THIS NOTICE DESCRIBES HOW YOUR PERSONAL DATA MAY BE PROCESSED BY SUPER COPY EDITORS LLC (“SUPER COPY EDITORS,” “WE,” “OUR,” AND “US”) AND WHAT YOUR RIGHTS ARE WITH RESPECT TO YOUR PERSONAL DATA. PLEASE REVIEW IT CAREFULLY.
This Notice is being provided to you in accordance with the requirements of the General Data Protection Regulation (Regulation (EU) 2016/679, or the “GDPR”) and similar privacy regulations.
What Are Personal Data and Processing?
Under the GDPR, “personal data” means any information relating to an identified or identifiable data subject, specifically including, but not limited to, name, an identification number, location data, an online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that data subject. A data subject is a natural person who can be identified, directly or indirectly, by reference to personal data.
Processing means any operation or set of operations that is performed on personal data or on sets of personal data, whether or not by automated means, such as collection; recording; organization; structuring; storage; adaptation or alteration; retrieval; consultation; use; disclosure by transmission, dissemination, or otherwise making available; alignment or combination; restriction; erasure; or destruction. “Process” and “processed” have a corresponding meaning.
The GDPR prohibits the processing of “special categories” of personal data unless certain exceptions apply, because the unauthorized use of this type of personal data could create more significant risks to a data subject’s fundamental rights and freedoms.
For example, unauthorized disclosure of “special categories” of personal data may put data subjects at risk of unlawful discrimination. For this purpose, processing of “special categories” of personal data includes processing of:
- Personal data that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership
- Genetic data
- Biometric data for the purpose of uniquely identifying a natural person
- Data concerning health
- Data concerning a natural person’s sex life or sexual orientation
How and When Do We Collect Your Personal Data?
We may lawfully collect your personal data in several ways for legitimate purposes. For example, we may collect your personal data:
- From the information you provide to us when you interact with us before applying (e.g., when you express your interest in working at Super Copy Editors)
- When you apply for work with Super Copy Editors and complete employment forms, independent contractor (freelancer) agreements, or other documentation
- When you communicate with us by telephone, email, or via our website (e.g., to make inquiries or raise concerns)
- When you interact with us during your time as an employee or independent contractor with Super Copy Editors, for one or more of the purposes set out below
- From third parties (e.g., from your previous employers), who may provide records or a reference about you
Failure to provide any personal data reasonably requested of you may result in an automatic disqualification from the recruitment and/or application for employment process.
The Types of Personal Data We Collect
We may process the following types of personal data about you that are described in the Notice, to the extent we obtain it in connection with your work, employment, or other interaction with us and to the extent permitted by law. Such personal data might include:
- Your name and contact information (e.g., local and permanent address, email address, and telephone number)
- Your date of birth, gender, and gender identity, Social Security number or taxpayer identification number
- Insurance information
- Your passport or national identity card details
- Your country of domicile and your nationality
- Your unique employee identification number
- Information relating to your education and employment history, including the school(s) and colleges or universities you have attended, places where you have worked, the courses you have completed, and dates of study
We also might collect and keep:
- Records relating to your work product and other information in your work record (including disciplinary records)
- Information about criminal convictions and offenses
- Information concerning your health and medical conditions (e.g., disability needs)
- Information about your personal or family circumstances
We also might collect:
- Your recruitment information (including your original work application form, résumé, cover letter, emails, and associated information submitted at that time)
- Other data relating to your recruitment (including your offer of employment or appointment letter and related correspondence, references we collected in relation to your appointment, and any pre-employment assessment of you)
- Evidence of your right to work in the United States (or, if applicable, another country)
We generally collect your personal data, which could include things like:
- Your photograph
- Your current and any previous job descriptions
- Your current and any previous contracts of employment, independent contractor agreements, and/or related correspondence
- Your training and development qualifications, requests, and requirements
- Records of your performance appraisals
- Records, where they exist, of any investigation or review into your conduct or performance
- Records of absences from work (including, for employees, annual leave entitlement, sick leave, parental leave, and bereavement leave)
- Correspondence between you and Super Copy Editors, and between other Super Copy Editors employees and independent contractors, regarding any matters relating to your work services and any related issues (including changes in duties, responsibilities, and benefits; your retirement, resignation, or exit from Super Copy Editors; and personal and professional references provided by Super Copy Editors to you or a third party at your request)
We also may collect:
- Certain banking information from you
- Details related to your employee benefits, if applicable
- Your current and previous salary and other earnings (e.g., maternity pay, disability, and overtime) and the amounts you have paid in payroll taxes
- Correspondence between you and Super Copy Editors, and between other Super Copy Editors employees or independent contractors, relating to your pay, benefits, and other remuneration.
