Employee Privacy Notice

1. Introduction

1. This Employee Privacy Notice (“Notice”) is a source of information that explains several aspects relating to the way the Company processes Employee’s personal data.
2. The wording in this Notice reflects the requirements of Republic Act No. 10173 (Data Privacy Act of 2012 and its Implementing Rules and Regulations (IRR) on the protection of natural persons with regard to the processing of personal information and on the free movement of such data, and repealing Directive 95/46/EC (the General Data Protection Regulation – the “GDPR”).
3. Where in this statement we refer to “we” or “our” or “us” or “Company” we are referring to Global Trade Tech Corporation (GTTC) with SEC Company Registration Number 2023120127687-00, with corporate address at One Pacific by the Bay, No. 7 Macapagal Avenue corner Diokno Avenue, Brgy. 76, Pasay City, as your employer and where we refer to “you” or “your” we are referring you as one of our employees.
4. As your employer, we process an array of employment-related personal data in order to manage the employment relationship. We are committed to protecting your personal information and to being transparent about what information we hold. We understand our obligations to you, in particular in providing you with the information to help you understand how and why we process your personal data, and we are committed to fulfilling our obligations to you under the applicable law on data protection.
5. The controller for the personal data submitted to us in connection with your employment is GTTC.
6. Our designated privacy personnel can be contacted on asiahr@pronetgaming.com in respect of any matter detailed in this Notice or to exercise any of your rights under this Notice.
7. We will notify you by email on your work email address of any significant updates to this Notice.

2. What Information does COMPANY Process?

1. We collect and process a range of information about you (“Employee Personal Data”). This includes:
2. Your full name and surname;
3. Your residential address and contact details, including your email address, home and mobile telephone number;
4. Unique personal identifiers and biographical information (e.g. your date of birth);
5. Your gender;
6. The terms and conditions of your employment;
7. Your curriculum vitae;
8. Other details of your qualifications, skills, experience and employment history, including start and end dates, with previous employers and with COMPANY;
9. Information about your remuneration, including entitlement to benefits such as pensions or insurance cover;
10. Details of your bank account and national insurance number;
11. Information about your marital status, next of kin, dependants and emergency contacts;
12. Information about your nationality, any visa you may require and other documentation required in connection with your entitlement to work in the Philippines;
13. Information about your criminal record;
14. Details of your work day schedule and working hours, and your attendance at work;
15. Details of any accident you may have at work;
16. Details of periods of leave taken by you, including vacation leave, sick leave, maternity or paternity leave, and any other type of leave availed by you;
17. Details of any disciplinary or grievance procedures in which you have been involved, including any warnings issued to you and related correspondence;
18. Assessments of your performance, including appraisals, performance reviews and ratings, performance improvement plans and related correspondence;
19. Information related to the prevention and detection of crime and the safety of our employees and our premises including, but not limited to, CCTV footage;
20. Information about medical or health conditions (“Conditions”), including the following:
  1. Whether you have a disability for which we need to make adjustments under the applicable law;
  2. Any related information we need to be aware of in order to provide you with adequate medical assistance in the event of any incident related to your Condition (e.g. immediate treatment and contact number of medical consultant);
  3. Any related information we would need to process in the event of long-term illness (which extends beyond annual statutory sick leave entitlement)
21. Any other information of relevance to a particular circumstance that may arise during the course of your employment of which you make us aware or which you otherwise submit to us during the course of your employment with us.
22. We may collect Employee Personal Data in a variety of ways, including the following:
  1. Through application forms, CVs or resumés;
  2. Information obtained from your passport or other identity documents such as your national identification card or your driver’s licence;
  3. From forms duly completed by you at the start of or during your employment (e.g. Jobsplus employee registration form);
  4. From correspondence with you;
  5. Through CCTV cameras;
  6. Through interviews, meetings or other assessments;
  7. From professional social media sites such as LinkedIn; or
  8. 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.

