'Probity HR Consulting' offers a range of people–centric solutions related to HR Systems and Services. In order to deliver these services effectively, there may be a need to collect personal information from time to time for different purposes – whether to respond to enquiries from potential clients about our products/systems and services or to offer customised solutions that meet the specific needs of our customers. Throughout this process, it's our endeavour to collect, store, process and ultimately delete or anonymise the information in compliance with applicable laws, particularly at the conclusion of our business relationship.

Depending on the type of products/systems or service offerings we engage in, with our clients, 'Probity HR Consulting' from time to time may play the role of either a 'controller' and decide why and how to process personal information or play the role of a 'processor' and purely follow the instructions of other data controllers while processing of personal information. As a processor, we may not engage in any decision–making concerning the use and processing of personal information which is likely to be more applicable in cases where the personal information of users is captured, recorded and available on 'Probity HR System' as part of subscription services provided to their employers. Our data protection and privacy policy covers important elements of the applicable laws while collecting, storing, using, and sharing personal information either as a 'controller' or a 'processor'. Here is an outline of some important points we aim to cover and situations where the privacy policy becomes applicable such as:

1. Individuals or end–users visit our company website to explore information about our products/systems and services.
2. Create an account with us either individually to avail 'service offerings' or through business subscriptions of their employers to avail 'cloud–based leave, attendance and payroll software'.
3. Individuals or end–users receive marketing communication, calls, messages, and emails subject to prior consent.
4. Individuals or end–users submit feedback, testimonials and reviews about our products/systems and service offerings, subject to their prior consent, review and final approval.
5. Register for service offerings including events, webinars, learning interventions and training programs that are scheduled from time to time.
6. Individuals or end–users request information through our website, expressing interest in collaborating or establishing a business relationship to either utilise our products/systems or partner with us for our service offerings.

Overall in any case, we endeavour to comply with the laws concerning General Data Protection Regulation (GDPR) and Digital Personal Data Protection Act (DPDP), as applicable from time to time. Approaches that we follow during various stages of the data management lifecycle are outlined below:

There may be various situations where the collection of personal information and its processing is necessary to fulfil the legitimate interests concerning system and service offerings – either the terms of service agreements we have with employers who have subscribed to our products, systems, and services or individuals or users who have separately subscribed to our services. While we strive to address all potential situations, some unforeseen circumstances may arise. In such cases, we are committed to updating our policy promptly upon becoming aware of them. This policy outlines common scenarios where personal information may be collected and processed

When information is requested from us: this usually happens when users/prospective clients visit our website and wish to contact us for further information regarding our products/systems or services. The details that are captured at this stage are – name, contact number, name of the organisation, business email ID, name of industry, headcount of the organisation, business location and related information subject to consent before submitting the required information. These details are captured to fulfil the overall 'request for information' and communicate till such time the requirement is fulfilled. Further, this information may also be used to provide further information about our products (ongoing, upcoming etc.) including telemarketing calls and marketing calls in accordance with the marketing preferences and consent provided while contacting us and submitting the required information.

In case of an existing association: this is usually gathered or used (from the repository) from users who have an ongoing business association with us and/or provide support or are subscribed to our product, systems, and services and whose details are either available in the repository or need to be updated for further information. The details that are captured at this stage are – name, contact number, business email ID, name of organisation, official address, GST and other related information (that is mandatory for business association) and reason for contacting. This information is used to understand any product/systems or services–related queries, provide resolution and store feedback against respective users, wherever applicable. The same is also stored and processed from time to time to manage accounts of various clients, invoicing, and other account–related matters.

In case of pursuing a business association: this is usually gathered from users who wish to collaborate for a business association with us and wish to provide services towards our products/systems and services. The details that are captured are – name, business email ID, contact number, name of organisation, official address and related information.

End–user of Probity HR System: this is usually in cases where users are subscribed to 'Probity HR System' through their employers, however, in such cases the individual account is owned and managed by the respective organisation that the users are part of. The personal and related statutory information, along with any documents that are submitted, uploaded, processed, utilised are all managed in accordance with the legitimate interests and terms of service outlined in agreements with respective employers to effectively manage their employees' information. The details are processed from time to time to manage the accounts of users in accordance with applicable laws and ensure secure access to information and usage of services and deliver requested information and services related to – attendance management, leave management and payroll management platforms.

Register for professional development programs or events offered by Probity HR Consulting: this is usually in cases where users express interest in our professional development programs and wish to register/subscribe for existing or upcoming learning programs subject to providing consent before submitting the required information. The details captured here are a mix of personal and demographic information such as – name, mobile number,personal email ID, location, qualification (minimum and highest), work history (fresher or experienced), years of experience, industry background, current working status and related information. These details are captured as per the legitimate interest of providing bespoke/customised learning experience basis analytics and outcome of the demographic information and background of applicants. The same is intended to be processed from time to time to manage, plan, design, and deliver various learning programs including sending related communications about existing, upcoming or to seek general feedback to improve learning experience in future.

