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Human Resources Privacy Policy

Our Commitment

As one of our employees, or applicant within our Group, it is our priority to offer you respectful and secure work conditions. Your trust in Accor is important to us.

We recognize that privacy is part of Your expectations. Therefore, we have designed and implemented this Global Human Resources Privacy Policy which describes how Accor uses Your Personal Information on the basis of Accor’s “7 Privacy Principles” (hereinafter “Accor 7 Privacy Principles”) which constitute core principles for Accor and which therefore apply throughout the Accor Group (Accor and its subsidiaries) worldwide.

Consent to this Human Resources Privacy Policy

You should read this Human Resources Privacy Policy carefully as it provides guidance on the nature of the Personal Information held by Accor on its employees and applicants and the way Accor uses it. By “Personal Information” (hereinafter referred to as “PI”), we understand any information collected and recorded in any format that identifies you personally, whether directly (e.g. name) or indirectly (e.g. phone number).

By accepting the terms of Your employment contract with Accor, or by applying within Accor, You expressly consent to this Human Resources Privacy Policy which is incorporated by reference to Your employment contract or may, in certain countries, be incorporated to the Internal Regulations of Your Company. You recognize and accept that this Human Resources Privacy Policy does not grant You any other rights than those provided by Your local law.

However, when required by local laws, this Human Resources Privacy Policy may be subject to Your prior consent.

Accor 7 Privacy Principles

The following constitute Accor 7 Privacy Principles, which apply throughout the Accor Group worldwide.

1. Transparency: when collecting and processing Your PI, we will provide You with relevant information and notice, for what purposes and who are the recipients.

2. Legitimacy: we will collect and process Your PI only for the purposes which are mentioned to You in this Human Resources Privacy Policy.

3. Relevance & Accuracy: we will only collect PI which is necessary for the purposes of the data processing as set out in this Human Resources Privacy Policy. We will take all reasonable measures to ensure You that the PI that we have stored is accurate and up to date.

4. Storage: we will keep Your PI for the period necessary for the purposes of the data processing as set out in this Human Resources Privacy Policy and in accordance with local law requirements.

5. Access & Rectification: we offer You ways to access, modify, correct or delete Your PI. Please see contact details below.

6. Confidentiality & Security: we will implement reasonable technical and organisational measures to protect Your PI against accidental or unlawful alteration or loss, or from unauthorized use, disclosure or access.

7. Sharing & International Transfer: we may share Your PI within the Accor Group or with third parties (such as commercial partners and service providers) for the purposes described in this Human Resources Privacy Policy. We will take appropriate measures to secure such sharing and transfer.

If You have any questions about these Accor 7 Privacy Principles, please contact Accor Data Privacy Contact as described in section 12 of this Human Resources Privacy Policy.

Scope

This Employee Privacy Policy is applicable to:

All Accor's employees working for an entity of Accor Group, i.e.:
- any employee of any subsidiary, affiliate or other entity controlled by, or under common control with Accor;
- or any person engaged (directly or indirectly) to perform work for Accor, including as temporary agency worker, trainee or contractor personnel, to the extent their data is processed by Accor in Accor’s systems.

Employees of managed and franchised hotels, as long as their data is processed by Accor in Accor’s systems;

Applicants to a job within an entity of the Accor Group.

Collectively herein after referred to “You”.

What Personal Information?

We collect, process and store to the extent it is relevant and permitted under Your local law, PI on You, Your family and relatives, such as:

Identification data: name, marital name, first name, gender, date and place of birth, nationality, contact information (address, home telephone number, e-mail, name and telephone number of a contact in case of emergency), passport number (for Employees with international mobility), driver’s license number (if relevant for the job), photos;

Social data: work permit number, social security number, and if any, disability rate;

Family status: marital status, name, first name and date of birth of Your spouse or partner, name, first name and date of birth of the children, insurance information and pensions information;

Transportation: any information pertaining to the means of transportation of an Employee, for reimbursement of traveling expenses, such as transportation cards, vehicle expenses, etc.;

Extracts of police records: when this is necessary for the job occupied by the Employee within Accor;
Military status: military situation, if any;

Education and career development: diplomas and training certificates, foreign languages, curriculum vitae (detailing Your work experience and if applicable, continuing education), mobility situation and management of career development actions, track of annual performance evaluation;

Professional life: fixed-term contract, open-ended contract, part-time or full-time job, hire date, termination date, division, department, reporting structure, Employee identification number, job title, work information, telephone number and e-mail address, job description, working time, absence (in particular sick leave, special leave or absence, maternity leave, parental leave), paid holidays (if applicable) and time off given in compensation for extra time worked; personnel representative status (such as member of the works council or of a trade union);

Economic and financial situation: tax and source tax deductions, pay grade, track of salary and other compensation elements, stock options plan, purchase option plan, related payments, pension fund contribution, bank account details;

