Employee Privacy Policy

Employee Privacy Statement

Last Updated February 20, 2019

Cygnacom Solutions (“Cygnacom”) values its commitment to protecting and respecting your privacy. This Employee Privacy Statement sets forth how we will use any personal data we collect or that you provide to us as an employee, consultant, independent contractor, intern or temporary worker.

Personal data is information that identifies you personally, either alone or in combination with other information available to us (e.g., your name or email address). More detail about the types of personal data we collect for employment purposes (“Employment Information”) is set forth below.

What Personal Data Does Cygnacom Collect for Employment Purposes?

Information you provide to us

We may collect the following personal data from you for employment purposes:

  • Your name, address and contact details, including email address and telephone number, date of birth, nationality, gender;
  • Details of your qualifications, skills, experience and employment history, including start and end dates with previous employers and with EDC;
  • Your photograph for purposes of issuing you a security badge;
  • Your fingerprint for purposes of access control (not at all locations);
  • The terms and conditions of your employment;
  • Information about your entitlement to work;
  • Information about your remuneration, including benefit entitlements;
  • Bank account information to issue your paycheck via direct deposit;
  • Social security number or tax identification number;
  • Information about your marital status, next of kin, dependents and emergency contacts;
  • Details of your schedule (days of work and working hours), work location, and attendance at work;
  • Details of periods of leave taken by you, including holidays, sick leave, family leave, and sabbaticals;
  • Details of any disciplinary or grievance procedures in which you have been involved, including any disciplinary action issued to you and related correspondence;
  • Employment administration information including performance assessments, reviews and ratings, training records, performance improvement plans, termination details and related correspondence;
  • Details of your whereabouts while at Cygnacom locations through electronic card access and video monitoring systems;
  • Details of your use of Cygnacom assets, including computers, telephones, and mobile phones, user IDs and passwords;
  • Information about your travel for Cygnacom business;
  • Information about expenses you incur for which you seek reimbursement from Cygnacom;
  • Information about your residential, travel, family, and relationship history; your relationships, if any, to foreign governments or terrorist organizations; your financial debts and criminal record; diseases that may affect your ability to exercise control, addictions, and your consumption of alcohol or drugs (where needed to secure government security clearances).

Depending on local law, we may also collect and process the following “special categories” of “sensitive personal data”:

  • Information about medical or health conditions, and whether or not you have a disability for which the organization needs to make reasonable accommodations during the length of your employment;
  • Equal opportunity monitoring information, including information about your ethnic origin, sexual orientation and religion or belief;
  • Information about your financial credit history and criminal record;
  • In the United States, and depending on your role, you may be required to undergo drug screening and provide Cygnacom with your fingerprints.

Cygnacom may collect this information directly from you through application forms, CVs or resumes, passport or other identity documents such as your driver’s license, forms completed by you at the start of or during your employment (such as benefit nomination forms), correspondence with you or through interviews, meetings or other assessments.

Information we collect

Cygnacom may also collect personal data about you from third parties such as former employers and employment background check providers, depending on local law. Before we conduct these checks, we will inform you that we are doing so and let you know what information will be collected, from whom the information will be collected, and what we will do with the information.

How Do We Use the Employment Information We Collect?

We need to process Employment Information in order to enter into and meet our obligations under an employment contract with you. For example, to pay you in accordance with your employment contract and to administer employee benefits, pension and insurance entitlements.

In some cases, we need to process Employment Information to ensure we comply with our legal obligations. For example, we are required to check an employee’s entitlement to work, to deduct taxes, to comply with health and safety laws and to enable employees to take periods of leave to which they are entitled.

In other cases, Cygnacom has a legitimate interest in processing Employment Information before, during and after the employment relationship has concluded for one or more of the purposes set forth below:

  • To maintain accurate and up-to-date employment records and contact details (including details of who to contact in the event of an emergency) for effective workforce management;
  • To maintain records of employee benefits, contractual and statutory rights for effective workforce management;
  • To maintain records of absences for absence management procedures;
  • To maintain records of other types of leave (including maternity, paternity, adoption, parental and shared parental leave) for effective workforce management and to ensure that the organization complies with its duties in relation to leave entitlement;
  • To maintain records of filed grievances and to record disciplinary actions taken to ensure acceptable conduct within the workplace;
  • For career development and succession planning purposes;
  • To ensure employees receive the pay or other benefits to which they are entitled;
  • To determine whether an individual’s criminal record may impact their ability to perform duties within a role;
  • To determine whether an individual has any current financial court judgments that would impact their ability to perform duties within a role;
  • To comply with Cygnacom’s customer security requirements when carrying out contractual obligations;
  • To the extent necessary and proportionate for the purposes of ensuring Cygnacom’s network and information remain secure and protected;
  • To ensure effective general HR and business administration;
  • To provide employment verification on request for current or former employees;
  • To respond to and defend against legal claims.

Employment Information about health or medical conditions that is categorized as “sensitive personal data” is processed to carry out employment, social security and social protection legal obligations such as those in relation to employees with disabilities.

