Privacy Policy & Disclaimer Privacy Policy & Disclaimer

Privacy Policy

1. Overview

Firstsource Solutions Limited (this expression means and includes its affiliates and subsidiaries) has created this Website Privacy Policy in order to demonstrate Firstsource’s commitment to privacy. This Website Privacy Policy demonstrates Firstsource’s (‘we’, ‘our’, ‘us’) information gathering and dissemination practices for its corporate website (www.firstsource.com) or such other websites of Firstsource (together referred hereafter as "Website”).

Firstsource is committed to protect the privacy and security of your (users accessing Firstsource Website and/or leaving information on Firstsource Website) personal data.

This Website Privacy Policy (“Policy”) does not define how third parties, whose external links are present on Firstsource’s Website, use or process your personal data (the terms personal data and data information are interchangeable). We encourage you to read their respective privacy policies and know your privacy rights before interacting with them.

2. Relationship

We are the Data Fiduciary / Data Controller of your personal data that we collect and process through the Website. This means we determine how and why personal data is processed.

3. What personal data do we collect and how

Information given by the User or You
We may receive, use and store any information which you enter on our Website or give us in any other way, such as:

• By submitting a web form on our Website, you will share with us information such as your name, phone number and email address to enable us to reply to you. This will be treated as a lawful consent and your personal data will not be shared outside of Firstsource.
• If you are applying for a vacancy with us, please refer to the job vacancy privacy policy for further information on how your data will be used.
• We do not share any personal information collected with any third parties. When completing a web form, we will store and process personal data and as per applicable laws.
  • Case 1: Forms on the contact page marked “Suppliers”, “Recruitment”, “Employees”, “Media/Press”, “Investors”, “Analysts” and “Other”

    • We will gather your name, phone number, email address, company, and job title (if applicable), Firstsource office you wish to contact (if applicable), and an optional message. Your details and message will be:
      a) sent via email to the relevant person within the organisation;

      b) stored in our database as long as required for business purpose or such other time as per applicable law before permanent deletion.

      This information can be removed from our database in case you wish to withdraw consent by sending an email requesting withdrawal of consent to the email address dpo@firstsource.com.

  • Case 2: All other web forms (excluding job applications)
    • We will gather your name, phone number, email address, location,, web page on which you filled out the form, actions taken on our Website, company and job title, industry, the solutions you are interested in, and an optional message.
    • We will also ask in a clear manner for your consent to a) receive marketing communications, and, separately, b) receive personal emails from Firstsource personnel, such as business development representatives. These options will either be presented as checkboxes, or be clearly indicated in the form title, e.g., “Sign up for our mailing list”.
    • Your details and messages and any form of communication with you will be stored in our marketing automation system as long as required for business purpose or such other time as per applicable law. If you opted in to receiving marketing communications, you will be added to the general mailing list and any other mailing lists based on your indicated industry and desired solutions. You may unsubscribe at any time by emailing dpo@firstsource.com or clicking “Unsubscribe” at the bottom of any marketing email.
    • If you opted in to receiving personal messages, your details and message will be sent to a relevant member of our business development team. Your details may also be stored in Active Campaign and Salesforce, our CRM system.
    • You can contact us at dpo@firstsource.com at any time to remove your information. We will not, without your explicit consent, disclose to anyone outside of Firstsource Solutions Limited any personal information you provide to us when you visit the website.

The data we would like to collect via forms is:

4. Email Communication

To help us make e-mails more useful and interesting, we often receive a confirmation when you open an e-mail from Firstsource.com if your computer supports such capabilities.
Our Website provides users the opportunity to opt-out of receiving communications from us and our partners by reading the unsubscribe instructions located at the bottom of any e-mail they receive from us at any time.

5. Cookies

To improve your experience on our site, we may use ‘cookies’. Cookies are an industry standard and most major websites use them. A cookie is a small text file that our site may place on your computer as a tool to remember your preferences. You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this you may not be able to use the full functionality of this Website. Please refer to the cookie policy https://www.firstsource.com/privacy-policy/ for more detailed information.

6. IP addresses

IP addresses are used by your computer every time you are connected to the internet. Your IP address is a number that is used by computers on the network to identify your computer. IP addresses are automatically collected by our web server as part of demographic and profile data known as “traffic data” so that data (such as the Web pages you request) can be sent to you.

