Employee Privacy Notice in the E.U.
Data Privacy Notice for Employees in the E.U. and U.K.
This Notice describes Fordham University’s practices concerning the collection, use, storage, and disclosure (“processing”) of Personal Information of employees covered by the European Union’s General Data Protection Regulation (GDPR) and GDPR U.K. This Notice applies to Fordham and its affiliated legal entities and branches (collectively “Fordham,” “us,” or “our”) solely concerning prospective employees of Fordham’s sites in the European Union (the “Sites”). All employees (referred to below as “you” or “your”) should carefully read the provisions of this Privacy Notice.
“Personal Information,” as used in this Notice, means any information that can be used to identify you, whether directly or indirectly, including 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 your physical, physiological, genetic, mental, economic, cultural or social identity.
Additional notices at any data collection point may supplement this general Notice. If you have specific questions about any data processing activities described in this or any other Notice, please contact the Office of Legal Counsel.
The Information We Process About You
We process the information we collect from you directly, either during our communications with you, when you apply for employment, when you sign up for employment benefits, or when you make use of Fordham equipment and systems, facilities, programs, resources, and Fordham services provided by third-party vendors. This includes information about your employment history with Fordham, job performance, compensation and benefits, and your dependents and emergency contacts.
Sometimes, we may require certain information to provide a service or benefit. Failure to provide that information may mean we cannot provide you with a service or benefit.
We use automated decision-making processes to process your data in certain contexts. For example, we may automatically evaluate information about your compensation and benefits to withhold taxes or determine your eligibility for employee benefits or other programs. You can learn more about the logic we use in our automated decision-making processes by contacting Fordham University in London.
In addition, we collect the following kinds of information about you from third parties:
- Information about your employment history and education: We collect information about your employment history and education during the application process or when taking an employment action – such as considering you for a promotion or a new position at Fordham. We may confirm the information you have provided about your previous employers and the educational institutions you attended.
- Information about your professional certifications: We may confirm information you have provided about any professional certifications you might have from third parties that provide or verify those certifications.
- Information about your health: Where permitted by applicable law, we may collect information about your ability to work or your sick leave status from your health care provider or another third party you direct us to confirm your employment status or to provide you with benefits to which you are entitled.
- Information we collect from other employees or students: Other employees or students may provide us with information about you, whether by reporting an incident or complaint, alerting us to an emergency involving you, or as part of the employment process. This information can include your name, information about your behavior or activities, and other information about the situation being reported to us.
- Immigration information: Governments and consulates may provide us with government identification, immigration information, or other information to facilitate travel related to your employment at Fordham. The type of information provided may vary by country, depending on applicable reporting requirements.
Fordham maintains video surveillance and card swipe systems for the security of our premises. Fordham or our contracted service operator may process images and video of you, and information about your use of and access to our premises, in connection with the operation of these systems.
Purposes and Legal Basis for Processing Your Data
We process your Personal Information to administer and manage Fordham programs and services, administer, manage, and evaluate your employment with Fordham, communicate with you regarding your employment, and provide you access to Fordham programs, services, and facilities. We also use data to make strategic decisions about Fordham programs or course offerings, administer those programs, file required reports with applicable governmental authorities, and engage in financial planning. We use your data for purposes required by law, including complying with application retention requirements and enforcing Fordham policies and applicable laws. We combine the data that we collect to provide these functions.
We have the following legal basis for processing the information you provide and that we collect about you during your employment.
We have a legitimate interest in hiring and retaining qualified employees, complying with laws and regulations that govern our conduct in the countries where we operate, and administering Fordham and its programs efficiently, ethically, and appropriately. We process all the information we collect from or about you to meet these purposes. You can obtain additional information about the legitimate interests we have in processing your information by contacting Fordham University in London.
We may be required to process your Personal Information to fulfill our obligations according to a contract of employment or an agreement to receive certain other benefits. You can obtain additional information regarding the processing we do to enter contracts with you by contacting Fordham University in London.
We may also be required to process your Personal Information to comply with laws applicable in the United Kingdom, European Union, or its member states. You can obtain additional information about our processing to comply with applicable laws by contacting the Office of Legal Counsel.
