The Employee Privacy Notice is a mandatory document for organizations operating in Switzerland that process employee personal data. It is required under the Swiss Federal Act on Data Protection (FADP/nFADP) and must be provided to employees at the time of data collection or employment commencement. The notice ensures transparency in data processing activities and helps organizations comply with their legal obligations regarding employee privacy. It should be updated whenever significant changes occur in data processing practices or relevant legislation. The document is particularly important given Switzerland's strict data protection requirements and the potential applicability of the GDPR for organizations with EU connections. The notice must be clear, concise, and easily accessible to all employees, covering all aspects of personal data processing in the employment context.
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1. Introduction: Overview of the notice's purpose and scope, including identification of the data controller (employer)
2. Types of Personal Data Processed: Comprehensive list of personal data categories collected and processed about employees
3. Purposes of Processing: Detailed explanation of why personal data is collected and how it will be used
4. Legal Bases for Processing: Explanation of the legal grounds under Swiss law for processing personal data
5. Data Retention: Information about how long different types of personal data will be retained
6. Data Security: Description of measures taken to protect employee personal data
7. Employee Rights: Explanation of employees' rights regarding their personal data, including access, rectification, and deletion
8. Data Sharing: Information about third parties with whom employee data is shared
9. Contact Information: Details of who to contact for privacy-related queries or concerns
1. International Data Transfers: Required if employee data is transferred outside Switzerland, detailing transfer mechanisms and safeguards
2. Automated Decision Making: Required if the employer uses automated processing to make decisions about employees
3. Video Surveillance: Required if workplace video monitoring is in place
4. Special Categories of Data: Required if processing sensitive personal data such as health information or biometric data
5. Employee Monitoring: Required if implementing specific monitoring of employee activities (e.g., IT systems, vehicles)
6. Data Protection Impact Assessments: Required if conducting high-risk processing activities
1. Data Processing Activities Register: Detailed inventory of specific data processing activities and their purposes
2. Third Party Processors List: List of approved data processors and their contact details
3. Retention Schedule: Detailed retention periods for different categories of employee data
4. Security Measures: Technical and organizational measures implemented to protect personal data
5. Employee Privacy Rights Request Form: Template form for employees to exercise their privacy rights
6. Incident Response Procedure: Procedures to follow in case of a data breach affecting employee data
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