Privacy Policy for Employees

Welcome to European Sperm Bank!

European Sperm Bank (”ESB” or “we”) will collect and process personal data about you as part of your employment with ESB, ESB UK, Ltd or IRC Hamburg in accordance with this Employee Privacy Notice.

ESB will collect and process personal data about you which is considered necessary for the administration of your employment with ESB.

The following personal data may be processed:

• Information such as social security number, name, address, phone number, e-mail address, etc.;
• Copy of passport and driver’s license
• Work information such as employee ID, hire date, CV, job location, work e-mail address, work phone number, title, job position, full time/part time, promotions, etc.;
• Financial information such as salary and other compensation, bonus, taxes, bank account number, other employee benefits, etc.;
• Registration of work hours;
• Sickness absence;
• Absence due to maternity leave or other employment leave;
• Training and education;
• Performance reviews;
• Results of personality tests, etc.;
• Copies of criminal records or other information on
• criminal offences;
• Photos and video;
• Employee purchases;
• Information obtained as part of access control;
• Disciplinary sanctions and criminal offences;
• Passwords and usernames;
• Family information such as next of kin;
• Information necessary in order to administer possible health insurances, pension schemes or other personal benefits, etc.;

Further, in some cases we may be required to collect and process special categories of personal data, such as:

• Health data;
• Other special categories personal data ex membership of a Trade Union, biometrical data etc.

ESB will only collect and process personal data about you, which is considered necessary in relation to your employment with ESB. The legal basis of processing, with respect to the majority of the personal data that ESB collects and processes about you, is the employment contract entered into between the ESB and you. ESB may also process HR data on the basis of a legal obligation (e.g. the processing of employee data in relation to social security reporting obligations, tax reporting and reporting of work related accidents) or the legitimate interests of ESB as employer, such as for example – but not only – employee evaluation.

Certain processing activities require your prior consent, e.g. the use of your photos on websites or for marketing purposes. Your personal data may also be processed in order to comply with legal requirements or to establish or defend legal claims.

European Sperm Bank (ESB) may process your personal data for the following reasons: 

• Staff administration, management and administration of compensation (salary, bonuses, benefits, etc.), training and other HR functions related to your employment with ESB;
• Planning and administration of the ESB workforce covering the entities of ESB;
• Appointments, promotions and demotions;
• Personal development records, performance management and appraisals, effectiveness assessment, etc.;
• Analysis and management of employee works skills, certifications, licences and competencies;
• Recording and maintaining employment history, absence records and disciplinary records;
• Completion of employee surveys;
• Administration of employee purchases;
• Facility management and security;
• Provision and support of IT systems, user profiles, investigations, etc.;
• Handling of claims and disputes;
• Compliance with legal, regulatory and other good governance obligations;
• Other legitimate business purposes.

It order to pursue the above listed purposes your personal data may be made available to third parties providing relevant services under contract to ESB such as processors of salary, expenses and other compensation information, and IT hosting and maintenance providers. Such service providers will only process the personal data in accordance with our instructions.

Certain personal data will also be reported to government authorities where required by law and for tax or other purposes or to pension or insurance providers as well as travel agencies, airline companies, leasing bureaus and financial institutions. Personal data may also be transferred to external parties as required by employment law or other relevant legislation, as well as to third parties you explicitly provide consent to ESB to transfer your personal data to.

If your personal data is transferred to data controllers or data processors which are located in countries outside the EU/EEA, including group entities, not ensuring an adequate level of data protection, such transfer will be safeguarded by the EU Commission’s standard contractual clauses.

As a general rule, your personal data will be kept for a period of 5 years following termination of your employment unless we are required to store your personal data for a longer period due to legal requirements or if necessary for the purpose of defending a specific claim or dispute.

Sensitive personal data will be deleted when the purpose for which it was collected and processed no longer exist.

We may process and store your data for a longer period than set out above in an anonymized form which means that we will no longer be able to refer the data back to you.

You have a right of access to the personal data, which we process and store about you, subject to certain statutory exceptions. Furthermore, you have the right to object to the processing and request restriction of the processing of your personal data. In addition, you also have the right to require us to rectify or erase your personal data, if necessary.

Under certain circumstances, you may also request that we provide you with an overview of your personal data in a structured, commonly used and machine-readable format and request us to transmit such data to another data controller.

You may read more about your rights on the Information Commissioner’s Office’s website on https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.

If you want to exercise any of your rights, if you have any questions regarding this privacy policy or the processing of your personal data, you may contact the ESB Data Protection Team on dataprotection@europeanspermbank.com. You may also file a complaint with your local data protection authorities, e.g. the Information Commissioner’s Office, https://ico.org.uk/, or the Danish Data protection Agency (Datatilsynet), https://www.datatilsynet.dk/.

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QM POL04-02 Privacy Policy for Employees_24Sep2018