Protection of personal information

Protection of personal information
1. GENERAL PROVISIONS.
1.1. This Regulation on the processing and protection of personal data (hereinafter referred to as the Regulation) determines the policy of 
GrandBusiness Expert LLC in relation to the processing of personal data, including the procedure for processing  GrandBusiness Expert LLC of personal data of persons who are not its employees, including the procedure for collecting, storing, using, transferring
and protection of personal data.
1.2. Streamlining the handling of personal data aims to ensure the rights and freedoms of citizens in the processing
personal data, maintaining the confidentiality of personal data and their protection.
1.3. The Regulations and amendments thereto are approved by the director of GrandBusiness Expert LLC.
1.4. The Regulation is a local legal act of GrandBusiness Expert LLC, mandatory for compliance and execution
employees, as well as other persons involved in the processing of personal data in accordance with this Regulation.
1.5. The regulation was developed on the basis of and in pursuance of:
a) the Constitution of the Republic of Belarus;
b) the Labor Code of the Republic of Belarus;
c) Council of Europe Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data of 01/28/1981;
d) Charter of Fundamental Rights of the European Union of 12.12.2007;
e) Law of the Republic of Belarus dated 07.05.2021 N 99-Z “On the protection of personal data” (hereinafter – the Law);
f) Law of the Republic of Belarus No. 418-З dated July 21, 2008 “On the Population Register”;
g) Law of the Republic of Belarus dated November 10, 2008 N 455-Z “On Information, Informatization and Information Protection”;
h) other normative legal acts of the Republic of Belarus.
1.6. This Regulation of GrandBusiness Expert LLC determines:
purposes and legal grounds for the processing of personal data;
categories of personal data subjects and the list of processed personal data;
the procedure and conditions for processing personal data, including the period of storage of personal data;
rights and obligations of personal data subjects;
issues of cross-border transfer of personal data;
organizational and technical measures to ensure the protection of personal data.
1.7. The following terms and definitions are used in the Regulations:
LLC "GrandBusiness Expert" — limited liability company “GrandBusiness Expert”, location Minsk, pr-
v. Pobediteley, 103, room. 507, post. index 220020;
processing of personal data – any action or set of actions performed with personal data, including
collection, systematization, storage, modification, use, depersonalization, blocking, distribution, provision,
deletion of personal data;
publicly available personal data – personal data disseminated by the personal data subject himself or with
his consent or disseminated in accordance with the requirements of legislative acts;
personal data – any information relating to an identified natural person or natural person,
which can be identified;
provision of personal data – actions aimed at familiarizing with the personal data of a certain person
or circle of people;
dissemination of personal data – actions aimed at familiarizing with the personal data of an indefinite
circle of persons;

subject of personal data – an individual in respect of whom the processing of personal data is carried out;
job seekers – persons applying for employment in  GrandBusiness Expert LLC;

cross-border transfer of personal data – transfer of personal data to the territory of a foreign state;
deletion of personal data – actions as a result of which it becomes impossible to restore personal data in
information resources (systems) containing personal data, and (or) as a result of which the
material carriers of personal data;
identifiable natural person – a natural person who can be directly or indirectly
defined, in particular, through the surname, first name, patronymic, date of birth, identification number, or through one
or several characteristics characteristic of his physical, psychological, mental, economic, cultural or
social identity.

2. CATEGORIES OF PERSONAL DATA SUBJECTS AND THE LIST OF PERSONAL DATA PROCESSED
2.1. In accordance with this Regulation, GrandBusiness Expert LLC processes personal data of the following
categories of personal data subjects:
applicants;
employees of GrandBusiness Expert LLC;
relatives of employees of GrandBusiness Expert LLC (including affiliates);
employees and other representatives of counterparties (potential counterparties);
visitors to the website of  GrandBusiness Expert LLC;

other entities whose interaction with GrandBusiness Expert LLC creates the need to process personal data.
2.2. GrandBusiness Expert LLC processes the following personal data of applicants:
surname, name, patronymic (as well as all previous surnames);
date and place of birth;
citizenship;
passport data or data of another identity document (series, number, date of issue, name of the authority,
issued the document, etc.);
data of the birth certificate (number, date of issue, name of the authority that issued the document, etc.) (if necessary);
floor;
information about the marital status and composition of the family, indicating the surnames, names and patronymics of family members, date of birth, place
work and/or study;
information about registration at the place of residence (including address, date of registration);
information about the place of actual residence;
number and series of the state social insurance certificate;
data on education, advanced training and professional retraining, academic degree, academic title;
taxpayer identification number;
information about labor activity (including length of service and work experience, employment data indicating the position, unit,
information about the employer, etc.);
specialty, profession, qualification;
military registration information;
information of a medical nature (in cases provided for by law);

