Renaissance Africa Energy Company Limited
Ethics & Compliance · Privacy Notices

Current & Former Employees, Contractors and Dependents

How Renaissance processes the personal data of employees, former employees, interns, individual contractors and dependents (‘Renaissance Staff’).

What does this Privacy Notice cover?

This Privacy Notice sets out the personal data Renaissance Africa Energy Company Limited (‘Renaissance’ or ‘we’) collects from individuals who are employees, former employees, interns or individual contractors as well as dependents (‘Renaissance Staff’), the purposes, and the rights of Renaissance Staff.

Every individual in Renaissance is responsible for protecting personal data of their colleagues and that of our customers, business partners and suppliers. For individuals who apply to work for Renaissance, please refer to the Privacy Notice – Job Applicants.

What personal data do we process about you?

We process personal data necessary to manage the employment relationship, to engage contractors and interns and to provide benefits to certain dependents of Renaissance employees. This includes personal home contact information, date of birth, marital status, payroll and bank account information, wage and benefit information including beneficiary information, emergency contacts, work performance information, information required to ensure you have the right to work in the country you are engaged in, and any other information necessary for managing the employment relationship and providing benefits to certain dependents.

Sensitive personal data

We also process some special categories of personal data (‘sensitive personal data’) such as data relating to an individual's health, racial or ethnic origin, religious or philosophical beliefs, sexual orientation, political opinions and trade union membership. We will only process such data where necessary for complying with employment and social security laws, for the establishment, exercise or defence of claims, for providing occupational medical advice and support, to protect the vital interests of an individual, where necessary for reasons of public health, or where the individual has provided their explicit consent.

Why do we process your personal data?

  • in order to satisfy our obligations to comply with extant laws and regulations;
  • for legitimate business interests (for example performance management to ensure we have qualified and competent personnel, or for health, safety and security purposes, litigation and defence of claims); or
  • where we have your explicit consent.

As a general principle, Renaissance does not seek or rely on the consent of Renaissance Staff for processing personal data; however, there are limited circumstances when consent is required, such as if required by applicable law. Personal data requested are the minimum required to fulfil legal and/or contractual requirements. Failure to provide the information requested may negatively affect your ability to remain in employment, internship or engagement, or to participate in a program or receive a benefit.

For what purposes do we process your personal data?

  • Human Resources, personnel management, business process execution, internal management, management reporting, organisational analysis and development — including budgetary, financial and organisational planning, administration, compensation and performance management;
  • Health, safety and security — including protection of Renaissance Staff's life or health, occupational health and safety, protection of Renaissance assets and authentication of status and access rights; or
  • Legal and/or regulatory compliance.

Monitoring

All activities on Renaissance IT equipment and/or when connected to the Renaissance IT network may be monitored for legitimate business purposes. All Renaissance Staff receive an access badge which allows Renaissance to record the date, time and access points within premises and assets, used for health, safety and security; to comply with legal and regulatory requirements; to monitor (on an aggregated basis) the number of individuals entering premises for HR and real estate planning; and, in the case of contractors, for financial management and control.

Most of our premises and assets are equipped with surveillance cameras (CCTV), which are identified where used. Images are routinely deleted unless there has been a health, safety or security incident or suspected/actual criminal activity, in which case they may be viewed by internal investigation teams and externally if legally required.

Screening

In order to comply with legal and regulatory obligations, we carry out screening on all employees and contractors on a periodic basis against publicly available or government-issued sanctions lists, compared with information held about you by Renaissance. This will not involve profiling or automated decision making regarding suitability for continued employment, internship or engagement.

Who is responsible for any personal data collected?

Renaissance Africa Energy Company Limited, Renaissance Industrial Area, Port Harcourt, Rivers State, Nigeria, will be responsible for processing your personal data, either solely or jointly with its affiliates, associates and partners. In the case of individual contractors, the company within the Renaissance Group that has contracted your services — solely or jointly with its affiliates, associates and partners — and your external contracting/employing company/agency.

Who will we share the personal data with?

  • Other companies within the Renaissance Group including affiliates, associates and partners which may be located outside of your location;
  • Authorised third-party agents, service providers, external auditors and/or subcontractors of Renaissance;
  • A competent public authority, government, regulatory or fiscal agency where necessary to comply with a legal or regulatory obligation, or as permitted by applicable law; or
  • Any person to whom Renaissance proposes to transfer any of its rights and/or duties.

Transfers of your personal data to other countries

Where your personal data have been transferred to companies within the Renaissance Group and/or to authorised third parties located outside of your country, we take organisational, contractual and legal measures to ensure your personal data are exclusively processed for the purposes mentioned above and that adequate levels of protection have been implemented, including Renaissance-approved transfer mechanisms and any additional local legal requirements.

Security of your personal data

We have implemented technology and policies with the objective of protecting your privacy from unauthorised access and improper use, and will update these measures as new technology becomes available, as appropriate.

How long do we hold your personal data for?

All information, including personal data, is managed in line with the Renaissance standards for Information and Records Management and securely deleted once no longer required for a legitimate business or legal/regulatory purpose. With some exceptions required to comply with local legal requirements:

  • information contained within personnel files is held for no longer than 10 years once your employment has terminated;
  • information relating to retirement benefits is held for no longer than 99 years from the commencement of employment;
  • personal data gathered as part of screening against sanctions lists and media sources is held for no longer than 15 years after first gathered;
  • the names, date, time and access points for all individuals entering Renaissance premises are held for 3 years from each access;
  • where an individual has been dismissed or had their contract terminated due to serious misconduct (including breaching the Life Saving Rules or the Code of Conduct), that information is held for up to 30 years post termination.

Information may be held for a longer period where there is a legal or regulatory reason, or a shorter period where you object to the processing and there is no longer a legitimate business purpose to retain it.

Your rights and how to exercise them

  • access to your personal data;
  • correction or deletion of your personal data (but only where they are no longer required for a legitimate business purpose);
  • that the processing of your personal data is restricted; and/or
  • that you receive personal data that you have provided to Renaissance, in a structured, digital form to be transmitted to another party, if this is technically feasible.

For individuals who have access to SuccessFactors, you can access your personal data there. Alternatively, please contact your HR adviser. If you are a contractor, you should speak with your external contracting/employing company/agency. For former employees or dependents, please contact dpo@renaissanceafrica.com.

If you are unsatisfied with the handling of your personal data by Renaissance, you have the right to lodge a complaint to the Nigeria Data Protection Commission (NDPC), No. 12 Dr Clement Isong Street, Abuja. Please visit https://ndpc.gov.ng for more information.

Changes to this Privacy Notice

This Privacy Notice may be changed over time. You are advised to regularly review this Privacy Notice for possible changes.