Last updated : Jan 31, 2022
This privacy notice (the “COVID-19 Privacy Notice”) explains how Everest for Urban Development and our affiliates (collectively, “Everest,” “we,” “us,” or “our”) collects, uses, discloses, and otherwise processes your Personal Information in connection with our response to COVID-19 and supplements the Everest Privacy Policy for People Data for employees and the Global Privacy Policy for members, vendors, visitors and guests.
1. PERSONAL INFORMATION WE COLLECT ABOUT YOU
In connection with Everest’s response to COVID-19, we may collect Personal Information, including Health Data (defined below): (i) directly from you; (ii) obtained about you from others; (iii) when you visit a Everest office; and (iv) from other sources.
- For employees:
- your contact details;
- information relating to your employment with us;
- household information (in particular, whether you live with a person who is considered vulnerable to complications from COVID-19 infection);
- information relating to how you travel/commute to your Everest office;
- recent travel history;
- information relating to your health, including your temperature; whether you have been infected by, may currently have, have previously had, are at risk of contracting, at risk of spreading or if you are considered vulnerable to complications from, COVID-19; COVID-19 symptoms; and antibody test results (“Health Data”); and
- other information you provide to us
- For members, visitors and guests:
- recent travel history;
- Health Data; and
- other information you provide to us;
Information we may collect about you, including when you visit our office:
- Thermal Scanning:
- We may require employees, members, visitors and guests to have their temperature taken in some Everest offices via a thermal scanning device (“Thermal Scanning Device”), before entering the building. The Thermal Scanning Device uses thermal imaging technology to determine whether you have a temperature above or below the local temperature threshold that indicates whether a COVID-19 infection may exist (e.g. 38°C, 99.5°F, etc.).
- The Thermal Scanning Device will momentarily collect and process data relating to your temperature – this information is personal information relating to your health.
- Health Screening Questionnaires:
- We may require employees, members, vendors, visitors and guests to complete a health screening questionnaire (“Questionnaire”) before entering our offices in order to detect whether any COVID-19 infection may exist. This is to assist in the prevention and containment of the infection in our workspaces.
- Completed Questionnaires will be retained for up to 60 days or as otherwise required by applicable law.
- Additional Screening or Monitoring Measures:
- We may, from time to time, implement additional screening or monitoring measures as official recommendations and regulations regarding COVID-19 continue to evolve. We will implement and adjust these measures to the extent permitted or required under applicable laws and regulations, which may vary depending on location. We may also leverage the information obtained from Thermal Scanning Devices, Health Screening Questionnaires, and additional measures to provide anonymized reporting and assist in notifying individuals who may have come in close contact with a COVID-19 affected individual on an anonymous, ‘no names’ basis.
Information we collect about you from other sources:
- Our vendors (including security personnel)
- Your contact details, Health Data, and any relevant Everest offices you have attended.
- Our members
- Your contact details, Health Data, and any relevant Everest offices you have attended.
- Visitors and guests
- Your contact details, Health Data, and any relevant Everest offices you have attended.
- Co-workers and your employer
- Your contact details, Health Data, and any relevant Everest offices you have attended.
2. HOW AND WHY WE USE YOUR INFORMATION
2.1 Personal Information and Health Data
Data protection law requires us to have a valid reason to process your Personal Information. The law refers to each reason as a ‘lawful basis’. The purposes for which we use your Personal Information and the lawful basis on which we rely are to comply with our legal obligations, to protect you or another’s vital interests, and in furtherance of our legitimate interests, as detailed below. In addition, to the extent Personal Information is considered Health Data (i.e., a special category of information under applicable law), we will process this information: (i) only where our processing is necessary for us to carry out our obligations in the field of employment (these obligations include protecting the health and safety of our employees and workspaces); (ii) with your explicit consent (we will rely on explicit consent only where we rely on consent as a lawful basis in this paragraph); or (iii) where relevant, in defense of legal claims.
Where necessary to comply with our LEGAL OBLIGATIONS
We will use your Personal Information to comply with our legal obligations:
- to protect the health and safety and well-being of our employees and workspaces (e.g. implementing measures that prevent individuals who have been infected with COVID-19 from infecting employees);
- to anonymise or delete your Personal Information when it is no longer required for the purposes described in this COVID-19 Privacy Notice;
- to comply with court orders or other notices where failure to do so would result in us breaking the law;
- to comply with any reporting obligations or government requests under applicable laws or legal mandates, including contact tracing; and
- to handle and resolve any complaints we receive relating to our processing of your Personal Information as described in this COVID-19 Privacy Notice.
Where it is in your or another individual’s VITAL INTERESTS
We will use your Personal Information to notify individuals you have been in close contact with and who may now be at risk of COVID-19 infection. We will do this in order to protect the health of our employees, members, visitors and guests. Any such notifications will be conducted on an anonymous basis.
Where there is a LEGITIMATE INTEREST
We may use and process your Personal Information where it is necessary for us to pursue our legitimate interests as a business, or that of a third party, for the following purposes:
- Processing is necessary for us to effectively operate our business and ensure our office spaces remain open;
- to monitor and reduce the spread of COVID-19 infection;
- to decide and plan how and when our workforce will physically return to our offices;
- Processing is necessary for our members to ensure their businesses can remain operational
- to monitor and reduce the spread of COVID-19 infection; and
- to protect the health and safety and wellbeing of our members’ workforce and workspaces.
Where you have provided CONSENT
We may use and process your personal information where you have consented for us to do so for the following purposes:
- in countries where our implementation of temperature screening is voluntary or optional (i.e., we do not require you to undergo temperature testing), to take your temperature and permit or reject your access to our offices; and
- in countries where we do not require you to disclose whether you may be infected with COVID-19, to use this information to permit or reject your access to our offices and inform others who you may have been in contact with of your infection (on a ‘no names’ basis).
You may withdraw your consent for us to use your information in any of these ways at any time.
3. DISCLOSURE OF YOUR PERSONAL INFORMATION BY US
Your information may be disclosed to or processed by our third party service providers, agents and subcontractors (“Suppliers”) and other individuals for the purposes set out above as follows:
- Security
- Security Vendors
- IT (Data Management)
- Facilities and technology service providers including saas, scanning, and data destruction providers
- Insurance (Underwriting & Broking)
- Insurers and insurance brokers
- Professional Services (Legal & Accounting)
- Legal, security and other professional advisers, auditors, and consultants
- Healthcare
- Health officials
- Various
- Members, Visitors, Guests, Employees
If you have symptoms associated with COVID-19 or report that you have tested positive for COVID-19, we will use your Personal Information to notify individuals you have been in close contact with and who may now be at risk of COVID-19 infection. We will do this in order to protect the health of our employees, members, visitors and guests. Any such notifications will be conducted on an anonymous ‘no names’ basis.
4. DATA STORAGE, RETENTION AND YOUR RIGHTS
For information about where we store your Personal Information, how long we retain your Personal Information, and your rights under data protection law, please visit the Everest Privacy Policy for People Data for employees and the Global Privacy Policy for members, visitors and guests which this COVID-19 Privacy Notice supplements. .
5. CONTACT US
For more information about our contact details and when to contact us, please visit the Everest Privacy Policy for People Data for employees and the Global Privacy Policy for members, visitors and guests which this COVID-19 Privacy Notice supplements.