This Personal Data Processing Policy (hereinafter referred to as the Policy) has been developed in accordance with the requirements of Federal Law No. 152–FZ dated 27.07.2006 "On Personal Data" and establishes the procedure for processing personal data of individuals in connection with the implementation of employment relations and in connection with the provision of Lotos LLC of hotel services.
Lotos LLC (the Operator of personal data processing) processes the following categories of personal data in connection with the implementation of an employment relationship:
- last name, first name, patronymic;
- gender, age;
- date and place of birth;
- passport data;
- the address of registration at the place of residence and the address of actual residence;
- phone number (home, mobile);
- data of documents on education, qualifications, professional training, advanced training;
- marital status, information about the composition of the family that the employer may need to provide benefits provided for by labor and tax legislation;
- attitude to military duty;
- information about work experience, previous jobs, income from previous jobs;
- SNILS;
- INN;
- information about admission, transfer, dismissal and other events related to employment in Lotos LLC;
- information about income in LLC "Lotos";
- information about business and other personal qualities of an evaluative nature.
The following categories of personal data are processed by Lotos LLC for the purposes of providing hotel services:
- last name, first name, patronymic;
- passport data;
- the address of registration at the place of residence;
- phone number (home, mobile).
The following categories of personal data are processed for the purposes of compliance with migration legislation:
- last name, first name, patronymic;
- date of birth;
- passport data of a foreign citizen or a stateless person;
- migration card;
- visa.
The personal data processing operator does not provide or disclose information containing personal data of clients to a third party without the written consent of the personal data subject, except in cases where this is necessary to prevent threats to life and health, as well as in cases established by Federal Laws.
Upon written request, the personal data of a personal data subject may be transferred without his consent solely for the purpose of fulfilling the functions and powers assigned by law.:
- to the prosecutor's office;
- to the police authorities;
- to the investigating authorities;
- to the judicial authorities;
- to the state security agencies;
- to other bodies and organizations in cases established by regulatory legal acts that are mandatory for execution.
The personal data processing operator does not respond to questions related to the transfer of personal data by phone or fax.
The personal data subject has the right to require the Operator of personal data processing to clarify his personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate or not necessary for the stated purpose of processing, as well as to take legally prescribed measures to protect their rights.
In order to exercise the above rights, a personal data subject may, in accordance with the procedure established by Article 14 of Federal Law No. 152-FZ dated July 27, 2016 "On Personal Data", contact the Personal Data Processing Operator with an appropriate request. In order to fulfill such requests, the Personal Data Processing Operator may need to identify you and request additional information.
If the personal data subject believes that the Personal Data Processing Operator is processing his personal data in violation of the requirements of this Federal Law or otherwise violates his rights and freedoms, the personal data subject has the right to appeal the actions or omissions of the Personal Data Processing Operator to a higher authority, to the prosecutor's office or in court.
In addition, the current legislation may establish restrictions and other conditions regarding the rights of the personal data subject mentioned above.
The personal data processing operator takes the necessary organizational and technical measures to protect personal data. The measures taken are based on the requirements of art. 18.1, art. 19 of Federal Law No. 152-FZ dated July 27, 2016 "On Personal Data", Decree of the Government of the Russian Federation dated September 15, 2008 No. 687 "On approval of the Regulation on the specifics of personal data processing carried out without the use of automation tools".
In particular:
1. Persons responsible for organizing the processing and ensuring the security of personal data have been appointed.
2. A Regulation on the protection of personal data of employees has been developed and implemented.
3. The Regulation on the protection of personal data of clients has been developed and implemented.
4. Persons who process personal data have been instructed and familiarized with the regulatory legal acts regulating the operation and protection of personal data.
5. Access rights to the personal data being processed are delimited.
6. In order to carry out internal control over the compliance of personal data processing with the established requirements, periodic checks of the personal data processing conditions are carried out.
7. In addition to the above-mentioned measures, technical measures are being implemented aimed at:
- preventing unauthorized access to systems where personal data is stored;
- backup and restoration of personal data of operability of technical means and software, information protection means in information systems of personal data modified or destroyed as a result of unauthorized access to them;
- other security measures.
Information related to personal data that has become known in connection with the implementation of employment relations and in connection with the provision of hotel services is confidential information and is protected by law.
Employees and other persons who have gained access to the personal data being processed have been warned about possible disciplinary, administrative or criminal liability in case of violation of the norms and requirements of the current legislation governing the rules of processing and protection of personal data.
This Policy may be supplemented or amended. If significant changes are made to this Policy, unrestricted access to them will be provided to all interested subjects of personal data.