Privacy Policy

This Regulation has as its scope of application: The Processing of Personal Data.

This Regulation covers the processing of personal data of employees, trainees, candidates, customers and suppliers (individuals).

1. Scope of Application

The Company respects the legal norms regarding the protection of personal data of its workers, job applicants, trainees, customers and suppliers (individuals), namely those that stem from national legal provisions and resolutions of the National Data Protection Commission.

2. Personal Data of Workers

O tratamento dos dados pessoais do trabalhador, no âmbito da relação laboral, decorre por um lado quer do conteúdo contratual, quer por outro, do cumprimento de obrigações legais, perante a AT, segurança Social, a ACT e demais entidades oficiais.

O tratamento dos dados pessoais dos trabalhadores é reservado apenas ao responsável de tratamento de dados designado a cada momento e com acesso limitado devidamente justificados nos termos da lei e, em qualquer caso, com salvaguarda da confidencialidade.

Em qualquer altura o trabalhador poderá, a seu pedido, aceder aos seus dados protegidos e solicitar a sua alteração ou correção, caso haja erro ou incompletude.

Os trabalhadores gozam, em conformidade com a lei, dos direitos de informação, acesso e oposição ao tratamento dos seus dados pessoais. Para o exercício desses direitos de acesso, e de oposição, têm de apresentar, por escrito, o pedido ao Responsável pelo Tratamento de Dados, no departamento de Recursos Humanos.

Os trabalhadores podem nos termos legais exercer o direito ao esquecimento dos seus dados pessoais, exceto nos casos previstos para o cumprimento de obrigações legais.

O tratamento dos dados clínicos dos trabalhadores, obedece ao regime de tratamento de dados sensíveis e são por isso exclusivamente de acesso ao médico da empresa ou à equipa médica certificada, tendo o trabalhador acesso aos mesmos desde que previamente os solicite diretamente ao médico de trabalho.

Com a celebração do contrato, e durante essa execução, o trabalhador dá o seu consentimento a que os seus dados pessoais, possam ser armazenados sob forma digital segura, processados e acedidos nos termos previamente especificados ou pontualmente especificados.

The processing of the employee’s personal data, within the scope of the employment relationship, arises, on one hand, from the contractual content, or, on the other, from the fulfillment of legal obligations, before the AT, Social Security, ACT and other official entities.

The processing of employees’ personal data is reserved only to the data controller designated at any time and with limited access, duly justified under the terms of the law and, in any case, with confidentiality safeguarded.

At any time, the employee may, at his/her request, access his/her protected data and request its alteration or correction, in the event of an error or incompleteness.

Workers enjoy, in accordance with the law, the rights of information, access and opposition to the processing of their personal data. To exercise these rights of access, and opposition, you must submit the request in writing to the Data Processing Officer in the Human Resources department.

Employees may, under legal terms, exercise the right to forget their personal data, except in cases provided for in compliance with legal obligations.

The processing of clinical data of employees follows the regime for the treatment of sensitive data and is therefore exclusively accessible to the company physician or the certified medical team, with the employee having access to them as long as they previously request them directly from the occupational physician.

With the conclusion of the contract, and during this execution, the employee gives his/her consent that his/her personal data may be stored in a secure digital form, processed and accessed under the terms previously specified or occasionally specified.

2.1 Purpose of processing personal data of employees

Personal data of people that are collected and processed by the Company for the following purposes:

  • Administrative management;
  • Calculation and payment of remuneration, benefits, allowances and subsidies;
  • Calculation and withholding tax related to mandatory or optional remuneration discounts, arising from a legal provision;
  • Execution of a court decision or sentence, as well as handling requests made by workers;
  • Dealing with other matters relating to remuneration, benefits, allowances; 
  • Issuance of training certificates by the employer and/or external training bodies;
  • Issuance of travel tickets, visas and / or other documents arising from the need for travel by the employee;
  • Records and attendance and/or access control;
  • Compliance with legal obligations in the field of safety and health at work.

2.2 Categories of personal data to be collected

For the purposes mentioned above, the entity may collect personal data as well as copies and original copies of the respective documents that are included in the following categories:

  • Identification data;
  • Family situation;
  • Data relating to professional activity;
  • Data relating to remuneration;
  • Other data comply with the fulfillment provided for in the previous article.

2.3 Data Retention Period

For the purpose of administrative management of workers, training certificates and documents necessary for issuing travel tickets and/or visas, the data may be kept for a legal period after termination of the employment relationship, and other accounting and tax obligations.

For the purposes of remuneration, benefits and benefits for employees, data may be kept for a maximum period provided for by law;

The period of the respective data may be extended for reasons of legal action, after the transfer of the data to the judicial institutions or the final and unappealable decision.

For the purposes of pensions, social security or the payment of subsequent supplementary benefits, due after the termination of the employment relationship, the strictly necessary data to prove the quality of the worker, the length of service and evolution of the remuneration may be kept within the legal deadlines by correspondence to each purpose.

