Privacy Policy

This Privacy Policy describes how Golden Mainland Ghana Ltd (“Company”, “we”, “us”, or “our”) collects, uses, and discloses your information in connection with your use of our HRNova platform (the “Platform”). The Platform is developed and maintained by C-Stack (“Platform Provider”), who acts as a data processor on our behalf.

1. AGREEMENT TO POLICY

You accept this Privacy Policy by using the Platform. If you do not agree with the terms of this policy, please do not access or use the Platform. We are the data controller for the personal data described here, meaning we are responsible for deciding how and why it is processed, in accordance with Ghana's Data Protection Act, 2012 (Act 843).

2. INFORMATION WE COLLECT

We may collect the following categories of personal information about you:

Personal and Contact Information

• Your full name, photograph, date of birth, gender, and marital status.
• Your work and personal contact details, such as email address and phone number.
• National identification details (e.g., National ID, Passport number) and related documents you provide.
• Emergency contact and next-of-kin information.

Financial and Statutory Information

• Your salary, allowances, deductions, loans, and complete payslip history.
• Bank account details and mobile money numbers for salary payment.
• SSNIT number, TIN, and other information required for statutory returns.

Employment and Performance Information

• Your employment contract, job title, department, and employment dates.
• Records of attendance, leave, and absence.
• Performance reviews, appraisals, goals, and key performance indicators (KPIs).
• Records related to disciplinary matters, grievances, and exit interviews.

Automatically Collected Information

• Log and Usage Data, including your IP address, browser type, device information, pages visited, and timestamps of your activity.
• An audit trail of significant actions you take within the system, such as creating, updating, or approving records. This is essential for security and accountability.

3. HOW WE USE YOUR INFORMATION

We use the information we collect for the following purposes:

• To Fulfill Our Employment Contract: To manage payroll, administer salaries and benefits, process leave requests, and manage your overall employment with us.
• To Comply with Legal Obligations: To process SSNIT contributions, file tax returns with the Ghana Revenue Authority (GRA), and maintain employment records as required by law.
• For Legitimate Business Interests: To manage employee performance, conduct appraisals, handle disciplinary matters and grievances, and for internal reporting and workforce planning.
• To Maintain and Secure the Platform: To monitor for security threats, prevent fraud, maintain an audit trail, and ensure the proper functioning of the Platform.

We do not sell your personal data to third parties. We do not use it for marketing or advertising, and we do not use it to make fully automated decisions that would have a legal or similarly significant effect on you.

4. DISCLOSURE OF YOUR INFORMATION

Access to your personal data is strictly controlled on a need-to-know basis. We may share your information with the following parties:

• Internal Staff: Access within the Platform is role-based. For example, only authorized HR and finance personnel can view sensitive payroll and bank details. Your direct manager may see your attendance and performance data, but not your salary.
• Government and Statutory Bodies: We share data with entities like SSNIT and the Ghana Revenue Authority as required by law.
• Service Providers:
  • Our Platform Provider (C-Stack) has access to the data for the purposes of system maintenance, support, and troubleshooting. They act as a data processor on our instruction and are bound by confidentiality and data protection agreements.
  • Our hosting provider (Hostinger) stores the Platform's data on servers located in London.
  • Our banking partners receive necessary information to process salary payments.
• Legal Requirements: We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).

5. CROSS-BORDER DATA TRANSFERS

Your information may be transferred to — and maintained on — computers located outside of Ghana, where the data protection laws may differ. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and that adequate data protection safeguards are in place.

6. SECURITY OF YOUR INFORMATION

We use administrative, technical, and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that no security measures are perfect or impenetrable.

• Access Control: Access to personal data within the Platform is strictly limited based on user roles and permissions.
• Encryption in Transit: All data transmitted between your browser and the Platform is encrypted using HTTPS/TLS.
• Password Security: User passwords are not stored in plaintext; they are protected using strong, salted hashing algorithms.
• Secure Storage: Uploaded documents are stored in a private location and are only accessible through authenticated and authorized requests.

If we become aware of a security breach that affects your personal data, we will notify you and the Data Protection Commission as required by law.

7. DATA RETENTION

We will retain your personal information for as long as your employment with us continues, and thereafter for the period necessary to fulfill the purposes outlined in this Privacy Policy. In particular, payroll, tax, and SSNIT records will be retained for the statutory period required by Ghanaian law, even after your employment ends.

8. YOUR DATA PROTECTION RIGHTS

Under Act 843 you have the right to:

• The right to access – You have the right to request copies of your personal data.
• The right to rectification – You have the right to request that we correct any information you believe is inaccurate or complete information you believe is incomplete.
• The right to erasure – You have the right to request that we erase your personal data, under certain conditions (this does not override our legal obligation to retain certain records).
• The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.
• The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.
• The right to complain – You have the right to lodge a complaint with the Data Protection Commission if you are unsatisfied with our handling of your data.

To exercise any of these, contact us at Hr@goldenmainlandglobal.com. We will respond to your request without undue delay.

9. Cookies

We use cookies and similar tracking technologies to operate and secure the Platform. These are strictly necessary for functionality, such as maintaining your login session and protecting against security threats (e.g., CSRF). We do not use cookies for advertising or third-party analytics tracking.

10. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. If we make material changes, we will notify you by requiring you to re-accept the policy upon your next login. We record the date and version you accepted.

11. CONTACT US

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us:

Golden Mainland Ghana Ltd
Hr@goldenmainlandglobal.com