Any PI Accor is required to collect in order to comply with its obligations as an employer under local law (e.g. trade unions membership, inability rates, etc.);

Your use of Accor’s information system: the conditions in which Your PI is collected and processed with respect to Your use of Accor’s System Resources are set forth in the Accor Information Technology Policy which is incorporated by reference to Your employment contract or in certain countries to the internal regulations of Your company;

Video surveillance and badge control data: Accor implements video surveillance systems in its premises, and access control devices which enable collection and processing of PI such as image recordings, access information and time collection information relating to You;

Whistleblowing hotline: for compliance with its legal obligations, Accor may implement a whistleblowing hotline which permits Employees to report unethical or inappropriate behaviour. Where applicable, the nature of PI collected and conditions of processing are set forth in a specific information notice which is incorporated by reference to Your employment contract or in certain countries to the internal regulations of Your company;

Any other additional PI we need in order to manage the employment relationship or that You supplied us when applying for a position within Accor (e.g. curriculum vitae or application letter, assessment report from external recruiting companies as well as previous managers).

What Sensitive Personal Information?

Accor may collect, use, store, and otherwise process certain sensitive PI about Employees that is necessary for the management of the employment relationship or for legal claims. In particular, Accor processes sensitive data as required by applicable law.
When required by local law, collection of said data is subject to Your express prior consent.

When is my Personal Information Collected?

Your PI may be collected through various means, including without limitation:

Recruitment:
- Accor’s online recruitment websites;
- Any other recruitment resources including external recruiting companies, job interviews, contact with previous employers.

Hiring and Employment relationship: any information collected through:
- Human Resources department interviews and collection forms on paper or electronic format ;
- Evaluation reports;
- Modification of identification data;
- Transportation expenses;
- Benefits information.

Accor internal and international mobility:
- Accor’s Intranet sites notably to manage career path or expatriation;
- Accor’s Human Resources Network.

Security measures:
- Image recordings from video surveillance systems (if any) placed in Accor’s premises;
- Time collection information through badge control devices for access control (if any);
- From other security devices.

Provision of information by third party service providers:
- Recruitment service providers;
- Profit sharing companies.

Usage of Accor’s System Resources: for more information, please refer to the Accor Information Technology Policy.

What are the purposes?

Your PI is collected, processed and stored by Accor, including without limitation for the following purposes:

To comply with applicable local law: such as for the management of:
- Maternity obligations;
- Organisation of professional elections;
- Diversity requirements;
- Working hours;
- Sick leaves;
- Payroll: wages and benefits due under Your employment agreement, annual merit increase, any other salary adjustment, annual bonus payment and pensions management; income tax and social security withholdings.

To check the qualifications:
- Applicants’ PI is collected either directly or indirectly to enable Accor to assess the applicant’s ability to perform the job (e.g. checking his/her references and qualifications).

For international mobility:
- To manage Employees’ mobility within the Accor Group around the world.

To provide services to Employees :
- Employee benefits (e.g. Luncheon Vouchers, Commuter Check Tickets, Ticket Tesorus, Carte bienvenue, Bien-Etre à la Carte, ...).

Stock options: for Employees’ benefits from stock option plans (if any);

Performance and talent management:
- To facilitate Employees’ performance management and career development, notably through annual performance appraisals, annual salary reviews and, if any, disciplinary sanctions in accordance with local law.

Security and monitoring: for the management of:
- Office access (badge control);
- Accor’s System Resources access;
- Security: video surveillance images recordings (if any).

General Management:
- Planning and budgeting;
- Headcount;
- Management of directories;
- Organisational charts;
- Management of Employees files;
- Financial reporting
- Corporate reorganisations, outsourcing, restructuring, acquisitions and divestments.

Resources management:
- For allocation and maintenance of resources, e.g. management of the Employees’ rights to access conference rooms, offices, the IT system and the database.

Training:
- For organisation of training sessions for Employees, (e.g. via Académie Accor).

Creation of marketing documentation:
- For commercial proposals in response to Requests For Proposals (RFPs) submitted by clients;
- Annual reports may include PI on certain categories of employees.

Disclosure to authorities:
- When requested by judicial authorities and/or law enforcement agencies in the context of legal investigations;
- Subject to local law requirements, Accor may use Your PI to protect its legal rights or support any claim, defence or declaration in a case or before any jurisdictional and/or administrative authority, arbitration or mediation panel, in the context of disciplinary actions/investigations or of internal or external audit and inquiries.

Sharing of your Personal Information

Accor may share Your PI with all the relevant personnel within the Accor Group or external recipients such as:

- Service providers involved in the different Human Resources data processing described above;
- Local or other authorities;
- Outside counsels (auditor or attorneys) to establish our legal rights and defend against legal claims;
- Business investors (in the event or merger or acquisition of another company);
- Clients in the course of business proposals or activities.

Accor will share Your PI only when necessary for the purposes above listed. It is Accor’s practice to require the recipients to keep Your PI confidential and to use Your PI only to perform functions for Accor.

