Employee Personal Information Privacy Notice

This Privacy Notice tells you how we will use and store the information you give us when you apply to work or volunteer at Awem Games Limited (“Awem Games”). Data controller: Awem Games Limited (“Awem Games”). Awem Games collects and processes personal data relating to its employees to manage the employment relationship. Awem Games is committed to being transparent about how it collects and uses that data and to meet its data protection obligations.

What information does Awem Games collect?

Awem Games collects and processes a range of information about you. This includes:
  • your name, address and contact details, including email address and telephone number, date of birth and gender;
  • the terms and conditions of your employment;
  • details of your qualifications, skills, experience and employment history, including start and end dates, with previous employers and with Awem Games;
  • information about your remuneration, including entitlement to benefits (if applicable);
  • details of your bank account and national insurance number;
  • information about your marital status, next of kin, dependants and emergency contacts;
  • information about your nationality and entitlement to work in the Cyprus;
  • information about your criminal record;
  • details of your schedule (days of work and working hours) and attendance at work;
  • details of periods of leave taken by you, including holiday, sickness absence, family leave and sabbaticals, and the reasons for the leave;
  • details of any disciplinary or grievance procedures in which you have been involved, including any warnings issued to you and related correspondence;
  • assessments of your performance, including appraisals, performance reviews and ratings, performance improvement plans and related correspondence.
Awem Games may collect this information in a variety of ways. For example, data might be collected through application forms, CVs or resumes; obtained from your passport or other identity documents such as your driving license; from correspondence with you; or through interviews, meetings or other assessments.

In some cases, Awem Games may collect personal data about you from third parties, such as references supplied by former employers, information from employment background check providers, information from credit reference agencies and information from criminal records checks permitted by law.

Data will be stored in a range of different places, including in your personnel file, in Awem Games’ HR management systems and in other IT systems (including Awem Games’ email system).

Why does Awem Games process personal data?

Awem Games needs to process data to enter into an employment contract/agreement with you and to meet its obligations under your employment contract/agreement. For example, it needs to process your data to provide you with an employment contract, to pay you in accordance with your employment contract and to administer [benefit, pension, and
insurance entitlements].

In some cases, Awem Games needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check an employee’s entitlement to work in Cyprus, to deduct tax, to comply with health and safety laws and to enable employees to take periods of leave to which they are entitled.

In other cases, Awem Games has a legitimate interest in processing personal data before, during and after the end of the employment relationship.

Processing employee data allows Awem Games to:
  • run recruitment and promotion processes;
  • maintain accurate and up-to-date employment records and contact details (including details of who to contact in the event of an emergency), and records of employee contractual and statutory rights;
  • operate and keep a record of disciplinary and grievance processes, to ensure acceptable conduct within the workplace;
  • operate and keep a record of employee performance and related processes, to plan for career development, and for succession planning and workforce management purposes;
  • operate and keep a record of absence and absence management procedures, to allow effective workforce management and ensure that employees are receiving the pay or other benefits to which they are entitled;
  • operate and keep a record of other types of leave (including maternity, paternity, adoption, parental and shared parental leave), to allow effective workforce management, to ensure that Awem Games complies with duties in relation to leave entitlement, and to ensure that employees are receiving the pay or other benefits to which they are entitled;
  • ensure effective general HR and business administration;
  • provide references on request for current or former employees;
  • respond to and defend against legal claims.
Some special categories of personal data, such as information about health or medical conditions, may be processed to carry out employment law obligations (such as those in relation to employees with disabilities).

Who has access to data?

Your information may be shared internally, including with members of the HR and recruitment team (including payroll), your line manager, managers in the service/business area in which you work and IT staff if access to the data is necessary for the performance of their roles.

Awem Games shares your data with third parties in order to obtain pre-employment references from other employers, obtain employment background checks from third-party providers. Awem Games may also share your data with third parties in the context of a sale of some or all of its business. In those circumstances, the data will be subject to confidentiality

Awem Games also may share your data with third parties that process data on its behalf, in connection with payroll, pension providers, absence management system, HR consultants, the provision of benefits and the provision of occupational health services.

International Transfers

Your personal data may be transferred outside of the country where you
work, including to countries that do not provide the same level of protection for your personal information. Awem Games is committed to protecting the privacy and confidentiality of personal information when it is transferred. Where such transfers occur, we will assure that adequate protection exists either through appropriate contractual arrangements or as required by law.

How does Awem Games protect data?

Awem Games takes the security of your data seriously. Awem Games has internal policies and controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by its employees in the performance of their duties. Access to HR systems is restricted to senior managers and the chief executive and HR

Where Awem Games engages third parties to process personal data on its behalf, they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organizational measures to ensure the security of data.

For how long does Awem Games keep data?

Awem Games will hold your personal data as long as necessary to achieve the purpose for which it was collected, usually for the duration of any contractual relationship and for any period thereafter as legally required or permitted by applicable law.

Your rights

As a data subject, you have a number of rights. You can:
  • access and obtain a copy of your data on request;
  • require Awem Games to change incorrect or incomplete data;
  • require Awem Games to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
  • object to the processing of your data where Awem Games is relying on its legitimate interests as the legal ground for processing.
If you would like to exercise any of these rights, please contact e-mail:
job@awem.com or phone +35799993770 and ask to speak to the Head of Recruitment.

If you believe that Awem Games has not complied with your data protection rights, you can complain to the Commissioner for the Protection of Personal Data.

What if you do not provide personal data?

You have some obligations under your employment contract to provide Awem Games with data. In particular, you are required to report absences from work and may be required to provide information about disciplinary or other matters under the implied duty of good faith. You may also have to provide Awem Games with data in order to exercise your rights, such as in relation to leaving entitlements. Failing to provide the data may mean that you are unable to exercise your rights.

Certain information, such as contact details, your right to work in the Cyprus and payment details, have to be provided to enable Awem Games to enter a contract of employment with you. If you do not provide other information, this will hinder Awem Games’ ability to administer the rights and obligations arising as a result of the employment relationship efficiently.

Automated decision-making

Employment decisions are not based solely on automated decision-making.
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