Who is responsible for enabling data subjects to exercise their rights?

Article author
Yancho Yanchev
  • Updated
  • Right to be informed: Remote is responsible for providing privacy notices to all individuals (including both contractors and employees) with an account on our platform. Where required by local law, these privacy notices are supplemented by localised versions which are notified to the relevant data subjects during onboarding. As soon as the employee/contractor becomes part of the client’s organisation, clients should consider notifying their own internal privacy notices applicable to their regular staff employed outside of Remote.
  • Right of access: Remote is best placed to enable individuals to exercise their right of access. In practice, however, all employee/contractor information is on our platform and all employees/contractors have access to it all by default, so such requests are very rare. That being said, if there is client-internal information off the platform, such information may be subject to access request which only the client may fulfil.
  • Right to erasure: Ordinarily, clients are best placed to action erasure requests by contractors. Remote will facilitate such requests upon client request. In practice, clients reach out to Remote and ask Remote to process contractor erasure requests, meaning delete contractor information from the platform. Ordinarily, Remote is best placed to action erasure requests by employees since Remote is the formal employer. Remote will notify clients of any and all such requests. In practice, there is often very little data processed by Remote that is not exempt from erasure requests. Most of the information we ask employees to provide is required for contracting and compliance purposes, and in most jurisdictions, it often needs to be kept for at least 3 years following employee termination.

To date, we haven’t received any other type of data subject requests, but we are committed to fulfilling these as and when they do come up.

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