DRAFT — pilot use. This is a first-pass notice reflecting the attendance/field-tracking practices already agreed for the pilot. It is not legal advice. Obtain a legal review — and a Tamil translation — before any wider or non-pilot rollout. Under the Digital Personal Data Protection Act, 2023 (DPDP), a worker is entitled to this notice in any Eighth-Schedule language, including Tamil; genuine informed consent on the shop floor depends on it.
Privacy Notice — Attendance & Field Tracking
Data Fiduciary: Clifton Export Private Limited
No. 8/328, Uppilipalayam, Palladam Road, Arulpuram PO, Tiruppur – 641605
This notice explains what personal data Clifton Export Private Limited ("the Company", "we") collects from you through the Rachis attendance application, why we collect it, how long we keep it, and the rights you have over it. The application is operated on our behalf by our technology service provider, Bhairaivi Infotech, which processes this data only on our instructions.
What we collect
- An attendance photograph (selfie) taken by you at the start of your duty, on devices that do not support fingerprint verification. This is used only to confirm it is you marking attendance.
- Location (GPS) readings taken periodically only while you are on an active duty session — from the time you start duty to the time you end it. We do not collect your location outside an active duty session.
- A device identifier, stored in a scrambled (hashed) form, used to link your account to one registered device.
- Work-session records: the times you start and end duty, and the attendance result.
Why we collect it
Solely to record your attendance and to verify field/duty presence for employment and payroll purposes. We do not use this data for any other purpose, and we do not sell it or share it for advertising.
Who can see it
Access is limited to the Human Resources team and your own department head. No one else in the Company can view your attendance photographs or location history. Our technology provider can access it only as needed to run and support the system.
How long we keep it
- Attendance photographs: 45 days, after which they are deleted.
- Location readings: [retention period — confirm].
- Work-session and attendance records: [retention period — confirm; note payroll/statutory record-keeping may require a longer period than the items above].
How we protect it
Photographs are stored in access-controlled storage; your device identifier is stored only in hashed form; and access is restricted to the roles named above. [Confirm this matches your deployed controls before publishing.]
Your consent, and withdrawing it
You provide consent within the app before attendance capture begins. You may withdraw consent at any time by contacting the Grievance Officer named below. Withdrawing consent will stop further collection; note that attendance capture is a condition of the attendance process, so we will discuss alternative attendance arrangements with you if you withdraw.
Your rights under the DPDP Act
You have the right to:
- access a summary of the personal data we hold about you and how it is processed;
- correct or complete inaccurate or incomplete data, and request erasure of data no longer needed for the stated purpose;
- grievance redressal — raise any concern with our Grievance Officer, who will respond within the time the law requires;
- nominate another person to exercise these rights on your behalf in the event of death or incapacity; and
- complain to the Data Protection Board of India if your grievance is not resolved.
Grievance Officer
Mr. C. Arumugam
Mobile: 9363039360
[Add email / postal contact if available.]