In the case of Sensitive Personal Information, which includes (i) information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership; (ii) genetic and biometric data, and (iii) data concerning health, sex life, or sexual orientation, we process information either (i) because we have your consent to do so or (ii) because we are required to process the information to comply with applicable laws. For example, we may be required to process your trade union membership to deduct applicable trade union fees from your payroll. You can obtain more information about these laws by contacting the Office of Legal Counsel.
When we process your Sensitive Personal Information based on your consent, you may withdraw that consent at any time by contacting the Office of Legal Counsel. If you withdraw your consent, we may still be required to process your Sensitive Personal Information to comply with applicable law, but we will explain to you at the time your consent is withdrawn what processing activities will continue for legal compliance purposes.
Finally, we process your Personal Information for additional purposes compatible with those already described, including conducting scientific, statistical, or historical research or creating archives in the public interest. Where possible, we do not use identifiable information for these purposes, or we take steps, including using pseudonymous data, to limit the amount of Personal Information we use in our research or archives.
Recipients of Your Personal Information
Fordham is concerned with ensuring adequate protection of all Personal Information. In this regard, Fordham endeavors to restrict Personal Information to only those needing access to carry out their duties. Your Personal Information will be received and processed by Fordham employees, students, and personnel, including third parties who provide services to Fordham in connection with the purposes of processing described above, like payroll and benefits service providers, technology providers that support Fordham’s systems and infrastructure, and other vendors acting on our behalf. We share your Personal Information with our service providers only when they have agreed to process your Personal Information only to provide services to us and have agreed to protect your Personal Information from unauthorized use, access, or disclosure. You may contact Fordham University in London to learn more about the categories of service providers to whom your data is disclosed.
We may also disclose your contact information at Fordham in staff and faculty directories available to Fordham students, employees, and the general public. You may request that your information be removed from this directory.
We may provide your information to other universities or entities to facilitate joint activities, including travel, collaborative events, professional affiliations, and research.
We also disclose your information to government authorities as required by laws that regulate immigration, tax, national security, and criminal activity.
Transfers to Third Countries
Fordham is a global university headquartered in the United States. We transfer your data to the United States and the countries where we operate. Fordham offers study abroad programs at international sites outside of the E.U. If you apply for employment at one of our E.U. or U.K. sites, your data will be accessed by our headquarters in the United States and the applicable E.U. or U.K. site as appropriate to evaluate your employment application.
You can find more information about how long we retain personal data by consulting our Records Retention and Disposal Policy. Certain E.U. sites may retain data for shorter or longer periods to meet local legal requirements or business practices. You can obtain additional information about these retention periods by contacting the Office of Legal Counsel.
You have the right to the following information regarding Fordham’s processing of your Personal Information:
- the purposes of the processing,
- the categories of Personal Information concerned,
- the recipients or categories of recipients to whom the Personal Information have been or will be disclosed,
- where possible, the envisaged period for which the Personal Information will be stored, or, if not possible, the criteria used to determine that period.
You also have the following additional rights concerning your Personal Information:
- The right to request access to the Personal Information that Fordham has about you, as well as the right to request rectification of any inaccurate or incomplete data.
- The right to request a copy of your Personal Information in electronic format so that you can transmit the data to third parties or to request that Fordham directly transfer your Personal Information to one or more third parties.
- The right to object to processing your Personal Information for marketing and other purposes.
- The right to the erasure of your Personal Information when it is no longer needed for the purposes for which you provided it, as well as the right to restriction of processing of your Personal Information to certain limited purposes where erasure is not possible.
- The right to lodge a complaint with the supervisory authority in the country where you live or work or where you believe your rights have been violated.
These rights may be exercised through the GDPR Data Request Process.
You can contact Fordham University’s Office of Legal Counsel with questions about this Notice, our data collection practices, or your rights.
Rose Hill Campus
441 East Fordham Road
Cunniffe House, Room 111
Bronx, New York 10458
+1 718 817 3110
Email: [email protected]
Fordham University in London’s local contact is:
Vanessa Beever, Senior Director
Fordham University in London
2 Eyre Street Hill
London EC1R 5ET
Phone: +44 20 3687 2950
Email: [email protected]