Insulation for a better tomorrow

 Data protection information to our employees

Data protection information to our employees

 

Processing of employee data

 

We are committed to protect your personal data and comply with applicable data protection law, in particular the EU General Data Protection Regulation ("GDPR") and we only process your personal data on the basis of a statutory provision, your employment contract, or our legitimate interests, or if you have declared your consent.

 

In this data protection notice, we explain which information (including personal data) are processed by us in connection with your employment relationship.

 

I. Who is responsible for the processing of personal data?

 

The controller responsible for the processing of your personal data is URSA UK Ltd, Crest House, 102-104 Church Road, Teddington, TW11 8PY, as your employer. Therefore, any reference to "we" or "us" in this data protection information is a reference to the aforementioned entity.

 

Our data protection coordinator may be contacted via the aforementioned means or via privacy@ursa.com.

 

II. Which data do we process?

 

The performance of your employment relationship requires the processing of personal data:

  1. Basic data: We process certain general data in relation to your person and your employment relationship with us, collectively "basic data". Basic data include

    a) any information provided by you in the course of the recruitment process or that we requested from you (e.g., gender treatment, name, surname, address, telephone number, email address, date of birth, marital status, nationality, national identity card/ passport number, tax identification number, social security number, and information on your education and previous employment; and

    b) any information stored in connection with our hiring decision (in particular the details of your employment agreement and information on your position and seniority within our organization).

  2. Performance data: We process personal data collected in the course of your employment other than by merely updating your basic data and that we refer to as "performance data". Performance data include

    a) Information on the performance of your employee tasks, such as your work / absence times, skills, and the assessment of your performance, if applicable;

    b) Information on our performance of the employment relationship, such as our payments to you or other benefits or compensation, banking data, contribution bases, or taxes or contributions paid or payable on your behalf;

    c) Personal data provided to us in the course of your employment, either by you actively or upon our request, or by third parties (in particular public bodies such as social insurance bodies or (tax) authorities). This may include information on sick leave, pregnancy, the birth of a child, maternity leave, disabilities, a marriage or comparable changes of marital status.

  3. Usage data: We process personal data collected in the course of your employment due to your use of our company infrastructure. Usage data include

    a) Information regarding your use of our information technology infrastructure (such as your business email account, internet access, landline and mobile services –data and voice-, or other applications, programs or devices provided to you); and

    b) Information on your use of other company infrastructure such as infrastructure collecting user data when accessed by an employee, like connected machines or time management applications.

  4. The aforementioned categories of data may include special categories of personal data in the sense of Article 9.1 GDPR, in particular

    a) Health data (e.g., the information on your inability to work due to illness, or whenever there is a claim under the insurance policies contracted to insure the employees;

    b) Trade union membership data (only whenever this information is provided by you); and

    c) Biometric data –photographs- (only whenever they are provided by you).

 

III. For which purposes and on which legal basis do we process your personal data?

 

  1. We process basic, performance and usage data for the performance of your employment relationship with us on the basis of Article 6.1(b) GDPR.
  2. We may process basic, performance and usage data also for compliance with legal obligations to which we are subject; this processing is based on Article 6.1(c) GDPR. Legal obligations may in particular include the mandatory disclosure of personal data to social insurance bodies and (tax) authorities, together with general retention mandatory provisions.
  3. To the extent necessary, we process personal data (in addition to the processing for the purposes of the employment relationship or to comply with legal obligations) for the purposes of our justified interests or the justified interests of a third party on the basis of Article 6.1(f) GDPR. Justified interest may include

    a) group-wide processes for internal administration of employee data;

    b) the establishment of or defence against legal claims;

    c) the prevention and investigation of criminal offences;

    d) maintenance of security for our information technology systems;

    e) the maintenance of security of our premises and infrastructure;

    f)  management and further development of our business operations including risk management;

    g) costs and headcount control within the Human Resources Department;

    h) filling of vacancies, promotion of employees or management of geographical and functional mobility;

    i)  to obtain subsidies and subsidized financing of the available Public Aid Lines; and

    j)  recruitment and career development processes.

  4. If the categories of data specified in section II above contain special categories of personal data (e.g. health data, trade union membership, biometric data), we process these data either for carrying out the obligations in the field of employment and social security and social protection law on the basis of Article 9.2(b) GDPR; on the basis of your making the data manifestly public according to Article 9.2.(e) GDPR; or for the establishment, exercise or defense of legal claims on the basis of Article 9.2(f) GDPR.
  5. If we provide – during the recruitment process or in the course of the employment – the option to declare a consent in the processing of personal data, we process the personal data covered by your consent for the purposes specified in such consent on the basis of Article 6.1(a) GDPR. If the consent refers to special categories of personal data (such as health data), the processing is based on Article 9.2(a) GDPR.

