Privacy Portal

Purpose and scope

Glenmark Life Sciences including its successors, assigns and representatives, its future worldwide subsidiaries and affiliates, if any, (“GLS”) respects your privacy and is committed to protecting your personal data.

Almost all of the jurisdictions in which GLS do business have privacy and data protection laws which govern how organisations can collect, use, and disclose the personal data of their commercial partners and GLS is committed to using any personal data fairly, lawfully and in accordance with all applicable laws.  
This GLS privacy policy outlines our practices regarding the collection, storage, use and disclosure of personal data meaning individually identifiable information about you or any other individual that is collected or otherwise received by GLS as a result of our commercial relationship.
It does not extend to GLS employees, directors, interns and permanent or temporary workers or agency staff and there is a separate privacy policy detailing the protection of their personal data available on GLS’s intranet site.

Use of Personal Data
We may use and disclose personal data for purposes connected to:

• the engagement or prospective engagement of you or your company for the supply of services to GLS;
• to answer your enquiries and meet your requests, for instance to send you requested information;
• to provide important information about our business relationship with you, about our terms of business or use or to send you other information related to processing of your personal data; and
• to respond to legal requests from administrative or judicial authorities, in accordance with applicable laws.
  
  

The Personal Data that GLS Collects
The personal data that GLS may collect, store and use includes but is not limited to:

• Name
• Contact information (including email address, mobile phone number, phone number, and postal address)
• CVs, qualifications and areas of subject matter expertise
• Citizenship and country of residence
• Date of birth (age)
• Social Insurance Number or similar government-issued identification numbers
• Gender
• Bank account details
• Marital status and incidentally, sexual orientation (when processing information related to marital status, family or dependents, such processing may unintentionally reveal a person’s sexual orientation by way of the name and gender of the partner)
• immigration status and information, such as passport and other identity documentation, citizenship, residency and other visas, details regarding family composition (names, genders, ages, including re spouse, dependents, and parents) and criminal convictions
• Languages spoken
• Photographs
• Signatures
• Moving image and voice from video (both CCTV and creative videos)
• Localisation data
• Hobbies and interests
• Health-related personal data such as vaccination status relating to an individual or their family members in case of exceptional situations or serious threats to health such as a pandemic spread of a lethal contagious disease, in accordance with applicable laws and provided that proportionate to the aim pursued and with appropriate safeguards
• Personal data contained or revealed through the use or maintenance of communications methods such as use and maintenance of GLS internal or external communications networks, equipment, applications or devices (for example, through voicemails, conference calls, telephone, video or telepresence, e-mails, correspondence, documents, and other work product and communications)
  
  

Methods of Collecting Personal Data
We may collect this personal data in various ways including the following:

• Directly from you
• From the public domain
• During your activities in the course of our engagement, such as through your performance and interaction with other workers or through your use of our systems; and
• From other parties, such as:
• Reference providers
• Data providers
• Former workers; and
• Miscellaneous third parties such as background checking agencies, due diligence service providers, police departments, company-approved and third party travel management systems.
  
  

On What Basis Do We Use Your Personal Data?

        1. We collect and use your personal data when this is necessary for the performance of a commercial contract (or other similar type of agreement) with Glenmark.

        2. We may process some of your personal data when there is a legal requirement or it is in our legitimate interest to do so. This is the case, for example, when we collect and use your personal data to:

• respond to a query you have raised
• comply with regulatory or legal requirements (pursuant to and amongst others, labour, tax, and social security laws
• secure our premises and IT systems
• prevent or investigate fraud or other criminal activities
• undertake intra-group administrative transfers
• respond to an application for charitable gifts or donations
• organise company events

What Happens if You Do Not Provide Us with the Personal Data We Request or Ask That We Stop Processing Your Personal Data?
Our ability to perform our obligations derived from the commercial contract (or similar type of agreement) with Glenmark and our ability to comply with our legal and contractual obligations sometimes depend on Glenmark having access to and being able to use certain personal data.
Therefore, depending on the circumstances, if you do not provide us with the personal data we request or if you ask that we stop processing your personal data, we may not be able to perform our contractual obligations (such as paying you for your work) or we may be in breach of one or more legal obligations imposed upon us. In some cases, if we are not allowed to process your personal data, this may result in us being required to terminate our work relationship with you.

