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SODEXO HONG KONG DATA PROTECTION REQUESTS POLICY

Last update: December 7th, 2020

 

1. PREAMBLE

Sodexo is committed to handling Personal Data in compliance with the Data Protection Law and any other applicable laws and aims to deal promptly and efficiently with any queries relating to the processing of Personal Data.

In some cases, Sodexo may act as a Data Processor on behalf of a Client. In such instances, the Client is responsible for handling Data Subject Requests relating to compliance with the Data Protection Law and the Data Subject’s Personal Data as the Data User.

2. DEFINITIONS

3. SCOPE

This policy applies to Personal Data collected by Sodexo, directly or indirectly, from all individuals including, but not limited to, Sodexo’s current, past or prospective job applicants, employees, Clients, consumers, suppliers/vendors, contractors/subcontractors, shareholders or any third parties.

In this policy, “you” and “your” means any covered individual. “We”, “us”, “our” and “Sodexo” means the global organization of Sodexo entities.

4. YOUR RIGHTS UNDER DATA PROTECTION LAW

The Data Protection Law applies where a Data User controls the processing of Personal Data in or from Hong Kong even if the whole data processing occurs outside Hong Kong.

Where Sodexo processes your Personal Data for its own purposes, please consult the Section “Your Rights” of our HK Data Protection Policy

Where Sodexo processes Personal Data on behalf of a Client, Sodexo will notify the Client of any Requests received. Sodexo will cooperate and provide the Client with assistance in relation to the Request, to the extent legally permitted by the Data Protection Law and any other applicable laws.

5. WHAT OUR TEAMS WILL DO IF THEY RECEIVE A REQUEST?

Our approach is to engage positively and to resolve your Request in a satisfactory manner without you having to file a complaint to the local court or the Commissioner.

If you have any queries with regarding the processing of your Personal Data, you should not hesitate to raise your query to Sodexo. To help us to deal with your Request, please provide a full written explanation of your query by completing the Request Form below.

Sodexo shall inform its Client acting as principal of any Request made by a Data Subject as soon as possible. The Client will be in charge of handling such Request and Sodexo will assist the Client in responding to Data Subject Requests. Sodexo will directly handle Requests only where it is specifically agreed with the Client. In all other cases, Sodexo will assist the Client in responding to Data Subject Requests.

6. HANDLING REQUESTS

At the time of drafting your Request and to allow Sodexo 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 Local Data Protection Point of Contact at the following email address: dpo.hk@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 forty (40) calendar days to provide you with an answer. In case we cannot respond to your request in a timely manner or where there are valid grounds for refusal in accordance with the Data Protection Law, we will notify you in writing of the reasons for the delay.

STEP 4: Please note that you can choose to lodge a complaint with the Commissioner in accordance with the Data Protection Law.

You have also the right to lodge your complaint before the courts where Sodexo has an establishment or where you have your habitual residence.

 

Click here to download the request form

 

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