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1. Introduction

This Employee Privacy Notice ("Notice") applies to the Hitachi ABB Power Grids Group of companies, which means Hitachi ABB Power Grids Ltd and its subsidiary companies. The Hitachi ABB Power Grids company that is your employer (referred to as "Hitachi ABB Power Grids" or "we") is responsible for the processing of your personal data and controls how it is used, in accordance with this Notice.

At Hitachi ABB Power Grids respecting your data protection rights is a top priority. This Notice explains how we use personal data about you and what rights you have regarding your personal data.

2. Who is responsible for the processing of your personal data?

Hitachi ABB Power Grids Ltd and its subsidiary companies are responsible for your personal data. For applicable privacy and data protection laws, the primary controller of your data is the Hitachi ABB Power Grids subsidiary company which is your current (or former) employer. Other subsidiary companies of Hitachi ABB Power Grids may also receive and process your personal data, either in the capacity of controller or processor, and this Notice applies equally to them.

3. The types of information we collect and use?

We collect and use personal data that concerns you in connection with your employment at Hitachi ABB Power Grids. We may collect the following categories of personal data:

  • Personal details and identification data such as name, personal and business address, personal and business telephone number, personal and business email address or any other contact details, date and country of birth.

  • Personal data related to family and social circumstances such as gender, age, marital and family status (including also the name and contact details of the next of kin).

  • Employment related personal data such as employee number, signature, employment status, social security and tax numbers, insurance number, country of residence, nationality, photo, emergency contacts and passport information, work and residence permit, immigration status and travel visa information.

  • Qualifications such as qualifications and certifications including current and previous positions, education and training courses, resume/CV, records of education and work achievements, in some cases: contact details of referees and results of capability assessments and interview assessment/feedback.

  • Job information and work metrics such as position, title, employment contract, payroll ID, line manager, job band, performance history, employment status, leave of absence information, working time logging, training records, performance targets and development goals. In some cases, we may also record results of capability assessments, safety reports and incidents, professional feedback.

  • Compensation, allowances, benefits and expense related information such as salary data, payroll data, pension plan number and contributions, non-salary benefits, bonus, compensation, share options, dependents, beneficiaries or health benefit nomination, bank statements, expense claims and receipts, bank account details, credit card data, phone expenses and insurance data.

  • Electronic identification data and information (where employee has access or is affected by such systems or applications) such as access logs, IT and internet usage, device identifiers (mobile device ID, PC ID etc.), registration and login credentials, IP address, tracking and analytics data, recordings (e.g. voice mail/call recordings), posts on corporate platforms (e.g. Yammer), password recovery data, information obtained via IT security tools.

  • Financial and other details such as account information, credit checks, payment details and transactions, investigation information and disciplinary history.

  • Other personal data (which may include special categories of information as mentioned below) namely where you or others (such as your colleagues) may register these data on or in our systems, programs and application such as business documents containing personal information (e.g. queries, questions, complaints, orders and related records; emails; reports; contracts; presentations, minutes; work products), photos, images and/or videos.

The below mentioned types of personal data are only collected and processed, if at all, in accordance with applicable local laws in your country of residence.

  • Special categories of personal data such as:

    • membership of religious congregations (e.g. if required for tax purposes);

    • health and medical information, including disability status, special working conditions (such as use of a standing desk) and medical devices needed on the premises, work related injury and illness information, data for travel emergency support (blood typemedical history, allergies);

    • race or ethnicity (e.g. where this is used for diversity purposes);

    • in some cases: trade union membership, political opinions and sex life or sexual orientation (e.g. where this is used for investigations of non-equal treatment).

  • Data about criminal convictions and offences such as criminal background information and sanction list information to the extent required for the purposes of criminal background screening and Know Your Customer (“KYC”) and Anti Money Laundering (“AML”) obligations.

  • To the extent necessary to fulfil our obligations, data obtained from publicly accessible sources or which are legitimately transmitted by other third parties (e.g. a credit agency) such as data in public professional social media (e.g. LinkedIn), background check data.

In case you would like to be provided with information about a specific personal data processing activity, you can request that by submitting a request at www.hitachiabb-powergrids.com/privacy.

