Human resources Privacy Policy

September 2010
1. CONSENT TO THIS HUMAN RESOURCES PRIVACY POLICY
You should read this Human Resources Privacy Policy carefully as it provides guidance on the nature of the
Personal Information held by Accor on its employees and applicants and the way Accor uses it.
By “Personal Information” (hereinafter referred to as “
recorded in any format that identifies you personally, whether directly (e.g. name) or
number).
By accepting the terms of Your employment contract with Accor, or by applying within Accor, You expressly
consent to this Human Resources Privacy Policy which is incorporated by reference to Your employment
contract or may, in certain countries, be incorporated to the Internal Regulations of Your Company. You
recognize and accept that this Human Resources Privacy Policy does not grant You any other rights than those
provided by Your local law.
However, when required by local laws, this Human Resources Privacy Policy may be subject to Your prior
consent.
2. ACCOR 7 PRIVACY PRINCIPLES
The following constitute Accor 7 Privacy Principles, which apply throughout the Accor Group worldwide.
1. Transparency: when collecting and processing Your PI, we will provide You with relevant information
and notice, for what purposes and who are the recipients.
2. Legitimacy: we will collect and process Your PI only for the purposes which are mentioned to You in
this Human Resources Privacy Policy.
3. Relevance & Accuracy: we will only collect PI which is necessary for the purposes of the data
processing as set out in this Human Resources Privacy Policy. We will take all reasonable measures to
ensure You that the PI that we have stored is accurate and up to date.
4. Storage: we will keep Your PI for the period necessary for the purposes of the data processing as set
out in this Human Resources Privacy Policy and in accordance with local law requirements.
5. Access & Rectification: we offer You ways to access, modify, correct or delete Your PI. Please see
contact details below.
6. Confidentiality & Security: we will implement reasonable technical and organisational measures to
protect Your PI against accidental or unlawful alteration or loss, or from unauthorized use, disclosure or
access.
7. Sharing & International Transfer: we may share Your PI within the Accor Group or with third parties
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Human ressources Privacy Policy
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(such as commercial partners and service providers) for the purposes described in th
Resources Privacy Policy. We will take appropriate measures to secure such sharing and transfer.
If You have any questions about these Accor 7 Privacy Principles
as described in section 12 of this Human Resources Privacy Policy.
3. SCOPE
This Employee Privacy Policy is applicable to:
All Accor's employees working for an entity of Accor Group, i.e.:
OLICY
” PI”), we understand any information collected and
indirectly (e.g. phone
, al , ul this Human
Principles, please contact Accor Data Privacy Contact
- any employee of any subsidiary, affiliate or other entity controlled by, or under common control with
Accor;
- or any person engaged (directly or indirectly) to perform work for Accor, including as temporary
agency worker, trainee or contractor personnel
Accor’s systems.
Employees of managed and franchised hotels
systems;
Applicants to a job within an entity of the Accor Group.
Collectively herein after referred to “You”.
4.WHAT PERSONAL INFORMATION?
