Data Privacy Notice
Last updated: November 18, 2020
Syniverse Global Data Privacy Notice for Employees, External Staff and Candidates
Syniverse is made up of different legal entities, and this Notice is issued on behalf of the Syniverse group so when we mention “Syniverse,” “we,” “us,” or “our” in this document, we are referring to the relevant company in the Syniverse group responsible for processing your personal data. This notice describes how Syniverse ("Syniverse", "we" or "us") handles personal information about our staff and job applicants (collectively referred to as "you"). The term "staff member" includes those who work on a non-permanent basis, including contingent workers, temporary and contract workers, independent contractors, consultants, professional advisors, secondees and interns.
This notice does not form part of any contract of employment or other contract to provide services. This notice is not intended and shall not be read to create any express or implied promise or contract for employment, for any benefit, or for specific treatment in specific situations. Nothing in this notice should be construed to interfere with our ability to process your data for purposes of complying with our legal obligations, or for investigating alleged misconduct or violations of company policy or law, subject to compliance with local legal requirements.
Syniverse’s processing of personal data is in all cases subject to the requirements of local law, internal policy, and any consultation requirements with worker representatives (where appropriate). To the extent this notice conflicts with local law in your jurisdictions, local law controls.
If you are in any doubt regarding the applicable standards, or have any comments or questions about this notice, please contact us at the contact details in Section 10 below.
In the course of your employment at Syniverse, or when making an application for employment, we may process personal information about you and your dependents, beneficiaries and other individuals whose personal information has been provided to us.
The types of personal information we may process include, but are not limited to:
If you are a contingent worker, the type of personal information we process is limited to that needed to manage your particular work assignment with Syniverse.
Special Category Data includes any information that reveals your racial or ethnic origin, religious, political or philosophical beliefs, genetic data, biometric data for the purposes of unique identification, trade union membership, or information about your health/sex life ("Special Category Data"). As a general rule, we try not to collect or process any Special Category Data about you, unless authorized by law or where necessary to comply with applicable laws.
However, in some circumstances, we may need to collect, or request on a voluntary disclosure basis, some Special Category Data for legitimate employment-related purposes: for example, information about your racial/ethnic origin, gender and disabilities for the purposes of equal opportunities monitoring, to comply with anti-discrimination laws and for government reporting obligations, or information about your physical or mental condition to provide work-related accommodations, health and insurance benefits to you and your dependents, or to manage absences from work.
As part of the hiring process Syniverse does obtain references from previous employers and uses third party vendors to carry out background screening of prospective employees from publicly available sources to verify the background and educational information provided to us.
If you are applying for a position at Syniverse, then we collect and use this personal information primarily for recruitment purposes – in particular, to determine your qualifications for employment and to reach a hiring decision. This includes assessing your skills, qualifications and background for a particular role, verifying your information, carrying our reference checks or background checks (where applicable) and to generally manage the hiring process and communicate with you about it. If you are accepted for a position at Syniverse, the information collected during the recruitment process will form part of your ongoing staff member record. If you are not successful, we may still keep your application for a reasonable period of time to allow us to consider you for other suitable openings within Syniverse in the future.
Employment or work-related purposes
As a staff member at Syniverse, we collect and use your personal information for the purpose of managing our employment or working relationship with you – for example, your employment records and contract information (so we can manage our employment relationship with you), your bank account and salary details (so we can pay you), your equity grants (for stock and benefits plans administration) and details of your spouse and dependents (for emergency contact and benefits purposes).
We process our staff members' personal information through a global human resources system ("HR System"), which is a tool that helps us to administer HR and staff member compensation and benefits at an international level and which allows staff members to manage their own personal information in some cases. This will involve transferring your personal information to our servers in the US. Our parent company in the U.S, Syniverse Technologies, LLC, may host these servers or utilize third-party servers, but in either case will be responsible for the security access of personal information on the HR System.
