Employee Privacy Notice

2. Do we need to state the legal entity of each country i.e. one version for each country?
3. Any example for “legal or business” purpose as mentioned in the template?
4. Do we need any consent (via the Data Subject Consent Form) from our employee when we use their photos on the corporate web site? We know consent is not needed for any personal data submitted for employment purpose but since the web site is generally used as a marketing tool, I would like to confirm the need of employee’s consent.

Answers:

1. The privacy notice could be sent by email to all employees and also placed on the intranet page of the company. Is not necessary to get the acknowledgment but only to make available the notice to the employees.
2. You need to have an Employee Privacy Notice for each country if you have separate entities there. The content however could be similar if the HR processing activities are similar.
3. I don`t understand this question can you please rephrase it. Usually for HR the legal basis are contract obligations and legitimate interest.
4. Publishing an employee photo on the corporate website is not part of executing the labor agreement so their consent would be needed.