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India HR Privacy Notice

Effective Date: August 1st, 2022

ACCO Brands Corporation, including its affiliates (collectively, “ACCO Brands,” “we,” “us,” or “our company”), is committed to protecting the privacy of prospective employees, existing employees, former employees as well as contractors working on behalf of our company.

  • What are the key points of this notice?
  • What does this notice cover?
  • Which ACCO Brands entity is the controller of your personal data?
  • What personal data do we collect?
  • From what sources do we collect personal data?
  • How do we use your personal data and what is the legal basis?
  • With whom do we share personal data?
  • To which countries do we transfer your personal data?
  • What rights do you have?
  • How long will we maintain your information?
  • How will you know if this notice has been updated or changed?
  • Whom should you contact with any questions or concerns about your personal data?
What are the key points of this notice? Chevron Icon

The key points of this notice that you should know are:

  • For potential, existing, and former employees, the controller for your personal data is generally the entity to which you are applying, by which you are employed, or by which you were formerly employed.  For contractors, the controller for your personal data is generally the entity to which you are providing services.
  • We collect various types of personal data, including some special categories of personal data (often called sensitive personal data), to manage our relationship with you and to operate our business.
  • Depending on the circumstances, we rely on different legal bases to process your data.  These include processing data to fulfill a contract with you, to comply with applicable laws, to fulfill our legitimate interests and your legitimate interests, and to fulfill other purposes for which you give your explicit consent.
  • Most of your personal data will remain with your local employer, but some data will be shared with ACCO Brands’ affiliates around the world.  Your personal data will also be shared with other companies and service providers, such as payroll providers, IT service providers, and insurance companies.  We do not sell your personal data.
  • Whenever we transfer your personal data to another country, we protect the data using various mechanisms, such as governmental adequacy decisions, standard contractual clauses, or government-recognized certifications.
  • You have rights over how your personal data is used, such as asking to access your data, delete your data, or have it corrected.  These rights are limited in some cases.
  • You can reach out to DataPrivacy@acco.com any time if you have questions or concerns about your privacy. You can also contact your local Human Resources Business Partner.
What does this notice cover? Chevron Icon

This notice describes how we collect and use your personal data as part of your recruitment, employment, or contracting relationship with our company. 

In some regions, different legal requirements may apply, and we may also collect different types of personal data.  Country-specific information is described in Annex 1 to this notice.

Which ACCO Brands entity is the controller of your personal data? Chevron Icon

For potential, existing, and former employees, the controller for your personal data is generally the entity to which you are applying, by which you are employed, or by which you were formerly employed. 

For contractors, the controller for your personal data is generally the entity to which you are providing services.

For a limited number of purposes, our ACCO Brands US entity, ACCO Brands USA LLC (“ABUL”) and the respective local entity will act as joint controllers. This means that each of ABUL and the local entity is responsible for deciding how we hold and use personal information about you, but that ABUL and the local entity will also cooperate to ensure data protection compliance. Additional details on this topic are available in the “With whom do we share personal data?” section below.

What personal data do we collect? Chevron Icon

We will collect and use the following personal data to manage your recruitment, employment, or contracting relationship:

  • Personal Details – your name, maiden name, date of birth, gender, home address, personal email address, personal phone number, emergency contact details, marital status, family member information, tax ID numbers, national ID numbers, citizenship and immigration status, copies of identity documentation;
  • Pre-Employment Details – curriculum vitae, job title, professional experience, past employment history, education, training, skills, certifications, languages spoken, background check results (only where permitted by local law and subject to any necessary consents), and statements from references;
  • Employment Details – hire date, employee ID, payroll number, work phone, work email, work mailing address, travel preferences, company vehicle details, personal vehicle details (only if required for parking passes), manager, department, benefits, pay grades, employment status, employment category, performance history, training records, assessment results, information regarding skills and development, career plans, records of disciplinary action, internal investigation records, reports of potential or suspected misconduct, and termination date and reason;
  • Financial Information – salary, incentives, benefits, bank account routing and account number, expense records, beneficiaries’ name, date of birth, gender, and any other information needed for payment and taxation purposes;
  • Computer and Network Information – ACCO Brands computer and network credentials, emails, instant messages, other electronic communications, firewall logs, system use data, and system access data;
  • Photography and Video – photographs, video recordings, and social media information you voluntarily share with us; and
  • CCTV Recordings – closed-circuit television video recordings outside of and within our offices and factories.