    Please note that

    • the declaration of your consent is always voluntarily, and neither the declaration of consent nor a later withdrawal of consent has negative consequences for the performance of your employment relationship;
    • ­that failure to declare consent or the withdrawal of a consent may, nevertheless, have consequences, and we will inform you about such consequences before you are given the option to declare your consent;
    • ­you may withdraw your consent at any time with effect for the future, e.g. by providing notice to us via mail, email using the contact information specified on the first page of this data protection notice.

 

IV. Are you obliged to provide data?

 

The provision of the basic, performance and usage data specified in section II above is necessary for entering into and maintaining an employment relationship with us, unless specified otherwise before or at collection of the data. Without the provision of these data, were are not able to enter into and maintain an employment relationship with you.

 

If we collect additional data from you, we will inform you if the provision of such information is based on a legal or contractual obligation or necessary for the performance of an agreement (in particular your employment agreement). We usually indicate which information may be provided voluntarily and is neither based on a legal or contractual obligation nor necessary for the purposes of an agreement.

 

V. Who obtains or has access to your data?

 

Your personal data are generally processed within our company. Depending on the categories of personal data, only dedicated departments / organizational units are granted access to your personal data. Such units include in particular the HR department, your managers, the Legal department in case of establishment of or defence against legal claims, and – if data are processed via our IT infrastructure – also our IT department. Based on a role / rights management concept, access to personal data is limited to the functions and the extent necessary for the respective purpose of the processing.

 

If and to the extent permitted by law, we may transfer your personal data to recipients outside of our company. Such external recipients may include

 

  • affiliated companies within Xella group, to which we may transfer personal data for internal administration of employee data;
  • ­service providers that – on the basis of separate agreements with us – provide certain services possibly including the processing of personal data, as well as approved subcontractors of our service providers;
  • ­private or public bodies, to the extent we are obliged to transfer your personal data on the basis of a legal obligation to which we are subject; and
  • ­business partners, to the extent the transfer of personal data (e.g. your business contact details) is necessary for the performance of your employment relationshwip with us.

 

VI. Do we use automated decision-making?

 

In the course of the recruitment process and the employment relationship we do not use automated decision-making (including profiling) within the meaning of Article 22 GDPR. If we apply such processes in the future, we will inform you separately in accordance with the applicable statutory provisions.

 

VII. Are data transferred to countries outside the EU / the EEA?

 

Generally your personal data are processed only within the European Union or the European Economic Area; we do not intend to transfer your personal data to other countries ("third countries") except for testing of applications and maintenance of the servers of the external service provider dealing with your payroll.

 

In those exceptional cases where we transfer your personal data also to "third countries", those countries do not necessarily ensure an adequate level of data protection comparable to the level in the European Union.

 

Prior to such third country transfer, we apply appropriate safeguards to ensure the necessary level of data protection at the recipient or in the recipient's country. Appropriate safeguards may, in particular, consist in an adequacy decision in which the European Commission has decided that the country ensures an adequate level of protection. Alternatively, we may transfer personal data on the basis of the EU Model Clauses or – in case of recipients in the U.S – its adherence to the "EU US Privacy Shield" principles.

 

We provide additional information on the appropriate or suitable safeguards upon request; our contact information can be found on the first page of this data protection notice. Information on the participants in the EU US Privacy Shield can also be found here www.privacyshield.gov/list.

 

VIII. How long are your data stored?

 

We generally store your personal data as long as we have a justified interest in the retention of such data and there your interests in refraining from the further processing do not prevail.

 

Even without a justified interest, we may continue to store the data if there is a legal obligation (e.g. to comply with statutory retention obligations). We delete your personal data even without an action from your side as soon as further retention is no longer necessary for the purposes for which the data were collected or otherwise processed or if further retention is not permitted by law otherwise.

 

In general, your basic data and the additional data collected in the course of your employment are retained at least until the end of your employment. The data are deleted in any case if the purposes for the collection or processing were achieved. This point in time may be after the end of your employment relationship with us. If personal data need to be stored to comply with a legal obligation, such data is retained until the end of the respective retention period. If personal data are only processed to comply with a statutory retention obligation, the access to such data is usually restricted so that the data are only accessible if needed for the purpose of the retention obligation.

 

IX. What are your rights as a data subject?

 

As a data subject, you may

  • request access to your personal data, Article 15 GDPR;
  • ­request the rectification of incorrect personal data, Article 16 GDPR;
  • ­request the erasure of your personal data, Article 17 GDPR;
  • ­request the restriction of the processing of your personal data, Article 18 GDPR;
  • ­exercise your right to data portability, Article 20 GDPR;
  • ­object the processing of your personal data, Article 21 DSGVO.

 

The aforementioned rights may be asserted against us, e.g. by providing notice to us via the contact details specified on the first page of this data protection notice.

 

In case of further questions, you may also get in touch with our data protection coordinator.

 

In addition, you are entitled to lodge a complaint regarding the handling of your personal data with the competent supervisory authority, Article 77 GDPR.