For example, we maintain records of employees’ use or enrollment in any employee benefits provided by us, which we may collect in the aggregate and monitor to review the effectiveness and desirability of our employee benefit offerings. The legal basis for this processing is that it is in our legitimate interest to ensure that any benefits offered by Super Copy Editors represent good value for money to both you and us.
Finally, we might collect details of your preferred emergency contact, including the person’s name, relationship to you, and contact details
How Your Personal Data Will Be Used
Super Copy Editors needs to keep and process information about you (including your personal data) for normal employment purposes or, in the case of independent contractors, for normal purposes of maintaining our working relationship.
The personal data we hold and process will be used lawfully for our management and administrative use. We will keep and use it to enable us to run our business and manage our relationship with you effectively, lawfully and appropriately, during the recruitment process, while you are working with us, and throughout the period you provide services to us, up until the termination of our professional relationship with you. This includes using personal data to enable us to comply with any employment or independent contractor contracts, collective bargaining agreements, severance agreements, and similar contracts to comply with any legal requirements, pursue our legitimate interests as an employer or business associate, and protect our legal position in the event of legal proceedings.
The legal basis for processing your personal data is that it is necessary for you to be employed by us or contracted by us as an independent contractor, where you will be subject to our governing documents. If you do not provide the personal data we request, we may be unable, in some circumstances, to comply with our obligations, and we will tell you about the implications of that decision.
Much of the personal data we process will have been provided by you, but some personal data may come from other internal sources (e.g., other employees or independent contractors, as applicable), previous employers, or in some cases, external sources.
We generally will not access personal data about you from social media sites, unless there is a legitimate interest for us to do so and it is done in a lawful manner (for example, if the role you have applied for has a significant public-facing element to it or is involved with publicity and presenting us to the public). Consequently, we do not routinely screen applicants’ social media profiles, but if aspects of your social media profile are brought to our attention and give rise to concerns about your suitability for the role in question, we may need to consider them.
How We Share Your Personal Data
For the purposes referred to in this Notice and relying on the lawful bases for processing as set out above, we may share your personal data with certain third parties in accordance with applicable law. We may disclose limited personal data to a variety of recipients if we determine it to be appropriate and lawful, including:
- The U.S. Department of Labor, the Internal Revenue Service, other federal agencies, and relevant state agencies and/or offices
- Other individuals where there is a legitimate reason for their receiving the information, including disclosures to:
- Third parties who work with us to provide employment services
- Third parties who work with us to provide employee benefits
- Third parties contracted to provide IT services for us
- Client organizations
- Internal and external auditors, attorneys, and other professional service providers
- Certain third parties interested in tracking employee progress, including current or potential employers (e.g., to provide references); professional and regulatory bodies; government departments and agencies where we have a statutory obligation to provide information; police or law enforcement agencies; and third parties conducting surveys
Retention of Your Personal Data
Your personal data will be stored in accordance with our Data Retention Policy, which is designed to comply with the GDPR, similar privacy regulations, New York state law, and U.S. federal law.
Your Rights With Respect to Your Personal Data
Under the GDPR, you have a number of rights with respect to your personal data. You have the right, in certain circumstances, to request:
- Access to your personal data
- Rectification of mistakes or errors and/or erasure of your personal data
- That we restrict processing
- That we provide your personal data to you in a portable format
In certain circumstances, you also may have the right to object to our processing of your personal data.
If Super Copy Editors requested and you provided your explicit consent for the processing of your personal data, you have the right (in certain circumstances) to withdraw that consent at any time. However, withdrawal of consent will not affect the lawfulness of the processing before your consent was withdrawn.
If you would like more information about, or if you would like to exercise any of these individual rights, please contact us (contact information is below).
If you have questions, concerns, or complaints about how we are using your personal data, we may be able to resolve your complaints, and we request that you contact the Data Protection Lead. You also have the right to lodge a complaint with the applicable supervisory authority if you believe we have not complied with the requirements of the GDPR regarding your personal data, or if you are not happy with the response you receive from us regarding your complaint.
Super Copy Editors may be both a “controller” and a “processor” (as those terms are used in the GDPR) of your personal data for the purposes of the GDPR. If you have any questions or concerns as to how your personal data is collected and/or processed, you can contact us using one of the following methods:
- Contact Dave Baker, company founder and Data Protection Lead, directly
- Submit a request via email: Privacy Information Request
- Reach us via mail at:
Super Copy Editors LLC
116 Conselyea St. #3A
Brooklyn NY 11211
Last updated: Jan. 8, 2023