1.1 Sapient Consulting Private Limited ("Sapient") is committed to respecting individual privacy and values the confidence of any provider of Personal Data or Information. To this end, Sapient understands the need to lay down a comprehensive policy to ensure that it strives to collect, use, access, hold, disclose and transfer Personal Data or Information including Sensitive Personal Data or Information of any individual including its employees (collectively "Information") in a manner consistent with the applicable law. This Data Privacy Policy ("Privacy Policy") sets forth the privacy principles that Sapient shall follow in respect of collection, access, usage, disclosure and transfer of Information.


1.2 All existing company guidelines and/or policies and procedures on data privacy shall be read in conjunction with this Privacy Policy and shall not be deemed to be inconsistent with or contrary to the provisions of this Privacy Policy. In case of any conflict between this Privacy Policy and existing company guidelines and/or policies and procedures on data privacy, this Privacy Policy shall prevail.



2.1 "Personal Data or Information" means any information that relates to a natural person, which, either directly or indirectly, in combination with other information available with Sapient, is capable of identifying the person concerned.


2.2 "Sensitive Personal Data or Information" means Personal Data or Information of any individual relating to password; financial information such as bank account or credit card or debit card or other payment instrument details; physical, physiological and mental health condition; sexual orientation; medical records and history; biometric information; any detail relating to the above as provided to or received by Sapient for processing or storage. However, any data/information relating to an individual that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law shall not qualify as Sensitive Personal Data or Information.



3.1 This Privacy Policy applies to all Information received or collected by Sapient from any individual in any format including electronic or paper. Sapient collects and processes Information through its Internet websites, its intranet site, electronic and traditional mail.


3.2 Sapient will share or allow access to Information which is collected or received by third parties in a manner consistent with the declarations in this Privacy Policy. Sapient will make good faith efforts to ensure that its vendors or third parties process the Information for the purposes set out in section 5 below and such vendors and third parties establish and maintain reasonable security practices and procedures in order to protect the Information.



The majority of Information is held on Sapient's internal systems. It is also held in manual form and on other electronic systems by or on behalf of Sapient by third parties and may, on a case to case basis, include the following:


PAN, blood group, known name, surname, title, initials; postal address, postal code, country; telephone number; sex; marital status; age; date and place of birth; personal email id, ethnic group; details of dependents; personal contact details including telephone and email address (including emergency contact details);


Job application date; effective start date; employee identification number/ oracle ID; job title; department; employment status; pay group; standard hours; consideration, salary; bonus; bonus dates; allowances; annual leave; sickness absence; other absence; disciplinary action; additional payments details; additional deductions details; official email id; employee benefit details including provident fund account number; salary payment details; bank details; corporate credit card details; visa and passport details; employee accomplishments; assessments; training data; expenses.



Information about you may be held and processed by Sapient and third parties, on a case to case basis, for purposes including the following:

recruitment; benefits administration (including medical, pension and other benefits including recording and processing eligibility of dependents); salary administration and payment of expenses; performance appraisals and performance monitoring; career planning; disciplinary, grievance and other investigations including through 'Speak up' hotline; skills monitoring; relocation; promotions and staff re-structuring; security of premises; administering bonus payments, including assigning amounts of bonus payments; running payrolls; absence and sickness monitoring; training course management; IT administration and assistance through the Help Desk; monitoring the use of Sapient assets; sickness and maternity leave administration; providing references on your behalf when you request us to do so; maintaining contact details for you, and your dependents in case of personal or business emergency; administration and handling of employee claims; preventative medicine, health checks and business travelers' health requirements; management of software and hardware computer assets, pre-employment checking and staff surveys; insurance and accident management; employee assistance program; visa and immigration; travel administration; exit interviews; health care services, retention of data as per Sapient's Document Retention Policy available on People Portal; for any other purpose which is directly or indirectly related to or in connection with your employment or engagement as the case may be.



Sapient will not intentionally disclose (and will take commercially reasonable steps to prevent the accidental disclosure of) your Information to third parties (i.e. persons or entities that are not affiliates of Sapient) subject to the following exceptions:

To third parties as required under the laws, rules, and regulations and or under orders of any relevant judicial or quasi-judicial authority or to protect and defend the rights or property of Sapient.