4. Why we use your personal data?

We may use your personal data as listed above for the following purposes:

  • human resources management including organization and personal administration, working hours management, improving and maintaining effective staff administration, internal workforce analysis, reporting and planning;

  • staff transfer management from different affiliates and succession planning;

  • payroll, compensation and benefits management including providing staff benefits and maintaining salary, compensations including intellectual property, allowances, benefits, insurances, pensions and performance reviews;

  • talent management and acquisition including recruitment, assessing suitability and working capacity, background checks and verification of qualifications, obtaining and providing references;

  • learning and development management including certifications, training staff and performing assessments and employee satisfaction surveys;

  • processes related to joining and leaving including internal moves and terminations;

  • sickness and other leave and vacations management;

  • internal health and safety programs including health and safety and accident records or reporting and managing process quality;

  • travel and expenses management and organization of business trips including monitoring of travelers to provide support during security or medical emergencies; providing travel security, health and safety training and on a voluntary basis assistance in giving security support during emergencies;

  • carrying out the obligations and exercising specific rights in the field of employment and social security law or a collective agreement;

  • internal and external communication of Hitachi ABB Power Grids' organization and representation of Hitachi ABB Power Grids including commercial register and assigning powers of attorney;

  • organizing Hitachi ABB Power Grids events and documentation of such events including managing and organizing internal non-marketing related campaigns, events and meetings;

  • managing Hitachi ABB Power Grids assets including pictures and videos depicting employees or other individuals available for download on our  intranet, website, etc.;

  • finance and shared accounting services providing record to report, order to cash and purchase to pay services;

  • reorganization, acquisition and sale of activities, business units and companies;

  • business reporting, statistics and analytics;

  • monitoring and auditing compliance of employees’ activities in the workplace with Hitachi ABB Power Grids' corporate policies, contractual obligations and legal requirements including disciplinary actions;

  • carrying out audits, reviews and regulatory checks to meet obligations to regulators;

  • governance, risk and compliance, including compliance with laws, law enforcement, court and regulatory bodies’ requirements (such as for the process of verifying the identity of customers, called as Know Your Customer ("KYC")/ Anti Money Laundering ("AML") monitoring purposes), customs and global trade compliance, conflict of interest and security obligations) and prevention, detection, investigation and remediation of crime and fraud or prohibited activities or to otherwise protect legal rights and to establish, exercise or defend legal claims;

  • managing the customer relationship, processing customer orders and providing customer support, processing, evaluating and responding to requests and inquiries;

  • managing the suppliers, contractors, advisers and other professional experts including contact interaction, processing and fulfilling purchases and invoices, and contract lifecycle management;

  • making use of work performance and products and for references on documents, such as drawings, purchase orders, sales orders, invoices, reports;

  • access control system providing electronically controlled ingress and/or egress for authorized individuals to locations that have access restrictions and a registry of personnel on site in case of emergencies;

  • intrusion detection including 3rd party monitoring of duress, perimeter, internal security points and ancillary supervisory monitors for site maintenance/automated systems;

  • maintaining and protecting the security of products, facilities, services, systems, networks, computers and information, preventing and detecting security threats, fraud or other criminal or malicious activities, and ensuring business continuity; and

  • managing IT resources, including infrastructure management including data back-up, information systems’ support and service operations for application management, end user support, testing, maintenance, security (incident response, risk, vulnerability, breach response), master data and workplace including user accounts management, software licenses assignment, security and performance testing and business continuity.

We collect only the personal data from you that we need for the purposes described above. Certain personal data collected from you relates to your next of kin and emergency contacts. In these cases, you are requested to inform such persons about this Notice.

In case you are working at a third-party site (for example Hitachi ABB Power Grids customer location or facility), such third party may need to process your personal data for their purposes acting as a data controller. In these cases, you will receive or may request a separate privacy notice from the relevant data controller.

What happens if you do not provide us with the information we have requested?

Where it concerns processing operations related to your employment (as described above), Hitachi ABB Power Grids will not be able to adequately employ you without certain personal data and you may not be able to exercise your employee rights if you do not provide the personal data requested. Although we cannot mandate you to share your personal data with us, please note that this then may have consequences which could affect your employment in a negative manner, such as not being able to exercise your statutory rights or even to continue your employment. Whenever you are asked to provide us with any personal data related to you, we will indicate which personal data is required, and which personal data may be provided voluntarily.