biometric personal data (including photographs, images from CCTV cameras, voice recordings);
information about social benefits and payments;
contact details (including home and/or mobile phone numbers, e-mail, etc.);
information about awards and promotions;
information provided by the applicant himself in the course of filling out personality questionnaires and taking measures to
psychometric testing, as well as the results of such testing (psychometric profile, abilities and
characteristics).
2.3. GrandBusiness Expert LLC processes the following personal data of employees of GrandBusiness Expert LLC:
surname, name, patronymic (as well as all previous surnames);
date of birth;
citizenship;
passport data or data of another identity document (series, number, date of issue, name of the authority,
issued the document, etc.);
data of visas and other documents of migration registration;
floor;
information about the place of stay;
biometric personal data (including photographs, images from CCTV cameras, voice recordings);
information about social benefits and payments;
contact details (including work and / or mobile phone numbers, e-mail, etc.);
other data necessary for the performance of mutual rights and obligations.
2.4.  GrandBusiness Expert LLC processes the following personal data of relatives of employees (including

affiliates):
surname, name, patronymic;
date of birth;
citizenship;
passport data or data of another identity document (series, number, date of issue, name of the authority,
issued the document, etc.);
information about the marital status and composition of the family, indicating the surnames, names and patronymics of family members, date of birth, place
work and/or study;
information about registration at the place of residence (including address, date of registration);
information about the place of actual residence;
number and series of the state social insurance certificate;
information of a medical nature (in cases provided for by law);
information about social benefits and payments;
contact details (including work, home and/or mobile phone numbers, e-mail, etc.).
2.5. GrandBusiness Expert LLC processes the following personal data of employees and other representatives
counterparties (potential counterparties):
surname, name, patronymic;
passport data or data of another identity document (series, number, date of issue, name of the authority,
issued the document, etc.);

information about registration at the place of residence (including address, date of registration);
contact details (including work, home and/or mobile phone numbers, e-mail, etc.);
job title;
other data necessary for the fulfillment of mutual rights and obligations between GrandBusiness Expert LLC and the counterparty.
2.6. GrandBusiness Expert LLC processes the following personal data of website visitors:
E-mail address;
position, surname, name, patronymic of an individual;
phone number;
IP address;
browser information;
cookie data;
URLs of requested pages;
access time.
2.7. GrandBusiness Expert LLC handles the trail

3. PURPOSE AND LEGAL BASIS FOR PROCESSING PERSONAL DATA
3.1. The processing of personal data of personal data subjects is carried out for the following purposes:
implementation and performance of the functions, powers and duties assigned to GrandBusiness Expert LLC
the legislation of the Republic of Belarus and international treaties of the Republic of Belarus;
providing relatives of employees with benefits and compensations;
identifying conflicts of interest;
consideration of employment opportunities for candidates;
maintaining a personnel reserve;
verification of candidates (including their qualifications and work experience);
organization and support of business trips;

holding events and ensuring the participation of personal data subjects in them;
security, preservation of wealth and prevention of offenses;
issue of powers of attorney and other authorizing documents;
negotiating, concluding and executing contracts;
verification of the counterparty;
advertising and promotion of services, including the provision of information about the services of GrandBusiness Expert LLC;
processing complaints and information on the security of services;
other purposes aimed at ensuring compliance with employment contracts, laws and other regulatory legal acts.
3.2. Personal data is processed solely for one or more of the specified legitimate purposes. If a
personal data has been collected and processed for a specific purpose, for the use of this data in
other purposes, it is necessary to notify the subject of personal data about this and, if necessary, obtain
new consent to processing.
3.3. The processing of personal data may be carried out for other purposes, if necessary in connection with the provision
compliance with the law.
3.4. The legal basis for the processing of personal data is Articles 4, 6, 19 of the Law.

4. PROCEDURE AND CONDITIONS FOR PROCESSING PERSONAL DATA. TERMS OF STORAGE OF PERSONAL DATA
4.1. Sources of personal data are documents and information provided by the subjects of personal data
employees of GrandBusiness Expert LLC, whose job functions include obtaining personal data.
The source of obtaining personal data of applicants may be information posted on resources on the Internet
or other sources of information that are publicly available, as well as information provided by the applicants themselves on their
own initiative.
4.2. GrandBusiness Expert LLC performs the following actions with personal data: collection, systematization, storage,
modification, use (including in newsletters), provision, deletion.
The use of personal data is carried out solely for the purposes for which the consent of the subject has been obtained
personal data.
Personal data can be reproduced in the form of making electronic copies of documents submitted to
paper media, their inclusion in programs and databases, CRM systems designed for accounting
or performance of other functions of employees of GrandBusiness Expert LLC in accordance with their competence.
4.3. GrandBusiness Expert LLC may entrust the processing of personal data to third parties.
4.4. Personal data may be transferred to third parties on the basis of the consent of the subject of personal data, including
the extent to which the consent of the subject of personal data to their processing is obtained.
4.5. Personal data may be transferred to third parties only for the performance of those actions for which 
GrandBusiness Expert LLC has received consent to the processing of personal data.

