TCS Multi-Tenant Privacy Notice

Privacy Notice

Version No: 01.10

Last Updated: 02-Aug-2024 

 Introduction

Your privacy is important to us. We believe it is important for you to know what personal data is collected from you, why it is collected, how it is used and what right you might be entitled to as a data subject or consumer.

SPONSOR as controller of personal data

Sponsor is the “data controller” for the scope and context set in this document.

To the extent of this notice, Sponsor as a “data controller” is responsible to determine the purpose for which and the means by your Personal Data is processed. “Affiliate” means an entity that owns or controls, is owned or controlled by or is under common control or ownership with Sponsor where control is defined as the possession,directly or indirectly, of the power to direct or cause the direction of the management and policies of an entity, whether through ownership of voting securities, by contract or otherwise.

This notice is meant for the users of TCS products/services which are accessible to you as per the contract which the sponsor has concluded with TCS.

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing Personal Data about you, so that you are aware of how and why we are processing such Personal Data.

TCS as processor ofpersonal data

You have been nominated by your Sponsor (Data Controller) to access this application.

The collection and processing of your Personal Data by the sponsor while using the application will be subject to the privacy notice published by the sponsor organization,who will act as controller.

Your use of the application on behalf of the sponsor constitutes instructions to TCS to process your Personal Data in accordance with the contractual agreement and Data Processing Agreement agreed with the sponsor or as otherwise necessary to perform its obligations under the Data Protection Laws.

If you want to exercise a data subject right regarding your Personal Data collected by the sponsor, please contact the sponsor.

Data Protection principles

TCS follows the data protection principles outlined in relevant Data Protection Law in the processing of your Personal Data. This means that the Personal Data we hold about you is:

    1.Used lawfully, fairly and in a transparent way

   2. Collected only for valid and specific purposes that we have clearly explained to you and the sponsor and not used in any way that is incompatible with those purposes.

   3. Relevant to the purposes we have told you and the sponsor about and limited only to those purposes.

   4. Accurate and kept up to date with best of our knowledge and informed by/to you and the sponsor.

   5. Kept only as long as necessary for the purposes we have told you and the sponsor about and/or as determined by applicable data protection law.

   6. Kept securely

What Personal Data is collected:

Personal Data means any information that relates to an identified or identifiable individual/person (as applicable in certain jurisdictions). It does not include data where the identity has been removed (aka anonymous data); country-specific notices might adopt a different terminology. 

You have been nominated by your sponsor to access this application on behalf of the sponsor. 

We will collect,store, and use the following categories of Personal Data about you/ or your users to provide access to TCS application on behalf of sponsor has contracted with TCS:

·         FirstName

·         ContactNumber

·         EmailID

·         ClientAddress

·         SecurityAnswer (if you have forgotten your password or need to reset it)

·         ClientName

Our web servers or third parties who provide analytics and performance enhancement services may collect:

• IP addresses,
• operating system details, browsing details,
• device and connectivity details, and/or
• language settings.

TCS uses the above information to service the scope of the contract with sponsor.

How is your Personal Data collected: 

Your Personal data is collected from you or your sponsor through Direct registration in the application

How we will use your Personal Data: 

We will use your Personal Data when the applicable Data Privacy Laws allows us to do so. We will use your Personal Data in the following circumstances:

1.      Where we need to perform the contract we have entered into with the sponsor.

2.      To provide you access to the application and associated services.

3.      Where we need to comply with a legal obligation.

4.      The above information is aggregated to measure the TCS application usage, to ensure safety and security, enhance performance and user experience of the website.

If you fail to provide personal data

If you fail to provide certain information when requested, we shall not be able to serve the purpose(s) for which we process your personal data, or we may be prevented from complying with our legal obligations also.

Change of purpose

We will only use your personal data for the purposes for which it is collected, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify the sponsor and we will explain the lawful basis which allows us to do so. 

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Do we need your consent?

In limited circumstances, we may approach you for your written consent to allow us to process certain personal data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

Personal Data Sharing:

We may share your Personal Data with third parties, where required by law, where it is necessary for one of the activities mentioned above or where we have another legitimate legal basis in doing so. We require third parties to respect the security of your Personal Data and to process it in accordance with the law and our instructions. 

For instance, we may share your data with Third party cloud service providers on which the application is hosted.

What about other regulatory and/or government authorities?

We may disclose your personal data with regulatory and/or government authorities when asked and in order to comply with the applicable law(s).

Transferring Personal Data outside the country:

 We may transfer the Personal Data we collect about you to one or more countries to provide you access to the TCS application and its associated services

 a.    where TCS or its affiliates or their respective service providers maintain their facilities; or

 b.   In order to comply with our contract obligations established in the contract in place with the sponsor, some geography/countries, where we transfer your Personal Data might not have appropriate (or adequate) privacy regulation and requirements, but TCS, as a global company, ensures that our global privacy policy is complied across globe.

c.    By accessing this application, you hereby consent to such transfer of data outside the country of your residence

We undertake all measures required to comply with cross-border Personal Data transfers, before transferring any of your Personal Data overseas.

Personal Data Security:

We have put in place appropriate technical, organizational and security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your Personal Data to TCS`s employees who have a business need to process your data. They will only process your Personal Data on our instructions, and they are subject to a duty of confidentiality.

 We have put in place procedures to deal with any suspected Personal Data security breach and will notify sponsor and any applicable regulator of a suspected breach where we are legally required to do so.

Retention:

Your Personal Data will be retained for the period mentioned or agreed in the agreement with the sponsor.  If required by applicable Data Privacy Law which TCS is subject to, TCS could retain a copy of your Personal Data for the period specified by the Law. We guarantee that the security, privacy and confidentiality of the Personal Data retained shall have the same level of security as a Personal Data currently in use.

What we may need from you 

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

What policies are in place for reporting any incidents of data breaches?

We have put in place procedures to deal with any suspected/materialised Personal Data security breach and will carry out notifications regarding a suspected breach in accordance with the terms of our agreement with the sponsor or as is required by applicable law.

How to contact us

If you have any questions regarding this privacy notice, please direct it to Privacy office of the Sponsor. 

Changes to this Privacy Notice:

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal data.