Staff Privacy Notice Template for Netherlands

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Key Requirements PROMPT example:

Staff Privacy Notice

"I need a Staff Privacy Notice for a Dutch tech company with 200 employees that processes data internationally, including in the US and India, and uses AI for recruitment - the notice needs to be ready by March 2025 when we implement new HR software."

Document background
The Staff Privacy Notice is a mandatory document under EU and Dutch data protection law, required for any organization with employees in the Netherlands. It serves as a transparent communication tool between employers and employees regarding the processing of personal data in the employment context. The document must comply with both the GDPR and specific Dutch requirements, including the UAVG and relevant employment laws. Organizations must provide this notice to employees at the start of employment and when significant changes occur in data processing practices. The notice should be written in clear, plain language and must cover all aspects of employee data processing, from recruitment through to post-employment record keeping.
Suggested Sections

1. Introduction: Overview of the privacy notice purpose and scope, including who it applies to and when it applies

2. Data Controller Information: Identity and contact details of the employer as data controller, DPO contact details if applicable

3. Categories of Personal Data: Comprehensive list of personal data types collected and processed about employees

4. Purposes of Processing: Detailed explanation of why the organization processes employee personal data

5. Legal Bases for Processing: Explanation of the legal grounds under GDPR for processing employee data

6. Data Retention: How long different types of employee data are kept and why

7. Data Sharing and Recipients: Information about who employee data is shared with, including service providers and other third parties

8. Employee Rights: Explanation of GDPR rights including access, rectification, erasure, and how to exercise them

9. Data Security: Overview of measures taken to protect employee personal data

10. Complaints Procedure: How to raise concerns about data processing and right to complain to supervisory authority

Optional Sections

1. International Transfers: Required if employee data is transferred outside the EEA, explaining transfer mechanisms and safeguards

2. Automated Decision Making: Required if the organization uses automated processing to make decisions about employees

3. Monitoring and Surveillance: Required if the organization conducts workplace monitoring or uses surveillance systems

4. Special Categories of Data: Required if processing sensitive data like health information or biometric data

5. Works Council Arrangements: Required if there are specific arrangements or agreements with works councils regarding data processing

6. Remote Working Provisions: Required if organization has specific data processing related to remote working arrangements

Suggested Schedules

1. Data Retention Schedule: Detailed retention periods for different categories of employee data

2. Processor List: List of main data processors and sub-processors handling employee data

3. Security Measures: Detailed description of technical and organizational security measures

4. Cookie Policy: Details of cookies and similar technologies used in employee-facing systems

5. Subject Rights Request Procedure: Detailed procedure for handling employee data subject rights requests

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

Financial Services

Healthcare

Manufacturing

Retail

Professional Services

Education

Transportation

Construction

Energy

Telecommunications

Public Sector

Non-Profit

Media

Real Estate

Hospitality

Relevant Teams

Legal

Human Resources

Compliance

Information Technology

Information Security

Risk Management

Operations

Internal Audit

Data Protection

Records Management

Relevant Roles

HR Director

Privacy Officer

Data Protection Officer

Legal Counsel

Compliance Manager

HR Manager

IT Security Manager

Risk Manager

Chief Privacy Officer

Employment Lawyer

HR Business Partner

Information Security Officer

Records Manager

Recruitment Manager

Operations Director

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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