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Excerpt from the Employee Personal Data Processing and Protection Policy

General Provisions

  • This Policy establishes the procedure for acquiring, registering, processing, accumulating and storing documents containing information related to personal data of employees of CASTAMONU INTEGRATED WOOD INDUSTRY LLC (hereinafter referred to as the Employer). 
  • Employees are defined as both those who are entering into (at the stage of reviewing the vacancy or interviewing) and those who have entered into an employment contract with the Employer.
  • The purpose of this Policy is to protect the employee personal data from unauthorized access and disclosure. Personal data is always treated as confidential and strictly protected information.
  • This Policy is based on the Constitution of the Russian Federation, the Labor Code of the Russian Federation, the Federal Law of 27.07.2006 No. 152-FZ “On Personal Data” and other applicable laws and regulations of the Russian Federation.

Definition and components of personal data

  • Personal data is any information directly or indirectly relating to the subject of personal data, that is an individual who is identified or can be identified.
  • Personal data authorized by the subject of personal data for distribution is personal data to which the subject of personal data provided access to an unlimited range of persons by giving consent to the processing of personal data authorized by the subject of personal data for distribution in the manner required by Federal Law of 27.07.2006 No. 152-FZ.
  • Components of employee personal data:
    • surname, first name, patronymic;
    • gender, age;
    • information about education, qualifications, professional training, and further training;
    • place of residence;
    • marital status, existence of children, family composition, family relationship;
    • biographical facts and career history (including place of employment, working as an elected official, civil servant, etc.);
    • financial situation, information about wages or salary;
    • passport particulars;
    • information about military registration;
    • information about social benefits;
    • work specialty;
    • position held;
    • the amount of wages or salary;
    • criminal record if any;
    • telephone numbers;
    • the content of the employment contract;
    • originals and copies of personnel orders;
    • personal files, employment records and information about employment history;
    • grounds for personnel orders;
    • files containing information on further training and retraining of employees, their performance appraisal, and official investigations;
    • copies of reports submitted to the statistical authorities;
    • information on the results of a medical examination on the employee's ability to perform his or her job function;
    • photographs and other information relating to the employee personal data;
    • the belonging of an individual to a particular nation, ethnic group, or race;
    • religious and political beliefs (belonging to a religious denomination, membership in a political party, participation in public associations, including a trade union, etc.);
    • business skills and other personal qualities which are evaluative in nature;

From this list, the Employer has the right to acquire and use only those information that characterizes a person as a party (potential party) to the employment contract.

  • Documents containing personal data of employees are:
    • documents supporting the process of registration of labor relations during hiring, transfer, and dismissal;
    • materials of questionnaires, testing, interviews, surveys, voting with the applicant for the position/Employee;
    • originals and copies of orders (instructions) concerning personnel;
    • personal files, employment records, information about employment history (STD-R form);
    • materials of performance appraisals;
    • materials of internal investigations;
    • reference and information bank of personnel data (card indexes, log books);
    • copies of reports submitted to state regulatory authorities.,

Responsibilities of the Employer

In order to ensure human and civil rights and freedoms, the Employer and its representatives must comply with the following general requirements when processing employee personal data:

  • Processing of employee personal data may be carried out solely for the purpose of ensuring compliance with laws and other regulations, assisting employees in employment, training and promotion, ensuring personal safety of employees, monitoring the quantity and quality of work performed and ensuring the safety of property, or staff recruitment.
  • When determining the scope and content of the employee personal data processed, the Employer shall be guided by the Constitution of the Russian Federation, the Labor Code of the Russian Federation and other federal laws.

Responsibilities of the Employee

The employee is obligated:

  • To provide the Employer or its representative with a set of reliable documented personal data (the data for which consent is given).
  • In a timely manner, within a reasonable period not exceeding 3 working days, to notify the Employer of any changes in their personal data.

Rights of the Employee

The Employee has the right:

  • To be fully informed about his or her personal data and the processing of that data.
  • To have unrestricted and no-cost access to his or her personal data, including the right to receive copies of any record containing the employee personal data, except in cases prescribed by the laws of the Russian Federation.
  • To request that the transfer (distribution, provision, access) of personal data authorized for distribution be stopped at any time. The request shall be made in writing. The request should include the surname, first name, patronymic (if any), contact information (phone number, email address or mailing address) of the employee, as well as a list of personal data the processing of which is to be stopped.

Collecting, Processing and Storing Personal Data

  • Processing of employee personal data means any action (operation) or a set of actions (operations), performed with or without the use of means of automation, in relation to personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, removal, destruction of employee personal data.
  • All personal data should be obtained from the employees themselves. If the employee personal data can only be obtained from a third party, the employee should be notified in advance and his or her written consent should be obtained.
  • The Employer shall inform the employee of the purposes, intended sources and methods of acquiring personal data, as well as the nature of the personal data to be acquired and the consequences of the employee's refusal to give written consent for the acquisition of such data.
  • The Employee shall provide the Employer with accurate information about himself or herself. The Employer has the right to request documents from the Employee confirming the accuracy of the information. 
  • At the time of hiring, an employee shall fill out a questionnaire.
  • The questionnaire is a list of questions about the employee personal data.
  • The questionnaire shall be filled out by the employee himself or herself. When filling out the questionnaire, an employee should fill in all of its columns, give complete answers to all questions, without corrections or crossing out, omissions or blots, in strict accordance with the records contained in his or her personal documents.
  • The questionnaire filled out by the employee should be kept in the employee personnel file. The personnel file shall also contain other personal record documents pertaining to the employee personal data.
  • An employee personnel file shall be created after the issuance of the employment order.

Protection of Employee Personal Data

  • When processing personal data, the Employer shall take the necessary legal, organizational and technical measures, or ensure that they are taken, to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as other unlawful actions in relation to personal data.
  • Personal data shall not be used for purposes contrary to the requirements of the Federal Law, protection of the constitutional order, morality, health, rights and lawful interests of others, national defense and security of the state.

Liability for Disclosing Information Related to the Employee Personal Data

  • Persons guilty of violating the rules governing the acquisition, processing and protection of employee personal data shall bear disciplinary, administrative, civil or criminal liability in accordance with federal laws.