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Personal data processing policy

Data use, treatment and protection policies of the African network of audiovisual, theater,
radio and new technology writers.

PERSONAL DATA TREATMENT POLICY

 

Data use, treatment and protection policies of the African network of audiovisual, theater, radio and new technology writers.

 

DATA CONTROLLER :

Name: Pan-African Alliance of Screenwriters & Filmmakers (APASER)

Address: VR 57 E Mahazoarivo Antananarivo 101 – Madagascar

Phone: (+261) 345434695

Email: infos@apaser.africa

 

  1. Types of personal data processed and purposes of the treatment:

The Controller may collect, store, use, circulate or delete the following Personal Data of its members, partners and affiliates, those persons with whom it has labor or commercial or business contractual relations, of the personnel of said persons, or of the visitors to the offices and facilities of The Controller (jointly "Owners"), according to the type of Owners, as specified below:

 

  • Personal data of employees, former employees and dependents of these and purposes of the treatment:

  • Identification data such as: morphological description, name, nationality, identity document number, address, telephone, physical or postal address, email, date and place of birth, marital status, position or title, contact information, location of the workplace, your handwritten and/or electronic signature.

  • Biometric data of the holders, such as their personal image captured through the cameras installed in the offices of THE CONTROLLER, fingerprints, photographs, videos and voice recordings.

  • Identification data of their relatives, beneficiaries or third parties such as: name, nationality, identity document number, address, telephone, physical or postal address, email, date and place of birth and marital status.

  • Information on the results of tests, laboratories, studies, medical diagnoses, general or specialized, psychological or psychiatric, medical or therapeutic of any kind, medical and occupational health history, as well as the support of safety studies and home visits made to the holders. Likewise, information is collected on disabilities and vulnerable situations in which the holders may find themselves.

  • Labor information including: resume, work history, academic certificates and professional experience, information on your current position, bosses and performance evaluation in your position, previous jobs, education, certifications obtained, competence, personal references, labor certificates, support of selection processes, interviews, psychotechnical and technical tests, home visit report, and any training, exams and respective notes;

 

  • Information on the employment relationship between THE CONTROLLER and the employee, including income, salaries, benefits and assistance, retirement documents, settlements, employment contract termination letters, resignation letters and supporting documents for all such information.

  • Financial information, including the bank account number, the type of account and the banking entities where the employee has the account, payroll and credit supports with any external entity.

  • Documents related to employee performance, including the results of comprehensive evaluations, results of talent and development processes, organizational climate, action plans, coaching processes, among others.

  • Access data to the different systems that are provided by THE CONTROLLER in its capacity as employer, such as users, access codes, IP addresses and employee browsing profiles.

  • Documents supporting judicial and disciplinary records, including dismissals, warnings and suspensions.

THE CONTROLLER collects and processes the Personal Data of the holders to comply with the normal development of its corporate purpose and to comply with the legal and contractual obligations of THE CONTROLLER in its capacity as employer.

 

In general terms, Personal Data is required for contractual purposes, affiliations, payroll payment processes, for the management of loans and liens of the holders, to comply with legal obligations in occupational health, and for the development of recreational activities, communications, demographic analysis and social balance of THE CONTROLLER. Likewise, Personal Data is required for internal procedures of THE CONTROLLER, including but not limited to the management of security incidents, for compliance with entry requirements to THE CONTROLLER, employee profile support and for the administration of labor certifications. that are issued by the company. Similarly,

 

THE CONTROLLER collects and processes Personal Data to provide medical care to its employees, which includes carrying out medical assessments, carrying out health promotion and disease prevention programs (detection and monitoring of possible cases of diseases). Likewise, THE CONTROLLER collects and processes Personal Data for the management of employees' medical disabilities and the management of accidents at work and/or occupational diseases.

 

Likewise, THE CONTROLLER collects and processes your Personal Data to carry out the management and management of human talent by the administrative area and to guarantee efficient productivity of THE CONTROLLER's employees. They will also be used for internal control purposes and for the development of employee health and wellness programs. Additionally, THE CONTROLLER may also use the data of the employees and the personnel of the contractors to carry out different labor well-being programs, as well as to carry out activities that will include but are not limited to training, contests and promotional activities.

 

The Personal Data of the personnel of THE CONTROLLER's contractors are collected and processed in order to comply with the obligations derived from the contracts between said Contractors and THE CONTROLLER.