7. Google Analytics

Our Website uses Google Analytics, a service which transmits Website traffic data to Google servers in the United States. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. We use reports provided by Google Analytics to help us understand Website traffic and webpage usage.
By using this Website, you consent to the processing of data about you by Google in the manner described in Google’s Privacy Policy (https://www.google.com/policies/privacy/) and for the purposes set out above. You can opt out of Google Analytics if you disable or refuse the cookie, disable JavaScript, or use the opt-out service provided by Google (https://tools.google.com/dlpage/gaoptout).

8. Social media

Firstsource also uses interfaces with social media sites such as Facebook, LinkedIn, Twitter, and others. If you choose to “like” or “share” information from this Website through these services, you should review the privacy policy of that service. If you are a member of a social media site, the interfaces may allow the social media site to connect your visits to this site with other personal information.

9. External links

Our Website may contain links to other websites. Please be aware that we are not responsible for the privacy practices of such other sites. When you go to other websites from here, we advise you to be aware and read their privacy policy.

10. What do we use your personal data for?

We use personal data to provide you with information that you have requested, including marketing purposes, sales (if you choose to be contacted for such sales and marketing purposes) and to process online applications.
Firstsource collects information including the following:

• Internet Protocol address- which will be anonymised, browser type, browser language, the date and time of your query. This information is collected in the interest of identifying any issues with the site, to establish which areas of the website are used more frequently and to help improve the website.
• Information provided through the web forms- including name, email address and contact number will only be used for the purpose of the web form submission including new customer contact, media enquiries and marketing. This will be processed under the lawful basis of consent.

Lawful basis:
We rely on the following lawful basis, for the above purposes:

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. (For example, we need to process for administrative and record keeping purposes, etc.)
• Where we need to protect your vital interests (or someone else's interests).
• Where we need to comply with a legal obligation.
• Where we have sought your explicit consent.

We will only use personal data for the purposes described above or as otherwise disclosed at the time we request such data from you. Should your personal data be processed for other purposes than those outlined in this Privacy Policy or other purposes than the ones your personal data has originally been collected for, we will update this information to provide you with information on that other purpose, and any additional relevant information.

11. Security

We have adopted reasonable and adequate security practices and procedures, in line with industry standards such as ISO 27001:2022, HITRUST, PCI DSS, HIPAA etc. to include strategic, operational, managerial, technical, and physical security controls to safeguard and protect your data and information.
We take steps such as the following to protect your personal data:

• Ensure that the data resides behind the firewall with access restricted to authorized personnel.
• Prevent people entitled to use data processing systems from accessing personal data beyond their needs and authorization.
• Ensure that in the case where processing is carried out by another entity on our behalf, the data is processed only in accordance with the data processing addendums and the agreed contractual obligations.

The information in our custody and control is protected by adherence to reasonable security procedures to safeguard against unauthorized access. We apply encryption or other appropriate security controls to protect personal data when transmitted and stored by us.

12. How long do we store your personal data?

We retain personal data only for as long as it is needed for the business purpose defined and as provided under applicable laws. This includes meeting our professional and legal requirements, to establishing, exercising, or defending our legal rights, and for archiving purposes.
Please note that retention periods vary in different jurisdictions and are set in accordance with regulatory and professional retention requirements.

13. Disclosure and transfer of personal information

Firstsource keeps your personal information confidential except where disclosure/transfer of personal information is required by an order under the law for the time being in force or by Government agencies including law enforcement agencies having authority of law, upon their request in writing, even without obtaining your consent.

However, sometimes Firstsource uses third parties to process your information. Firstsource requires these third parties to comply strictly with its instructions and not to further transfer your personal information or use it for any purpose other than the purpose for which it is being collected by Firstsource. Firstsource also ensures that they do not use your personal information for their own business purposes unless you have explicitly consented. We ensure this by signing appropriate data processing agreements with such third parties.

We may transfer your personal data to other processing locations in cases where our data centres are in other geographical locations. In such instances, appropriate data transfer agreements are signed with FSL entities in accordance with applicable data protection laws.

14. Minor/Child’s personal data

Firstsource Website is not meant for minors under the age of 18 years. If you are a minor, please do not use this Website or provide any personal data to us. We are not required to collect any personal data from minors. If we find that any minor has used our application or provided any Personal Data, then we reserve our right to delete such personal data of the minor. If as an authorized user, you come to know that any minor has posted any Personal Data, then you may please contact us using the contact details mentioned in “Contact Us” section of this privacy policy.