We also collect the following special categories of personal data (often called sensitive data):

  • Health Information – medical certification, medical leave information, work-related injuries and illnesses, work restrictions, pregnancy status, any required reasonable accommodations, health insurance coverage, and information you voluntarily share with us (only where permitted by local law and subject to any necessary consents).
From what sources do we collect personal data? Chevron Icon

We collect personal data from you directly as well as from third parties, such as recruiting agencies.  We use that data for the purposes listed below in the “How do we use your information and what is the legal basis?” section.

How do we use your personal data and what is the legal basis? Chevron Icon

We use your personal data for the purposes and under the legal bases described below.  We have broadly grouped the “Types of Personal Data Processed” for each purpose to make this Notice easier to read; however, we only process the types of personal data necessary to achieve the respective listed purpose. 

The legal bases we rely on are:

  • Legitimate Interests – this means that the processing of data is necessary for ACCO Brands’ or a third party’s legitimate interests, which are not overridden by individuals’ privacy rights;
  • Entering into and Performing Contract – this means that the processing of data is necessary to enter into or perform a contract with the individual;
  • Compliance with Law – this means that the processing of data is necessary to fulfil a legal obligation
  • Consent – this means that the processing is done pursuant to an individual’s freely given, specific, informed, unambiguous, and demonstrable consent.

If you have any questions or want additional information about the purposes, legal bases or types of data processed, please contact us at DataPrivacy@acco.com.

Purpose Types of Data Processed Legal Basis

Recruitment

We process personal data in order to find potential candidates, to conduct interviews, and ultimately hire the best candidates.

Personal Details

Pre-Employment Details

Legitimate Interests
We have legitimate interests in finding the best candidates for our company.

Entering into and Performing Contract
We need to process personal data in order to enter into the contractual or employment relationship with you.

Compliance with Law
We need to process personal information to comply with applicable employment and other laws.

Consent
We rely on explicit consent to store information regarding potential candidates that are not hired if they would like us to store that information to be considered for future positions.

Onboarding

Once a candidate has been selected, we process personal data in order to onboard the candidate.

Personal Details

Pre-Employment Details

Employment Details

Financial Information

Health Information

Entering into and Performing Contract
We need to process personal data in order to enter into the contractual or employment relationship with you.

Compliance with Law
We are required by law to collect and store personal data as part of the onboarding process, such as for taxation purposes.

Timekeeping and Payroll

We process personal data to track employee time worked, to manage leave, and to administer payroll.

Personal Details

Employment Details

Entering into and Performing Contract
We need to process personal data in order to compensate you as part of our contractual or employment relationship with you.

Compliance with Law
We are required by law to collect and store payroll data for purposes such as financial reporting and taxation.

Benefits Administration

We process personal data as part of the administration of benefits, as well as providing cafeteria allowances (where applicable), insurance coverage, retirement funding, and stock benefits.

Personal Details

Employment Details

Health Information

Entering into and Performing Contract
We need to process personal data in order to administer contractually agreed benefits.

Compliance with Law
We are required by law to provide employees with certain benefits.

Legitimate Interests
Even where not legally required, we have legitimate interests in providing benefits in order to attract and retain employees.

Development and Performance Management

We use personal data for performance and talent management, succession and career planning, training, career and leadership development, award recognition, diversity metrics, and conducting employee surveys. We also use personal data as necessary when handling disciplinary processes.

Personal Details

Employment Details

Computer and Network Information

Entering into and Performing Contract
In order to fulfil our contract with you, we need to process your personal data for merit increases and for disciplinary actions in the event of a breach of the contract.

Legitimate Interests
We have legitimate interests in helping our employees develop and grow with our company.  We also have legitimate interests in promoting an equitable workplace comprised of individuals with different views and backgrounds. We also have legitimate interests in establishing work standards as well as enforcing compliance with our Code of Conduct, policies, and the law.

Offboarding

We process personal data as part of the offboarding process, including to ensure you are properly compensated, to remove your system access, and to conduct exit interviews.

Personal Details

Pre-Employment Details

Employment Details

Financial Information

Entering into and Performing Contract
We need to process personal data in order to end our contractual or employment relationship with you.

Compliance with Law
We are required by law to take certain steps during the offboarding process and to store personal data for a certain period of time afterwards.

Communications
We use personal data in internal and external communications, including posting information on our websites and hosting events.

Personal Details

Photography and Video

Consent
We rely on your explicit consent to use photos or videos of you in communications.

Legitimate Interests
We rely on our legitimate interests in facilitating communications, promoting a positive work environment, and promoting our business. 

Health and Safety

We process personal data to conduct ergonomic assessments, ensure individuals receive medical attention for work injuries, handle workers’ compensation claims, and respect any medically required work restrictions.