 

THE RESPONSIBLE may also process the Personal Data of its employees and the personnel of its contractors, through the monitoring of work tools and technological resources (which may include, but are not limited to computers, email accounts, text messages, data, landlines or mobile phones, etc.) that THE CONTROLLER has made available to its employees for the following purposes:

 

  • Protect and prevent the abuse of said work tools and technological resources;

  • Protect the employees of THE RESPONSIBLE and prevent the commission of crimes;

  • Guarantee that THE CONTROLLER complies with the obligations contained in the contracts it signs;

  • Safeguard the personal data for which it is responsible;

  • Comply with legal obligations of THE CONTROLLER in the framework of eventual or existing litigation;

  • Prevent the theft or unauthorized disclosure of confidential information of THE CONTROLLER;

  • Detect eventual or current violations of other policies of THE CONTROLLER;

  • Prevent the inappropriate and inadequate use of the technological resources of THE CONTROLLER;

  • Prevent intrusions or malicious or unauthorized access and spread of computer viruses;

  • Protect the data and/or systems of THE CONTROLLER and prevent the occurrence of situations that may threaten said data or systems;

  • Increase the productivity of the employees of THE CONTROLLER;

  • Verify that THE CONTROLLER's systems are accessed only by authorized persons.

  • Similarly, for the security and verification of proper behavior within the facilities of THE CONTROLLER, the image of all employees, contractors' staff and visitors to the facilities of THE CONTROLLER, may be captured through cameras or other devices of a similar nature, located in the facilities of THE CONTROLLER.

  • Finally, THE RESPONSIBLE may deliver the personal data that it collects to the public, judicial and administrative authorities, in order to comply with the legal obligations that derive from the activities carried out by the company.

 

THE RESPONSIBLE will only use the Personal Data within the use that has been authorized by the owners of the same, and will only transmit and/or transfer them to its related companies, clients or third parties, when this is necessary as a result of the ordinary course of business. operation of THE CONTROLLER and the relevant authorities when required in accordance with applicable laws. THE RESPONSIBLE will safeguard and protect the Personal Data received at his address, limiting its use and disclosure to the authorized object. In those cases in which THE CONTROLLER transfers your personal data to third parties, it will obtain your prior, express and informed consent to do so. In those cases in which THE CONTROLLER transmits your personal data to third parties, it will do so in compliance with legal requirements,

 

In the case of Personal Data of employees of THE CONTROLLER, the revocation of the consent granted to THE CONTROLLER for the collection and processing of Personal Data, prevents the development of the employment contract between the employee and THE CONTROLLER, and therefore, said request for Revocation may lead to the termination of the employment relationship. The foregoing has no application in relation to the sensitive information that THE CONTROLLER collects from its employees, in accordance with article 6 of Decree 1377 of 2013 or those regulations that add or modify it.

 

Personal information may be obtained electronically, through electronic messages of a personal or work nature, information filed in THE CONTROLLER's system, voice messages, recorded telephone calls (prior notice), information stored in THE CONTROLLER's computers, fax system, Internet access, or through any other electronic device for communications and any other technological resource that has been provided by THE CONTROLLER to its employees.

 

THE CONTROLLER may consult documents and reports prepared by third parties within the selection process, understood as employment agencies, companies that provide security and surveillance services, companies that carry out comprehensive security evaluations and polygraph tests applied to human talent, or any other company related to this type of services.

 

  • Personal data of members, partners and affiliates and purposes of the treatment:

a) Identification data such as: morphological description, name, nationality, identity document number, address, telephone, physical or postal address, email, date and place of birth, marital status, position or title, contact information, and Workplace.

b) Data related to the works of members, partners and affiliates and the collections made by THE RESPONSIBLE for the use thereof.

These Personal Data are used to fulfill the main purpose of existence of THE CONTROLLER, which is to administer and manage the works contained in the repertoire of works of the members, partners and affiliates of THE CONTROLLER. THE RESPONSIBLE may give access to this Personal Data to the DNDA in the exercise of its functions of inspection, surveillance and control.

THE CONTROLLER may transfer the Personal Data of the members, partners and affiliates of THE RESPONSIBLE to those countries with which it has signed representation and reciprocal representation agreements.

For these purposes, data protection clauses have been included in the aforementioned agreements to guarantee that the Personal Data transferred is being safeguarded in accordance with suitable security measures and is being processed exclusively for the purposes described.

When the users of the works that make up the repertoire of works managed by THE CONTROLLER, in a motivated manner request THE CONTROLLER, THE CONTROLLER may deliver the list of authors and works that make up said repertoire.

