Personal Data Processing Policy

Chapter 1. General Provisions

  1. The Operator is the Limited Liability Company “Green Legal” (hereinafter referred to as the Operator), registered in the Unified State Register of Legal Entities and Individual Entrepreneurs by the Minsk City Executive Committee on 01/05/2024, UNP 193733691, legal address: Republic of Belarus, 220029, Minsk, Masherova Ave., 9, room 1 (room 217).
  2. The Operator’s personal data processing policy (hereinafter referred to as the Policy) defines the basic principles, goals, conditions and methods of processing personal data, lists of subjects and personal data processed by the Operator, the Operator’s functions in the processing of personal data, the rights of personal data subjects, as well as the requirements for the protection of personal data implemented by the Operator.
  3. The policy was developed in accordance with the Law of the Republic of Belarus dated 05/07/2021 No. 99-Z “On the Protection of Personal Data” (hereinafter referred to as Law No. 99-Z), also taking into account the requirements of the Constitution, legislative and other regulatory legal acts (hereinafter referred to as the NLA) of the Republic of Belarus in the field of personal data.
  4. The policy uses concepts whose meaning is specified in Art. 1 of Law No. 99-Z.
  5. The operator is obliged to provide unlimited access, including using the global computer network Internet, to documents defining the operator’s policy regarding the processing of personal data, before such processing begins in accordance with clause 4 of Art. 17 of Law No. 99-Z.
  6. The provisions of the Policy serve as the basis for the development of local legal acts (hereinafter referred to as LLA) regulating the Operator’s processing of personal data of the Operator’s employees and other subjects of personal data.

Chapter 2. Objectives and Legal Bases for Processing Personal Data

The Operator’s personal data processing policy is determined in accordance with the following regulations:

  • Constitution of the Republic of Belarus
  • Labor Code of the Republic of Belarus;
  • Law No. 99-Z;
  • Law of the Republic of Belarus dated July 21, 2008 No. 418-Z “On the Population Register”;
  • Law of the Republic of Belarus dated November 10, 2008 No. 455-Z “On information, informatization and information protection”;
  • Decree of the President of the Republic of Belarus dated October 28, 2021 No. 422 “On measures to improve the protection of personal data”;
  • Order of the National Center for Personal Data Protection of the Republic of Belarus dated November 15, 2021 No. 14 “On cross-border transfer of personal data” (hereinafter referred to as Order No. 14);
  • other legal acts of the Republic of Belarus and regulatory documents of authorized government bodies.

8. In order to implement the provisions of the Policy, the Operator develops relevant LPA and other documents, including:

  • Regulations on the processing and protection of personal data.
  • other LPA and documents regulating the Operator’s issues regarding the processing of personal data.

9. Personal data is processed by the Operator for the purposes of:

9.1. Processing applications from site users

Subject of personal dataList of processed personal dataLegal groundsStorage period
Users of the website: https://en.glegal.by/Name, contact phone number, other data that the user can provide at his own discretionConsent of the subject of personal data (Article 5 of the Law)3 months

9.2. Considering the employment opportunities of candidates

Subject of personal dataList of processed personal dataLegal groundsStorage period
Persons who sent a resumePersonal data in accordance with the content of the resume (questionnaires, autobiographies, personnel registration sheets, applications, letters of recommendation, etc.)
  1. When sending a resume by e-mail – consent of the subject (Article 5 of the Law).
  2. When sending (providing) a resume in writing or in the form of an electronic document – paragraph sixteen of Article 6 of the Law.
  3. In relation to previously distributed personal data (for example, on the rabota.by service) – paragraph nineteen of Article 6 of the Law
No more than 1 year (in case of non-hiring);
1 month (if hired)

9.3. Regulation of labor relations with the Operator’s employees

Subject of personal dataList of processed personal dataLegal groundsStorage period
Operator’s employees, members of their families
  • surname, first name, patronymic (as well as all previous surnames);
  • date of birth; citizenship;
  • passport data or data of another identification document;
  • gender; information about marital status and family composition;
  • information on registration at the place of residence;
  • information about the place of actual residence;
  • number and series of insurances state social insurance certificate;
  • information on education, advanced training and professional retraining;
  • taxpayer identification number;
  • information on work activity (including length of service and work experience);
  • specialty, profession, qualification;
  • information on military registration;
  • medical information (in cases stipulated by law);
  • information on the individual rehabilitation program for the disabled;
  • information on social benefits and payments;
  • contact information (including work and/or mobile phone numbers, email address);
  • information on awards and incentives;
  • information on membership in public associations;
  • information on scientific works, inventions;
  • information on the academic degree, academic titles;
  • information on participation in elected legislative and representative bodies.
Employment relations and work activities of the personal data subject (Clause 8, Article 6 of Law No. 99-Z).After dismissal – 55 years

9.4. Preparation, conclusion, execution, and termination of contracts with counterparties

Subject of personal dataList of processed personal dataLegal groundsStorage period
Representatives of organizational counterparties, individual entrepreneur counterparties
  • last name, first name, patronymic;
  • information on registration at place of residence – for individual entrepreneur counterparties;
  • contact information (including work, home, and/or mobile phone numbers, email address);
  • job title, if any;
  • company name, its details, or details of the individual entrepreneur.
Agreement concluded (to be concluded) with the personal data subject (Clause 15, Article 6 of Law No. 99-Z).Within three years after the expiration of the agreement, if the tax authorities conduct a compliance audit. If the tax authorities have not conducted a compliance audit, within 10 years after the expiration of the agreement.

