Employee Privacy Notice
Personal Data notice
This notice provides information on VOLVO’s processing of your personal data.
The company you are employed by (“VOLVO”) is the controller of the personal data that VOLVO obtains from you and the other sources described below. Controller means that it is VOLVO that decides on the purpose and means for the processing of your personal data. VOLVO is responsible for the processing of your personal data under applicable data protection laws and regulations. VOLVO’s processing of your personal data is necessary with regard to your employment at VOLVO. If you have questions regarding the processing of your personal data, please contact VOLVO’s data protection officer.
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VOLVO may process the following categories of personal data. Please note that it is not necessarily so that VOLVO will process all the personal data listed below. Please note that the examples listed under each category are not exhaustive.
Individual data, such as name, date of birth, social security number (or equivalent), gender, nationality, preferred language, marital status, photo
Organizational data, such as employee number, job description, position, place of work, business unit, department, manager, direct reports
Contact data, such as work address, home address, email, telephone number
Compensation and benefits data, such as salary, salary reviews, tax deductions, pension information, bank account details
Employment administration data, such as employment contract and other agreements between you and VOLVO, applications or other forms regarding e.g. parental leave, information about hiring date and termination date
Time data, such as working hours, worked time, vacation, leaves of absence (parental leave, sick leave etc.)
Union membership data, if applicable and relevant
Security data, such as access cards, access rights and use of access cards and access rights
Health and safety data, such as information about sick-leave, rehabilitation plans, work related incidents, health examinations
Manufacturing/repair/service data, such as tracking and logging of activities undertaken by you in connection with manufacturing, maintenance, repair or service on vehicles
Performance and evaluation data, such as evaluations, assessments and disciplinary records, if any
Competence data, such as learning records and training activities
Travel administration data, such as information on business trips, booking details, passport number, company credit card number, travel invoices and allowances
Help desk and support data, such as questions from you/your manager/HR relating to your employment or IT-equipment or support provided to you in relation to the same
IT-related data, such as user-ID, passwords, log-in details as well as data and logs about your use of VOLVO’s IT equipment, application or services, as per VOLVO’s IT policies, as applicable from time to time
It is specifically noted that union membership and some aspects of health and safety data are regarded as Sensitive Data under the applicable data protection laws and shall be handled with extra care. It is specifically noted that Sensitive Data must only be processed in case of legal obligation, authorized by collective bargaining agreement and/or explicit consent.
Please also note that certain vehicle generated data (for example vehicle/chassis number, signals etc) are automatically generated when you use a Volvo-owned product, for example a truck. However, VOLVO does not use such data unless the usage is linked to testing activities, solving quality issues or product development purposes. Please note that this section does not refer to company cars.
VOLVO may also process limited amount of personal data (name and contact details) of persons indicated by you as persons to be contacted by VOLVO in case of emergency. In some countries, next of kin data may also be processed for certain purposes relating to benefits and/or labour law requirements.
VOLVO will process your personal data based on either of the following legal grounds, see also further details below.
Legal obligation. Example, VOLVO may be obliged by law to report your income to tax authority.
Contractual obligation. Example, VOLVO must process your personal data to be able to pay your contractually agreed salary.
Legitimate interest. VOLVO’s legitimate interest is normally to manage its daily operations, secure its facilities and equipment and keep internal control. In order to base its processing of personal data on the legitimate interest-basis, VOLVO makes an assessment on case-by-case basis. Example, VOLVO needs to process certain personal data to enable administration of your business-related travels where VOLVO’s legitimate interest is to manage its daily operations; or VOLVO needs to process certain personal data to review the status of its IT-equipment where VOLVO’s legitimate interest is to secure its equipment.
In exceptional cases and only when no other legal ground can be applied, VOLVO may ask for your explicit consent to process your personal data.
VOLVO will process your personal data, as exemplified above, for the general purposes stated below. Please note that the examples listed under each purpose are not exhaustive.