 

  • Personal data of third parties with commercial links or of other kinds different from labor and purposes of the treatment

a) Identification data such as: morphological description, name, nationality, identity document number, address, telephone, physical or postal address, email, date and place of birth, marital status, position or title, contact information, and Workplace.

b) Information that is sent to THE CONTROLLER or consulted through the databases of universities, websites or social networks such as Linkedin, El Empleo.com, among other means where the Holders have included their Personal Data. THE RESPONSIBLE may also collect information such as resume, work history, academic certificates and professional experience, information on the current position, bosses and performance evaluation in their position, previous jobs, education, certifications obtained, skills, personal references, certificates employment, selection process supports, interviews, psychotechnical and technical tests, home visit report, and any training, exams and respective notes of the Holders;

c) Biometric data of the Holders, such as the personal image captured through the cameras installed in the offices or facilities of THE CONTROLLER, fingerprints, photographs, videos and voice recordings.

d) Information on medical history and occupational health. Likewise, THE CONTROLLER may collect information on the legal and/or disciplinary records of the Holders.

e) Data for access to information systems, such as users, passwords, IP addresses and profiles.

f) In certain cases THE CONTROLLER will collect sensitive data such as membership in unions, social, political or human rights organizations, data on their ethnic-racial origin, and information on conditions of vulnerability.

THE RESPONSIBLE will process the Personal Data of a financial nature of Holders only when this information is necessary to be able to carry out the billing, portfolio, collection and payment processes for the products and services that have been provided or supplied to and by THE CONTROLLER , and for the sending of the invoices through the means that would have been agreed.

 

   2. PERSONNEL POLICY:

HE RESPONSIBLE will itself be responsible and in charge of data processing; if required, it could subcontract to CONTROLLERS for the treatment of certain information, if this situation occurs THE RESPONSIBLE will warn said Holders about the commitment to protect personal information with appropriate security measures, the use of information for their own purposes will be prohibited and it will be requested that it not be disclosed to others. Likewise, THE RESPONSIBLE, will be in charge of including data protection clauses in contracts that imply the circulation of personal data and signing the transmission and/or data transfer contracts that are required, in accordance with the legal requirements that govern said contracts, in order to adequately protect the personal data for which it is responsible.

 

   3. RIGHTS OF HOLDERS, SERVICE CHANNELS, RESPONSIBLE AREA AND PROCEDURE FOR THEIR EXERCISE

THE RESPONSIBLE will advocate for the protection of the following rights of the HOLDERS of personal data, whether they are exercised by themselves or through their representative and/or proxy or successor in title: right of access, right to update, rectify and delete, right to request proof of authorization, right to be informed regarding the use of your personal data, right to file complaints with the Superintendency of Industry and Commerce, right to request compliance with orders issued by the Superintendency of Industry and Commerce.

 

For the effective exercise of the aforementioned rights, THE CONTROLLER makes the following service channels available to the owner, whose responsible area is the administrative area of ​​The Controller:

Address: VR 57 E Mahazoarivo Antananarivo 101 – Madagascar

Phone: (+261) 345434695

Email: infos@apaser.africa

The request, complaint or claim must contain the identification of the Holder, the description of the facts that give rise to the claim, the address, and accompanying the documents that you want to assert. If the claim is incomplete, the interested party will be required within five (5) business days following receipt of the claim to correct the failures. After two (2) months from the date of the request, without the applicant submitting the required information, it will be understood that he has withdrawn the claim.

In the event that the person receiving the claim is not competent to resolve it, they will transfer it to the corresponding person within a maximum term of two (2) business days and inform the competent person of the situation. The maximum term to address the claim will be ten (10) business days from the day following the date of receipt. When it is not possible to address the claim within said term, the interested party will be informed of the reasons for the delay and the date on which their claim will be addressed, which in no case may exceed eight (8) business days following the expiration of the first finished.

 

PARAGRAPH : For the purposes of exercising the rights described above, both the Holder and the person representing him must demonstrate his identity and, if applicable, the capacity by virtue of which he represents the holder.

 

   4. SECURITY POLICY:

THE CONTROLLER will protect the information in its databases according to the security principle established , adopting the tools that are necessary to avoid adulteration of the personal data registered in it: technical, human and administrative measures.

THE RESPONSIBLE will record the privacy notice in the data collection form, letting the owner of the personal data know the purpose for which the data will be used and the availability of the treatment policies and by what means they can access them.

All persons involved in the Processing of personal data are obliged to guarantee the confidentiality of the information, even after the end of their relationship with any of the tasks included in the Treatment.

   5. VALIDITY OF THIS POLICY:

This Policy of use, treatment and protection of data of THE RESPONSIBLE entered into force on January 23, 2023. The Responsible will keep and process your personal data until the purposes for which they were collected have been fulfilled, or in case there is special legal provision, at the end of the term of time established in said legal provision. Notwithstanding the foregoing, Personal Data will be processed and stored when required to comply with a legal or contractual obligation.

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