9.5. Review of appeals

Subject of personal dataList of processed personal dataLegal groundsStorage period
Individuals who submitted the appeal. Other persons whose personal data is specified in the appeal.Last name, first name, patronymic, or initials, residential address (place of stay), subject of the appeal, other personal data specified in the appeal.The processing of personal data is necessary for the performance of duties (powers) stipulated by legislative acts (paragraph twenty of Article 6, paragraph seventeen of clause 2 of Article 8 of the Law).5 years.

9.6. Pre-registration for an in-person appointment

Subject of personal dataList of processed personal dataLegal groundsStorage period
Individuals requesting an in-person appointmentLast name, first name, patronymic, contact phone number, subject of question (appeal), and other personal data provided during the appointment.Processing of personal data is necessary to fulfill the duties (powers) stipulated by legislative acts (paragraph twenty of Article 6 of the Law).5 years

Chapter 3. Terms of Personal Data Processing by the Operator

  1. The Operator processes personal data with the consent of the personal data subject to the processing of their personal data or on other grounds specified in Chapter 2.
  2. The Operator does not disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by the legislation of the Republic of Belarus.
  3. Information required for deciding whether to grant consent to the processing of personal data (in cases where personal data is processed based on consent):
    • Name and location of the Operator: Green Legal Limited Liability Company, Republic of Belarus, 220029, Minsk, Masherov Ave., 9, office 1 (room 217).
    • Duration for which consent is granted:
      • Website users: 3 months.
      • Upon conclusion of an agreement, personal data is processed in accordance with Section 9.4 of the Policy.
      • Consideration of employment opportunities for candidates (if resumes are sent by email): no more than 1 year (if rejected) / 1 month (if accepted).
    • The list of personal data for which consent is given by the personal data subject is contained in Chapter 4 of the Policy for the relevant category of personal data subjects.
    • The list of actions with personal data that the personal data subject is authorized to perform: collection, systematization, storage, modification, use, depersonalization, blocking, distribution, provision, and deletion of personal data, including storage on email servers (including servers in foreign countries) and on the Company’s local server.
  4. For internal information support purposes, the Operator may create internal reference materials, which, with the written consent of the personal data subject, unless otherwise provided by the legislation of the Republic of Belarus, may include their last name, first name, patronymic, place of work, position, year and place of birth, address, subscriber number, email address, and other personal data provided by the personal data subject.
  5. Access to personal data processed by the Operator is permitted only to the Operator’s employees holding positions included in the list of positions in the Operator’s administrative divisions, branches, and representative offices, for which personal data is processed.
  6. Personal data is stored no longer than required for the stated purposes of personal data processing.

Chapter 4. List of Actions with Personal Data and Methods of Processing Them

16. The Operator processes personal data (any action or set of actions performed with personal data, including collection, systematization, storage, modification, use, depersonalization, blocking, distribution, provision, and deletion of personal data).

17. The Operator processes personal data in the following ways:

  1. Using automation tools;
  2. Without the use of automated tools, provided that this provides for searching and/or access to personal data based on specific criteria (card indexes, lists, databases, journals, etc.).

Chapter 5. Rights of Personal Data Subjects

18. The personal data subject exercises their rights to the extent and in the manner established by the legislation of the Republic of Belarus.

19. The personal data subject has the right to revoke their consent at any time without explanation by sending a written statement to the Operator (by registered mail or in person) to the following address: 9 Masherov Ave., Office 1 (Room 217), Minsk, 220029, Republic of Belarus. The statement may also be submitted electronically to the corporate email address: info@en.glegal.by.

Contact information for the person responsible for internal control over the processing of personal data: Director Andrey Mikhailovich Slabko, slabko@en.glegal.by, +375 (33) 680 30 20.

The data subject’s application must include:

  • the data subject’s last name, first name, patronymic (if any), and residence (place of stay) address;
  • the data subject’s date of birth;
  • the data subject’s identification number, or, if such number is not available, the number of the data subject’s identity document, if this information was provided by the data subject when giving consent to the operator or if the personal data is processed without the data subject’s consent;
  • a statement of the data subject’s requirements;
  • the data subject’s personal signature or electronic digital signature.

20. The personal data subject has the right to submit an application, in accordance with the procedure set forth in Clause 19 of this Policy, to receive information regarding the processing of their personal data, including:

  • the name (last name, first name, patronymic (if any)) and location (residence address (place of stay)) of the operator;
  • confirmation of the processing of personal data by the operator (authorized person);
  • their personal data and the source thereof;
  • the legal basis and purposes for processing the personal data;
  • the period for which their consent is given;
  • the name and location of the authorized person, who is a government agency, a legal entity of the Republic of Belarus, or another organization, if the processing of personal data is entrusted to such person;
  • other information required by law.

21. The personal data subject has the right to submit an application, in accordance with the procedure provided for in paragraph 19 of this Policy, requesting changes to their personal data if the personal data is incomplete, outdated, or inaccurate.

22. The personal data subject has the right to submit an application, in accordance with the procedure provided for in paragraph 19 of this Policy, to receive information from the operator about the provision of their personal data to third parties once per calendar year free of charge.

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