Privacy Notice for Employees, Applicants, and Independent Contractors¶
EN | FR
TNS Parsons (“Parsons Paris”), of 45 Rue Saint Roch, 75001 Paris France (“we”, “us”, or “Parsons Paris”), has prepared this privacy notice (including, where applicable, any country-specific schedules) (the “Notice”) to describe its practices regarding the collection, use, storage, transfer, and other processing of personal data about Employees (as defined below). Parsons Paris is the controller responsible for the personal data that we collect and process as described in this Notice. For the purposes of this Notice, “Employee” means:
- Past and present employees;
- Past and present consultants, independent contractors, and agents1;
- Job applicants;
- Past and present temporary employees;
- Retirees; and
- Past and present directors and officers.
This Notice will provide information about:
- Personal data we collect and use;
- How we use your personal data and the basis on which we use it;
- Special categories of personal data;
- How we store personal data and who can access it;
- Who has access to your data;
- How your personal data is protected and stored;
- International transfer of your data;
- Dependents’ privacy;
- How to exercise your rights;
- How to contact us; and
- Changes to the privacy notice.
1. Personal data we collect and use¶
We may collect your personal data from a variety of sources, including information we collect from you directly (e.g., when you apply for a job, during your employment, following termination of employment), and information we collect about you from other sources (where permitted by law).
Certain personal data is required as a consequence of the contractual relationship we have with you when we employ you, to enable us to carry out our contractual obligations to you. Failure to provide this information may prevent or delay the fulfilment of these obligations.
1.1 Personal data we collect directly from you¶
The categories of information that we may collect directly from you include the following:
- personal details (e.g., name, age, date of birth, place of birth);
- contact details (e.g., phone number, email address, postal address);
- family contact personal details (e.g., emergency contact details comprised of name of contact, relationship, phone number and email address);
- other information about you and your family (e.g., gender, marital status (for employees and applicants), family status, number of dependent children);
- educational and career background (e.g., your curriculum vitae);
- other relevant data with respect to your job application or employment with us (e.g., nationality, visa to live and work in France if applicable, bank details);
- French social security number (for employees);
- Citizenship status;
- Conflict of interest information (e.g., familial relationships, business relationships);
- Beneficiary information;
- Professional liability insurance information and registration number (for independent contractors); and
- Photographs for use in identification (for faculty).
1.2 Personal data generated by us¶
In addition, Parsons Paris generates personal data in the following contexts:
- Relating to employees and independent contractors:
- employee identifiers, such as ID numbers, and other internal identification numbers;
- Parsons Paris email address;
- employment details (e.g., employee number; University email address, annual review reports, performance records, and attendance and absence records; payroll records; employee contracts; use of communication systems, devices, and IT systems; travel details; training records); and
- employment and salary administration (e.g., salary amount, payroll records, bank details for direct deposits (name of bank, branch address, Swift code, IBAN, Siret number), benefit details, information related to tax withholding, reimbursement records, employment certificate and contract documentation).
- Relating to applicants:
- hiring and evaluation details (e.g. internal notes created in relation to your application, interview, or prior work experience or qualifications; referrals; hiring recommendations; information relating to salary negotiations; information about any association you may have with any current or former Parsons Paris employees).
- Audio and visual information captured by lecture capture systems, videoconferencing systems, web-based meeting applications, and similar technologies;
- Visual information captured by security cameras.
1.3 Personal data we collect from other sources¶
We use external sources to collect certain personal data where permitted by law. The following are examples of the categories of information we may collect from other sources:
- personal details (e.g., name, age, date of birth);
- contact details (e.g., phone number, email address, postal address);
- educational and career background (e.g., references from former employers);
- other information about you and your family (e.g., gender, marital status, family status);
- employment administration data (e.g., tax payment details); and
- company details (for independent contractors).
2. How we use your personal data and the basis on which we use it¶
We use your personal data in relation to your job application and (current or past) employment with us, to:
- carry out our obligations to you under your employment contract or your independent contractor agreement;
- exercise our rights under your employment contract or independent contractor agreement;
- provide any services you request from us;
- keep our records accurate and up-to-date; and
- comply with legal obligations to which we are subject.
We must have a legal basis to process your personal data. In most cases the legal basis will be one of the following:
- to fulfill our contractual obligations to you, for example to ensure that your salary is paid correctly, and for ensuring you have appropriate access to our premises;
- to meet our legal obligations to you based on our employment or contracting relationship, for example health and safety obligations while you are on our premises; or to a third party (e.g. tax authorities); and
- to meet our legitimate interests, for example to ensure that we can provide you with any services, such as human resources services from us, and that our records are kept up to date and accurate.
3. Special categories of personal data¶
We collect and process certain special categories of personal data about Employees where necessary and in compliance with applicable local data protection laws. In particular, Parsons Paris processes health and medical information, trade union membership, information about your gender identity, sex assigned at birth, and preferred pronoun, and information about the facts and circumstances surrounding instances or allegations of sexual misconduct (which may be collected in the context of investigations into or adjudications of allegations of sexual misconduct, assault, or unlawful activity), and to the extent permitted under local laws, information relating to your criminal record, as required and to the extent permitted under local laws to carry out our obligations in the field of employment, health and safety, social security and social obligations law and, where necessary, for the establishment or defense of legal claims. In some cases, we may also process special categories of data with your express consent, in which case specific information will be provided to Employees and Contractors before requesting their consent.