5. The legal basis we rely on

For the use of your personal data for the purposes described above (in section 4), we rely on the following legal basis, as applicable:

  • We process your personal data for the fulfilment of obligations in your employment contract with us and similar collective employment agreements, or as part of pre-contractual measures to establish employment and related contracts;

  • In some cases, we rely on our legitimate interests to process your personal data insofar as this is not overridden by your own privacy interests. Such interests may include:

    • monitoring (for example through IT systems), investigating and ensuring compliance with legal, regulatory, standard and Hitachi ABB Power Grids internal requirements and policies;

    • prevention of fraud and criminal activity including investigations of such activity, misuse of Hitachi ABB Power Grids assets, products and services, and as strictly necessary and proportionate for ensuring network and information security; and

    • transmitting personal data within the Hitachi ABB Power Grids group for internal administrative purposes as necessary, for example to provide centralized services.

You may obtain a copy of our assessment regarding our legitimate interest to process your personal data by submitting a request at www.hitachiabb-powergrids.com/privacy.

  • In some cases, we process your personal data on the basis of statutory requirements, for example, on the basis of labor and social security law, allowances, tax or reporting obligations, cooperation obligations with authorities or statutory retention periods in order to carry out our contractual responsibilities as an employer;

  • In exceptional circumstances we may ask your consent at the time of collecting the personal data, for example photos, communications materials and events. If we ask you for consent in order to use your personal data for a particular purpose, we will remind you that you are free to withdraw your consent at any time and we will tell you how you can do this.

With regard to special categories of personal data we will only process such data in accordance with applicable law and:

  • with your explicit consent for specific activities in accordance with applicable law;

  • when necessary for exercising rights based on employment, social security or social protection law or as authorized by collective agreement, or for preventive and occupational medicine or and evaluation of working abilities; or

  • where necessary for establishment, exercise and defense of legal claims.

  • With regard to personal data concerning criminal convictions and offences, we will only process such data where such processing is permitted by applicable (local) law.

6. Parties we share your personal data with (in and outside the EU and EEA or outside the country where your employer is located)

We only share your personal data with other Hitachi ABB Power Grids affiliates or third parties as necessary for the purposes described in the table below. Where we share your personal data with an affiliate or third party so that it transfers to or becomes accessible from outside the European Union (“EU”) and European Economic Area ("EEA") or outside the country where your employer is located, we always put adequate safeguards in place to protect your personal data. Examples of these safeguards are an adequacy decision of the European Commission (read more here), Standard Contractual Clauses (read more here), and the Binding Corporate Rules that some of our suppliers have adopted (read more here). We have taken additional measures for the transfer of data from within to outside the EU, EEA and outside the country where your employer is located to protect your personal data. If you would like an overview of the safeguards which are in place, please submit a request at www.hitachiabb-powergrids.com/privacy.

Recipient category

Recipient location

Purposes

Hitachi ABB Power Grids affiliates and subsidiaries

See the list of Hitachi ABB Power Grids subsidiaries

The purposes described in section 4, including human resource management, talent management and organizing internal trainings and events.

Hitachi ABB Power Grids customers, distributors, agents and other business partners

EU/EEA and non-EU/EEA (global)

The purposes described in section 4, including project placements, carrying out audits, reviews and regulatory checks, customer relationship management and travel and expense management.

Service providers

EU/EEA and non-EU/EEA (global)

IT services, HR and training, payroll and payment processors, professional and advisory services including accountants, auditors, lawyers, insurers, bankers, recruiters, travel agents and other advisors working on Hitachi ABB Power Grids' behalf.

Pension funds, labor and industry organizations and associations

EU/EEA and non-EU/EEA (global)

The purposes described in section 4.

Potential or actual acquirers of Hitachi ABB Power Grids businesses or assets

EU/EEA and non-EU/EEA (global)

For the evaluation of the business or assets in question or for the purposes described in section 4.

Recipients as required by applicable law or legal process, to law enforcement or government authorities, etc.

EU/EEA and non-EU/EEA (global)

Where required by applicable law or a legitimate request by government authorities, or a valid legal requirement.

You may obtain a copy of the safeguards which we use to protect your personal data by submitting a request at www.hitachiabb-powergrids.com/privacy.