15. Access to information and your rights

You have the following rights with respect to your personal data: -

• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to judicial review – in the event that Firstsource refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined below.

16. Complaint

If you are concerned about an alleged breach of privacy law or any other regulation by Firstsource, you can contact the Firstsource Data Protection Officer who will investigate your complaint and give you information about how your personal data will be handled.

You also have the right to complain to the data protection authority in your country and their contact details are enlisted below:

17. Contact Us

If you have any questions or concerns about this Privacy Policy, or your dealings with this Website, you can contact dataprivacy@firstsource.com for clarifications.
Our Data Protection Officer can be contacted at-
Firstsource Solutions Limited,
Unit 201 to 204, 2nd Floor,
Block C2 Brigade Tech Gardens SEZ,
Brigade Properties Pvt. Ltd, Brooke fields,
Kundalahalli, Marathahalli Post, Bengaluru,
Karnataka, 560037

The residents of India may request the content of this policy in any of the 22 languages specified in the eighth schedule of the Constitution of India.

18. Changes to this Website Privacy Policy

We may update this Policy from time to time in line with Firstsource’s business requirements and changes in applicable laws.

UK Job Applicant Privacy Policy

1. Scope

All individuals applying for a job vacancy with Firstsource Solutions UK Limited

2. Privacy notice

Who are we?

Firstsource Solutions UK Limited is a business processing outsource company who collects and stores personal information regarding employees, clients, and as an outsourcing solutions provider, our client’s customers. Firstsource Solutions UK Limited is committed to ensuring this data is collected and processed fairly, lawfully and in a transparent manner and commits to adhering to the statutory duty to comply with the General Data Protection Regulation (GDPR).

Our UK Head Office address is:

Firstsource Solutions UK Limited, Space One, 1 Beadon Road, London, W6 0EA

Our Data Protection Officer can be contacted at:

• Firstsource Solutions UK Limited, Space One, 1 Beadon Road, London, W6 0EA

The personal data we collect will be used for the following purposes:

• We need to process data to take steps as part of the recruitment process, prior to entering a contract with you. We may also need to process your data to enter into a contract with you if you are successful in your application for employment.
• In some cases, we need to process data to ensure that we are complying with our legal obligations. This includes eligibility to work documentation.

Our Lawful Basis for Processing Personal Data

• Contract
• Legal Obligation
• Legitimate Interests
• Article 9 for Special Category Data
• Article 9(2)(b) – employment
• Data Protection Bill – Schedule 1 Employment

Any legitimate interests pursued by us, or third parties we use, are as follows:

• We process health information in the interest of providing reasonable adjustments.
• We process ethnicity information in the interest of monitoring equality.

Special Categories of Personal Data Concerned

• Ethnicity
• Health Information
• Gender
• Community Background Information (Northern Ireland only)

2.2 Disclosure

Firstsource Solutions UK Limited will pass on your personal data to third parties during the recruitment process. The following third parties will receive your personal data for the following purpose(s) as part of the processing activities:

2.3 Retention Period

For successful candidates Firstsource Solutions UK Limited will process personal data and will store the personal data for the length of your employment. In addition, further retention periods apply for Payroll and Recruitment information which will be held for up to 7 years after your employment ceases. Background checks for criminal convictions and credit checks will be completed on successful candidates and will be held on the Experian portal for 24 months. If you are unsuccessful in an application Firstsource Solutions UK Limited will retain your information for 1 year.

2.4 Your rights as a data subject

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

• Right of access: You have the right to request a copy of the information that we hold about you.
• Right of rectification: You have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten: In certain circumstances, you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing: Where certain conditions apply, you have the right to restrict the processing.
• Right of portability: You have the right to have the data we hold about you transferred to another organisation.
• Right to object: You have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling: You also have the right to be subject to the legal effects of automated processing or profiling.
• Right to judicial review: In the event that Firstsource Solutions UK Limited refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined below.

All of the above requests will be forwarded on should there be a third party involved in the processing of your personal data.

2.5 Complaints

In the event that you wish to make a complaint about how your personal data is being processed by Firstsource Solutions UK Limited (or third parties above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Firstsource Solutions UK Limited’s Data Protection Officer.

