This Personal Data Protection Policy (hereinafter referred to as the “Policy”) document explains our privacy practices regarding the collection, use, disclosure and transfer of your Personal Data by Synechron and/or its subsidiary(ies) and/or affiliate(s) (collectively referred to as the "Synechron" or “we” or “us”, “our”)
1. About Synechron
“Synechron is a leading digital transformation consulting firm focused on the financial services industry and is working to Accelerate Digital initiatives for banks, asset managers, and insurance companies around the world. Synechron uniquely delivers these firms end-to-end Digital, Consulting, and Technology capabilities with expertise in wholesale banking, wealth management, and insurance as well as emerging technologies like Blockchain, Artificial Intelligence, and Data Science. This has helped the company to grow to $650 Million+ in annual revenue and 11,000+ employees, and we’re continuing to invest in research and development in the form of Accelerators (prototype applications) developed in our global Financial Innovation Labs (FinLabs).”
This policy applies to processing of personal data in electronic form or otherwise and shall apply to Synechron, its operations and business units and supersedes any other policy relating to Personal Data protection. This means that this Policy shall apply to all employees, contractors, working partners and businesses carried on by Synechron and any other Affiliates of Synechron except to the extent, if any, stated under exemptions below, must comply with it.
4. Policy Guidelines
5. Data Collection, Transfer, and Processing
Synechron may collect, store, use and disclose information about individuals which may constitute Personal Data (including Sensitive Personal Data) under various applicable data protection laws (including but not limited to Information Technology Act 2000 (IT Act), Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules 2011 (IT Rules), General Data Protection Regulation (GDPR), UK DPA 2018, Data Protection Act 1998 (USA), California Consumer Protection Act (CCPA), The Personal Information Protection and Electronic Documents Act (PIPEDA) Canada, Personal Data Protection Act 2012 (PDPA) Singapore, Personal Data (Privacy) Ordinance (PDPO) Hong Kong, Act on Protection of Personal Information (APPI) Japan for lawful, explicit and legitimate purposes and for further processing of Personal Data consistent with those purposes.
The Personal Data may be processed for purposes including without limitation:
Synechron shall specifically mention the purpose and obtain free consent, if required from the data subject prior to collecting, storing and processing of Personal Data.
Synechron shall not utilize an individual’s Personal Data in its control, beyond the scope for which it was collected without prior written consent from the individual. Individual’s Personal Data shall not be provided or otherwise disclosed to third parties other than Synechron, investigators, or law enforcement personnel where consent has been obtained from the concerned individual or when disclosure is legally mandated. Synechron may record and monitor electronic and voice communications, to the extent permitted by applicable laws, to ensure compliance with the legal and regulatory obligations, internal policies and for the purposes outlined above in this policy.
Synechron entities may transfer personal data internally or to third party recipients. In order for Synechron to carry out its operations across its various entities, there may be occasions when it is necessary to transfer personal data from one entity to another, or to allow access to the personal data from an overseas location.
Any transfer of Personal Data to a third party shall take place only if, adequate levels of protection of Personal Data in accordance with applicable data protection laws is guaranteed by such third party. Data shall be encrypted and anonymized wherever necessary.
6. Confidentiality and Security
Synechron shall take prudent steps to safeguard the confidentiality and security of all Personal Data including taking procedural and organizational steps to protect Personal Data from accidental or unlawful destruction and disclosure. These steps include entering into written agreements to protect Personal Data with all its vendors, subcontractors who process Personal Data.
In addition, Synechron strives to protect personally identifiable information that it maintains or disseminates so that it is not accessed or obtained by unauthorized individuals or used in unauthorized ways.
7. Data Subject Access, Correction, and Deletion
Synechron recognizes that data subjects have a right to request a copy of the Personal Data held by Synechron. If any Personal Data is found to be incorrect, the individual concerned has the right to file a request to amend, update or delete it, as appropriate. Individuals also have a right to object or restrict to the processing of their Personal Data as per the prevailing laws.
The right to data portability gives data subjects the right to receive personal data they have provided to Synechron in a structured, commonly used and machine-readable format.
If Synechron undertakes transactions or other services that involves the processing or disclosure of Personal Data on behalf of any of our client or counterparty, it shall be the responsibility of such client or counterparty to ensure that it has all necessary authority to permit Synechron to process and disclose the Personal Data accordingly.
Privacy consent can be withdrawn by the data subject by informing the appropriate authority within Synechron as mentioned in access revocation process document.
Please note that we may ask you to verify your identity before responding to such requests.
The personal data shall be deleted from the system on request or when it has served its purpose, only after a complete evaluation of compliance with any applicable legal obligations or business processes.
8. Data Protection Office
Data subject concerns shall be addressed and their rights related to information access; objection to processing, automated decision-making and profiling; restriction of processing; data portability; data rectification; and data erasure shall be upheld through an internal data protection office.
If an individual makes a request relating to any of the rights above, Synechron shall consider each such request in accordance with all applicable data protection laws and regulations. No administration fee will be charged for considering and / or complying with such a request unless the request is deemed to be unnecessary or excessive in nature. This demonstrates our commitment to data protection, and it shall enhance the effectiveness of our compliance efforts
All employees shall have their data protection responsibilities outlined to them as part of the induction training. A culture of data protection and privacy shall be inculcated among the employees by providing regular training in order to sustain awareness
10. Privacy by Design
Privacy controls shall be considered while designing and implementing new or existing systems or processes, based on the technologies available, cost of implementation, scope, context and purposes of collecting, storing and processing Personal Data.
Synechron shall implement appropriate data-protection principles, technical and organizational measures to ensure that Personal Data is secure.
11. Data Protection Impact Assessment
Synechron shall conduct periodical Data Protection Impact Assessment that shall include:
12. Breach Notification
All Synechron personnel handling Personal Data have a responsibility to report any data privacy breach related incidents and any violations of this policy; such incidents shall be reported immediately to SIRT by sending an email to SIRT@Synechron.com or using SIRT Portal (https://SIRT.Synechron.com).
All Synechron personnel handling Personal Data shall take reasonable measures for protection of Personal Data. The Data Privacy Officer (DPO) is responsible for administration of this policy and monitoring its compliance.
Enforcement of this Policy is mandatory and the steps to be taken in case of any violation by Synechron and its Affiliates personnel: