This Privacy Notice for employees describes how Forges Gorce, including all of its subsidiaries collects and processes personal information about you during and after your working relationship with us. This notice also outlines how we protect your privacy and information rights.
For the purposes of EU data protection laws, Forges Gorce is the "data controller". This means that we are responsible for deciding how we hold and use personal information about you.
This notice applies to current and former employees, directors, officers, workers and contractors of Forges Gorce (“Employees”). This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time.
Processing of your personal information
Forges Gorce will process your personal information in accordance with applicable data protection laws. We require some of your personal information in order to fulfil our legal and contractual obligations and where in the legitimate interests of Forges Gorce for the performance of the employment relationship. If you do not provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers). Your Right to Object – Please note that you have a right to object to the processing of your personal data where that processing is carried out for our legitimate interests. Please note however that we may not be able to fulfil this request in all instances.
The kind of information we hold about you
We may process the following categories of personal information about you, were required:
Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
Date of birth.
Gender.
Marital status and dependants.
Next of kin and emergency contact information.
National Insurance number.
Bank account details, payroll records and tax status information.
Salary, annual leave, pension and benefits information.
Start date.
Location of employment or workplace.
Copy of driving licence, birth certificate/passport.
Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process).
Employment records (including job titles, work history, working hours, training records, evidence of qualifications and professional memberships).
Compensation history.
Performance information.
Disciplinary and grievance information.
CCTV footage and other information obtained through electronic means such as time and attendance records.
Information about your use of our information and communications systems.
Photographs.
Other information voluntarily disclosed by you relating to your employment.
We may also process your sensitive personal information (i.e. health data including drug and alcohol testing) where necessary for us to comply with our employment law obligations.
Purposes for which we will use your personal information
We may process your personal information for the purposes set out below subject to any applicable data protection laws:
Making a decision about your recruitment or appointment, including the right to work.
Administering human resource functions including performance reviews and appraisals, talent management and succession planning, sickness leave, training, administering business travel arrangements including car hire and driving licence checks, internal directories and organisational charts, internal communications, professional elections including employee union elections and membership, social and cultural activities directly implemented by Alamo Group Europe Ltd and dealing with disciplinary action, termination and retirement of Employees.
Administering payroll, the payment of expenses, remuneration and other benefits of Employees such as bonuses, stock/shares, car allowances, loans, pensions, health insurance, life insurance, travel insurance, death-in-service benefits, and disability plans.
Marketing and promotional materials for the purposes of promoting the company’s products
Sharing with third parties in order for you to carry out your role
Managing Employee communications including authorising, granting and administering access to or use of Alamo Group Europe Ltd systems, facilities, devices and records including management of email accounts.
Carrying out audits and to investigate and resolve complaints, grievances or misconduct.
Preparing for and acting in relation to enquiries, investigations or proceedings, by governmental, administrative, judicial or regulatory authorities, including civil litigation.
Monitoring Employees where done in accordance with Alamo Group Europe Ltd policies and procedures and applicable laws, including for the purposes of occupational health.
In connection with a potential asset or stock acquisition of Alamo Group Europe Ltd, or the outsourcing or insourcing of services provided by Employees, providing reasonable diligence material to a third party or meeting any disclosure obligations as required by law.
Any other purposes relating to the above.
We will use your sensitive personal information in the following ways:
We will use information relating to leaves of absence, which may include sickness absence or family related leaves, to comply with employment and other laws.
We will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits.
We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.
We will use trade union membership information to pay trade union subscriptions, register the status of a protected employee and to comply with employment law obligations.
We may use your information in order to obtain professional advice if required.
Disclosure of your personal information
We may disclose your personal information for the above purposes to the following recipients, subject to any applicable data protection laws:
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Other entities in the Alamo Group.
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Financial institutions, pension plan institutions, insurance companies, consultant and professional advisors.
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Other service providers such as, payroll administrators, benefits providers and administrators, and information technology systems providers (duly appointed as data processors) and involved in the provision of services to Forges Gorce and/or its Employees.
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Independent public accountants and auditors, authorized representatives of internal control functions such as, audit, legal and/or corporate security.
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Local tax authorities and any governmental or administrative body where Forges Gorce determines that it is necessary or desirable in order to comply with applicable laws, court orders, or government regulations.
Transferring information outside the EU
We may transfer your personal information, for the above listed purposes, to other Alamo Group entities, or to other recipients as referred to above, that are located in countries outside the European Economic Area (“EEA”) including in the U.S. which are not considered by the European Commission to grant an adequate level of data protection.
We also operate [Insert name –whistleblowing hotline] which is based in the US, and forms part of the Code of Ethics Policy, whilst calls may be made anonymously, there may be instances where you choose to provide data internationally.
We have technical and organizational measures to protect your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed, and against all other unlawful forms of processing. We limit access to your personal information to employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and are subject to a duty of confidentiality.
How long will you use my information for?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. If you would like further information regarding how long we store your personal data, please contact Eric Tesnière via etesniere@alamofr.com and request a copy of the group-wide retention policy. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer an employee, worker or contractor of the company we will retain and securely destroy your personal information in accordance with group-wide data retention policy.
Rights of access, correction, erasure, and restriction
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
Request access to and rectification or erasure of your personal information.
Obtain restriction of processing or to object to processing of your personal information.
Request the transfer of your personal information to another party.
Any requests should be made to Eric Tesnière, Director of Human Resources, via etesniere@alamofr.com. You also have the right to lodge a complaint about the processing of your personal information with the Information Commissioner’s Office via www.ico.org.uk. You also have the right to lodge a complaint about the processing of your personal data with your local data protection authority. In France this is the Commission Nationale de l’Informatique et des Libertés, www.cnil.fr