4.6. Personal data obtained on the basis of the consent of the subject of personal data is stored until received by 
GrandBusiness Expert LLC of the substantiated request of the subject of personal data to stop their processing or recall

consent of the subject of personal data. Personal data of counterparties are stored for at least 10 years from the date of termination
agreements with relevant contractors.
Personal data obtained on other grounds is stored for the periods of storage established by law
The Republic of Belarus. If such deadlines are not set, GrandBusiness Expert LLC periodically audits
personal data for the relevance of their processing and deletes personal data, in the processing of which there is no
need.

5. RIGHTS AND OBLIGATIONS OF PERSONAL DATA SUBJECTS
5.1. Subjects of personal data have the right to:
withdraw your consent to the processing of personal data at any time without giving reasons;

receive information regarding the processing of personal data;
require changes to personal data if they are incomplete, outdated or inaccurate;
receive from GrandBusiness Expert LLC information about the provision of personal data to third parties once a
calendar year free of charge;
demand a free termination of data processing, including their deletion.
5.2. In order to exercise these rights, an application must be submitted to GrandBusiness Expert LLC in writing according to
address: Min

6. CROSS-BORDER TRANSFER OF PERSONAL DATA
6.1. GrandBusiness Expert LLC may store personal data in electronic form.
6.2. The basis for the cross-border transfer of personal data is the consent of the subject of personal data.
6.3. Cross-border transfer of personal data is carried out to countries in whose territory it is provided
an appropriate level of protection of the rights of personal data subjects.

7. ORGANIZATIONAL AND TECHNICAL MEASURES TO ENSURE THE PROTECTION OF PERSONAL DATA
7.1. GrandBusiness Expert LLC will take legal, organizational and technical measures to ensure the protection
personal data from unauthorized or accidental access to them, modification, blocking, copying,
distribution, provision, deletion of personal data, as well as from other illegal actions in relation to them,
including:
appointment of a person responsible for internal control over the processing of personal data;
determining the circle of persons directly involved in the processing of personal data
publication of this Regulation and other documents on the processing of personal data;
familiarization of the employees of  GrandBusiness Expert LLC and other persons directly involved in the processing of personal

data, with the provisions of the legislation on personal data, these Regulations and other documents of 
GrandBusiness Expert LLC on the processing of personal data;

training of employees in the manner prescribed by law;
establishing the procedure for access to personal data, including those processed in the information resource (system) (when
availability of such resources (systems));

implementation of technical and cryptographic protection of personal data in the manner prescribed by the Operational
analytical center under the President of the Republic of Belarus, in accordance with the classification of information resources
(systems) containing personal data (if such resources (systems) are available).
7.2. Documents on paper containing personal data, data of site visitors, their electronic copies,
should be stored in such a way that only the person responsible for the implementation of the internal
control over the processing of personal data, as well as employees of GrandBusiness Expert LLC, directly
processing personal data.
7.3. It is forbidden to transfer personal data to employees of GrandBusiness Expert LLC who are not responsible
for internal control over the processing of personal data, as well as to employees of GrandBusiness Expert LLC,
not directly processing personal data.
7.4. It is prohibited to process personal data without legal grounds for such processing, including cases
lack of consent to perform certain actions with personal data, or for purposes not provided for
such consent.
7.5. In the case of entrusting the processing of personal data to third parties, the relevant agreement must define:
the purposes of processing personal data;
a list of actions that will be performed with personal data by an authorized person;
obligation to respect the confidentiality of personal data;
measures to ensure the protection of personal data in accordance with Article 17 of the Law.
7.6. If there are reasonable doubts about the lawfulness of the processing of personal data or questions regarding
application of legislation on personal data, documents of GrandBusiness Expert LLC on personal
data (including this Regulation), an employee of GrandBusiness Expert LLC is obliged to seek clarification from the person
responsible for internal control over the processing of personal data.
7.7. For violation of the legislation on the protection of personal data, the guilty person is liable under the
legislative acts.