact employees outside working hours, the addresses of the employees' place of residence, personal telephone numbers and personal e-mail addresses are processed. It is necessary for the employer to process these data in order to contact the employee in case of emergency in connection with the performance of work functions. These data are destroyed within one month of the end of the employment relationship, but in certain cases, with the employee's written consent, the employer may process his/her contact details beyond the end of the employment relationship, for example, if a former long-term employee is to be invited to events organized by the employer;
For the purpose of protecting the material resources of the employer and ensuring public order in accordance with the GDPR Art. 6 Para 1 Item (f) In some business locations owned or leased by the employer, video data may be processed which includes real-time video surveillance where individuals might be identified, as well as making a video recording without sound. These data shall be processed for 30 calendar days, unless an investigation into a possible breach of law or internal work procedures has been initiated;
For the purpose of the Company's car protection and fuel efficiency monitoring in accordance with the GDPR Art. 6 Para 1 Item (f) the following data relating to the employee may be processed (in the case the employee is assigned a Company car due to his/her work duties): vehicle trajectory, travelling start and end times and kilometers traveled, average and maximum speed of the vehicle, location of the vehicle, direction of movement of the car, name, surname and workplace of the employee driving the car. These data are processed for one year, or while an investigation or legal proceedings are pending for a possible violation of the Road Traffic Rules, other legal acts or internal work procedures;
Employees in certain positions may be offered participation in employer incentive schemes. By agreement between the employee and the employer, as per the GDPR Art. 6 Para 1 Item (b), the following personal data of the employee may be processed: name, surname, position, workplace address, work e-mail address, work telephone number. These data are processed during the employee's work in the Company and destroyed in accordance with the procedure established by national and internal legal acts;
In order to create an appropriate environment for employee cooperation and friendly communication, counseling and learning, with the consent of the employee, in accordance with the GDPR Art. 6 Para 1 Item (a,) the following personal data of the employee are processed: name, surname, position, work address, date of birth, work e-mail address, work phone number, and facial image. These data shall be destroyed within one month after the end of the employment relationship, unless otherwise provided by the applicable legislation. The employee's personal data may not be processed for these purposes if the employee has not consented to it or must destroyed if the employee has revoked his/her consent to the processing of personal data;
In order to invite persons to fill a vacancy, personal data contained in the candidates' own curricula vitae shall be processed. The following data are regarded sufficient for the application to a vacancy: name, surname, date of birth, place of residence, telephone number, e-mail address, information on education, relevant professional qualifications, level of foreign language skills, valid driving license and work experience, feedback from a former employer. Excess documents and data (e.g., image, copies of identity documents, diplomas, etc.) provided by the candidates themselves separately from the curriculum vitae, will be destroyed if it is technically possible. The data of non-selected candidates will be destroyed within three months of the end of the selection process. With the consent of the candidate, his/her personal data may be processed for up to two years.