The Employee Privacy Notice is a mandatory document under both EU GDPR and Belgian data protection law, required for all organizations employing staff in Belgium. It serves as a transparent communication tool between employers and employees regarding the processing of personal data throughout the employment relationship. This document must be provided to employees at the start of their employment and when significant changes occur in data processing practices. The notice must comply with Article 13/14 of GDPR, Belgian Data Protection Act requirements, and relevant CLAs, particularly regarding workplace monitoring and surveillance. It forms a crucial part of an organization's data protection compliance framework and should be regularly reviewed and updated to reflect changes in processing activities or legal requirements.
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1. Introduction: Overview of the notice's purpose and the employer's commitment to data protection
2. Data Controller Information: Identity and contact details of the employer as data controller, DPO contact details if applicable
3. Categories of Personal Data: Comprehensive list of personal data types collected and processed about employees
4. Purposes of Processing: Detailed explanation of why the employer processes employee personal data
5. Legal Bases for Processing: Explanation of the legal grounds under GDPR for processing employee data
6. Data Recipients and Transfers: Information about who receives employee data and any international transfers
7. Retention Periods: How long different types of employee data are kept
8. Employee Rights: Explanation of GDPR rights and how employees can exercise them
9. Security Measures: Overview of measures to protect employee data
10. Updates to this Notice: Information about how changes to the notice will be communicated
1. Automated Decision Making: Required if the employer uses automated decision-making or profiling for employee data
2. Specific Processing Activities: Detailed sections on specific types of monitoring or processing (e.g., CCTV, vehicle tracking, electronic communications monitoring)
3. International Operations: Additional section for companies with international operations detailing cross-border data flows
4. Works Council Information: Section addressing specific arrangements agreed with works councils or union representatives
5. Bring Your Own Device Policy: Section needed if employees are allowed to use personal devices for work
6. Covid-19 Related Processing: Special section for pandemic-related data processing if still relevant
1. Data Processing Inventory: Detailed table of data categories, purposes, retention periods, and legal bases
2. Security Procedures: Detailed information about specific security measures and protocols
3. Third Party Processors: List of main data processors and categories of processing activities
4. Cookie Policy: If relevant, detailed information about workplace technology monitoring and cookies
5. Contact Information: Detailed contact information for privacy-related queries, including DPO, HR, and relevant authorities
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