We collect, process and store to the extent it is relevant and permitted under
family and relatives, such as:
Identification data: name, marital name, first name, gender, date and place of birt
information (address, home telephone number, e
of emergency), passport number (for Employees with international mobility), driver’s license number (if
relevant for the job), photos;
Social data: work permit number, social security number, and if any, disability rate;
Family status: marital status, name, first name and date of birth of Y
name and date of birth of the children, insurance informatio
Transportation: any information pertaining to the
reimbursement of traveling expenses, such as transportation cards, vehicle expenses, etc
Extracts of police records: when this is necessary
Military status: military situation, if any;
Education and career development: diplomas and training certificates, foreign languages, curriculum
vitae (detailing Your work experience and if app
management of career development actions, track of annual performance evaluation;
Professional life: fixed-term contract, opentermination
date, division, department, reporting structure,
information, telephone number and e-mail address
sick leave, special leave or absence, maternity leave, paren
time off given in compensation for extra time worked; personnel representative status (such as member
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of the works council or of a trade union);
Economic and financial situation: tax and source tax deductions
compensation elements, stock options plan, purchase option plan, related payments,
contribution, bank account details;
Any PI Accor is required to collect in order to comply with its obligations as an em
law (e.g. trade unions membership, inability rates, etc.);
Your use of Accor’s information system: the conditions in which Y
with respect to Your use of Accor’s System Resources
Policy which is incorporated by reference to Your
internal regulations of Your company;
Video surveillance and badge control data:
premises, and access control devices which enable collection and processing of PI such as image
recordings, access information and time collection information relating to You;
September 2010
Human ressources Privacy Policy
idiary, personnel, to the extent their data is processed by Accor in
hotels, as long as their data is processed by Accor in Accor’s
Your local law, PI on You, Your
birth, nationality, contact
e-mail, name and telephone number of a contact in case
mployees irst Your spouse or partner, name, first
information and pensions information;
means of transportation of an Employee, for
etc.;
for the job occupied by the Employee within Accor;
ence applicable, continuing education), mobility situation and
-ended contract, part-time or full-time job, hire date,
Employee identification number, job title, work
address, job description, working time, absence (in particular
parental leave), paid holidays (if applicable) and
deductions, pay grade, track of salary and other
pension fund
employer under local
Your PI is collected and processed
esources are set forth in the Accor Information Technology
employment contract or in certain countries to the
Accor implements video surveillance systems in its
ion
Whistleblowing hotline: for compliance with its legal obligations, Accor ma
whistleblowing hotline which permits Employees to report unethical
applicable, the nature of PI collected and conditions of processing are set forth in a specific information
notice which is incorporated by reference to Your
internal regulations of Your company;
Any other additional PI we need in order to manage the employment relationship or that
us when applying for a position within Accor (e.
report from external recruiting companies as well as previous managers).
5.WHAT SENSITIVE PERSONAL INFORMATION ?
Accor may collect, use, store, and otherwise process certain
the management of the employment relationship or for legal claims
as required by applicable law.
When required by local law, collection of said data is subject to
6.WHEN IS MY PERSONAL INFORMATION COLLECTED ?
Your PI may be collected through various means, including
Recruitment:
- Accor’s online recruitment websites;
- Any other recruitment resources including external recruiting c
previous employers.
Hiring and Employment relationship: any information collected
- Human Resources department interviews and
- Evaluation reports;
- Modification of identification data;
- Transportation expenses;
- Benefits information.
Accor internal and international mobility:
- Accor’s Intranet sites notably to manage career path or expatriation;
- Accor’s Human Resources Network.
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Security measures:
- Image recordings from video surveillance systems (if a
- Time collection information through badge control devic
- From other security devices.
Provision of information by third party service providers:
- Recruitment service providers;
- Profit sharing companies.
Usage of Accor’s System Resources: for more information,
Technology Policy.
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Human ressources Privacy Policy
may implement a
mployees or inappropriate behaviour. Where
employment contract or in certain countries to the
You supplied
g. curriculum vitae or application letter, assessment
sensitive PI about Employees that is necessary for
claims. In particular, Accor processes sensitive data
Your express prior consent.
without limitation:
companies, job interviews, contact with
ny through:
collection forms on paper or electronic format ;
age any) placed in Accor’s premises;
ime devices for access control (if any);
please refer to the Accor Information
7.WHAT ARE THE PURPOSES ?
Your PI is collected, processed and stored by Accor, including without limitation for the following purposes:
To comply with applicable local law: such as for the management of:
- Maternity obligations;
- Organisation of professional elections;
- Diversity requirements;
- Working hours;
- Sick leaves;
- Payroll: wages and benefits due under Your
other salary adjustment, annual bonus payment and pensions management; income tax and social
security withholdings.
To check the qualifications:
- Applicants’ PI is collected either directly or indirectly to enable Accor to assess the applicant’s ability
to perform the job (e.g. checking his/her references and qualifications).
For international mobility:
- To manage Employees’ mobility within the Accor Group around the world.
