Privacy Policy


All data subjects whose personal data is collected, in line with the requirements of the GDPR, UAE PDPL, and ADGM “The Regulations” collectively referred to as “PDPL” for the purpose of this document.


The Data Protection Officer (DPO) is responsible for ensuring that this notice is made available to data subjects prior to BCS collecting/processing their personal data.

All Employees/Staff of BCS who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and that their consent to the processing of their data is secured.

Privacy notice

The personal data we would like to collect, and process for you is:

Personal data type:

Source (where BCS obtained the personal data from if it has not been collected directly from you, the data subject. Note if the personal data has been accessed from publicly accessible sources):

Trade License

Employer or Individual

Attested Educational Certificate

Employer or Individual

Immigration Cancellation papers

Employer or Individual

Copy of valid previous health insurance card or Certificate of Continuity issued by the Insurer

Employer or Individual

Tenancy Contract (Thawteeq/Ejari)

Employer or Individual

Employment Contract

Employer or Individual

Passport Copy

Employer or Individual

Residence Visa Copy

Employer or Individual

Emirates ID

Employer or Individual

Labor Card and Contracts

Employer or Individual

Insurance Cards Copy

Employer or Individual

Qualification Certificates

Employer or Individual

Tenancy Contracts/ Thawteeq/Ejari

Employer or Individual


Employer or Individual

Government Application Approvals

Employer or Individual

Employment Offer Letters

Employer or Individual

Employee Applications and Resumes

Employer or Individual

Promotions, Letter of Reprimand, Termination

Employer or Individual

Job Description, Performance Goals

Employer or Individual

Employee Contracts

Employer or Individual

Confirmation of Offer Letters

Employer or Individual

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

  • New Visa Applications
  • Visa Renewals
  • Establishing Legal Entities
  • Trade License Renewals
  • MOA Amendments
  • POAs

The special categories of personal data are:

Special Categories of Personal Data (previously referred to as Sensitive Personal Data) include “Personal Data revealing or concerning (directly or indirectly) racial or ethnic origin, communal origin, political affiliations, or opinions, religious or philosophical beliefs, criminal record, trade-union membership and health or sex life and including genetic data and biometric data where it is used for the purpose of uniquely identifying a natural person.” Such data must not be processed unless one of the conditions set out in the New Law exists (in addition to the general requirements for Processing and lawfulness).

In this respect, PDPL grants specific rights to the Controller to process Special Categories of Personal Data for Data Subjects’ employment purposes including recruitment, visa or work permit processing, the performance of an employment contract, and termination of employment. Such processing rights are also available to Controllers in a healthcare context.


By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified.

Consent is required for BCS to process both types of personal data, but it must be explicitly given. When we are asking you for sensitive personal data, we will always tell you why and how the information will be used.

You may withdraw consent at any time by written request to


BCS will not pass on your personal data to third parties without first obtaining your consent unless otherwise required by law.

Retention period

BCS will process personal data for five years and will store the personal data for five years.

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 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 organization.
    • 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: If BCS 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 in Complaints.

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


If you wish to make a complaint about how your personal data is being processed by BCS (or third parties as described above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and BCS’s DPO.

Personal data

Under the UAE’s PDPL and ADGM’s “The Regulations” personal data means any data relating to an identified natural person or Identifiable Natural Person.

In other words, it means data that relates to a living individual who can be identified:

    • from that data, or
    • from that data and other information, which is in the possession of, or is likely to come into the possession of, the Data Controller,

and includes any expression of opinion about the individual and any indication of the intentions of the data controller or any other person in respect of the individual.

How we use your information

This privacy notice tells you how we, BCS, will collect and use your personal data where we need to collect personal data by law, or under the terms of processing a service we have with you and you fail to provide that data when requested, we may not be able to perform or complete the process/job that we have with you.

Why does BCS need to collect and store personal data?

For us to provide you services, we need to collect personal data. 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.

In terms of being contacted for marketing purposes, BCS would contact you for additional consent.

Will BCS share my personal data with anyone else?

We may pass your personal data on to third-party service providers contracted to BCS while 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 provide services When they no longer need your data to fulfill this service, they will dispose of the details in line with BCS’s procedures. If we wish to pass your sensitive personal data onto a third party, we will only do so once we have obtained your consent unless we are legally required to do otherwise.

How will BCS use the personal data it collects about me?

BCS will process (collect, store and use) the information you provide in a manner compatible with the PDPL. We will endeavor to keep your information accurate and up to date, and not keep it for longer than is necessary. BCS is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

Under what circumstances will BCS 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 minimize the risk of unauthorized access or disclosure.

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

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

    • Identity and the contact details of the person or organization that has determined how and why to process your data. In some cases, this will be a representative in the UAE.
    • 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 BCS or a third party, information about those interests.
    • The categories of personal data collected, stored, and processed.
    • Recipient(s) or categories of recipients to whom the data is/will be disclosed.
    • If we intend to transfer the personal data to a third country or international organization, information about how we ensure this is done securely. The UAE 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.
    • How long the data will be stored.
    • 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 to access this?

BCS accepts the following forms of ID when information on your personal data is requested:

    • Passport
    • Emirates ID

Contact details of the Data Protection Officer:

Data Protection Officer’s contact details

Contact Name:

Dr. Jason Gamage

Address line 1:

Al Maryah Island, 16th Floor, Office 115,

Address line 2:

Al Khatem Tower

Address line 3:

Abu Dhabi, PO Box 112028

Address line 4:

United Arab Emirates



+971 56 414 5798



Risk Acceptance — Non-compliance with these and other information security requirements can result in disciplinary action, including termination. In rare cases, a business case for non-compliance can be established. The non-compliance situation must be approved in advance through a risk acceptance process in all such matters. This process requires a risk acceptance memo signed by a department manager and approved by Information Security.

Further Information — Questions about this document should be directed to the BCS Information Security department.

Violation of Duties

Violation of Duties — Non-compliance with this policy will be considered a breach of the employee’s working duties and can result in disciplinary action, including termination.