I. Policy Scope
II. Policy Changes
III. Policy Content
This policy seeks to answer questions you may have about the Services and Millowsatya Services information practices.
i. What information we collect and why we collect it
ii. How we share and use that information
iii. General Exceptions
iv. Consent and Update of Records
v. Services regarding tracking, analytics and email communications
vi. Security and Compliance with regulatory authorities
vii. How we protect your information
viii. Where is the information processed or stored?
ix. Who can use the services?
x. Data Protection Officer
IV. Information We Collect
Personally Identifiable Information:
Personally Identifying Information (“PII”) of a person means such information that can potentially identify you, such as your name, date of birth and address. It does not include anonymized, aggregate or statistical information.
Personally Identifying Information that we collect and hold about an individual will vary depending upon the background checks required by the Client and the information the individual supplies to us. Personally Identifiable Information and Sensitive Personal Information or Data (SPI) shall have the same meaning as defined under The Information Technology Act, 2000 read with Rules along with the amendments made there under.
Personally Identifiable Information about an individual that we may collect and hold includes name, age, date of birth, employment history, reference information, education, professional qualifications, residency, sanctions, immigration status, claims, judgments, insolvency, current and previous directorships, character, personal reputation, and such other checks and enquiries as the client considers necessary to verify information provided by an individual.
From clients we may collect company address and the name, email and phone number of any system users.
From clients and individuals, we may collect information related to conducting a background check, payment details.
From the sources of our background checks we may collect the name and job title of the person who supplied us with the information.
How do we collect information?
In order to process and verify information for a client’s request, the client and Millowsatya Services may collect an individual’s Personally Identifying Information directly from the individual. We may also collect information which the client provides directly through their client portal access or usage of our applicant portal, wherein clients/applicant upload applicant’s details on the portal and access is given to Millowsatya Services Users. We collect information to provide better services to all in the following ways:
a) Information given to us.
i. Clients: If client want to use the services to screen applicants we may collect the following information including, but not limited to:
• Account creation information, including client name, email address.
• Contact information such as address and phone number;
• Corporate and individual applicable license information not limited to Driver license, doctor’s license.
• If client is an employer, employee identification number.
ii. Applicants: If applicant directly provides us details who will be the subject of a screening or background check, we may collect the following information including, but not limited to:
• Account creation information, including full name, e-mail address;
• Contact information, including phone number and address;
• Identity verification information, including identity number and date of birth; and
• Additional information or supporting documentation submitted or upload regarding identity, background, query;
• Examples include an uploaded picture, a driver’s license, or education qualification document.
We may use the Personally Identifiable Information (“PII”) & Sensitive Personal Information ("SPI"), documents and any responses an individual or third party reference has provided to us for verification of an individual’s personal and other information, to collect additional Personally Identifiable Information (“PII”) & Sensitive Personal Information ("SPI"), and to conduct public court record searches. Example of sources include, but are not limited to, government agencies, law enforcement bodies, publicly available records, public registries, court or tribunal records, insolvency registers, educational institutions, current and/or previous employers, and regulatory and licensing bodies.
b) Information used by Millowsatya.
We collect information for conduct and delivery of services contracted by our client or applicants. Millowsatya may collect this information via online request through email, this information includes:
i. Candidate Information: Millowsatya Services Private Limited may use (only with permission) this information to provide its client with background check information & additional information regarding products and services.
• verify applicant identity.
• conduct background checks bases upon information provide by client;
• conduct quality assurance checks;
• investigate disputes; or
• provide certain communications, including adverse action notices.
• contact client regarding their use of the Services;
• send client communications regarding updates or modifications to the services.
V. Information We Share
We do not share Personal Identifiable Information with companies, organizations and individuals outside of Millowsatya Services unless one of the following circumstances applies:
• With client and applicant consent.
We will share applicant Information with companies, organizations or individuals outside of Millowsatya Services for employment services when we have client consent to do so.
• For external processing.
For conduct of background reports that may arise during the course of the verification service. Millowsatya Services may use researchers & third party service Providers, whom Millowsatya Services may provide access to client information to select third parties who perform services on our behalf. These third parties provide a variety of services to us, including without limitation conducting components of background checks, billing, fulfilment, data storage, analysis and processing, identity verification, fraud, accounting, auditing, and legal services.
• For legal reasons.
We will share Personally Identifiable Information (“PII”) & Sensitive Personal Information ("SPI") /data with companies, organizations or individuals outside of Millowsatya Services if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
• Meet any applicable law, regulation, legal process or enforceable governmental request.
• Enforce applicable Terms of Service, including investigation of potential violations.
• Detect, prevent, or otherwise address fraud, security or technical issues.
• Protect against harm to the rights, property or safety of Millowsatya, our users or the public as required or permitted by law.
• General visitors: We do not store cookies to track website activity.
If Millowsatya Services is involved in a merger, demerger, acquisition or asset sale or reconstruction we will continue to ensure the confidentiality of any Personally Identifiable Information (“PII”) & Sensitive Personal Information ("SPI")/ data and give affected users Notices.
