Employment and HR
Employment processing spans candidates, employees, contractors, dependants, nominees, alumni and visitors. Systems include ATS, background verification, HRIS, payroll, benefits/insurance, attendance/access, biometrics, learning, performance, travel, whistleblowing, DLP/SIEM and global HR analytics.
Processing route
Section titled “Processing route”Section 7 includes a specified employment-related use with statutory wording and conditions. It is not a blanket exemption for every monitoring or analytics activity. Classify payroll, benefits, security, performance, wellbeing, surveillance, internal communications and alumni/recruitment talent pools separately. Where consent is used, assess whether the choice is genuinely free in the employment relationship.
Notice and transparency
Section titled “Notice and transparency”Give role- and channel-specific notice before collection: recruitment, onboarding, biometric attendance, CCTV/access, device/security monitoring, benefits and investigations. State data, purpose, recipients, retention, contact and routes in plain language without disclosing controls in a way that defeats security.
Biometrics and monitoring
Section titled “Biometrics and monitoring”Default to less intrusive attendance/access methods. A biometric or monitoring assessment records necessity, alternative, scope, proportionality, device/template architecture, access, matching failure, retention, vendor, bias/performance and grievance. Do not use covert emotion/productivity inference as a default product capability.
Rights and investigations
Section titled “Rights and investigations”Use employee/candidate IDs and existing authenticated HR access. Responses must review third-party, manager, whistleblower, legal privilege, fraud and investigation material. A refusal/partial result needs exact legal reasoning and reviewer approval, not a generic “confidential” label.
Retention
Section titled “Retention”Separate unsuccessful candidates, employment file, payroll/tax, attendance, benefits, health, performance, grievance, investigation, access/security logs and litigation holds. Termination does not start one universal destruction clock. Restrict former-employee data to the retained purposes.
Minimum configuration
Section titled “Minimum configuration”Country/state and employing entity, worker populations, purpose pack, monitoring inventory, processor list (payroll/BGV/benefits), global HR transfers, retention sources, assisted grievance, insider incident path and joiner/mover/leaver access controls.
Sample leaver flow
Section titled “Sample leaver flow”Disable access; preserve scoped payroll/tax, investigation and litigation records; delete optional profiles and obsolete device data; instruct processors; revoke support/admin credentials; record backup expiry; retain an alumni contact only if a lawful purpose and notice support it.
Evidence and counsel questions
Section titled “Evidence and counsel questions”Evidence includes assessment, notice delivery, alternative choice, access review, processor instruction, rights case, retention decision and leaver certificate.
Counsel must resolve current central/state labour, tax, benefits, industrial-relations, whistleblowing and limitation sources; cross-border global HR roles; works council/union/contract terms; and whether a particular monitoring purpose fits section 7 or needs another route.