Further, this information may also be used to provide further information about our services (ongoing, upcoming etc.) including telemarketing calls and marketing calls in accordance with the marketing preferences and consent provided while contacting us and submitting the required information or registering for a service with us.

Feedback or testimonial of experience while availing products/systems or service offerings: at this stage the information will be used solely at the user's discretion and provided the user has given consent to publish or share his/her testimonial on our website or related social media handles. In any case, it's our endeavour to legitimately use the information, seek feedback, make amendments and seek final approval before proceeding with publishing the testimonial on various platforms concerning 'Probity HR Consulting'

Through website or service offerings and content: Considering the stage at which the organisation is at, we may not consider the need for 'collecting information automatically' unless required for the purpose of understanding background of users who visit our website and navigate through the products/systems and service offerings and such information may be collected using cookies and similar tracking technology, with an overall objective to meet the parameters of applicable laws that govern the use of cookie policies.

In due course as the organisation grows and number of clients increases there may be a need to understand the type of users seeking information about our products/systems and service offerings, their location, type of information and content they are interested in etc. Such information will be collected only for internal analytics purposes to work on enhancing our existing products/systems and service offerings. The information that are likely to be captured are – IP address, device type, usage, unique device identification numbers, browser type, geographic location (for example, country or city–level location based on public IP address), performance and other technical information. We could also collect information about how user navigates on our website and 'Probity HR System' (for instance, pages visited, features used etc.), emails, content or other features (for instance, when marketing email is viewed, or when the user clicks on embedded links, or if videos are viewed, chat features etc. are used). In any case, we do not intend to capture personal information as the same is not required while planning or enhancing products/systems and service offerings and hence there may not be a mechanism for individuals to request and confirm that we limit our use of sensitive personal information.

Through 'Probity HR System' web or mobile application: When individuals are users of our platforms through subscriptions and engaged in business relationships through their employers, considering that our system is cloudbased software, there may be a need to record systems usage automatically either through the web application or mobile application. This information may include IP address, operating system type and version, mobile device make, model, and memory etc. date and time stamps, and details about the type of our products/systems and services being used. In any case we do not intend to identify the end–user through such system usage information unless the concerned employer gives express instructions to perform such activity and provides us with certain additional information about the end–user account. This could arise out of a service request raised through the ticketing system and the need to resolve such issues. The personal information in this context is processed only for the purpose of troubleshooting, understanding and improving end–user experience with our web and mobile applications, look for mechanisms to remotely enable/disable features within the web and mobile application, resolve issues and maintain functionality of our products/systems and services whether raised by the end–user or the organisation, assess the user and organisation's experience while using 'Probity HR System', use the outcome of user experience to improve performance of the systems and services and eventually to protect the misuse of our systems and services in line with our terms of service. In any case, it's our endeavour to avoid using personally identifiable information for the purpose of tracking, monitoring, and enhancing user experience regarding our products/systems and service offerings.

Third–party websites and other publicly available sources, referrals from business associates and service providers: it's quite likely that personal information of users will be received as an outcome of either existing business relationships with any of our clients and/or service providers either in the form of referrals, to seek information about our products/systems and services or as part of feedback and recommendation in response to our services and/or professional development programs through any of the social media platforms. Such information may be recorded and processed if and only if there is a need to provide information about our products/systems and services, understand the feedback of concerned users, fulfil service requests, answer and follow up on queries and resolutions till such time an effective outcome is achieved for both parties. In any case the endeavour is to avoid using personally identifiable information for the purpose of marketing activities.

As part of business requirements and a need to build efficiency through effective HR solutions, Probity HR Consulting may disclose personal information to third parties such as:

Probity HR System partners: these could be third–party service providers or vendors who are empanelled to provide services on our behalf (for example, data analytics, customer support, call recording, chatbot technology, payment services, IT services, attendance device manufacturers among others)

Service providers: these could be third–party service providers or vendors who are empanelled to provide periodic support in the areas of:

1. E–learning platforms: these service providers will be approached to understand service offerings and implementation mechanisms of online learning management solutions.
2. Consulting firms, Executive coaches/facilitators of workshops, and seminars: Assessment and testing providers:these service providers will be approached from time to time to build bespoke assessment solutions either aptitude or psychometric to provide credible solutions that align with the overall requirements of professional development journey of both individuals and organisations
3. Assessment and testing providers: these service providers will be approached from time to time to build bespoke assessment solutions either aptitude or psychometric to provide credible solutions that align with the overall requirements of professional development journey of both individuals and organisations.
4. Analytics providers: these would be vendors who offer tools and services for tracking and analysing the effectiveness of various learning programs and service offerings, capturing and assessing feedback post– learning programs and service offerings, measuring ROI etc. to ensure effectiveness of future learning programs.

Existing Organisation: In this context, personal information may be shared with the individual's organisation, who are either an existing or prospective client of 'Probity HR System'. This disclosure may occur through the use of modules such as attendance, leave, and payroll management, or other services like professional development programs, events, webinars, or courses completed by the individual. The outcomes of these activities are shared with the organisation to enable them to address relevant matters directly, rather than through 'Probity HR Consulting'.