2.4 Recipients of workers’ personal data

2.4.1- The following are eventually recipients of personal data:

a) The entities to which the data must be communicated by virtue of a legal provision or request of the data subject;

b) Financial institutions that manage the entity’s accounts for the payment of employees’ remuneration;

c) The management entities of Pension Funds or Pension Funds;

d) The insurance companies with which the work accident or personal accident contract is signed;

e) Training bodies for issuing training certificates;

f) Travel agencies or transport companies to issue documentation necessary for travel;

g) The Accounting/HR department for the purpose of processing Salary or obligations;

h) To auditing entities (internal or external) within the scope of certification processes;

I) External consulting entities within the scope of their provision of consultancy services;

j) Entities that, in the scope of Occupational Medicine and Safety, ensure at all times the fulfillment of these obligations in the company;

Entities that provide IT management in the processing of personal data.

2.4.2- External entities (Subcontractors) to whom, within the scope of this regulation, the personal data of employees are provided, are contractually subject to compliance with legal obligations in terms of data protection that are attributed to the Responsible for the Processing of Data.

2.5 Photos/Films/Recordings

It is prohibited to photograph, film or carry out any type of recording, or other process of copying and/or reproducing personal documents, without the consent of the data subject, except in cases provided for by law or duly authorized by a competent entity for the purpose.

3. Personal Data of Job Seekers

The company guarantees the safeguard of the right to protection of the data of job seekers, which are voluntarily and authorized by the Data Subject, to which they will be treated confidentially, under the terms of the law in force.

Our company’s recruitment privacy policy is defined in a specific document that forms an integral part of these Internal Regulations.

4. Personal Data of Trainees, Trainers and Candidates

The processing of the personal data of trainees and trainers, on the one hand, either from the contractual content or on the other from the fulfilment of legal obligations, before the official entities.

The processing of personal data of trainees and trainers is reserved only to the data controller designated at each moment, and with limited access duly justified under the law, in any case with confidentiality safeguarded.

At any time, the trainee/trainer may, at his/her request, access his/her protected data and request its alteration or correction, in case there is an error or incompleteness.

Trainees/trainers enjoy, in accordance with the law, the rights of information, access and opposition to the processing of their personal data. In order to exercise these rights of access and opposition, the request must be submitted in writing to the person responsible for the Treatment, in the Human Resources department.

Trainees/trainers may, under legal terms, exercise the right to forgetting their personal data, except in cases provided for in compliance with legal obligations.

With the conclusion of the training contract, and throughout its execution, the trainee/trainer consents to their personal data being stored in a digital, secure form, processed and accessed under the terms previously specified or occasionally specified.

Trainees and trainers apply, in terms of data protection, the regime provided for in this regulation for workers, in terms of collection processing, the purpose of treatment, category of data to be collected, retention period, recipients of data, the provided for personal data with the necessary adaptations and if applicable.

5. Personal Data of Customers and Suppliers

The company collects, uses and retains personal data provided by customers and suppliers under the terms permitted by applicable law, in a manner appropriate to the execution of the contractual relationship with them and for the use and billing of services.

The customer and supplier, within the scope of the contractual, commercial relationship and also in the legitimate interest and pursuit of the activity of the Data Controller, authorize the introduction of their personal data in a company file and its termination by the same to third parties, located in the European Union for its treatment within the scope of this contract, also for commercial or other marketing purposes, Customer satisfaction surveys and information about the company’s products and services.

The customer/supplier must notify this company immediately if there are changes in personal data that affect the contractual relationship or billing for the services.

The data necessary for the execution of the contract and billing of services may be stored and used by the company even after the end of the process or contract, under the legal terms and until the invoicing and legal obligations arising from the commercial and/or contractual relationship are completed.

6. Use of the Company’s Website

If you are a user of our website through the user registration process and by “Username – Password”, your data will be stored in a specific user control database. You can request its deletion whenever you want, through the written request to our official address on our website. Deleting the data means that you will not be able to use the website in registered mode from that moment on.

If you use our website unregistered and contact us through contact forms, the data requested in these forms may be stored. You may also request their deletion and continue to use our website as usual.

7. Final Provisions – Obligations regarding the protection of personal data

The company or Organization that individually or together with another (subcontractor) determines the purposes and means of data processing is “responsible for the processing” and must, to that extent, among other aspects, ensure that:

  1. Personal data is collected for specified purposes; explicit and legitimate and are not subsequently treated in a way incompatible with the purposes of the collection;
  2. Only appropriate personal data relevant and not excessive concerning the purposes of the collection are collected;
  3. The personal data collected is accurate and up to date;
  4. Personal data are only kept for the period necessary to pursue the purposes of collection/processing (ensuring compliance with applicable CNPD resolutions and applicable legislation and specific legislation applicable to certain sectors of activity);
  5. All information related to the processing carried out is made available to the data subject, granting him the right to access, rectify, delete his data, as well as to oppose its processing, under the terms of the law;
  6. Data subjects may, using their own form, apply to the company’s Data Controller to exercise their rights.
  7. The consent of the data subject is obtained for the processing of data, in cases where this is required:

a) Data processing is duly notified or notified to the CNPD (if applicable) and, when legally required, the respective prior authorization is obtained or duly regulated in the legal terms;

b) That employees authorized to access personal data are bound by the duty of confidentiality;

c) That the respective written contracts to safeguard confidentiality and privacy have been signed with the subcontracted entities regarding the processing of personal data of our data subjects;

d) That adequate technical and organizational measures have been implemented to protect personal data against accidental or unlawful destruction, alteration, unauthorized access and disclosure is against any form of lawful processing.

e) That the registration of personal data processing activities is carried out under legal terms.

This Regulation enters into form on May 25, 2018.