Where Cygnacom processes other sensitive personal data, such as information about ethnic origin, sexual orientation, religion or belief, this is done for the purpose of equal opportunity monitoring. This sensitive personal data is anonymized or is collected with the express consent of employees and consent can be withdrawn at any time. Employees are free to decide whether or not to provide such sensitive personal data and there are no consequences for failure to do so.

Does Cygnacom Share and Disclose Employment Information?

Cygnacom may share and disclose Employment Information in the following limited circumstances:

  • Changes to Cygnacom’s Business. Cygnacom may disclose or transfer Employment Information as part of a company merger, acquisition or sale of all or a portion of Cygnacom assets.
  • Corporate Affiliates. Cygnacom may share Employment Information with other Cygnacom affiliates, including members of Accounting, Human Resources and Talent Acquisition, your line manager, managers in the business area in which you work, and IT staff if access to the Employment Information is necessary for performance of their roles. These Cygnacom affiliates are permitted to use Employment Information in a manner consistent with this Employee Privacy Statement.
  • Third Party Service Providers. Cygnacom may share Employment Information with third party vendors, consultants, or other service providers. These third parties process Employment Information pursuant to Cygnacom’s instructions and solely for the purpose and under the security measures indicated in the agreements we sign with them. These third party vendors may be responsible for pre-employment references and background checks, criminal records checks, financial credit checks, payroll or the provision of benefits and occupational health services.
  • Customers. Depending on your role, Cygnacom may need to share your Employment Information with customers (for example, your previous or current experience and employment details) pursuant to the customer’s request and in order to satisfy their security requirements and Cygnacom’s contractual obligations.
  • Protection of Cygnacom’s rights, prevention of fraud, and compliance with laws. Cygnacom may disclose Employment Information to other interested parties to protect or enforce our rights, or as required by law. Cygnacom may also disclose Employment Information to other interested parties to prevent or investigate a possible crime, such as fraud or identity theft, to protect the security of our business, or to enforce or apply this Employee Privacy Statement.

Cygnacom will never sell, rent or lease your personal data to a third party.

Keep Your Employment Information Accurate

Cygnacom will do its best to maintain accurate and up to date records with respect to Employment Information. Please notify us if your personal details change (e.g., change of address, emergency contact details, emergency contacts, dependents, beneficiaries) or if you become aware of any inaccuracies in the personal data we hold about you.

How Long Do We Retain Employment Information?

Cygnacom will retain Employment Information for as long as necessary for the purpose in which it was collected and subject to local law. Cygnacom may also retain Employment Information as necessary to comply with our legal obligations, resolve disputes, pursue legitimate business interests, conduct audits and protect or enforce our rights.

How Do We Protect Your Employment Information?

Cygnacom uses appropriate technical, organizational and administrative security measures to protect your personal data from loss, misuse, unauthorized access, disclosure, alteration, and destruction. These security measures are designed to provide a level of security appropriate to the risk of processing your personal data.

Storage and International Data Transfers

The personal data that Cygnacom collects from you may be transferred to and/or stored at a destination other than the one in which your personal data was collected. This may be necessary as our organizational structure and management teams are located across a number of offices around the globe. Certain privacy and data protection laws require data controllers to put in place safeguards to protect personal data transferred across borders. To comply with this requirement, Cygnacom has put in place agreements that include the standard contractual clauses recommended by the European Commission to provide adequate safeguards for personal data.

What Rights Do You Have With Respect to Your Employment Information?

Depending upon the applicable data protection law in your country of residency, you may have the right to ask Cygnacom for information relating to personal data about you we control and process; to correct, delete, or restrict any active processing of your personal data; and/or to obtain a copy of your personal data in a structured, machine readable format, and to ask us to share this personal data with another controller.

Additionally, you can object to the processing of your personal data in some circumstances (in particular, where we don’t need to process the information to meet a contractual or other legal requirement). These rights may be limited, for example, if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests to keep (e.g., for purposes of fraud prevention).

If Cygnacom has collected and processed your personal data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data on lawful processing grounds other than consent.

What If You Do Not Provide Employment Information?

If you do not wish to provide Employment Information that we request directly from you or with your consent from third parties, this may prevent Cygnacom from administering rights and obligations arising from the employment relationship appropriately and effectively. If you have any concerns with respect to providing specific information or providing consent for Cygnacom to contact a third party for specific information, please contact Human Resources. HR can provide you more detail about the nature and purpose of the information requested and how your failure to provide the information may impact you.

Amendments to the Employee Privacy Statement

We reserve the right to amend this Employee Privacy Statement from time to time as our business, laws, regulations and industry standards evolve.

Other Notices

This Employee Privacy Statement is not intended to replace other notices provided by Cygnacom in accordance with national and local laws and regulations. In the event of any conflict between this Statement and other notices required by local law, the notices required by local law will prevail. This Employee Privacy Statement applies to the processing of Employment Information by or on behalf of Cygnacom anywhere in the world.

Contact Us

If you have questions or concerns about this Employee Privacy Statement or our handling of your personal data, please contact us using our online form. We will do our best to answer your questions and address your concerns.