Access to Personal Data
Access to your personal data will be given to those who need such access for the purposes listed above or where required by law. These parties include, amongst others, the GLS’ human resources department, relevant business managers and, on limited occasions, members of the Information Technology ("IT"), finance, tax, legal and compliance departments.
Where we are lawfully permitted to do so, we may also transfer or assign personal data to third party business partners who provide products or services to or on behalf of GLS. These third parties may include and are not limited to payroll administrators, benefits administrators, financial consultants and financial services providers, professional advisers, IT systems providers (including enterprise resource planning and cloud-based software providers and consultants), outside counsel, expense claims providers, data management solutions providers, timekeeping solutions providers, hardware providers, travel and mobility companies (including company car management) and general administrative service providers.
GLS will carefully select such third parties and we will enter into appropriate written agreements including a duty of confidentiality. To the extent required, we will ensure that such third parties collect, store, use and disclose your personal information in accordance with applicable local privacy laws. Under certain circumstances, it may be appropriate to allow these third parties to determine the purpose and means of processing of your personal data in order to achieve specified purposes. You should refer to the contents of their respective privacy notices for further information in respect to the manner in which they process your personal data and any queries arising therefrom should be addressed to them directly.
Finally, personal data may be disclosed and transferred to respond to law enforcement requests, court orders, government regulations (including disclosures to tax, social security, and other authorities) or government entities to manage or administer GLS’ financial and tax affairs. We may also disclose personal data to external legal counsel to assist us with the establishment and defence of legal claims or to other third parties also engaged in such legal matters (for example, to the adverse party in court proceedings, to judicial experts or to other stakeholders involved in the claim).

Where is Your Personal Data Stored?
The aforementioned recipients of your personal data and their information storage systems may be located in other countries. Equally, GLS operates globally, and your personal data may be stored and processed by it in multiple jurisdictions. 
In the event that we or our partners transfer any personal data, we will ensure that this is only done so in accordance with applicable law, and will require that there is an adequate level of protection for the personal data and that appropriate security, technical and organisational measures are in place.
GLS has policies and procedures in place to ensure that we comply with all applicable laws in the event of a data breach leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data.
For more information about the safeguards relating to cross border personal data transfers or data breach please contact dpo@glenmarklifesciences.com

Your Rights
You may have certain rights regarding the personal data that we collect, use and hold about you. These rights may include the following:
Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (as explained below). Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you at the time of your request.
Object to processing of your personal data In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.  In such circumstances we may reserve the right to delete your personal data rather than hold it but restrict processing, where our processes are not set up to enable a restriction.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Request information about your personal data. On request, we will disclose to you the categories of personal information Glenmark collected, used or shared about you, which third parties were involved (if any) and why they collected, used or shared that information.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
These rights can be exercised by contacting dpo@glenmarklifesciences.com however, please note that in the case of blocking or suppression or further use of personal information, we may need to retain or continue processing certain information, for example for legal or administrative purposes (for example the maintenance of social security records). 
We will respond to your request as soon as practically possible and within the timeframes set forth by applicable law.

Retention and Accuracy of Personal Data Collected
GLS intends to keep personal data in its control accurate and up-to-date. We will retain personal data only as long as is necessary to carry out the purposes for which it was obtained and as described in this privacy notice. If there are any changes to your personal data, please notify the business function with whom your GLS relationship is held or the human resources department accordingly. If you inform us of any changes or we otherwise become aware of any factual inaccuracies in your personal data, we will seek to promptly correct such inaccuracies.
GLS has internal retention policies and procedures that build upon the following criteria to determine suitable retention periods for personal data in the context of the abovementioned purposes:

• End of the contractual relationship with Glenmark
• Sensitivity of the personal data
• Security reasons
• Applicable statutes of limitation
• On-going or potential litigation or dispute; and
• Regulatory or legal obligation to retain the personal data (for example, for social security purposes or in the context of CCTV surveillance).
  
  

Monitoring
Under certain circumstances, GLS may monitor the use of its information systems including for the purposes of detecting and addressing information security threats or improper use of GLS’ information systems. This may require the processing of certain personal data of individuals related to their use of information systems.

Revisions to this privacy notice
GLS may update this privacy notice from time to time. In order to keep up-to-date with the ways in which Glenmark handles your personal data we request that you visit and review the relevant privacy notices on our privacy portal on a regular basis.

Questions
If you have any questions about this privacy notice, how we handle your personal information or wish to exercise any of your rights contained hereunder, please contact us by email at dpo@glenmarklifesciences.com

Complaints

If you are unhappy with the way in which we have processed your personal data please address any complaint to dpo@glenmarklifesciences.com In any case, you also have the right to lodge a complaint with the relevant supervisory authority which can be found at https://pdpecho.com/the-list/