Personal Details

Employment Details

Health Information

Compliance with Law
We are legally required to protect the health of safety of employees and others on our premises.

Legitimate Interests
Even where not legally required, ACCO Brands and employees both have legitimate interests in promoting employees’ well-being, health, and safety. 

Vital Interests of Individual
In the event that an individual is injured and requires immediate medical attention, we process personal data for that individual’s vital interests.

Facility Access and Security

We use personal data to provide individuals with access to our facilities and parking areas by issuing ID badges or parking permits.  We also process personal data in the form of CCTV recordings.

Personal Details

CCTV Recordings

Entering into and Performing Contract
To fulfil our contract with you, we must provide an appropriate workplace.

Legitimate Interests
We have legitimate interests in providing a suitable workplace.  We also have legitimate interests in preventing theft, deterring illegal behaviour, guarding the physical safety of individuals, and protecting ACCO Brands’ facilities and assets.

Administration of Business

We process personal data as part of managing our business, including expense management, business travel, planning, budgeting, calibration, headcount, executing legal instruments, providing system access, managing our IT systems and infrastructure, creating company directories, executing agreements with other entities, and managing relationships with other entities.

 

Personal Details

Employment Details

Financial Information

Computer and Network Information

Legitimate Interests
We have legitimate interests in maintaining a successful business, adequately accounting for and forecasting financial metrics, facilitating communications, managing our workforce, and managing relationships with other entities and individuals.

Cyber Security

We process personal data to protect the security and functionality of our systems and data.  This includes user access authentication, managing firewalls, managing antivirus and anti-malware protection, reviewing system access logs, monitoring systems for malicious activity, preventing phishing attempts, identifying and resolving security breaches, and preventing fraud.  The Cyber Security team also performs periodic phishing campaigns to measure employees’ ability to identify and properly respond to potential phishing emails. We may also access ACCO Brands computers, emails, instant messages, records, and network information as required to investigate potential security breaches (subject to any legal and privacy requirements as well as employee works council or union rights).  We do not, however, carry out real-time monitoring of employee emails, instant messages, computer usage, or internet usage.

 

Personal Details

Computer and Network Information

Compliance with Law
We are required by certain laws to maintain the security and confidentiality of personal data. We are also obligated under various finance laws to ensure the adequacy of our financial and IT controls.

Legitimate Interests
We have legitimate interests in protecting the security of our company’s confidential information as well as personal data collected from individuals.

Promoting Compliance with Company Policies and the Law

We process personal data to promote compliance with our Code of Conduct, our policies, our procedures, and the law.  This includes issuing policies to employees, coordinating training, asking employees to disclose conflicts of interest, receiving employee reports, maintaining our ethics hotline, and conducting investigations, and conducting audits.  As part of investigations, we may access ACCO Brands computers, emails, instant messages, records, and network information (subject to any legal and privacy requirements as well as employee works council or union rights).

 

Personal Details

Employment Details

Financial Information

Computer and Network Information

CCTV Recordings

Compliance with Law
ACCO Brands and its employees are required to comply with the law.  Some laws require that ACCO Brands implement certain policies, training, and reporting mechanisms. They also require ACCO Brands to investigate and address potential violations such as discrimination. If the government initiates an audit or investigation, ACCO Brands may be obligated to cooperate.

Legitimate Interests
As a U.S. based company group, ACCO Brands also has legitimate interests in complying with U.S. laws.  It also has legitimate interests in promoting compliance and ethics across the company.

Responding to Lawful Governmental Requests and Voluntarily Providing Information to the Government

We use and provide personal data in compliance with lawful requests by regulatory, civil, or criminal authorities, including to meet security or law enforcement requirements.  We may also voluntarily provide information to the government or self-regulatory entities to protect our company.

 

Personal Details

Pre-Employment Details

Employment Details

Financial Information

Computer and Network Information

Health Information

CCTV Recordings

Compliance with Law
ACCO Brands and its employees are required to comply with the law, including responding to lawful requests from governmental or self-regulatory entities.

Legitimate Interests
Even where not legally required, ACCO Brands may voluntarily disclose information to the government or cooperate with a government investigation to protect its financial and reputation interests.

Making and Defending Legal Claims

We use personal data when making or defending against legal claims, such as in labour disputes.  We may also use personal data in responding to discovery requests in litigation.

 

Personal Details

Pre-Employment Details

Employment Details

Financial Information

Computer and Network Information

Health Information

CCTV Recordings

Legitimate Interests
We have legitimate financial and reputational interests in pursuing legal claims or defending our company from legal claims.

Make or Defend Legal Claim
Only where necessary, we may process special categories of personal data, such as health information, to make or defend legal claims.

