This Privacy Notice (“Notice”) provides information regarding Electric Boat Corporation’s (“EB”) compliance with the European Union General Data Protection Regulation (“GDPR”).
This Notice aims to provide guidance to EB employees, applicants, customer, vendors, or an employee thereof on the standards that govern EB’s privacy policies to include the nature of the personal data held by EB regarding EB’s employees and the way EB uses and otherwise processes the personal data of EB’s employees. This Notice also aims at providing EB employees with transparent information regarding the processing of their personal data.
This Notice is designed to comply with all applicable national, state and local laws and regulations, including primarily the GDPR.
Scope and Intended Audience
This Notice applies to Electric Boat Corporation and its affiliates. This Notice covers all personal data related to EB’s employees who are residents of the European Union, European Economic Area, United Kingdom and Switzerland.
Listed below are the definitions that pertain to this Notice. Where a term is not specifically defined in this section, the definitions of article 4 of the GDPR shall apply.
“Personal Data”: Any information relating to an identified or identifiable natural person (“data subject”). An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to his /her physical, physiological, mental, economic, cultural or social identity. Data is considered personal when it enables anyone to link information to a specific person, even if the person or entity holding that data cannot make that link.
“Processing” Personal Data: This term is broadly defined and includes any manual or automatic operation (or set of operations) on Personal Data, including its collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, use, transmission, dissemination or publication, alignment or combination, and even restriction, erasure, or destruction.
“Personnel” or “You” or “Your”: All employees of EB that are placed on assignment in the European Union, European Economic Area, United Kingdom and Switzerland.
“Data Controller”: A person or entity who, either alone or jointly or together with other persons or entities, determines the purposes for which and the manner in which any Personal Data are, or are to be, processed. For purposes of this Notice, the Data Controller is EB, which processes payroll for employees on long term assignment; General Dynamics Corporation when employee data for employees on long term assignment is sent to Corporate headquarters).
“Sensitive Personal Data”: Personal Data that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the Processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
Personal Data shall be collected and processed in compliance with the requirements of the GDPR and/or other applicable local data privacy laws (“Privacy Laws”).
EB collects and processes Personal Data relating to its Personnel primarily for job-related purposes. You can find a list of the purposes for which EB processes Your Personal Data in “Purposes of the Personal Data Processing” section below. EB does not collect and process more or other types of Personal Data than are necessary to fulfill the respective purposes. EB will only use Personal Data as set forth in this Notice, unless You have specifically provided Your consent to another use of Your Personal Data or such use is otherwise permissible under applicable Privacy Laws. You shall be informed about the categories of Personal Data collected and how the Personal Data will be processed. Where the Processing is subject to Your consent, EB will use Your Personal Data for a different purpose only with Your permission. Access to the Personal Data shall be role-based and consistent with the job duty responsibilities of EB employees who are given access.
Personal Data Collected and Held
Unless limited by local legislation, only the following Personal Data will typically be collected, processed, and stored as part of the personnel record EB holds on You:
Collection and Processing of Sensitive Data
In principle, no Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, and the Processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning Your health or sex life or Your sexual orientation are collected or processed by EB.
However, racial or ethnic origin Personal Data (e.g. Your identified race and ethnic origin as provided by You at Your time of hire or when You voluntarily self-disclose such information after Your time of hire) may be collected and processed by EB to the extent that EB is required to do so in order to comply with its affirmative action and equal employment opportunity obligations.
Further, health-related Personal Data (e.g., absence records associated with illness or accidents, including possible exposure to certain materials or contaminants; maternity leave; disabilities; work-related injuries or claims; etc.) may be collected and processed by EB to the extent EB is required to do so in order to comply with its labor and social security obligations or to manage the safety at the workplace.
Additionally, Personal Data related to trade union membership may be collected and processed for purposes of administering the terms of union agreements, benefits, and retirement plans, and other activities governed by collective bargaining agreements.
Purposes of the Personal Data Processing
Where it is necessary, we use Your Personal Data to help ensure effective personnel administration, for the following purposes:
Legal Basis for Processing
EB only processes Your Personal Data so far as such Processing is legally permitted. Please see below for a more comprehensive description of the legal basis on which We process Your Personal Data.
Personal Data Retention Period and Place of Storage
EB will only keep Your Personal Data for so long as they are relevant for the purposes for which they were collected or as required by law.
