Privacy Notice for Meeting Recordings on Microsoft Teams
Last update: 03rd March, 2022
Invitation to attend a Microsoft Teams meeting or training sessions
Vertiv Holdings Co. or its affiliate (“Vertiv” or “We”) may from time-to-time record meetings for limited purposes. These purposes are limited to:
- enable meeting or training session participants/non attendees to access the recording.
- share meetings and/or training sessions recorded to new employees and third parties (e.g., shareholders, services providers etc.) to improve organizational effectiveness.
In any circumstance, Vertiv shall only record a meeting and/or training sessions based on a genuine purpose (e.g., necessary due to the large number of attendees and training sessions) and will not configure a video recording feature as standard day-to-day practice.
If a recording is going to take place on the day you are in attendance, you are informed of recording the session by Microsoft Teams software prior to any recording taking place. It is likely if you ask a question this will be recorded. If a meeting attendee does not wish to be recorded, they can mute their microphone and turn their webcam off.
You need to read and be aware of this Privacy Notice if you attend a meeting and/or training sessions that may be recorded, using Microsoft Teams.
Privacy Notice
This Privacy Notice explains how Vertiv, as data controller, processes your personal data that is collected by Vertiv while recording a meeting or training session on Microsoft Teams software.
We will never ask for information that is unnecessary to deliver this service. One of our responsibilities is to tell you about the different ways we collect and use your personal data. This Notice will give you further information about how your personal data will be used when meeting or training session meetings are recorded by Vertiv.
Further information regarding the processing of personal data is contained in VP&P 900.03-PR.AT-02 – Attachment 1 – Electronic Tools Usage Baseline. It is posted in a place accessible to all and is available on Vertiv’s intranet. Vertiv recommends that you read the policy in its entirety.
Personal data processed
We collect, store, and use your personal data while recording a meeting or training session on Microsoft Teams, which includes your name, surname, video recording your live image or picture (profile), voice, personal opinions, actions taken, or contributions made (e.g., audience participation and chat logs).
If a meeting or training attendees choose to have the camera on, they must be mindful of the background and any impact on their privacy.
Purposes of the processing
Processing is necessary for the purposes of the legitimate interests pursued by Vertiv or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is an employee (e.g. it is in the interests of Vertiv and meeting attendees to record a meeting or training session for the benefit of individuals not in the position to attend it or to replay the meeting and/or training session to new employees and third parties).
In any circumstance, Vertiv shall only record a meeting and/or training session based on a genuine purpose (e.g., large number of attendees, training sessions etc.).
Nature of providing the requested data
Vertiv will always make individuals aware that a meeting is about to be recorded at the start of the meeting or training session and make sure that this privacy notice is available in the invite. If a meeting attendee does not wish to be recorded, they can mute their microphone and turn their webcam off.
Methods and place of processing and place of storage of personal data
Your personal data will be processed in accordance with the principles of correctness, lawfulness, and transparency.
Rest assured that we maintain appropriate security, technical, and organizational measures that ensure a level of security appropriate to the risk of unauthorized access to, and accidental or unlawful destruction, loss, alteration, and unauthorized disclosure of, personal data transmitted, stored, or otherwise processed.
Your personal data will be processed electronically, using automated tools that ensure the security and confidentiality of the data. For further information on the usage company tools and how to collect information, please refer to VP&P 900.03-PR.AT-02 – Attachment 1 – Electronic Tools Usage Baseline, which you are recommended to read.
We will process only personal data necessary for the above purposes. The people authorized to perform the data processing will immediately delete or make anonymous personal data unnecessary for the above purposes.
Your personal information is stored on Microsoft Office 365 servers. Microsoft will have access to your personal information for the purposes of providing the services to us.
Microsoft Teams has been configured to preserve the confidentiality of the information you exchange by implementing encryption during all communications and in storage, and anonymous access is not authorized.
For more information about how Microsoft may process your personal information please see the information in the Microsoft Trust Centre: www.microsoft.com/en-us/trustcenter/privacy.
You should be aware that your personal information may be transferred to, and stored at, a destination outside the country and economic area in which you reside. Transfers of personal data to third country outside EU are based on standard contractual clauses approved by the European Commission.
Data retention period
Microsoft Teams is configured to delete recorded videos in 60 days - after which time they are automatically deleted. Vertiv may download videos recorded on Microsoft Teams and post them in internal communications hubs (e.g., SharePoint, Microsoft Streams etc.) for the time strictly necessary to achieve the purposes stated above.
Data dissemination, sharing and communication
Personal data is disclosed on a need-to-know basis to the following recipients:
- Meeting attendees and external users included in the MS Teams team that is used for the exchange of information.
- Vertiv and Microsoft personnel involved in the data processing necessary to provide the service.
Right to access, update, correct, and supplement your data, to object to the processing, and to submit complaints
You have the right to obtain confirmation of the existence or non-existence of personal data relating to you.
You also have the right to be informed of the following:
- the origin of the personal data
- the purpose and methods of data processing
- the logic applied to the data processed electronically
- the identity of the data controller and the data processors
- the identity of the individuals or categories of individuals to whom your personal data may be sent to or who may acquire your data as appointed representatives of our company in your country of residence or as individuals authorized to process your data
You also have the right to:
- have your data erased
- have any unlawfully processed data erased, made anonymous, or blocked
No automated decision making will take place regarding the personal information submitted.
If you believe that we or a person/company we have communicated your data to has violated your rights, you may file a complaint with the Data Protection Authority in your country and other competent supervisory authorities.
Contact details of the Data Controller and Data Protection Officer
If you wish to exercise your data privacy rights, please submit a request by completing Vertiv’s Privacy Webform (click here) or sending an email to dataprotection@vertiv.com
If you are a resident of EAA countries, you are more than welcome to contact Vertiv’s Data Protection Officer, Dott. Donato Eugenio Caccavella, at dpo.vertiv@amicadpo.eu.
We will try to comply with your request(s) as soon as possible within the required timeframe specified in the data protection and privacy law of the country and state you are residing in.