The details for each of these contacts are:

3. Privacy Statement

Personal data

Under the EU’s General Data Protection Regulation (GDPR), personal data is defined as:

How we use your information

This privacy notice tells you how we will collect and use your personal data for the purposes of our recruitment process. The information collected will not be used for any other purpose than the recruitment process. If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your HR file (electronic and paper-based) and retained during the period of your employment and, in some circumstances, afterwards. The periods for which your data will be held should you become an employee will be provided to you in the privacy notice for employees. For unsuccessful applicants, this data will be retained for 1 year.

Why does Firstsource Solutions UK Limited need to collect and store personal data?

As an employer, we need to collect personal data for the purposes of employment, including recruitment, HR and payroll activities as well as managing performance. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.

Will Firstsource Solutions UK Limited share my personal data with anyone else?

We may pass your personal data on to third-party service providers contracted to Firstsource Solutions UK Limited in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you on our behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with Firstsource Solutions UK Limited procedures.

How will Firstsource Solutions UK Limited use the personal data it collects about me?

Firstsource Solutions UK Limited will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Firstsource Solutions UK Limited is required to retain information in accordance with the law, such as information needed for income tax and audit purposes.

Under what circumstances will Firstsource Solutions UK Limited contact me?

Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.

Can I find out the personal data that the organisation holds about me?

Firstsource Solutions UK Limited, at your request, can confirm what information we hold about you and how it is processed. If Firstsource Solutions UK Limited does hold personal data about you, you can request the following information:

• Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU.
• Contact details of the data protection officer, where applicable.
• The purpose of the processing as well as the legal basis for processing.
• If the processing is based on the legitimate interests of Firstsource Solutions UK Limited or a third party, information about those interests.
• The categories of personal data collected, stored, and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.
• If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
• Details of your rights to correct, erase, restrict or object to such processing.
• Information about your right to withdraw consent at any time.
• How to lodge a complaint with the supervisory authority.
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
• The source of personal data if it wasn’t collected directly from you.
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

What forms of ID will I need to provide in order to access this?

Firstsource Solutions UK Limited accepts the following forms of ID when information on your personal data is requested:

Passport, driving licence, birth certificate, utility bill (from last 3 months).

Contact details of the Data Protection Officer:

Disclaimer

The information contained in this website is for general information purposes only. While Firstsource Solutions Limited (‘we’) endeavor to keep the information up-to-date and correct, we make no representations or warranties of any kind, express or implied, about the completeness, accuracy, reliability, suitability or availability, with respect to the website, of the information, services, or related graphics contained in the website for any purpose. Any reliance you place on such information is therefore strictly at your own risk.

This site is subject to periodic update and revision. Materials should only be considered current as of the date of initial publication appearing thereon, without regard to the date on which you may access the information. We maintain the right to delete or modify information on this website without prior notice to any third party or person and shall maintain a complete discretion on the content published.

In no event shall we be liable for any loss or damage including without limitation any direct, indirect, special, or consequential loss or damage, loss of data, profits, business, reputation or any loss or damage whatsoever arising out of, or in connection with, the use of this website or any information contained herein.

Past financial performance should not be taken as an indication or guarantee of future performance and no representation and warranty, express or implied, is made regarding future performance.

Every effort is made to keep the website up and running. However, we take no responsibility for, and will not be liable for, the website being temporarily unavailable due to technical issues beyond our control. We reserve the right, at our sole discretion, to correct any errors or omissions in any portion of the website. Any unauthorized use of this website may give rise to a claim for damages including criminal prosecution.

Unless otherwise stated, we or our licensors, as the case maybe own all intellectual property rights in the website and any information or material on the website. All our intellectual property rights in relation to the website are reserved.

Subject to the terms and conditions set forth herein, We will grant a non-exclusive, non-transferable, limited right to access this site and the materials thereon.

You agree not to:

• Interrupt or attempt to interrupt the operation of the site in any way.
• Intrude or attempt to intrude into the site in any way.
• Post any obscene, defamatory or annoying materials on the site.
• Obscure any material, including this notice, already posted on the site.
• Use the site or any contents thereof to defame, intimidate, annoy or otherwise cause nuisance or breach the rights of any person.

This disclaimer will be governed by and construed in accordance with the laws of India, and any disputes relating to the website or this disclaimer shall be subject to the exclusive jurisdiction of the courts in Mumbai, India.