Some data collected is not compulsory, therefore it is considered as ‘optional’. Providing the following data can contribute towards an improved employee experience:

1. T-Shirt size – the data is collected in the eventuality that marketing material is created
2. Social links – the company will monitor the social links solely for the use of company logos.

3. Why does COMPANY Process your Personal Data?

1. We need to process some Employee Personal Data as it is necessary in order to enter into a Contract of Employment (“Agreement”) with you and to meet our obligations under your Agreement. For instance, we need to process your data to provide you with your Agreement, to pay you in accordance with your Agreement and to administer any benefit or entitlement due to you under your Agreement or the applicable law.
2. In some cases, we need to process data to ensure that we are in compliance with our legal obligations. For instance:
  1. We are required to check an employee’s entitlement to work in the Philippines, we are required to deduct tax and national insurance contributions at source, we are to comply with health and safety laws, we are to enable you to take all periods of leave to which you are entitled at law, etc.; and
  2. We may require sensitive personal data, such as information about Conditions, in order to ascertain that we carry out our employment law obligations (such as those in relation to employees with disabilities).
3. In other cases, we have a legitimate interest in processing personal data before, during and after the end of the employment relationship. In this respect, processing Employee Personal Data allows us to do the following:
  1. Undertake recruitment and career progression (e.g. promotion) processes;
  2. 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 your contractual and statutory rights;
  3. Operate and keep a record of disciplinary and grievance processes, to ensure acceptable conduct within the workplace;
  4. Operate and keep a record of employee performance and related processes, to plan for career development, and for succession planning and workforce management purposes;
  4. 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;
  5. Ensure effective general HR and business administration;
  6. To provide references on request for current or former employees;
  7. Ensuring security of our premises;
  8. Respond to any data subject requests that you make; and
  9. Respond to and defend against any legal claims.

1. We require to process your data for internal and external communications, e.g. when you communicate with other employees or with external parties for business reasons.
2. We will process your data for security reasons as well, when registering your building access, managing and securing our IT systems and services.
3. We may ask you for your consent to process other personal data such as the following:
  1. Photos or images in which you are identifiable for publicity and marketing purposes (including inclusion on our website, or otherwise online, in print and on social media). Any such data will be collected and processed with your express consent, which can be withdrawn at any time. There are no consequences of failing to provide such consent;
  2. Your personal email address in connection with electronic mailings and communications.
4. We may be required to process sensitive personal data, such as information about your ethnic origin, sexual orientation or religion or belief, as may be required by the relevant authorities in connection with non-discrimination in employment. Any such data as collected will be anonymised and collected with your express consent, which can be withdrawn at any time. You are entirely free to decide whether or not to provide such data and there are no consequences of failing to do so.

4. How does COMPANY Store Employee Personal Data?

Employee Personal Data will be stored in a range of different places, including in your personnel file, with COMPANY third party HR service provider as well as in other systems (including the COMPANY’s third party email processor system). Access to HR management systems is restricted to HR team, and to a limited extent to Office Management and Finance teams on a need-to-know basis.
All data will be stored or otherwise processed within the Philippines or the United Kingdom or a country in the European Economic Area and no Employee Personal Data will be transferred to a country outside the Philippines or the United Kingdom or the European Economic Area.