Accor reserves the right to disclose Your PI to authorized requests from government authorities, to address national security situations or when otherwise required by law.

International transfers

We may transfer for the purposes set forth in Article 7 of this Human Resources Privacy Policy Your PI to recipients, internal or external, which may be located in countries with different levels of PI protection.

Therefore, in addition to the implementation of the present Human Resources Privacy Policy, Accor implements, , appropriate measures, including contractual clauses, to secure transfer of Your PI to any Accor entity or external recipient located in a country with a level of protection different from the one existing in the country in which the PI is collected.

Data security

Accor takes appropriate technical and organisational measures, in accordance with local law requirements, to protect Your PI against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access. To this end, we have implemented technical measures such as firewalls and organisational measures such as a login/efficient password system, physical protection, etc.

Data storage

We will store Your System PI only for the time necessary for the purposes stated in this Human Resources Privacy Policy, or as permitted by the applicable law.

Access and Modification

You have the right to access and modify Your System PI that Accor may have collected, subject to applicable law requirements.

For this purpose, You may exercise Your rights by contacting Your Data Privacy Contact :

Accor
Data Privacy Dpt.
82 rue Henri Farman
CS 20077, 92445 Issy-Les-Moulineaux

Updates

We may amend this Human Resources Privacy Policy from time to time.

Therefore, we invite You to read this Human Resources Policy posted on Your company’s Intranet or bulletin board on a regular basis and each time You are notified of changes, to check the updates.

Specific Provisions For EU Employees or applicants

Accor recognizes that the European Union has established strict standard of protections regarding the handling of EU Personal Data. Accor has thus elected to submit EU Employees and applicants to specific provisions with respect to their personal data processing.

Therefore, Accor’s practices with respect to EU Employees and applicants personal data are reflected in the Human Resources Privacy Policy as revised in its Sections 5 (“What sensitive personal information?”), 8 (“Sharing of Your Personal Information”) and 12 (“Access and Modification”) which are replaced, by the provisions below. The provisions of the Human Resources Privacy Policy which are not revised below are applicable “AS IS” to EU Employees and applicants.

What Sensitive Personal Information ?

Except when required by local data privacy law, Accor does not collect or process any PI revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, data concerning health or sex life.

If any such information is somehow transferred to Accor (e.g. enclosed in Your CV or application letter) and if not required by the local law, they will be deleted by Accor.


Sharing of your Personal Information

Accor may share Your PI with internal or external recipients in the following way:

The Accor Group: We may share Your PI, only when relevant with the following Accor authorized personnel who need access in the context of their job within Accor for the purposes described above:

- Your supervisors and line manager, Your Human Resources Department; Information Technology personnel, Legal Department, controllers and accounting business managers, Marketing Department, relevant managers of other Accor Group entities for specific categories of data stored on global databases, or for pre-litigation and litigation purposes;
- The General Human Resources Department (DGRH), General IT Department (DGSIT) and other General Departments centralized in Accor S.A. in France.

External service providers: we may share Your PI, when relevant, with third party providers, such as:

- Payroll administrators, benefits providers and administrators, information technology systems providers, financial institutions, pension plan institutions, insurance companies, consultant and professional advisors;
- Employment or recruitment agencies, interim companies and outplacement services;
- Other distributors and suppliers of goods or services such as travel agencies, outsourcers for various services;
- Any other service providers involved in the provision of services to Employees.

Local authorities – internal investigations: we may share information with local authorities in compliance with local regulations, or as part of internal investigations within the Accor Group:

- Tax authorities, social security services, judicial authorities, employment/labour or other authorities;
- Independent public accountants, authorized representatives of internal control functions such as auditors or attorneys, corporate security, and legal firms;
- Your PI may be shared to respond to internal or external audit and inquiries, law enforcement requests, to administrative or judicial authorities or where required by applicable laws, court orders, or government regulations.


Business investors:

- Your PI 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 Accor (or any of its subsidiaries) to potential investors, their auditors, and legal counsels.

Other recipients:

- Clients in the course of a commercial proposal for instance in response to Requests For Proposals (RFPs) submitted by clients.

Access and Modification

You have the right to access, modify or delete Your PI, you can also object to the processing of Your PI as described in this Employee Privacy Policy provided that You have legitimate reasons to do so.

You may also exercise Your rights by contacting locally, the Data Privacy Contact of Your company:

Accor
Data Privacy Dpt.
82 rue Henri Farman
CS 20077, 92445 Issy-Les-Moulineaux

Please note that in the interest of protecting Your privacy, we will need to identify You properly to respond to Your request. To this end, we may request a copy of a valid identification paper such as a current driver's licence, identity card or passport.

If Your PI is not accurate, complete or up-to-date, please provide Your Human Resources Manager with Your request for correction. Any requests for correction will be dealt with promptly in compliance with applicable law.