Complaints/Request Handling Policy

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Complaints/Requests Handling Policy

PREAMBLE

Sodexo Group is committed to handling Personal Data in compliance with the General Data Protection Regulation (GDPR) and any other applicable law and aims to deal promptly and efficiently with any queries relating to the Sodexo entities’ processing of Personal Data.

In some cases, Sodexo entities may act as a Processor on behalf of a Client. In this instance the Client is responsible for handling Data subject Requests relating to compliance with the GDPR and the Data subject’s Personal Data.

DEFINITIONS

  • Client means organisations or corporations that ask Sodexo to perform services on their behalf for their employees / On-site personnel that are the end-users of these services.
  • Complaint means the complaint lodged by a Data subject with a Supervisory Authority or a court of justice if the Data subject considers his or her rights under GDPR are infringed.
  • Controller means the entity that determines the purposes and means of the Personal Data processing.
  • Data subject means an identified or identifiable individual whose Personal Data is concerned by processing within Sodexo, including the Personal Data of Sodexo’s current, past and prospective applicants, employees, clients, consumers/beneficiaries, suppliers/vendors, contractors/subcontractors, shareholders or any third parties.
  • General Data Protection Regulation or GDPR means the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, and repealing Directive 95/46/EC
  • Group Data Protection Officer means the person appointed and endorsed by the Sodexo Group Executive Committee to oversee data protection issues at the Sodexo Group level, to define and administer the Sodexo data protection compliance program and good practices relating to data protection and to ensure their implementation as set out in Rule 20.
  • Local Single Data Protection Point of Contact means the individual appointed by a Sodexo entity, in charge of handling local data protection issues. In some cases, the Local Single Data Protection Point of Contact can be appointed as Local Data Protection Officer where required by applicable data protection law.
  • Personal Data means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Processing or Personal Data Processing means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
  • Request means one of the mechanisms provided by the GDPR to individuals to allow them to exercise their rights (such as the right of access, to rectification, to erasure etc.). An individual may make a Request against any entity which processes its Personal Data.
  • Sodexo entity or Sodexo entities means any corporation, partnership or other entity or organisation which is admitted from time to time as a member of the Sodexo Group. Collectively ‘Sodexo’.
  • Supervisory Authority means an independent public authority which is established by a Member State as specified in the GDPR.

SCOPE

This policy applies to the organisations of Prestige Nursing Ltd and Prestige Nursing (Scotland) Ltd for all dimensions and activities, in all geographies where we operate, where the Data Protection Act 2018 or the General Data Protection Regulation apply.

This policy applies to the Processing of Personal Data collected by Prestige Nursing Ltd and Prestige Nursing (Scotland) Ltd, directly or indirectly, from all individuals including, but not limited to Prestige Nursing Ltd and Prestige Nursing (Scotland) Ltd.’s current, past or prospective job applicants, employees, clients, consumers, children, suppliers/vendors, contractors/subcontractors, shareholders or any third parties, with “Personal Data” being defined as any data that relates to an identified or identifiable individual or a person who may be identified by means reasonably likely to be used. In this policy, “you” and “your” means any covered individual. “We”, “us”, “our” and “Prestige Nursing Ltd and Prestige Nursing (Scotland) Ltd” means Prestige Nursing Ltd and Prestige Nursing (Scotland) Ltd entities.

YOUR RIGHTS UNDER GDPR

Where Prestige Nursing Ltd and Prestige Nursing (Scotland) Ltd processes your Personal Data for its own purposes, please consult the Section “Your Rights” of our Data Protection Policy.

Where Prestige Nursing Ltd and Prestige Nursing (Scotland) Ltd processes Personal Data on behalf of a Client, Prestige Nursing Ltd and Prestige Nursing (Scotland) Ltd will notify the Client of any Data subject’s Request received. Prestige Nursing Ltd and Prestige Nursing (Scotland) Ltd will cooperate and provide the Client with assistance in relation to the Request, to the extent legally permitted and to the extent the

WHAT OUR TEAMS WILL DO IF THEY RECEIVE A REQUEST?

Our approach is to engage positively and resolve your Request in a satisfactory manner without you having to file a complaint to the local Court or the relevant Data Protection Supervisory Authority. If you have any queries with the Processing of your Personal Data, you should not hesitate to raise your query to Prestige Nursing Ltd or Prestige Nursing (Scotland) Ltd, where applicable. To help us to deal with your Request, please provide a full written explanation of your query by completing the Request Form below.

Prestige Nursing Ltd and Prestige Nursing (Scotland) Ltd shall inform its Client acting as Controller of any Request made by a Data subject as soon as possible. The Client will be in charge of handling such Request and Prestige Nursing Ltd and Prestige Nursing (Scotland) Ltd will assist the Client in responding to Data subject Requests. Prestige Nursing Ltd and Prestige Nursing (Scotland) Ltd will directly handle Requests only when it is agreed with the Client or if the Client disappeared or cease to exist in law or became insolvent. In all other cases, Prestige Nursing Ltd and Prestige Nursing (Scotland) Ltd will assist the Client in responding to Data subject Requests.

HANDLING REQUESTS

At the time of drafting your Request and to allow Prestige Nursing Ltd and Prestige Nursing (Scotland) Ltd to deal promptly with your Request in the most efficient manner, you are invited to follow these steps:
STEP 1: Complete and submit the Request Form by email to the generic email address as indicated in the information notices and/or the privacy policies provided to you at the time of the collection of your Personal Data and/or to the Group Data Protection Officer at the following email address: dpo.group@sodexo.com..
STEP 2: Your Request will be treated confidentially and fully investigated where necessary. During this process, you may receive additional communication from the relevant Sodexo’s Local Single Data Protection Point of Contact and/or Sodexo’s Global Data Protection Office to investigate your concern. If you have not provided sufficient information in your Request, we will let you know what further information is needed to process your Request.
STEP 3: Once the information related to your Request is complete, we will contact you within thirty (30) days to provide you with an answer. This deadline may be extended in certain circumstances, depending on the nature of the Request.
STEP 4: Please note that you can choose to lodge a complaint with the Data Protection Supervisory Authority in the country of your habitual residence, place of work or place of the alleged infringement, regardless of whether you have suffered damages. Personal Data
You have also the right to lodge your complaint before the courts where the Sodexo entity has an establishment or where you have your habitual residence.

REQUEST FORM

To be sent by email to the generic email address as indicated in the information notices and/or the privacy policies provided to you at the time of the collection of your Personal Data and/or to the Global Data Protection Office at the following email address: dpo.group@sodexo.com.

Download the Request Form

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