In response to enquiries by Government agencies including for the purpose of verification of identity, or for prevention, detection, investigation including cyber incidents, prosecution, and punishment of offences.

To service providers appointed by Sapient for the purpose of carrying out services on Sapient's behalf under contract (who are under a duty of confidentiality) such as background check and drug tests/human resource management/payroll/travel/insurance services/health checkups, information technology support services and or for any incidental or ancillary purposes.

To prospective buyers of Sapient's businesses who are under a duty of confidentiality.

In response to requests from third parties such as prospective employers, investigation agencies etc.

In response to request from Sapient clients as part of staffing, client audits related to Sapient's compliances etc.



From time to time you may provide Sapient with Information relating to other third party individuals. For example, you may provide Sapient with Information relating to your family members. When you provide such information, it is your responsibility to ensure the accuracy of the Information and to ensure that the individual concerned is aware of the nature of the Information that is being provided and the way in which it will be used, accessed, held, processed, disclosed and/or transferred by Sapient and that the individual has consented to all of the above.



Sapient reserves the right to retain certain types of Information even after termination of any contractual relation with you, including post termination of employment/engagement, as per its Document Retention Policy ("Document Retention Policy") available on the People Portal. The Information will not be retained for longer than it is required.  



Information will be obtained, stored, used and processed fairly and lawfully in accordance with the following guiding principles:

9.1 NOTICE: Wherever Sapient collects Information directly from any provider of Information, it will be lawful purposes and in accordance with the purposes set out in section 5 above and the third parties to which Sapient is likely to or will disclose that information are set out in section 6 above.

9.2 CHOICE: Any individual who wishes to opt out or withdraw his/her consent should contact his/her People Strategist. Sapient will not provide the goods, services or the benefits for which the Information was sought from such an individual. Some examples of the above mentioned goods, services and benefits include payroll and transport services, insurance claims and services.

9.3 TRANSFERS: Sapient shall share Information obtained from any individuals with third parties only in furtherance of the purpose for which it is obtained from them. Sapient will enter into independent agreements with and obtain assurances from its agents and third parties to whom such information is supplied that they will safeguard Information consistently with this Privacy Policy.

9.4 DATA INTEGRITY: Sapient will use Information only in ways that are compatible with the purposes for which it was collected from the concerned individual. Sapient will also ensure that Information is not kept for a period longer than required.

9.5 ACCESS AND CORRECTION: Sapient will grant any provider of Information upon request, reasonable access to Information that it holds about the concerned individual or entity. In addition, Sapient will take reasonable steps to permit the provider of Information to correct, amend or delete information that is demonstrated to be inaccurate or incomplete. However, Sapient shall not be responsible for the authenticity of the Information furnished to it by any individual including Information provided by the employees.

9.6 PROTECTION OF INFORMATION: Sapient will take reasonable precautions to protect Information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction. Individuals who have been granted access to Information will be made aware of their responsibilities to protect the security, confidentiality and integrity of the Information.

9.7 ENFORCEMENT OF THIS PRIVACY POLICY: Sapient will conduct compliance audits of its relevant privacy practices to verify adherence to this Privacy Policy. Any individual that Sapient determines is in violation of this Privacy Policy will be subject to appropriate action including but not limited to disciplinary action in case of employees, which may lead up to termination of employment or termination of engagement in case of contractors or any other arrangement that Sapient has entered into with an individual. Sapient will ensure that it co-operates with any data protection authorities under the applicable law from time to time, to ensure compliance with this Privacy Policy or to deal with any non-compliance thereof.



Any questions or concerns regarding the use or disclosure of Information should be directed to the Privacy Officer - Khushnooma Mohan appointed by Sapient at the following addresses kmohan@sapient.com. Sapient will investigate and resolve your complaint in accordance with the principles contained in this Privacy Policy.



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About Sapient

Sapient, part of the Publicis Groupe, is a global services company that helps clients transform in the areas of business, marketing, and technology. The company operates three divisions that enable clients to gain a competitive advantage and succeed in an increasingly digital world. SapientRazorfish, Sapient Global Markets, and Sapient Government Services fuse insight, creativity, and technology to drive innovation and to help clients navigate complex business problems. Our approach is the subject of case studies used by MBA programs at Harvard and Yale. The company has operations in North America, Europe, and Asia-Pacific. For more information, visit http://www.publicis.sapient.com.