Employee Privacy Notice Template for Germany

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Key Requirements PROMPT example:

Employee Privacy Notice

"I need an Employee Privacy Notice for my mid-sized manufacturing company in Munich, Germany, that specifically addresses workplace video surveillance and biometric time recording systems we plan to implement in March 2025."

Document background
The Employee Privacy Notice is a mandatory document required under both the EU General Data Protection Regulation (GDPR) and German data protection law, particularly the Federal Data Protection Act (BDSG). It must be provided to employees at the time their personal data is collected, typically during the hiring process and updated when processing activities change. The notice explains how the employer processes employee personal data, the legal bases for processing, data sharing practices, retention periods, and employee rights. Under German law, this document requires particular attention to local requirements, including Works Council consultation rights and specific provisions of the BDSG regarding employee data processing. The document should be written in clear, plain language while maintaining legal accuracy and covering all required information under Articles 13 and 14 of the GDPR and Section 26 BDSG.
Suggested Sections

1. Introduction: Overview of the notice's purpose and scope, explaining why employees are receiving this privacy notice

2. Data Controller Information: Identity and contact details of the employer as data controller, contact details of the Data Protection Officer

3. Categories of Personal Data: Detailed list of personal data types collected and processed during the employment relationship

4. Purposes and Legal Bases for Processing: Explanation of how and why employee data is processed, including the legal bases under GDPR Article 6 and BDSG Section 26

5. Data Recipients and Sharing: Information about who has access to employee data, including internal departments and external service providers

6. Data Retention: Information about how long different types of employee data are retained

7. Employee Rights: Detailed explanation of employee rights under GDPR and German law, including access, rectification, erasure, and complaint rights

8. Security Measures: Overview of technical and organizational measures to protect employee data

9. Works Council Involvement: Information about works council's role in data processing activities, if applicable

Optional Sections

1. International Data Transfers: Required if employee data is transferred outside the EU/EEA, detailing transfer mechanisms and safeguards

2. Automated Decision Making: Required if any automated decision-making or profiling is used in HR processes

3. Video Surveillance: Required if workplace video surveillance is in use

4. Time Recording Systems: Required if electronic time recording systems are used

5. Remote Working Provisions: Required if employees work remotely, covering specific data processing related to remote work

6. Bring Your Own Device (BYOD): Required if employees are allowed to use personal devices for work purposes

Suggested Schedules

1. Schedule 1: Detailed Data Categories and Retention Periods: Comprehensive list of specific data categories collected and their respective retention periods

2. Schedule 2: Third-Party Processors: List of data processors and sub-processors with their roles and locations

3. Schedule 3: Technical and Organizational Measures: Detailed description of security measures implemented to protect employee data

4. Schedule 4: Department-Specific Processing Activities: Breakdown of data processing activities specific to different departments or roles

Authors

Alex Denne

Head of Growth (Open Source Law) @ Genie AI | 3 x UCL-Certified in Contract Law & Drafting | 4+ Years Managing 1M+ Legal Documents | Serial Founder & Legal AI Author

Relevant legal definitions
Clauses
Relevant Industries

Technology

Manufacturing

Financial Services

Healthcare

Retail

Professional Services

Education

Construction

Transportation

Hospitality

Energy

Telecommunications

Media

Real Estate

Non-Profit

Public Sector

Relevant Teams

Human Resources

Legal

Compliance

Information Technology

Information Security

Data Protection

Works Council

Employee Relations

Internal Communications

Risk Management

Relevant Roles

HR Director

Data Protection Officer

Legal Counsel

Compliance Manager

HR Manager

Privacy Manager

Works Council Member

Information Security Manager

HR Business Partner

Employee Relations Manager

Recruitment Manager

Payroll Manager

IT Director

Chief Privacy Officer

General Counsel

Industries
Teams

Employer, Employee, Start Date, Job Title, Department, Location, Probationary Period, Notice Period, Salary, Overtime, Vacation Pay, Statutory Holidays, Benefits, Bonus, Expenses, Working Hours, Rest Breaks,  Leaves of Absence, Confidentiality, Intellectual Property, Non-Solicitation, Non-Competition, Code of Conduct, Termination,  Severance Pay, Governing Law, Entire Agreemen

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