Confidentiality & Data Protection Policy

Effective Date: 01/02/2025
Approved By: President, KPG99 Inc.

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1. Purpose

The purpose of this policy is to ensure that all confidential, proprietary, and personal information handled by KPG99 Inc. is protected from unauthorized use, disclosure, or loss. As a staffing and recruiting organization, KPG99 Inc. manages sensitive data related to clients, candidates, employees, and subcontractors. Protecting this information is critical to maintaining trust and compliance with contractual, ethical, and legal obligations.

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2. Scope

This policy applies to all employees, subcontractors, vendors, and consultants of KPG99 Inc. who have access to confidential information or company systems.

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3. Policy Statement

All KPG99 Inc. personnel must handle confidential and personal information responsibly. Confidential information includes, but is not limited to:

• Client business details, contacts, and open job requirements
• Candidate resumes, personal details, compensation, or employment information
• Internal company data, such as policies, financials, and operational processes
• Any non-public information shared by clients, candidates, or partners

Unauthorized use or disclosure of confidential information is strictly prohibited and may result in disciplinary action, termination of engagement, or legal action.

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4. Data Protection Principles

KPG99 Inc. follows these key data protection principles:

1. Lawful and Fair Processing: Data shall be collected and used only for legitimate business purposes.
2. Data Minimization: Only relevant and necessary data will be collected.
3. Access Control: Access is restricted to authorized personnel based on job roles.
4. Accuracy and Retention: Data will be maintained accurately and retained only for the required period.
5. Security: Appropriate administrative, physical, and technical safeguards are in place to protect data from unauthorized access or disclosure.

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5. Confidentiality Obligations

• Sign a Confidentiality Agreement as a condition of engagement.
• Protect client, candidate, and company data from unauthorized sharing or misuse.
• Refrain from discussing confidential matters in public or online platforms.
• Avoid using personal devices or public Wi-Fi to access confidential data unless securely connected via company-approved methods.

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6. Breach of Confidentiality

Any breach or suspected breach of confidentiality must be reported immediately to the Compliance & Operations Team at compliance@kpgtech.com.

Violations will be investigated, and corrective action—including retraining, warnings, or termination—will be taken based on severity.

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7. Training and Awareness

All personnel receive confidentiality and data protection training at onboarding and periodic refresher sessions. The training emphasizes the importance of handling client and candidate information responsibly.

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8. Review

This policy will be reviewed annually and updated to ensure alignment with legal and contractual requirements, including client-specific data protection standards.

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Approved and Authorized by:
Puneet Gulati
President, KPG99 Inc.
Date: 01/02/2025