 

With whom do we share personal data? Chevron Icon

ACCO Brands USA LLC (ABUL)

Most of your personal data will remain with your local data controller, though personal data processed for the purposes listed below may be transferred to ABUL in the United States to comply with legal obligations or for the legitimate interests of your local data controller and ABUL. 

For the following purposes, ABUL and your local entity will act as joint controllers:

  • Benefits Administration – ABUL works with your local data controller to provide stock grants and insurance benefits;
  • Communications – any information posted on the ACCO Brands Corporate Intranet is managed by the ACCO Brands Corporate Communications team, which works for ABUL;
  • Administration of Business – to efficiently manage the entire ACCO Brands company group, ABUL processes personal data to provide central budgeting, expense management, planning, calibration, headcount, auditing, IT systems, and IT infrastructure;
  • Cyber Security – the corporate Cyber Security team (which works for ABUL) processes personal data to provide central multi-factor authentication support, spam and virus filtering of emails, URL and firewall filtering, investigating cyber security incidents. The Cyber Security team also performs periodic phishing campaigns to measure employees’ ability to identify and properly respond to potential phishing emails;
  • Promoting Compliance with Company Policies and the Law – the Corporate Compliance team (which works for ABUL) processes personal data as part of managing ACCO Brands’ compliance program (communications, training, auditing, and investigations) relating to anti-corruption, trade sanctions, money laundering, antitrust/fair competition, conflicts of interest, data protection, and other topics covered in the Code of Conduct;
  • Responding to Lawful Governmental Requests and Voluntarily Providing Information to the Government – in the event ACCO Brands receives a request for information from a governmental body, ABUL may be required to or may voluntarily provide to the government personal data, such as to demonstrate compliance with applicable laws; and
  • Making and Defending Legal Claims – significant litigation or legal actions are centrally managed by the ACCO Brands Legal and Compliance Department (which works for ABUL) and processes personal data in connection with making or responding to legal claims.

Potential Purchasers

We do not sell your personal data, though we may transfer that information to a potential purchaser of our business, including the potential purchaser’s consultants, attorneys, or financial advisers.

Service Providers

Finally, we also share personal data with the following categories of third parties:

  • ACCO Brands affiliates (list of ACCO Brands affiliates);
  • IT service providers;
  • payroll service providers;
  • travel agencies and travel service providers;
  • medical service providers, doctors, and third-party administrators for workers’ compensation claims;
  • recruiters, social media platforms, and career websites;
  • insurance and benefit providers;
  • auditors, accountants, and actuaries;
  • banks, credit card companies, payment service providers, financial brokers, and electronic stock trading platforms;
  • training, survey, and assessment providers;
  • attorneys, consultants, and investigators;
  • local, state, federal, or other government authorities or law enforcement officials; and
  • other individuals, organizations, or associations as necessary in furtherance of the interests of employees, contractors, or ACCO Brands.

We require third-party data processors to implement adequate technical and organizational measures to protect personal data, to notify us of a potential data breach, and not to use personal data for purposes other than providing services to us.

To which countries do we transfer your personal data? Chevron Icon

Personal data may be transferred to ABUL and service providers in the United States as described above.  Personal data regarding employees in the European Economic Area (“EEA”) may be transferred to service providers and regional HR management located in the EEA and the United Kingdom.

Whenever data is sent to third-party countries, we take steps to ensure it is adequately protected.  This is done through government-approved adequacy decisions, certifications, Binding Corporate Rules, or Standard Contractual Clauses.  If you have questions about the methods we use to ensure adequate data protection, you can reach out to DataPrivacy@acco.com at any time.

What rights do you have? Chevron Icon

You have rights over how your personal data is used, including:

  • to request details regarding the processing of your personal data;
  • to request a copy of your personal data;
  • to have your personal data transferred to another data controller;
  • to correct or delete your personal data;
  • to withdraw your consent, where we rely on that consent to process your data;
  • to object to or restrict the processing of your personal data; and
  • to submit a complaint with your regional data protection authority.

Exercising Rights

You can exercise your rights by contacting your local Human Resources Business Partner or by contacting us using the information in the “Whom do I contact with any questions or concerns about my personal data?” section below. 

Limitations

These rights may be limited, for example, if during the fulfilment of your request, information about another individual would be disclosed or if you ask us to delete data that we are legally required to store or need to operate our business.  They may also be limited by legal privileges and protections.

Also, if you revoke your consent or refuse to give consent, we will be unable to process your data for that specific purpose.  The revocation of consent will apply to all processing after the date of revocation but not to processing that occurred before that date.

