Processing of Personal Data

Processing of Personal Data

I affirm

General Director of “Termo-Nord Stream” LLC

Zlotin Vladimir

January 01, 2017


“Termo-Nord Stream” LLC

1. Purpose and scope

1.1. This document (hereinafter referred to as the Policy) defines the goals and general principles for the processing of personal data, as well as the implemented measures to protect personal data at “Termo-Nord Stream” LLC (hereinafter referred to as the Operator). The policy is a public document of the Operator and provides for the opportunity to familiarize any person with it.

1.2. The policy is valid indefinitely after approval and until it is replaced with a new version.

1.3. The Policy uses terms and definitions in accordance with their meanings, as defined in Federal Law-152 “On Personal Data”.

1.4. The policy applies to all employees of the Operator (including employees under labor contracts and employees working under work contracts) and all structural divisions of the Company, including separate divisions. The requirements of the Policy are also taken into account and presented in relation to other persons if they need to participate in the processing of personal data by the Operator, as well as in cases when they are transferred to them in the prescribed manner based on agreements, contracts, processing orders.

2. Information on the processing of personal data
2.1. The processing of personal data by the Operator is carried out in a mixed way: using automation tools and without.

2.2. Actions with personal data include the collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

2.3. Processing of personal data is carried out by the Operator on a legal and fair basis, legal grounds for processing are:

Constitution of the Russian Federation;
Labor Code of the Russian Federation;
Civil Code of the Russian Federation;
Tax Code of the Russian Federation;
Federal Law of July 27, 2006 No. 152 “On Personal Data”;
Federal Law of January 10, 2002 No. “On electronic digital signature”;
Federal Law of 04/06/2011 No. 63 “On electronic signature”;
Federal Law of 05/04/2011 No. 99 “On licensing of certain types of activities”;
Federal Law of 07.07.2003 No. 126 “On Communication”;
Federal Law of 04/01/1996 No. 27 “On individual (personified) accounting in the system of compulsory pension insurance”;
Federal Law of July 24, 2009 No. 212 “On insurance contributions to the Pension Fund of the Russian Federation, the Social Insurance Fund of the Russian Federation, the Federal Fund for Mandatory Medical Insurance and territorial funds of mandatory medical insurance”;
Federal Law of 10.22.2004 No. 125 “On Archival Affairs in the Russian Federation”;
The law of the Russian Federation of 10.07.1992 No. 3266-1 “On Education”;

2.4. The content and volume of the processed personal are determined based on the processing objectives. Personal data that is redundant or incompatible with respect to the following main purposes is not processed:

conclusion of labor relations with individuals;
fulfillment of contractual obligations of the Operator;
performing the functions of a certification center;
compliance with applicable labor, accounting, pension, and other legislation of the Russian Federation.

2.5. The main categories of personal data subjects whose data are processed by the Operator include:

individuals who are in labor and civil law relations with the Operator;
individuals who are in labor and civil law relations with the counterparties of the Operator;
candidates for vacant posts.

2.6. For these categories of subjects can be processed: last name, first name, middle name; year, month, date of birth; place of birth, address; marital status; social status; property status; education; profession; income; contact information (phone, email address), other information provided by standard forms and established processing procedures.

2.7. When processing, the accuracy of personal data is ensured, its sufficiency and relevance in relation to the purposes of processing personal data. If inaccurate or incomplete personal data is found, they are updated and updated.

2.8. For personal data that is not publicly available, confidentiality is ensured.

2.9. The processing and storage of personal data is carried out no longer than the purpose of processing personal data requires, if there are no legal grounds for further processing, for example, if the federal law or an agreement with the subject of personal data does not establish an appropriate storage period. The processed personal data is subject to destruction or depersonalization upon occurrence of the following conditions:
achievement of personal data processing goals or maximum storage periods — within 30 days;loss of need to achieve processing goals