EB will delete Your Personal Data when Your Personal Data are no longer relevant and, in any case, upon expiration of the maximum storage term of Your Personal Data as set forth by the applicable law, unless otherwise required by applicable law to store Your Personal Data (e.g., in connection with reporting obligations or in the event of litigation). If required by national law, EB will first block your data for a determined period of time to keep it available for authorities or courts before we can finally delete it. Such blocked data will only be accessed by individual employees who are in charge of managing such data and responding to court orders and requests from authorities.
EB Personnel’s Personal Data are held in paper, electronic, and other formats, and must be securely stored and accessible only in accordance with job responsibilities. Refer to EB’s policies on record retention practices.
Conditions of Disclosure of Personal Data
Access to Personal Data is given to those individuals of EB and its affiliates who need such access for a purpose listed above or where required by law. These parties Human Resources, Finance, Accounting, Payroll, Contracts, Procurement, Ethics, Business Services, Security, Tax, and other department personnel who require access to administer designated responsibilities. EB will from time to time and for the purposes listed above, need to make some of Your Personal Data available to:
In addition, where permitted by applicable law, Personal Data may be disclosed in connection with a corporate restructuring, sale, or assignment of assets, merger, divestiture, or other changes of control or financial status of General Dynamics Corporation, EB, or any of their affiliates. Finally, and to the extent permitted by applicable laws, Personal Data may be transferred to respond to internal or external audit and inquiries, to law enforcement requests, to administrative or judicial authorities or where required by applicable laws, court orders, or government regulations (including disclosures to tax, employment/labor or other authorities).
You can be assured that Your Personal Data is disclosed or transferred to EB employees or to the recipients within the departments listed above who need to use Your Personal Data for the purposes described in this Policy, and that Your Personal Data will be treated confidentially. EB requires from the service providers to whom Your Personal Data may be transferred that they undertake to process Your Personal Data only on behalf and subject to EB’s instructions and to implement appropriate security measures to keep Your Personal Data confidential.
Transfer of Personal Data Outside of the EU & UK
As certain of the recipients listed in the above paragraphs may be located outside the EU & UK where the data protection laws might not provide a level of protection equivalent to the laws in Your jurisdiction, EB has taken the appropriate measures to comply with the requirements of the Privacy Law to secure transfer of Personal Data outside EU & UK.
Security Measures Implemented to Protect Personal Data
EB has undertaken efforts to put into place appropriate technical and organizational security measures to minimize the risk of unauthorized or unlawful disclosure or access to, or accidental or unlawful loss, destruction, alteration or damage to Your Personal Data. These measures will help ensure an appropriate level of security in relation to the risks inherent to the Processing and the nature of the Personal Data to be protected. Your Personal Data will only be accessible to those EB employees who have a need-to-know Your Personal Data for the performance of their job duties.
EB works to have appropriate physical, technical and organizational security measures in place to protect the security of Your Data that it processes. The security measures taken by EB include controlled access to hard copy personnel and medical files, directory access controls for electronic data files, and user id/password access for systems containing personal information including, but not limited to, HRIS Systems (e.g. PeopleSoft, iCIMS, Cornerstone on Demand), Payroll/Timekeeping Systems (e.g. TAS/Infor Workforce Management), and Medical/Workers’ Compensation Systems (e.g. ATS). These security measures may be updated over time when legal and technological developments occur.
You have certain rights regarding the personal information EB holds about you, subject to local, state, or international law (including the GDPR), such as the right to access, correct, delete, restrict, object to EB’s use of, withdraw consent if applicable, or receive a portable copy in a usable electronic format of your personal information.
Pursuant to the law, You may object to the Processing of Your Personal Data for legitimate reasons, notably the transfer of Your Personal Data to some recipients. Please note that where EB collects, holds and processes Your Personal Data to perform its obligations under Your employment contract, You may not oppose to such Processing.
You may contact EB at the contact information set forth below to update or correct Your information if it changes or if the personal information EB holds about you is inaccurate.
You further have the right to lodge a complaint with a relevant supervisory authority if You believe that EB may have infringed Your rights.
Changes to this Notice
EB may change or update this privacy notice from time to time. If any revisions made by EB materially alter the ways in which EB processes your personal information, EB will communicate such changes via the email address you have on file with EB.
If you have questions or concerns regarding the way in which your personal information has been used, you may contact EB at firstname.lastname@example.org or by phone at 860-433-8279.
Represented employees should direct their questions or concerns to their Union representative who can then address any issues with the Legal Department.