Complaints

If you have a privacy concern, you can reach out using the contact details in the “Whom do I contact with any questions or concerns about my personal data?” section below.    You also have the right to lodge a complaint with the relevant data protection authority for your region.

How long will we maintain your information? Chevron Icon

We will keep your personal data for as long as needed to fulfil the purpose for which it was collected.  We will also maintain your information as needed to establish compliance with our legal obligations.  For more details, please see the ACCO Brands Record Retention Policy and Schedule, available on the corporate intranet.

How will you know if this notice has been updated or changed? Chevron Icon

As our business evolves and new processes are implemented or changed, we may need to update this notice.  If there are any significant changes to this notice, we will notify you in writing, such as by email.  We will also update the Effective Date to show the most recent revision date.

Whom should you contact with any questions or concerns about your personal data? Chevron Icon

If you have any concerns about this notice or your personal data, we recommend you contact your local Human Resources Business Partner.  You can also reach out to DataPrivacy@acco.com at any time. 

For certain regions, ACCO Brands has appointed local data protection officers.  Any questions or concerns about your personal data can be sent to the relevant data protection officer using the contact details below:

 

ABUL has appointed the following data protection representative in the EU:

Leitz ACCO Brands GmbH & Co KG
Siemensstraße 64,
70469 Stuttgart, Germany
Datenschutzbeauftragter@acco.com

ABUL has appointed the following data protection representative in the UK:

ACCO UK Limited
Oxford House, Oxford Road,
Aylesbury, Buckinghamshire, HP21 8SZ
DataPrivacy@acco.com

Annex List

  • Annex 1 – Specific Country Provisions
Annex 1 – Specific Country Provisions Chevron Icon

In some regions, additional legal requirements may apply, and we may also collect other types of personal data.  Below is a list of country-specific provisions.

Austria

  • Religion Information – information regarding your religion to pay religious taxes on your behalf (subject to your consent); and
  • Trade Union Information – information regarding your membership to a works council to pay membership dues on your behalf (subject to your consent).

Belgium

  • Trade Union Information – information regarding your membership to a works council to pay membership dues on your behalf (subject to your consent).

Brazil

  • Biometric Information – fingerprint data to manage attendance, timekeeping, and access to our facilities (subject to your consent);
  • Race and Ethnicity Information – race details for government reporting purposes, as required by law (subject to your consent);
  • Disability Status Information – disability status details for government reporting purposes, as required by law; and
  • Trade Union Membership – trade union membership details in order to deduct and pay union dues from your payroll (subject to your consent).

Germany

  • Copy of Identity Card to Verify Right to Work – copy of your identity card stored by HR to verify your right to work; the legal basis under German law is Section 26(1) of the Bundesdatenschutzgesetz;
  • Information for Relocation Services – information necessary to assist you with moving from one location to another; the legal basis under German law is Section 26(1) of the Bundesdatenschutzgesetz;
  • Personal Email Address and Phone Number – personal contact details; the legal basis under German law is Section 26(1) of the Bundesdatenschutzgesetz; and
  • Religion Information – information regarding your religion to pay religious taxes on your behalf; the legal basis under German law is Section 26(1) of the Bundesdatenschutzgesetz.

Italy

  • Trade Union Information – information regarding your membership to a works council to pay membership dues on your behalf (subject to your consent).

Portugal

  • Biometric Information – fingerprint data to manage attendance, timekeeping, and access to our facilities, only as permitted by national law; and
  • Trade Union Information – information regarding your membership to a trade union to pay membership dues on your behalf (subject to your consent).

Spain

  • Trade Union Information – information regarding your role as an employee representative (subject to your consent).

Sweden

  • Trade Union Information – information regarding your membership to a trade union to pay membership dues on your behalf (subject to your consent).

Switzerland

  • Religion Information – information regarding your religion to pay religious taxes on your behalf (subject to your consent).

United Kingdom

  • Health Information – As permitted under the UK Data Protection Act 2018, we collect information regarding the reason for an employee’s absence from work as well as the medical advice or treatment sought to determine whether an accommodation is needed or whether the employee is fit to work.

United States

  • Race and Ethnicity Information – race details for promoting diversity and government reporting purposes, per our legitimate interests and legal obligations;
  • Social Media Information – social media information you voluntarily share with us such as when you apply for a position with our company via LinkedIn, per our legitimate interests; and
  • Past Address History – past address history collected during the recruitment process, per our legitimate interest.
  • Privacy Rights – the rights mentioned in the “What rights do you have?” section are only available to individuals in the state of California.

PN-GL-HR-ACCO-2022.08