To provide services to Employees:
- Employee benefits (e.g. Luncheon Vouchers, Commuter Check Tickets,
bienvenue, Bien-Etre à la Carte, ...)
Stock options: for Employees’ benefits from stock option plans (if any);
Performance and talent management:
- To facilitate Employees’ performance management and career development, notably through annual
performance appraisals, annual salary reviews and,
local law.
Security and monitoring: for the management of:
- Office access (badge control);
- Accor’s System Resources access;
- Security: video surveillance images recordings (if any).
General Management:
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- Planning and budgeting;
- Headcount;
- Management of directories;
- Organisational charts;
- Management of Employees files;
- Financial reporting
- Corporate reorganisations, outsourcing, restructuring, acquisitions and divestments.
Resources management:
- For allocation and maintenance of resources, e.g. management of the Employees’ rights to access
conference rooms, offices, the IT system and the database.
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Human ressources Privacy Policy
employment agreement, annual merit increase, any
justment, Ticket Tesorus, Carte
if any, disciplinary sanctions in accordance with
Training:
- For organisation of training sessions for Employees,
Creation of marketing documentation:
- For commercial proposals in response to Requests For Proposals (RFPs) submitted by clients
- Annual reports may include PI on certain categories of employees
Disclosure to authorities:
- When requested by judicial authorities and/or law enforcement agencies in the context of legal
investigations;
- Subject to local law requirements, Accor may use
claim, defence or declaration in a case or before any jurisdictional and/or administrative authority,
arbitration or mediation panel, in the context of disciplinary actions/investigations or of internal or
external audit and inquiries.
8. SHARING OF YOUR PERSONAL INFORMATION
Accor may share Your PI with all the relevant personnel within the Accor G
- Service providers involved in the different H
- Local or other authorities;
- Outside counsels (auditor or attorneys) to establish our legal rights and defend against legal claims
- Business investors (in the event or merger or acquisition
- Clients in the course of business proposals or activities
Accor will share Your PI only when necessary for the purposes above listed. It is Accor’s practice to require the
recipients to keep Your PI confidential and to use Your PI only to perform functions for Accor
Accor reserves the right to disclose Your PI to authorized requests from government authorities, to address
national security situations or when otherwise required by law.
9. INTERNATIONAL TRANSFERS
We may transfer for the purposes set forth in Article
recipients, internal or external, which may be located in countries with different levels of PI protection.
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Therefore, in addition to the implementation of the present
appropriate measures, including contractual clauses, to secure transfer of Your PI to any Accor entity or external
recipient located in a country with a level of protection different from the one existing in the country in which the PI
is collected.
10. DATA SECURITY
Accor takes appropriate technical and organisational measures, in accordance with local law requirements, to
protect Your PI against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or
access. To this end, we have implemented technical measures such as firewalls and organisational measures
such as a login/efficient password system, physical protection, etc.
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Human ressources Privacy Policy
mployees, (e.g. via Académie Accor).
clients;
employees.
Your PI to protect its legal rights or support any
ant Group or external recipients such as:
fferent Human Resources data processing described above;
claims;
of another company);
ss activities.
Accor.
7 of this Human Resources Privacy Policy Your PI to
Human Resources Privacy Policy, Accor implements, ,
ess.
11. DATA STORAGE
We will store Your System PI only for the time necessary for
Privacy Policy, or as permitted by the applicable law.
12. ACCESS AND MODIFICATION
You have the right to access and modify Your System PI that Accor may have collected, subject to applicable law
requirements.
For this purpose, You may exercise Your rights by contacting
ACCOR
Data Privacy Dpt.
Immeuble Odyssey
110 Avenue de France
75210 Paris Cedex 13, France
13. UPDATES
We may amend this Human Resources Privacy Policy from ti
Therefore, we invite You to read this Human Resources
board on a regular basis and each time You are notified of changes, to check the updates.
**
*
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Human ressources Privacy Policy
the purposes stated in this Human Resources
Your Data Privacy Contact :
time to time.