Attendance device manufacturers for facial/biometric recognition feature: the information that will be captured and processed for this purpose are – thumb impression, image, location, unique employee ID set by the organisation and related information. The image is captured each time the user encounters a need for clock–in/clock–out through the attendance systems. Once the image detection and related verification is completed with the original profile image stored in 'Probity HR System', the same is permanently deleted from the servers unless the organisation's admin has enabled an option of 'Capture and save photo'. Location details will be captured based on organisation's settings configured by the admin and where location information is made mandatory at the time of attendance marking. The concerned admin users will be able to access all employees' images and attendance information while those in reporting manager roles will only be able to access their subordinate's images and attendance entries in 'Probity HR System'.

We endeavour to treat personally identifiable information with integrity and confidentiality including protection against unauthorised processing through the use of appropriate technical and organisational measures to mitigate the risks associated with unlawful processing personal information. Further, it is ensured that through our systems and service offerings sensitive information is only made available to authorised parties who ensure that data is processed in an authorised way. While all possible effort is and will be made to ensure protection of sensitive information at our end, the security of information processes through the Internet can never be guaranteed. Hence, we recommend that individuals and/or end–users take complete responsibility for maintaining the security of their passwords or other forms of authentication that are usually involved while accessing password–protected or secured resources.

We endeavour to seek appropriate consent from individuals and end–users and keep them informed about the lawful grounds and legitimate business purposes for which their information is being collected before they submit their personal information for further processing. Here is an outline of some important elements of the rights of individuals regarding their own personal information that is captured, recorded, stored, and processed as part of our products/systems and service offerings:

1. Right to transparent information: ensure that appropriate consent and complete information including legitimate grounds for processing is given to individuals and/or end–users each time their personal information is collected and processed.
2. Right to access: individuals or end–users have the right to raise a request to access their personal information that is stored, maintained, and processed by us from time to time. Some elements of this request will be processed in line with the terms of service of the agreement, in case the user is subscribed to our products/systems and service offerings through their employers. In any case, any user who seeks access to their personal information which is directly handled by 'Probity HR Consulting ' as a controller or processor, the same will be honoured accordingly.
3. Right for data rectification: individuals or end–users have the right to raise a request to rectify their personal information that is recorded as part of our systems and service offerings. Based on the purpose for which the information is used, the users can instruct us to modify and/or update additional information wherever found necessary and subject to providing appropriate consent.
4. Right to erasure: individuals or end–users have the right to request that their personal information is deleted in situations where it's no longer necessary either at the end of a business relationship or upon fulfilment of our service offerings. However, in such cases, the users must be able to authenticate and identify themselves appropriately. In certain unavoidable situations, where deletion is not possible because the information is stored in backup archives, then we will ensure that the information is stored securely and isolated from any further processing till such time the deletion is possible.
5. Right to restriction to further processing: individuals or end–users have the right to raise a request to stop any further processing of their personal information, this includes situations where the user has requested to avoid using the personal information, however the concerned employers, service partners, including us, in turn, need time to determine whether the legitimate reasons for processing outweigh the request from user. During this period, the personal information would still be stored but not actively processed for any purposes other than those related to an ongoing resolution that is pending to be provided.
6. Right to data portability: individuals or end–users can request the portability of their personal information in a structured, commonly used, and machine–readable format
7. Right to opt–out: individuals or end–users have the right to opt–out of marketing preferences that they may have subscribed to initially.
8. Right to withdraw consent: individuals or end–users have the right to withdraw the consent that they had provided towards the use of their personal information that was collected and processed at the start of the business relationship. However, this will not affect the lawful grounds under which the personal information was processed before their withdrawal, nor will it affect the processing of personal information that was conducted under the legitimate interests of the purpose of processing that was done as per applicable laws in situations apart from those that required consent.
9. Right to lodge a complaint: individuals or end–users have the right to lodge a complaint with a supervisor or a concerned authority.

Overall, in order to exercise the overall right revolving around the use of personal information, individuals and/or end–users can contact 'Probity HR Consulting' through the 'Contact us' page and we will acknowledge and provide appropriate response within a time period as permitted by applicable law, unless in certain unavoidable situations where we might need an extension to fulfil the request, we will notify the users accordingly.

The Privacy policy may be amended or revised from time to time at the discretion of 'Probity HR Consulting' and to comply with the applicable laws concerning GDPR and DPDP acts that are updated from time to time, the same will be notified through appropriate mediums as and when applicable.

In case of any questions regarding our privacy policy, please connect with us via the 'Contact us' page or send an email to 'enquiries@probity–hr.com' or send us a query at our office address as mentioned below, and one of the representatives will reach out to you at the earliest possible.

Probity HR Consulting Private Limited:
Shop no. 2, Ekta Angan CHS, Opp. YMCA ground,
I C Colony, Borivali (West), Mumbai – 400103