4. How we store personal data and who can access it¶
Parsons Paris maintains an automated record of each Employee’s personal data. This automated record contains most of the data held in the Employee’s personnel file. Additionally, Parsons Paris maintains personal data in various human resources applications, including applications for payroll, benefits, talent management, and performance management. We may also maintain individual hard-copy personnel files. The Human Resources Department maintains these files in a secure environment.
Access to personal data is restricted to those individuals who need such access for the purposes listed above or where required by law, including members of the Human Resources Department, the managers in the Employee’s department (including employees responsible for managing work performed by independent contractors), and to authorized representatives of Parsons Paris’ internal control functions such as Compliance and Legal. Access may also be granted on a strict need-to-know basis to other managers in the school where relevant if the Employee is being considered for an alternate job opportunity, or if a new manager appointed in the line of business needs to review files. All Employees, including managers, are bound by the requirements of this Notice.
5. Who has access to your data¶
In general, we do not share your personal data with third parties (other than service providers acting on our behalf) unless we have a lawful basis for doing so.
We rely on third-party service providers to perform a variety of services on our behalf, which may mean that we have to share your personal data with these third parties. When we share your personal data in this way, we put in place appropriate measures to make sure that our service providers keep your personal data secure.
Other situations in which we may disclose your personal data to a third party are:
- Parsons Paris is a branch campus and is part of The New School, whose global headquarters is located in the United States. The branch campuses work closely with our US-based operations and, from time to time, with each other. As a result, we may share certain personal data about you collected or used in the context of our academic programs with other New School personnel located at our main campus in the United States or other branch locations;
- where permitted by law, to protect and defend our rights and property; and
- when required by law, and/or public authorities.
6. How your personal data is protected and stored¶
We implement physical, technical, and organizational measures designed to safeguard the personal data we process. These measures are aimed at ensuring the ongoing integrity and confidentiality of personal data.
We will retain your personal data for the duration of the employment contract, unless a shorter retention period is required by law or the data is no longer necessary for the purposes for which it was obtained. Once our relationship with you has come to an end, we will retain your personal data in our archives for a period of time that enables us to:
- provide you with any continuing benefits, such as pension or insurance benefits;
- maintain business records for analysis and/or audit purposes;
- comply with record retention requirements under applicable law;
- defend or bring any existing or potential legal claims; and
- deal with any queries or complaints you may have.
We will delete your personal data when it is no longer required for these purposes. If there is any information that we are unable to delete entirely from our systems for technical reasons, we will put in place appropriate measures to prevent any further processing or use of that data.
7. International transfer of your data¶
Your personal data may be transferred to, stored, and processed in a country (such as the United States) that is not regarded as ensuring an adequate level of protection for personal data under European Union law.
We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your personal data is adequately protected. For more information on the safeguards in place, please contact us at the details below.
8. Dependents’ privacy¶
We may process personal data of your family members, including your children and dependents. When we do so, such processing will be carried out in compliance with data protection laws as they apply to children.
9. How to exercise your rights¶
You have certain rights regarding your personal data. You have the right to access personal data Parsons Paris holds, and in some situations you have the right to have that personal data corrected or updated, erased, restricted, or delivered to you or a third party in a usable electronic format (the right to data portability). You may also object to how Parsons Paris uses your personal data if the legal basis for processing that information is our legitimate interest. In addition, you may also give directives on the fate of your personal data after your death.
Where we are using your personal data on the basis of your consent, you have the right to withdraw that consent at any time. You also have the right to register a complaint to the applicable supervisory data protection authority.
If you wish to exercise these rights, or notify us of a change in your details, please visit our Data Subject Access Rights webpage at https://ispo.newschool.edu/dsar/.
10. How to contact us¶
If you have questions or concerns regarding the way in which your personal data has been used, please contact us at email@example.com or:
Office of Information Security and Privacy
71 Fifth Avenue, 9th Floor
New York, NY 10003 USA
Our representative in the European Union is TNS Parsons, of 45 rue Saint-Roch, 75001 Paris, France.
We are committed to working with you to obtain a fair resolution of any complaint or concern about your privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the applicable supervisory data protection authority:
- For Parsons Paris, the supervisory data protection authority is the Commission Nationale de l’Informatique et des Libertés – CNIL, 3 Place de Fontenoy, TSA 80715 – 75334 Paris, Cedex 07, https://www.cnil.fr/.
11. Changes to the privacy notice¶
You may request a copy of this Notice from us using the contact details set out above. We may modify or update this Notice from time to time.
Where changes to this Notice will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will notify you of the changes and give you sufficient advance notice so that you have the opportunity to exercise your rights (for example, to object to the processing).
REVISED NOVEMBER 11, 2020
ADOPTED June 1, 2020
|1 Jun 2020||
|11 Nov 2020||
For the avoidance of doubt, references to ‘Employee’ and ‘your terms of employment’ in this Notice are for the purpose of this Notice only and nothing in this Notice shall constitute an agreement between Parsons Paris and any consultant, independent contractor, or agent that they are or were an employee or worker of Parsons Paris, to the extent permitted by applicable local law. ↩