Employee Data
Protection Notice.
This notice explains how Pintop Technologies Limited collects, uses, shares, protects and retains personal data relating to applicants, employees, contractors, interns and former members of its workforce.
Privacy throughout the workforce relationship.
This notice applies to applicants, employees, contractors, interns, former employees and other individuals whose personal data is processed in connection with work for Pintop.
It applies from recruitment and onboarding through employment, professional development, payroll, workplace administration, offboarding and the retention of relevant records after the relationship ends.
This notice should be read together with Pintop’s Data Protection Policy, Data Retention Policy, Acceptable Use Policy and other workforce policies that apply to a particular activity.
Personal data across the
employment lifecycle.
The information held depends on the individual’s role, relationship with Pintop and the administrative or legal requirements applying to the engagement.
Recruitment information
Name, contact details, CV, application information, employment history, qualifications, references, interview notes, assessment results and information required to confirm identity or eligibility for the role.
Employment and contract records
Employment or engagement agreements, role information, amendments, work location, reporting arrangements, emergency contacts and other records needed to administer the relationship.
Payroll, tax and benefits
Bank details, salary information, payroll records, tax identifiers, PAYE information, pension details and information needed to administer statutory or employment-related benefits.
Performance and development
Objectives, performance reviews, feedback, attendance, leave, training, qualifications, professional development, disciplinary, grievance and related workplace records.
Systems and security information
User accounts, access rights, login records, device information, audit logs, support activity and other information produced through the responsible use and administration of Pintop systems.
Sensitive personal data
Health or other sensitive information may be processed where needed for legal obligations, workplace safety, sick leave, reasonable accommodation, benefits, explicit consent or the establishment or defence of legal claims.
Why workforce information is
processed.
Pintop processes workforce information where there is an appropriate employment, contractual, legal, operational or legitimate reason.
| Purpose | Relevant basis |
|---|---|
| Recruitment, assessment, communication and selection for available roles. | Steps connected to a possible contract and legitimate interests. |
| Administering employment or another workforce agreement, including salary, leave, benefits and work allocation. | Contractual necessity and applicable employment obligations. |
| Payroll, PAYE, pension, social insurance and other statutory administration. | Legal obligations and contractual administration. |
| Performance management, training, promotion, attendance, disciplinary and grievance processes. | Contractual necessity, legal obligations and legitimate interests. |
| Workplace health, safety, sick leave and reasonable accommodation. | Legal obligations, vital interests and another appropriate basis for sensitive data. |
| Administering devices, systems, accounts, access, cybersecurity and acceptable-use controls. | Legitimate interests, legal obligations and contractual responsibilities. |
| Responding to legal claims, audits, investigations and regulatory requests. | Legal obligations and legitimate interests. |
| Workforce planning and appropriately anonymised organisational analysis. | Legitimate interests. |
Access follows the
need to know.
Workforce information is accessed or shared only where it is reasonably required for an authorised business, employment, legal or administrative purpose.
Within Pintop
Outside Pintop
International transfers are subject to appropriate safeguards.
Some workforce systems or service providers may process information outside Nigeria. Where this occurs, Pintop applies the transfer mechanism and protections required for the circumstances.
How long workforce information is
kept.
Retention depends on the information category, employment relationship, legal obligations and whether the records are needed for an active claim, request or investigation.
Employment records
Core employment and workforce-administration records may be retained for the employment period and up to six years after the relationship ends.
Payroll and statutory records
Payroll, tax, pension and related statutory records may be retained for six years or another period required by applicable obligations.
Unsuccessful applicants
Recruitment information for an unsuccessful application may be retained for up to twelve months after the recruitment exercise concludes.
CCTV footage
Where CCTV is installed at a Pintop-controlled workplace, footage may normally be retained for up to thirty days unless a relevant incident requires it to be preserved.
You may ask Pintop to take action concerning your data.
Rights are subject to the conditions and limitations applying to the information and processing involved.
Access
Ask whether personal data is being processed and request a copy of eligible information.
Rectification
Ask for inaccurate or incomplete information to be corrected.
Erasure
Ask for deletion where there is no continuing lawful or required reason to retain the data.
Restriction
Ask for processing to be limited in appropriate circumstances.
Portability
Request eligible information in a suitable machine-readable format.
Objection
Object to certain processing where the applicable conditions are satisfied.
Withdraw consent
Withdraw consent where consent is the relevant basis for a processing activity.
Raise a concern
Contact Pintop about workforce privacy or submit a complaint to the Nigeria Data Protection Commission.
Workplace systems generate
operational records.
Information generated through workplace technology is used for legitimate administration, support, accountability and security—not for unrestricted personal monitoring.
Accounts and access
Account creation, role assignment, authentication, access history and account-removal information may be processed to protect Pintop systems and information.
Devices and support
Device assignments, configurations, support requests and technical records may be processed for maintenance, security and asset management.
Communications systems
Email and collaboration records may be processed for business continuity, security, support and compliance with applicable workplace policies.
Security and investigation
Relevant audit logs and workplace records may be reviewed where reasonably necessary to investigate a suspected security issue, misuse, policy breach or legal concern.
Questions about how your workforce information is handled?
Include the relevant employment, application, payroll, account or workplace context so the enquiry can be reviewed appropriately.
The notice may change as Pintop’s workforce practices evolve.
Pintop may update this notice when workforce systems, benefits, processing activities, service providers or applicable requirements change.
Related workforce and
privacy documents.
These documents provide additional information about privacy, retention, rights, system use and workplace concerns.
This Employee Data Protection Notice is effective from 1 Aug 2026.