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Employee Privacy Notice

Employee Privacy Notice Template for Belgium

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Key Requirements PROMPT example:

Employee Privacy Notice

"I need an Employee Privacy Notice for our Belgian technology startup that processes employee biometric data and uses AI-powered performance monitoring tools, with implementation planned for March 2025."

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Document background
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.
Suggested Sections

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

Optional Sections

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

Suggested Schedules

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

Authors

Alex Denne

Head of Growth (Open Source Law) @ Genie AI | 3 x UCL-Certified in Contract Law & Drafting | 4+ Years Managing 1M+ Legal Documents | Serial Founder & Legal AI Author

Linkedin in social icon imageX social icon image
alex.den.21@genieai.co
Relevant legal definitions
Personal Data
Processing
Data Controller
Data Processor
Data Subject
Special Categories of Personal Data
Data Protection Officer (DPO)
Consent
Legitimate Interest
Data Protection Impact Assessment
Third Party
Recipient
International Transfer
Supervisory Authority
Belgian Data Protection Authority
Works Council
Filing System
Pseudonymization
Data Minimization
Privacy by Design
Privacy by Default
Employee
Workplace Monitoring
Electronic Communications
Biometric Data
CCTV
Access Logs
Data Breach
Retention Period
Right of Access
Right to Rectification
Right to Erasure
Right to Object
Automated Decision-Making
Profiling
Joint Controller
Sub-Processor
Privacy Notice
CLA (Collective Labour Agreement)
Data Protection Laws
Clauses
Data Controller Information
Scope of Processing
Categories of Personal Data
Legal Basis for Processing
Data Collection Methods
Workplace Monitoring
International Transfers
Data Security
Data Retention
Employee Rights
Data Sharing
Automated Decision Making
Cookie Usage
CCTV Surveillance
Access Control Systems
Communication Monitoring
Data Protection Officer
Complaint Procedures
Updates and Amendments
Contact Information
Consent Management
Third Party Processing
Data Breach Procedures
Special Category Data Processing
Record Keeping
Training and Awareness
Works Council Consultation
Regulatory Compliance
Cross-Border Data Flows
Device Management
Relevant Industries

Technology

Manufacturing

Financial Services

Healthcare

Retail

Professional Services

Education

Transportation

Construction

Energy

Telecommunications

Public Sector

Non-Profit

Media and Entertainment

Real Estate

Hospitality

Relevant Teams

Human Resources

Legal

Compliance

Information Technology

Information Security

Data Protection

Risk Management

Internal Audit

Employee Relations

Training and Development

Relevant Roles

HR Director

Privacy Officer

Data Protection Officer

Legal Counsel

Compliance Manager

HR Manager

IT Security Manager

Employee Relations Manager

Recruitment Manager

Payroll Manager

Benefits Administrator

HR Business Partner

Chief Privacy Officer

General Counsel

Chief Human Resources Officer

HR Operations Manager

Industries
GDPR: General Data Protection Regulation (EU) 2016/679 - The primary legislation governing personal data processing in the EU, including employee data
Belgian Data Protection Act: Law of 30 July 2018 on the protection of natural persons with regard to the processing of personal data - Belgian implementation of GDPR
Belgian Employment Contracts Act: Law of 3 July 1978 on employment contracts - Contains provisions about employee rights and employer obligations, including privacy-related aspects
Act on Well-being of Workers: Law of 4 August 1996 on well-being of workers - Includes provisions on psychosocial risks and workplace surveillance
CLA No. 81: Collective Labour Agreement No. 81 on monitoring electronic online communications data - Specific rules about employee monitoring and privacy
CLA No. 68: Collective Labour Agreement No. 68 on camera surveillance at work - Regulates the use of cameras in the workplace
Belgian Social Criminal Code: Contains provisions on enforcement and penalties for violations of employee privacy rights
ePrivacy Directive Implementation: Belgian telecommunications law implementing EU ePrivacy Directive - Relevant for electronic communications monitoring
Teams

Employer, Employee, Start Date, Job Title, Department, Location, Probationary Period, Notice Period, Salary, Overtime, Vacation Pay, Statutory Holidays, Benefits, Bonus, Expenses, Working Hours, Rest Breaks,  Leaves of Absence, Confidentiality, Intellectual Property, Non-Solicitation, Non-Competition, Code of Conduct, Termination,  Severance Pay, Governing Law, Entire Agreemen

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