Privacy Policy
How we collect, use, store and protect your personal data, issued under India's Digital Personal Data Protection Act, 2023 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011.
1. Who we are
This Privacy Policy applies to Tanisha Overseas Placements (TOP) ("Tanisha Overseas", "we", "us", or "our"), a government authorised international recruiting agency operating from:
414, Essel House, 10 Asaf Ali Road, New Delhi - 110002, Republic of India
Email: info@tanishaoverseas.net
Phone: (+91)-11-23232343, (+91)-11-23232332
For the purposes of the Digital Personal Data Protection Act, 2023 ("DPDP Act"), Tanisha Overseas Placements (TOP) is the Data Fiduciary in respect of personal data processed through this website and our recruitment services.
2. The personal data we collect
We collect only the personal data that is necessary for our recruitment, employer-coordination and documentation services.
2.1 Data you provide to us directly
- Candidate data: name, age, gender, nationality, contact details (phone, email, address), passport details, qualifications, professional experience, references, photographs, résumé / curriculum vitae, preferred country and sector, salary expectations, language skills, and any other information you choose to include in your résumé or enquiry.
- Employer data: company name, contact person, role title, location, sector, number of vacancies, selection criteria and other details required to publish or process your demand.
- Correspondence: information contained in messages you send through forms, email, phone calls or messaging applications.
2.2 Data we collect automatically
- Technical data: IP address (stored only as a salted one-way hash), browser user-agent string, device type (desktop/mobile/tablet), pages visited, time and date of visit, and the referring URL.
- Cookies and local storage: a per-tab session identifier and your cookie-consent preference, stored in your browser's session/local storage. See our Cookie Policy.
We do not use third-party advertising trackers, social-media pixels, profiling cookies, or behavioural-targeting cookies.
3. Sensitive personal data
Recruitment for overseas employment may involve processing of categories that qualify as Sensitive Personal Data or Information ("SPDI") under the IT Rules 2011, for example passport details, financial information for visa processing, and medical fitness reports. We process SPDI strictly on the basis of your explicit, informed consent, only for the recruitment purpose for which you provided it, and we apply reasonable security practices as required by Rule 8 of the IT Rules 2011.
4. Purposes and lawful basis
| Purpose | Lawful basis (DPDP Act) |
|---|---|
| Registering and processing your candidate profile, matching you to overseas openings | Consent (Section 6) |
| Processing employer demand notices and matching candidates | Performance of a recruitment engagement / legitimate use (Sections 7, 9) |
| Communicating with you about openings, documentation, and deployment | Consent |
| Statutory recordkeeping under the Emigration Act, 1983 and rules | Compliance with a legal obligation (Section 7(b)) |
| Website operation, security, fraud prevention and abuse detection | Legitimate use (Section 7(i)) |
| Aggregate analytics about website usage | Consent (cookie banner) |
5. How long we keep your data
- Active candidate profiles: retained while you are actively under consideration for placements and for up to 24 months after the last activity, unless you ask us to delete sooner.
- Employer demand records: retained for the duration of the engagement and up to 5 years thereafter for statutory recordkeeping.
- Deployment / emigration records: retained for the period required by the Emigration Act, 1983 and the Protector General of Emigrants' instructions.
- Website analytics: 30 days for raw pageview logs.
- Login and security logs: 90 days.
After the relevant retention period your data is either deleted or anonymised so it can no longer identify you.
6. Who we share your data with
We share personal data only on a strict need-to-know basis with:
- Overseas employers and their representatives evaluating your profile for a specific role you have applied to or consented to be put forward for.
- Government authorities as required by the Emigration Act, 1983, the Ministry of External Affairs, the Protector General of Emigrants, and equivalent destination-country authorities (e.g. embassies, consulates, visa offices).
- Service providers who help us operate the website and store data securely (hosting, email delivery), bound by written confidentiality and data-protection obligations.
- Legal authorities where required by law, court order, or to defend our legal rights.
We do not sell, rent or trade your personal data to any third party for marketing purposes.
7. Cross-border transfers
Because we place candidates with overseas employers, your data will be transferred to the destination country (commonly GCC countries, European Union states, and other markets we recruit for). Such transfers are made only with your consent and only to countries not restricted by the Central Government under Section 16 of the DPDP Act. We require recipients to apply appropriate confidentiality and data-protection standards.
8. Your rights as a Data Principal
Under the DPDP Act you have the right to:
- Access: obtain a summary of the personal data we hold about you and the processing activities we undertake.
- Correction and erasure: request that we correct inaccurate data or erase data that is no longer needed.
- Grievance redressal: raise a complaint with our Grievance Officer (see Section 12).
- Withdraw consent: withdraw your consent at any time. Withdrawal will not affect lawfulness of prior processing.
- Nominate: nominate another individual to exercise your rights in the event of your death or incapacity.
To exercise any right, please email info@tanishaoverseas.net with the subject line "DPDP Data Principal Request" or use the in-page form at data-request.html if available. We will respond within the timeframe prescribed by the DPDP Act and accompanying rules.
9. How we protect your data
We follow reasonable security practices and procedures consistent with the IT Rules 2011, including:
- TLS / HTTPS encryption for data in transit (production deployment).
- Salted one-way hashing of IP addresses used for analytics.
- Access controls, rate limiting, CSRF protection and audit logging on administrative interfaces.
- Documented incident-response and breach-notification procedures.
In the event of a personal data breach likely to result in risk to data principals, we will notify the Data Protection Board of India and the affected individuals as required by the DPDP Act.
10. Children's data
Our recruitment services are offered only to candidates who are of legal working age under Indian law and the destination country's employment law. We do not knowingly collect personal data from individuals below the age of 18. If you believe a minor has provided us with personal data, please contact us so we can delete it.
11. Cookies and similar technologies
This website uses a minimal set of first-party cookies and browser storage:
- Strictly necessary: a signed session cookie used solely for the admin login area (no public visitor uses it).
- Functional: your cookie-consent preference, stored in
localStorage. - Analytics (with consent): a per-tab session identifier in
sessionStorageused to count distinct sessions in aggregate reports.
Analytics tracking is disabled by default and only activates after you accept the cookie banner. See the full Cookie Policy.
12. Grievance Officer
In compliance with Section 8(9) of the DPDP Act and Rule 5(9) of the IT Rules 2011, we have designated the following Grievance Officer:
Grievance Officer
Tanisha Overseas Placements (TOP)
414, Essel House, 10 Asaf Ali Road, New Delhi - 110002
Email: grievance@tanishaoverseas.net
Phone: (+91)-11-23232343
We will acknowledge complaints within 48 hours and aim to resolve them within 15 days, in line with the IT Rules 2011 and Intermediary Guidelines, 2021.
If you are not satisfied with our response, you may approach the Data Protection Board of India constituted under the DPDP Act.
13. Changes to this Policy
We may update this Privacy Policy from time to time to reflect changes in law or in our practices. Material changes will be notified by a banner on this website and, where appropriate, by email to candidates and employers with active engagements. The current version is shown at the top of this page.
14. Governing law and jurisdiction
This Privacy Policy is governed by the laws of India. Disputes will be subject to the exclusive jurisdiction of the courts at Delhi.