Data Retention: Millowsatya Services retains Personally Identifiable Information (“PII”) & Sensitive Personal Information ("SPI") as needed to provide services or product information, respond to inquiries, or as required by contractual obligation such as Client – Millowsatya Services contracts, statutory or other legal obligations. All Client Information is stored/ Retained digitally.
Data Retention is defined as the maintenance of data in a production or live environment which can be accessed by an authorized user in the ordinary course of business. For the avoidance of doubt, data used in staging, development, and testing or draft versions of data shall not be retained beyond their active use period, nor copied into production or live environments.
The retention period of Millowsatya Services data shall be an active use period of five years unless an exception has been obtained from client in a documented/stated expression - permitting a longer or shorter active use period by the division responsible for creating, using, processing, disclosing storing and destroying the data or as directed by client contracts.
VI. General Exceptions
If we are required to intercept, disclose, monitor and/or store client Personally Identifiable Information (“PII”) & Sensitive Personal Information ("SPI"):
• by law.
• to conduct our business;
• to secure our systems; or
• to enforce our own rights, we will do so in the manner as prescribed by law.
• National security.
VII. Withdraw Consent
VIII. Update Records
Clients should promptly update their contact information pursuant to a change or inaccuracy of such information, with their customers/employer or may contact us on their behalf. Applicants may review, access, and change certain account information such as email address, phone number and mailing address via the applicant portal on the services. Requests to change certain other information, such as identity numbers, may require verification before the change is accepted. Applicants can request deletion of certain information in Millowsatya’s control by directly contacting Millowsatya, as set forth at the end of this Policy. Applicants can dispute background check reports through the applicant portal/ or by directly contacting their employer/customer (requestor), which is accessible through the Services.
Once a Customer, such as an employer, has received a background check report, Millowsatya Services Private Limited does not control the customer’s retention of such information.
Millowsatya Services will be unable to proceed with the provision of services to Clients in the absence of necessary permissions or consent from the individual subject to the background check.
IX. Choices Regarding Online Tracking, Analytics and Email Communications
Millowsatya Services may send periodic promotional or informational emails to its Clients. Clients may opt out of such communications by connecting with their concerned account manager or sending an email to Millowsatya Services (please see last section for contact email id). Please note that it may take up to 15 business days for us to process opt-out requests. If client opts out of receiving emails about recommendations or other information we think may interest them, we may still send emails about clients account or any services that have been requested or received from us.
X. Security and Confidentiality
Millowsatya Services strives to protect Personally Identifiable Information (“PII”) & Sensitive Personal Information ("SPI") that we collect, maintain and disclose through the use of reasonable administrative, physical and technical safeguards. Our products and/or services online are transmitted through a Secure Socket Layer (SSL) transmission, which is a protocol for establishing a secure connection for transmission of Personally Identifiable Information (“PII”) & Sensitive Personal Information ("SPI").
Millowsatya Services has also employed security protocols and measures to ensure confidentiality and protection of Personally Identifiable Information (“PII”) & Sensitive Personal Information ("SPI"), in order to avert unauthorized access or alteration as well as unlawful disclosure of the collected information. These measures include internal and external firewalls, physical security and technological security measures, as well as encryption of certain information and password protection for account information. Ergo, our security program is designed to: (1) ensure the security and confidentiality of personal identifiable information that may include Pan Number, Aadhar Card Number etc.;(2) protect against any anticipated threats or hazards to the security or integrity of the information; and (3) protect against unauthorized access, use, alteration, or unlawful disclosure of the information that could result in substantial harm or inconvenience to any individual.
XI. Compliance and Cooperation with Regulatory Authorities
Millowsatya Services ensures - we regularly review our compliance with our Policy. We also adhere to several self-regulatory frameworks, including and not limited to adherence to Information Technology, Privacy and Data Protection legislations applicable in India.
XII. International – Onward Transfer of Personal Identifiable Information
We may disclose Personally Identifiable Information (“PII”) & Sensitive Personal Information ("SPI") for the purposes of conducting our services to overseas recipients. The circumstances of disclosure may be as follows:
We may need to disclose an individual’s Personally Identifiable Information overseas in order to carry out background checks. For example, if an individual lived, studied or worked overseas, we may need to disclose that individuals Personally Identifiable Information (“PII”) & Sensitive Personal Information ("SPI") to obtain data from sources, employers, third party reference or education institutes. Disclosures of this kind may be to any country in the world, depending upon the nature and scope of work to be carried, and where the candidate’s data resides.
We may also disclose an individual’s Personally Identifiable Information (“PII”) & Sensitive Personal Information ("SPI") to related bodies for purposes including operations, processing of background report or make it accessible to law enforcement and national security authorities in India, upon receipt of authorization letter, notice, warrants or legal mandate.
XIII. Information from Children
Millowsatya Services background verification is not directed to children under the age of 14 as per the local legal requirement of the country, and we do not knowingly collect personally identifiable information from children under the age of 14. If we learn that we have collected personally identifiable information of a child under the age 14, we will take reasonable steps to delete such information from our files as soon as is practicable.
Please contact us at email@example.com. If you believe we have any information from or about a child under the age of 14.