Syniverse global directory
We maintain a global directory of staff members which contain your professional contact details (such as your name, location, photo, job title and contact details). This information will be available to everyone in the Syniverse group to facilitate global cooperation, communication and teamwork.
Other legitimate business purposes
We may also collect and use personal information when it is necessary for other legitimate purposes, such as to help us conduct our business more effectively and efficiently – for example, for general HR resourcing on a global level, IT security/management, accounting purposes, or financial planning. We may also process your personal information to investigate violations of law or breaches of our own internal policies. In the event of a natural disaster or other life/safety emergency or other similar circumstances, we may use your personal information, including location based information, to notify you of such event or circumstances, to account for our employees or to protect the life and safety of employees and others.
We also may use your personal information where we consider it necessary for complying with laws and regulations, including collecting and disclosing staff member personal information as required by law (for example, for tax, health and safety, and anti-discrimination laws), under judicial authorization, or to exercise or defend the legal rights of the Syniverse group of companies.
Syniverse owns all company Information Assets. Where appropriate, proportionate , and permissible under national and local law and work council agreements, the use of Syniverse Information Assets constitutes consent for Syniverse to monitor, inspect, audit, collect , and remove any information from company owned assets. Syniverse reserves the right to remove any non-Syniverse device or software from its network without notice.
We take care to allow access to personal information only to those who require such access to perform their tasks and duties and to third parties who have a legitimate purpose for accessing it. Whenever we permit a third party to access personal information, we will implement appropriate measures to ensure the information is used in a manner consistent with this notice and that the security and confidentiality of the information is maintained.
Transfers to other group companies
As mentioned above, we will share your personal information with other members of the Syniverse group around the world in order to administer human resources, staff member compensation and benefits at an international level on the HR System, as well as for other legitimate business purposes, such as IT services/security, tax and accounting, and general business management.
Transfers to third party service providers
In addition, we make certain personal information available to third parties who provide services to us. We do so on a "need to know basis" and in accordance with applicable data privacy law. For example, some personal information will be available to our staff member stock and benefit plans service providers and third party companies who provide us with payroll support services, relocation, tax and travel management services.
Transfers to other third parties
We may also disclose personal information to third parties on other lawful grounds, including:
If you are in the European Union or any other state of the European Economic Area, or Brazil, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you (i.e., to administer an employment or work relationship with us), or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided at Section 10 below.
As we operate at a global level, we may need to transfer personal information to countries other than the ones in which the information was originally collected. When we export your personal information to a different country, we will take steps to ensure that such data exports comply with applicable laws. For example, if we transfer personal information from the European Economic Area to a country outside it, such as the United States, we will implement an appropriate data export solution, such as entering into EU standard contractual clauses with the data importer, or taking other measures to provide an adequate level of data protection under EU law. Syniverse Technologies, LLC has put in place model clause contracts between it and its EEA affiliates to enable transfers of employee personal information from the EEA to the United States.
Personal information will be stored in accordance with applicable laws and kept as long as needed to carry out the purposes described in this Notice or as otherwise required by applicable law. Generally, this means your personal information will be retained until the end or your employment, employment application, or work relationship with us plus a reasonable period of time thereafter to respond to employment or work-related inquiries or to deal with any legal matters (e.g., judicial or disciplinary actions), to document the proper termination of your employment or work relationship (e.g., to tax authorities), to provide you with ongoing pensions or other benefits, or to allow us to consider you for other suitable positions within Syniverse in the future.
If you are a resident of the European Union or any other state of the European Economic Area, or Brazil, you may exercise the rights available to you under applicable data protection laws as follows:
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
This notice may be updated periodically to reflect any necessary changes in our privacy practices. In such cases, we will indicate when it was most recently updated. We encourage you to check back at this website periodically in order to be aware of the most recent version of this notice.
Please address any questions or requests relating to this notice the following or alternatively, you can raise any concerns with your line manager, local HR department or local Data Protection Officer (DPO) if you have one:
Global Data Protection Officer
The data controller of your personal information is as follows: