1             Privacy Policy

This privacy policy for Hitachi solutions India private limited (HSIN) is derived from the primary policy of Hitachi solutions Europe Limited based out of UK. HSIN plays the role of Data processor for customer related data processing being offshored from Hitachi solutions UK , being the primary Data controller. HSIN shall play the role for data controller for employee related data and part of Supplier data.

1.1.       Approach to Privacy

As a leading information services company, Hitachi Solutions Group handles a diverse range of information including our own technical information and information from our customers. We have an established framework for information management that we stringently apply out of respect for the value of the information we are trusted with. We have established management systems for the protection of personal data, a framework for information management, and a privacy policy. The management systems are designed to be consistent with applicable legislation concerning the handling of personal data including the General Data Protection Regulation (EU) (BS10012 :2016 +A1 2018) (the GDPR) and ISO 27701, as a basis. We ensure that our directors and employees are continuously informed about these policies. We are consistently implementing, maintaining and continuously improving the management systems. This privacy policy sets out how we look after your personal data including when you visit our websites Hitachi Solutions India : http://india.hitachi-solutions.com/ (regardless of where you visit it from), your privacy rights and how the law protects you.

1.2.        Important information and who we are

1.2.1.     Hitachi Solutions’ Privacy Policy

        OUR PRIVACY POLICY :   The Top management of Hitachi Solutions India Pvt Ltd.(HSIN) is committed to the rights of individuals whose data they collect and process and will comply with applicable personal information management system processes.   OUR KEY FOCUS: Our Key Focus is  ensure security and protection of the personal information we process by:
  • Compliant and consistent approach to cover privacy by design, Right to be forgotten with risk enabled approach.
  • Transparency regarding use of data
  • That any processing is lawful, fair, transparent and necessary for a specific purpose
  • That data is accurate, kept up to date and removed when no longer necessary
  • That data is kept safely and securely
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Our website is not intended for children and we do not knowingly collect data relating to children. Please read this privacy policy together with any other privacy or fair processing notice we may provide on specific occasions when we are collecting or processing your personal data. This privacy policy supplements the other notices and is not intended to override them. Our website may include links to third-party websites, plug-ins and applications which we do not control, and we are not responsible for their privacy statements.

1.2.2.     Contact details

For the purpose of the GDPR, the data controller is Hitachi Solutions Europe Limited (HSUK), a company incorporated in England  and Data processor is Hitachi Solution India private limited (HSIN), a company incorporated in Chennai, Tamilnadu, India. We have appointed a data protection officers (DPO) who is responsible for overseeing questions in relation to this privacy policy from data processor perspective for HSIN: Name or title of DPO for HSIN:  Abinsam KA Email address: Abinsam@hitachisolutions.com Registered Postal address: 1/124 Shivaji gardens, Ground floor, Block 1C, DLF IT Park – Chennai -89, INDIA You have the right to make a complaint at any time to CERTIN (https://www.cert-in.org.in/), the Indian supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach CERTIN, Hence, please contact us in the first instance.

1.3.       Collection and processing of personal data

Hitachi Solutions Group provides information services, which involves activities through which we collect and process personal data, through our website and our business activities. We may collect and process the following types of personal data:
  • Identity Data: this includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data: this includes postal address, email address and telephone numbers.
  • Financial Data: this includes bank account details.
  • Transaction Data: this includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data: this includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
  • Profile Data: this includes purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data: this includes information about how you use our website, products and services.
  • Marketing and Communications Data: this includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Employment Data: this incudes your employment history, academic qualifications, background checks and information provided in references.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy. We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).

1.4.       Information about criminal convictions

We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with this Privacy Policy. Less commonly, we may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public. We envisage that we will hold information about criminal convictions. We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so. We will use information about criminal convictions and offences in the following ways:
  • For our recruitment activities;
  • For the provision of our services to any customers.
We are allowed to use your personal information in this way for the purpose of our legitimate interest and pursuant to law. We have in place an appropriate policy and safeguards which we are required by law to maintain when processing such data.

1.5.        How we collect personal data

We use different methods to collect data from and about you including through:
  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • make an enquiry about, or engage us to provide, our products and services;
    • subscribe to our mailing list, participate or view our webinars or download any publications from our website;
    • request marketing to be sent to you;
    • enter a survey; or
    • provide us with feedback.
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details].
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
  • Technical Data from analytics providers such as Google
  • Identity and Contact Data from publicly availably sources such as Companies House.

1.6.        Use of personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us. Purposes for which we will use your personal data We have set out below how we may use your personal data and the legal bases we rely on to do so (including our legitimate interests where appropriate). We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer (a) Identity (b) Contact Performance of a contract with you
To process and deliver services for you including:   (a) Manage payments, fees and charges (b) Collect and recover money owed to us (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our services, business activities, terms or privacy policy (b) Asking you to leave a review or take a survey (a) Identity (b) Contact (c) Profile (d) Marketing and Communications (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated, to study how customers use our products and services and to develop our services and grow our business)
To enable you to complete a survey (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products and services, to develop them and grow our business)
To administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data and monitoring the functionality of our website) (a) Identity (b) Contact (c) Technical (d) Usage (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical Necessary for our legitimate interests (to study how customers use our products and services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products and services, marketing, customer relationships and experiences (a) Technical (b) Usage (c) Profile Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about services that may be of interest to you (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile Necessary for our legitimate interests (to develop our products and services and grow our business)
To process your application for a role with us and to administer our human resources functions (a) Identity (b) Contact (c) Financial (c) Employment a)     Performance of a contract with you b)     Necessary to comply with a legal obligation c)     Necessary for our legitimate interests (to keep our records updated and to run our recruitment process)

1.7.       Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason which is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

1.8.       Disclosure of personal data

We may share your personal data for the purposes set out in the table above with:
  • Any member of the Hitachi group of companies, acting as joint controllers or processors (including any group companies who are based in India, Japan, USA, Canada, & Europe) and who provide IT and system administration services.
  • Selected third parties as follows:
    • business partners, suppliers and contractors acting as processors (based in the UK or country in which we are providing services to you) who provide IT and system administration services and where required for the performance of any contract we enter into with you.
    • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers (based in the UK or country in which we are providing services to you) who provide consultancy, banking, legal, insurance and accounting services.
    • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers (based in the UK or country in which we are providing services to you).
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We may process your personal data or disclose it to third parties, without your knowledge or consent, where this is permitted by law or where we are under a duty to process or disclose your personal data in order to comply with any legal obligation.

1.9.       Data security

We have implemented appropriate technical and organisational measures to ensure the security of personal data that is held by us, including by conforming with rules concerning information security, controlling access to, restricting the means for removal, and preventing unauthorized external access to information. We are ISO 27001 certified. In the event that we suspect there are issues with our safety measures or that there has been a personal data breach, we will identify the cause and take appropriate corrective action including, where we are legally required to do so, notifying you and any applicable regulator of a breach.

1.10.    Storage and international transfers of personal data

The data that we collect from you will be stored  securely in our servers within HSIN.  We are part of a global group of companies, and the data may be transferred within our group to a destination outside of the India, US, EEA, Japan and/or processed by staff operating outside of the India. Whenever we transfer your personal data out of India, we ensure a similar degree of protection is afforded to it, by ensuring that at least one of the following safeguards is implemented: Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of India.

1.11.    Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us. In some circumstances you can ask us to delete your data: see Request erasure below for further information. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

1.12.    About cookies and web beacons

Our website uses cookies and web beacons to improve your user experience. For detailed information on the cookies and web beacons used on our website, please see our cookie policy.

1.13.     Marketing

You will receive marketing communications from us if you have requested information from us, subscribed to our mailing list or webinars or purchased services from us and, in each case, you have not opted out of receiving that marketing. You have the right to ask us and third parties not to process your personal data for marketing purposes by checking certain boxes on the forms we use to collect your data, by following the opt-out links on any marketing message sent to you or at any time by contacting us. Where you opt out of receiving these marketing messages, the opt-out will not prevent us from processing your personal data provided to us as a result of a product or service purchase or other transactions.

1.14.    Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

1.15.    Access to information

The GDPR\ISO27701 gives you the right to access information held about you. Your right of access can be exercised in accordance with the GDPR\ISO27701. Any access request will be free of charge but we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive (or we may refuse to comply with your request in these circumstances). If we refuse to comply with a request, we will explain the reason why and you can exercise your right to complain to the ICO and CERTIN based on applicable GEO. Please address your requests to our DPO at first instance , before highlighting to the applicable GEO. We try to respond to all legitimate requests within one month. If it takes us longer than a month because your request is particularly complex or you have made a number of requests, we will notify you and keep you updated.

1.16.    13. Changes to our privacy policy

This version was last updated on 16-Feb-2020 We may update our privacy policy in the future in line with business practices and applicable laws. Any new versions of the privacy policy will be made available on our website with the date of the last revision noted. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

1.17.    14. Questions

Please contact our Data Protection Officer using the contact details set out above if you have any questions, comments or requests in relation to this privacy policy, including any requests to exercise your legal rights.

1.18.    15. Glossary

1.18.1.   Lawful basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by these impacts on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

1.18.2.   Your legal rights

You have the right to: Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.