Privacy notice for project sites in Macau

1. Introduction

ISG Asia (Macau) Limited is a company registered in Macau under the registration number 22253(SO).  Our registered address is Flat E, 4/F, 411-417 Alameda Dr. Carlos D’Assumpção, Dynasty Plaza, Macau. All references to 'we', 'us', 'our' are references to ISG Asia (Macau) Limited and its affiliates.

Please click here to view ISG’s Global Privacy Policy and how we comply with the provisions of the European General Data Protection Regulation for EU residents. 

ISG Asia (Macau) Limited respects personal data privacy and is committed to fully implementing and complying with the requirements under the Personal Data Protection Act (Act 8/2005) (“PDPA”). Furthermore, being a direct subsidiary of ISG Asia (Hong Kong) Limited, we also comply to the Personal Data (Privacy) Ordinance (Cap. 486) (“PDPO”). Personal data will be collected only for lawful and relevant purposes and all practicable steps will be taken to ensure that personal data held by us is accurate. We will take all practicable steps to ensure security of the personal data and to avoid unauthorized or accidental access, erasure or other use.

We understand that you care about your privacy, and we take that seriously. This Privacy Notice explains our information processing practices. It applies to any personal data you provide to ISG and, subject to local law, any personal information we collect from other sources.

2. Data protection officer

ISG plc is headquartered in England and Wales. ISG plc has appointed an internal data protection officer (DPO) for you to contact if you have any questions or concerns about the ISG plc's personal data policies or practices. ISG plc's data protection officer's name and contact information are as follows:

Richard Yates
Data Protection Officer
ISG Plc
Aldgate House
33 Aldgate High Street
London EC3N 1AG
data.protection@isgplc.com

3. Why we collect your information

3.1. Purposes

As is true of most companies, ISG Asia (Macau) Limited needs to collect and use your personal information for various purposes. On our project sites we collect personal information for the following purposes;

  • Health and Safety: Personal information we collect to for your safety and the safety of others
  • Security: Personal information we collect to ensure security on project sites
  • Legal reasons: Personal information we are required to collect by law

3.2. Legal Basis for collecting and using your data

The legal basis for collecting and using your personal information on project sites are Legitimate interests, Legal obligation and Performance of a contract.

For more information on what ISG’s legitimate interests are please refer to the appendices or contact us at hongkong@isgplc.com

3.3. Automated decision making

We do not make any automated decision-making or profiling using your personal information.

4. How we collect and use your information

4.1. How we collect your data

Your personal information may be collected by many different methods when you visit or work on a project site. These may include but are not limited to the following;

  • Forms you fill in with your personal information
  • Records of CCTV and other security systems
  • Forms and records filled in by other for example health and safety reports
  • Copies of your documents e.g. qualifications

4.2. The types of data we collect

In addition to ordinary personal data we may also collect data the is considered sensitive by the General Data Protection Regulation (GDPR). The sensitive data we may collect includes biometric data in the form of fingerprints may be collected for use in security systems.

4.3. How we share and use your personal information

The personal information ISG collects from you is stored in one or more ISG databases hosted by third parties located in the European Economic Area (EEA). These third parties do not use or have access to your personal information for any purpose other than cloud storage and retrieval.

We may also share your information with 3rd parties in the following categories;

  • Security: Security on project sites may be assigned to 3rd party organisations
  • Legal obligations: We may share your personal information with enforcement authorities when we are required to by law.

4.4. How long we keep your personal information

The personal information ISG collects from you may be stored on the project site and also in one or more ISG databases hosted by third parties located in the European Economic Area (EEA). Information relating to projects will be stored for the duration of the project and up to 40 years after the completion of the project.
Information relating to employees will be kept for the following periods:

  • 3 years from the termination of the employment; or
  • 30 years, to the extent necessary for locating any due pay or other obligation incurred by the employment relationship.
     

5. Transferring personal data

ISG may transfer certain personal data across geographical borders to ISG entities or service providers in other countries working on our behalf in accordance with applicable law.

By providing us with your data or using our websites, you consent to the collection, international transfer, storage, and processing of your data. These transfers are governed by the appropriate data transfer mechanisms in order to protect the security and confidentiality of personal data.

6. Your rights

Under the GDPR data subjects have the following rights:

  • The right to be informed
  • The right of access
  • The right to rectification
  • The right to erasure
  • The right to restrict processing
  • The right to data portability
  • The right to object
  • Rights in relation to automated decision making and profiling.

If you wish to exercise your rights as a data subject, please contact us at data.protection@isgplc.com

7. Security of your information

To help protect the privacy of data and personally identifiable information you transmit through use of this Site, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your personal data to those employees who need to know that information to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees' privacy responsibilities.

8. Appendices

8.1 Legal basis

Information collected Legal basis Justification
Name Legitimate interest ISG has a legitimate interest to identify operatives on sites for various reason including security.
Trade Legitimate interest ISG has a legitimate interest to identify the trades and qualifications of operatives working on sites.
Operative Type Legitimate interest ISG has a legitimate interest to identify the types of operatives on sites
Induction Date Legal obligation / Legitimate interest In some cases, ISG is required by law to demonstrate when operatives completed induction.
Induction Course Legal obligation / Legitimate interest In some cases, ISG is required by law to demonstrate the courses that operatives have completed on induction.
Date of Birth Legal obligation / Legitimate interest ISG has a legal obligation to verify the age of operatives on site. Dates of birth may also be used to verify other documents e.g. certificates and licences.
Nationality Legal obligation / Legitimate interest In some cases, ISG has a legal obligation to verify the nationality of operatives e.g. right to work checks.
Macau ID (of Macau Resident) Number or Work Permit (“Blue Card”) Number (of non-Macau Resident) Legal obligation In some cases, ISG has a legal obligation to collect the ID / work permit numbers of operatives and other persons working in the site for anti-illegal employment purpose
Medical History Legal obligation / Legitimate interest ISG has legal obligation to ensure the safety of operatives on sites. Activities on sites may endanger operatives or colleagues if carried out by operatives with certain medical conditions.
Post code Legitimate interest ISG requires this information in order to comply with sustainability requirements. ISG may need to calculate distances travelled by operatives or number of workers from particular areas, percentage of workers from particular areas.
Next of Kin Legitimate interest In some cases, such as accidents, ISG has a legitimate interest to be able to contact next of kin.