The Workforce Privacy Notice is a mandatory document for organizations operating in Switzerland that process employee personal data. It is designed to comply with the Swiss Federal Data Protection Act (FADP/DSG) and related regulations, providing employees with transparent information about how their personal data is handled. This document becomes particularly important in the context of increased digitalization of HR processes and cross-border data transfers. The notice must be provided to employees at the start of their employment and updated when significant changes occur in data processing activities. It serves both as a compliance tool and as a means of building trust with employees by demonstrating commitment to data protection principles.
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1. Introduction: Overview of the privacy notice's purpose and scope, including who it applies to and when it takes effect
2. Definitions: Key terms used throughout the notice, including definitions of personal data, processing, and other relevant terminology
3. Data Controller Information: Identity and contact details of the employer as data controller, including DPO contact information if applicable
4. Categories of Personal Data: Comprehensive list of personal data types collected and processed, including special categories of data
5. Purposes of Processing: Detailed explanation of why personal data is collected and how it will be used
6. Legal Bases for Processing: Legal grounds under Swiss law for processing personal data, including legitimate interests where applicable
7. Data Retention: Information about how long different types of personal data will be retained
8. Data Security: Measures taken to protect personal data and prevent unauthorized access
9. Employee Rights: Explanation of employee rights under Swiss data protection law, including access, rectification, and deletion rights
10. Reporting Procedures: How to raise concerns or make complaints regarding data protection
11. Updates to the Privacy Notice: Process for updating the notice and notifying employees of changes
1. International Data Transfers: Required if personal 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. CCTV and Monitoring: Required if workplace surveillance or monitoring systems are in place
4. Remote Working Data Processing: Required if employees work remotely and specific data processing occurs in this context
5. Special Category Data Processing: Required if processing sensitive personal data such as health information or biometric data
6. Third-Party Data Sharing: Required if employee data is shared with third-party service providers or group companies
1. Data Retention Schedule: Detailed retention periods for different categories of personal data
2. Authorized Third-Party Processors: List of approved third-party processors and purposes of processing
3. Security Measures: Detailed description of technical and organizational security measures
4. Department-Specific Processing Activities: Specific data processing activities by department or role
5. Contact Information: Detailed contact information for data protection queries and complaints
6. Related Policies: List of related workplace policies and procedures affecting data processing
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