Policy posted on Your company’s Intranet or bulletin
*
SPECIFIC PROVISIONS FOR EU
Accor recognizes that the European Union has established strict standard of protections regarding the handling of
EU Personal Data. Accor has thus elected to submit EU Employees and applicants to specific provisions with
respect to their personal data processing.
Therefore, Accor’s practices with respect to EU Employees and applicants personal data are reflected in the
Human Resources Privacy Policy as revised in its Sections 5 (“What sensitive personal information?”), 8
(“Sharing of Your Personal Information”) and 12 (“Access and Modification”) which are replaced, by the provisions
below. The provisions of the Human Resources Privacy Policy which are not revised below are applicable “AS IS”
to EU Employees and applicants.
5. WHAT SENSITIVE PERSONAL INFORMATION ?
Except when required by local data privacy law, Accor does not collect or process any PI revealing racial
origin, political opinions, religious or philosophical beliefs, trade
life.
If any such information is somehow transferred to Accor (e.g. enclosed in Your CV or application letter) and if not
required by the local law, they will be deleted by Accor.
8. SHARING OF YOUR PERSONAL INFORMATION
Accor may share Your PI with internal or external recipients in the following way:
The Accor Group: We may share Your PI, only when relevant with the following Accor authorized
personnel who need access in the context of their job within Accor for the purposes described above:
- Your supervisors and line manager, Your Human Resources Department; Informat
personnel, Legal Department, controllers and accounting business managers, Marketing
Department, relevant managers of other Accor Group entities for specific categories of data stored
on global databases, or for pre-litigation and litigation
- The General Human Resources Department (DGRH), General IT Department (DGSIT) and other
General Departments centralized in Accor S.A. in France;
- Académie Accor, and the relevant Accor entities involv
to Employees.
External service providers: we may share Your PI, when relevant, with third party providers, such as:
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- Payroll administrators, benefits providers and administrators, information technology syste
providers, financial institutions, pension plan institutions, insurance companies, consultant and
professional advisors;
- Employment or recruitment agencies, interim companies and outplacement services;
- Other distributors and suppliers of goods or servic
various services;
- Any other service providers involved in the provision of services to Employees.
Local authorities – internal investigations:
compliance with local regulations, or as part of internal investigations within the Accor Group:
- Tax authorities, social security services, judicial authorities, employment/labour or other authorities;
- Independent public accountants, authorized representatives of
auditors or attorneys, corporate security, and legal firms;
- Your PI may be shared to respond to internal or external audit and inquiries, law enforcement
requests, to administrative or judicial authorities or where requir
or government regulations.
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Human ressources Privacy Policy
EMPLOYEES OR APPLICANTS
s or ethnic
n, trade-union membership, data concerning health or sex
Information Technology
purposes;
involved in the provision of products and services
systems
services such as travel agencies, outsourcers for
we may share information with local authorities in
internal control functions such as
required by applicable laws, court orders,
Business investors:
- Your PI may be disclosed in connection with a corporate restructuring, sale, or assignment of
assets, merger, divestiture, or other changes of control or financial status of Accor (or any of its
subsidiaries) to potential investors, their auditors, and legal counsels.
Other recipients:
- Clients in the course of a commercial proposal
(RFPs) submitted by clients.
12. ACCESS AND MODIFICATION
You have the right to access, modify or delete Your PI
described in this Employee Privacy Policy provided that Y
You may also exercise Your rights by contacting locally, the
ACCOR
Data Privacy Dpt.
Immeuble Odyssey
110 Avenue de France
75210 Paris Cedex 13, France
Please note that in the interest of protecting Your privacy, we will need
request. To this end, we may request a copy of a valid identification paper such as a current driver's licence,
identity card or passport.
If Your PI is not accurate, complete or up-to-date, please provide
request for correction. Any requests for correction will be dealt with promptly
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Human ressources Privacy Policy
ssets, ) for instance in response to Requests For Proposals
PI, you can also object to the processing of Your PI as
You have legitimate reasons to do so.
Data Privacy Contact of Your company:
to identify You properly to respond to Your
. Your Human Resources Manager with Your
in compliance with applicable law.