7. How long do we process and keep your personal data?

Based on mandatory legislation, Hitachi ABB Power Grids must keep certain personal data for a minimum period of time. For example, employment contracts, information about salary payments and reimbursements need to be kept for a minimum period based on local corporate and tax legislation.

At the same time, applicable data protection laws require that we do not keep personal data in an identifiable form for any longer than is necessary for the purpose for which the personal data is being processed. Through the setting of IT applications and policies we ensure that your personal data is deleted when we no longer need it.

The retention periods for the information that we hold can be found in our Records Management Directive GD/LI-44 or your local records management directive. After an applicable retention period has lapsed, we will securely delete or anonymize your personal data, unless there are specific circumstances that require us to keep such personal data, such as legal or regulatory obligations or to resolve potential disputes.

For more information regarding specific retention periods that apply to your personal data, please submit a request at www.hitachiabb-powergrids.com/privacy.

8. Security and monitoring of Hitachi ABB Power Grids systems and sites

Hitachi ABB Power Grids takes the security of its data very seriously, including your information and Hitachi ABB Power Grids' digital business assets.Hitachi ABB Power Grids sees this as a shared responsibility, where it takes the necessary steps to secure such data, and where it expects its staff members to do the same. You can read more about our security measures and your responsibilities End User Security Policy.

Monitoring of Hitachi ABB Power Grids' systems 

For business reasons, and in order to maintain IT security measures, information about the use of Hitachi ABB Power Grids' systems including telephone (mobile and fixed) and computer systems (including email and internet access), and any personal use of them, is collected and monitored, and used when necessary for the security of Hitachi ABB Power Grids’ system and compliance with Hitachi ABB Power Grids security group policies and in accordance with the applicable law. If you access services by the use of passwords and login names on Hitachi ABB Power Grids' IT and communication systems, this might mean that your access details can be seen by Hitachi ABB Power Grids.

Monitoring is only carried out if and to the extent permitted or as required by law and as necessary and justifiable for business purposes. The resulting log files will be kept for a minimum period in accordance with section 7. This is required so that instances of attempted misuse and other security events can be detected, and that information is available to support any subsequent investigation and follow up actions. To the extent permitted by law and internal policies, action may be taken under the disciplinary procedure.

If necessary such information may be handed to the police or other law enforcement agencies. Investigations and disclosure of information to the relevant authorities shall be carried out only to the extent permitted by law.

9. Which data protection rights do you have with regards to your personal data?

You are entitled to certain rights where in concerns information regarding you.

Data protection rights

What it means

The right to access your data

You are entitled to ask Hitachi ABB Power Grids for an overview of or to obtain a copy of the personal data we hold about you.

The right to have your data corrected

You may request immediate correction of inaccurate or incomplete personal data we hold about you.

The right to have your data erased

You may request that personal data be erased when it is no longer needed, where applicable law obliges us to delete the data or the processing of it is unlawful.

The right to restrict data processing

You have the right to restrict the processing of your personal data in specific circumstances.

The right to data portability

You have the right to receive your personal data in a structured, machine-readable format for your own purposes, or to request us to transfer it to a third party.

The right to object to data processing

You have the right to object to our processing of your personal data where we rely on our legitimate interests as the basis for our processing, where your data protection rights outweigh our reasoning for legitimate interests.

The right to withdraw consent

Where Hitachi ABB Power Grids has asked for your consent to process personal data, you may withdraw your consent at any time.

Please note that the rights described above are not absolute, and that your request cannot always be met entirely. If you want to know more about your data protection rights as well as  the conditions and restrictions under which they are available to you, you may want to refer to the Annex to this Notice.  

You may request to enforce any of your data protection rights at www.hitachiabb-powergrids.com/privacy

10. Contact and further information 

If you want to access your personal data, make use of any of your other rights mentioned above or if you have any questions or concerns about how Hitachi ABB Power Grids processes your personal data, please contact our Group Data Protection Officer at privacy@hitachi-powergrids.com, or submit your complaint at www.hitachiabb-powergrids.com/privacy.  

Should you not be satisfied with our response or believe we are processing your personal data against the law, you have the right to file a complaint with the Data Protection Authority in your country of residence or work, or seek a remedy through the courts where you believe an infringement of data protection laws (and your rights) may have taken place.  

 Date of publication: July 1, 2020