Administration (normally based on contractual obligation and/or legitimate interest)
Enabling registration of you in VOLVO’s systems and general administration of your employment with VOLVO
Enabling proper license usage
Enabling keeping an up-to-date organization chart and record of employees, including production of internal reports and statistics
Enabling payment of salary, pension and other benefits to you, as well as reviews of salary, including production of internal reports and statistics
Enabling follow-up on projects
Reporting (normally based on legal obligation and/or legitimate interest)
Enabling reporting to authorities, as required by law, such as tax agency
Enabling keeping track of your working time/leaves of absences/vacations, for remuneration as well as invoicing purposes
Labour law requirement (normally based on legal obligation)
Enabling fulfillment of VOLVO’s obligations as per collective bargaining agreements with unions or by labour law
Work environment and product safety (normally based on legal obligation and/or legitimate interest)
Enabling fulfillment of VOLVO’s obligations to provide a safe work environment (including control and prevention of unauthorized access to VOLVO’s premises or equipment) and other work environment obligations as set out by work environment or labour laws
Enabling fulfillment of VOLVO’s obligations related to product safety and quality
Employee development (normally based on legal and/or contractual obligation and/or legitimate interest)
Enabling activities regarding competence development/improvement as well as performance evaluations and assessments
Enabling and suggesting learning and training activities
Employee work related activities (normally based on legal and/or contractual obligation and/or legitimate interest)
Enabling the performance of your work tasks, such as writing emails, establishing documents, reports, presentations, drawings etc.
Enabling business travels
Enabling answering questions from you/your manager/HR regarding your employment or IT-equipment/services or provision of support necessary for the performance of your work tasks
Enabling follow-up of VOLVO’s policies, including Volvo Group Code of Conduct and VOLVO’s IT policies, as applicable from time to time, to ensure that such policies are adhered to and to investigate suspected prohibited activities
Research and development and solving quality issues (normally based on legitimate interest)
Enabling research and development activities related to Volvo products (e.g. trucks), involving the use of vehicle data generated when you have used a Volvo-owned product (see above)
Enabling solving quality issues related to Volvo products (e.g. trucks), involving the use of vehicle data when you have used a Volvo-owned product (see above)
VOLVO will primary obtain your personal data from yourself, your manager or HR or other third party to whom you have directed us to obtain your personal data. Some personal data might also be automatically generated from VOLVO’s IT-system, or equivalent, for example when creating your user-id to VOLVO systems.
VOLVO will normally not share your personal data with anyone outside of the Volvo Group, unless required by law, regulation or collective bargaining agreement. However, VOLVO may, if necessary to fulfill the purpose for processing the personal data, share your personal data with other Volvo Group company, including company outside of EU/EEA. Volvo may also, if necessary to fulfill the purpose for processing the personal data, share your personal data with third party suppliers, including supplier outside of EU/EEA. VOLVO will in all cases use all reasonable endeavors to satisfy itself that there are appropriate safeguards in place which provide adequate levels of protection of your personal data as required by applicable data protection laws. For example, this may include the use of intercompany or external data processing agreements based on EU approved Standard Contractual Clauses or EU-US Privacy Shield or such other mechanisms as have been recognized or approved by the relevant authorities from time to time. If you have questions about the transfer, please contact VOLVO’s data protection officer.
VOLVO will normally keep your personal data during the employment. After your employment has ended, VOLVO will only keep the personal data deemed necessary for the fulfillment of the purposes for which it was collected and only up and until such purpose has been fulfilled or, if later, for such time as may be required to comply with local legal, tax or benefits obligations or to satisfy any legal requirements in the event of an actual, threatened or anticipated dispute or claim.
You have the right to request access to your personal data. You also have the right to request VOLVO to rectify or erase your personal data or restrict the processing of the same. You may also object to VOLVO’s processing of your personal data or request data portability. However, please note that VOLVO may not always be obliged to comply with a request of deletion, restriction, objection or data portability. Assessment will be made on a case by case basis of VOLVO’s legal obligations and the exception to such rights.More information about Data Subject Rights