5. Who has access to Employee Personal Data?

1. Your personal data 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 performance of their roles. We may share sensitive personal data (such as Conditions) with members of staff who legitimately need the information to carry out their normal duties, such as members of the HR department or your line manager, to the extent necessary for the performance of their duties.
2. We share your data with third parties:
  1. In order to obtain pre-employment references from other employers, obtain employment background checks from third-party providers;
  2. In order to obtain necessary criminal records and other checks; and
  3. Where we have a legal obligation to do so, such as disclosures to the police for prevention or detection of crime; state benefit-providers (the Social Security Department or others); the tax authorities; employment authorities (the Department of Industrial and Employment Relations or others); and the immigration authorities in connection with your entitlement to work in the Philippines.
3. We also share your data with third parties that process data on our behalf as follows:
  1. HR services provider;
  2. Public authorities;
  3. Payroll providers;
  4. Insurance providers;
  5. System Admins;
  6. Travel Agency for business travel purposes (when applicable)
4. Any data shared under Section V.3 above is subject to the conclusion, with such third parties, of a data processing agreement (“DPA”) as required under the DPA and in compliance with DPA IRR and subject further to specific instructions regarding processing as provided by us to such third parties. Where data is shared within the Philippines, the third party will be required to comply with and safeguard the data under the terms of the DPA and its IRR. Your personal information will only be transferred to countries outside of the Philippines, whose data protection laws have been assessed as adequate by the Philippine Government, or where adequate safeguards are in place such as binding corporate rules or the use of standard contractual clauses as required by the DPA.
5. We may also share your data with third parties in the context of a sale of some or all of our business – in such circumstances the data will be subject to strict confidentiality arrangements.
6. We do not sell your personal data or grant access to it for financial gain under any circumstances or permit third parties to use it for the purpose other than that which we have provided it to them for.

6. How does COMPANY protect data?

We have 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 as described in Section V above.
Where we engage third parties to process personal data on our behalf, they are obliged to implement appropriate technical and organisational measures to ensure the security of Employee Personal Data.

7. Retention Periods

1. We retain Employee Personal Data for as long as is necessary to fulfill the relevant purposes of processing explained in this Policy. Furthermore, we may retain your Employee Personal Data after the expiration of the relevant processing purposes in the following limited cases:
  1. In case that there is a legal obligation under a relevant statutory provision; and
  2. In order to defend our rights and legitimate interests before any competent court and any other public authority.
2. After the period of retention, Employee Personal Data is erased from our databases. For more information about data retention terms in relation to specific Employee Personal Data, please contact us in the manner stipulated in section I.6 above.

8. Your Rights as a Data Subject

As a data subject, you have the following rights:

1. To be informed: This Privacy Notice provides the information you are entitled to receive.
2. To access your Employee Personal Data: Please contact us if you would like confirmation that your data is being processed and if you would like access to your Employee Personal Data. There is no charge for us providing you with this data and it will usually be provided within one (1) month of the request (unless the request is unfounded or excessive).
3. To rectification: Please inform us of any data which you would like rectified and we will usually respond within one (1) month of the request. We will pass on the changes to any third parties who need to change their records and let you know that this has been done.
4. To erasure (to be forgotten): You may exercise your right to have your personal data erased in a number of circumstances (e.g. if the data is no longer necessary in relation to the purpose for which it was created or if you withdraw your consent, where consent is required). Notwithstanding a request for erasure, we will continue to retain any Employee Personal Data in accordance with section VII above.
5. To restrict processing: You can tell us that we can keep your data but must stop processing it, e.g. where the data is no longer necessary for the purposes of processing, including for preventing future publicity, marketing, electronic mailings and communications. We will inform any third parties to whom your data has been disclosed (with your consent) of your requirement.
6. To data portability: Your data is across manual records and an online database. We will do our best to provide information in a portable format, where technically feasible.
7. To object: Without prejudice to section VII above, if we can, we will consider stopping any processing of your Employee Personal Data if you object to processing based on legitimate interest. If you tell us to, we will stop processing your Employee Personal Data for future publicity, marketing, electronic mailings and communications.
8. Not to be subject to automated decision-making including profiling: We do not use any automated decision-making.
9. If you would like to exercise any of these rights, please do so in the manner stipulated in section I.6 above.

9. What if you do not provide personal data?

1. Some obligations to provide us with data arise out of your employment relationship with us and thus a result of the Agreement. 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 us with data in order to exercise your statutory rights, such as in relation to statutory leave entitlements. Failing to provide the data may mean that you are unable to exercise your statutory rights.
2. Certain information, such as contact details, your right to work in the Philippines and payment details, have to be provided to enable us to enter into a contract of employment with you.
3. If you do not provide other information, this will hinder our ability to administer efficiently the rights and obligations arising as a result of the employment relationship.

10. Complaints

You have the right to lodge a complaint with the National Privacy Commission at

https://privacy.gov.ph.