Effective Date; June 24, 2019
Please note that this privacy statement will regularly be updated to reflect any changes in the way we handle your Personal Information or any changes in applicable laws.
Privacy of Employee Personal Information
Accenture Federal Services is committed to protecting the personal information of prospective, current, and former employees and that of their dependents with regard to Accenture Federal Services employment-related activities (collectively, Employee Personal Information), while complying with applicable privacy laws and contractual obligations, including agreements and undertakings by, between, and among Accenture Federal Services, Accenture Federal Services subsidiaries, Accenture, and Accenture entities.
This Accenture Federal Services HR Privacy Statement describes how Accenture Federal Services HR interprets and applies Policy AFS-0090, Privacy and Personal Information to Employee Personal Information.
What is Employee Personal Information?
Employee Personal Information is any information from or about a prospective, current, or former employee and any persons they may identify in an employment-related context, including dependents and spouses, that either identifies that person directly or that makes that person identifiable when the information is combined with other information from or about that person.
Employee Personal Information does not include personal information that has been aggregated, excerpted, deidentified, or otherwise anonymized sufficiently that the individual is no longer identified or identifiable and cannot be reidentified using reasonable efforts, resources, and technology.
What Employee Personal Information does Accenture Federal Services HR collect or access?
Accenture Federal Services HR collects, creates, and maintains many types of Employee Personal Information, including information in
- Resumes and employment applications;
- Employment references and interview notes;
- School transcripts, certifications, and credentials;
- Letters of offer and acceptance of employment;
- Evaluations, performance assessments, and disciplinary records;
- Mandatory policy and compliance acknowledgements;
- Benefits-related information including eligibility for short disability and leaves of absence.
- Photographs and video
Accenture Federal Services HR may access the following types of information collected and maintained by Accenture
- Photographs and video;
- Payroll-related information, including social security numbers, financial institution information, wage and benefits information, and tax information;
- Benefits-related information including eligibility, enrollment, and changes in health, welfare, and retirement benefits, including long term disability, medical and dental care; and
- Beneficiary, dependent, and emergency contact information.
Accenture Federal Services HR does not collect information about:
- Racial or ethnic origin;
- Political opinions;
- Religious, philosophical, or other similar beliefs;
- Trade union membership;
- Genetic and biometric data;
- Physical or mental health;
- Veteran status;
- Sexual life and sexual orientation; and
- Criminal record
except to the extent necessary for employment-related or security clearance purposes, to satisfy Accenture Federal Services legal or contractual obligations, and/or when a prospective, current, or former employee has voluntarily provided that information to Accenture Federal Services HR.
Whenever possible, Accenture Federal Services HR collects personal information directly from the individuals or uses personal information that individuals have provided to another Accenture entity or to a third-party acting on Accenture Federal Services’ or Accenture’s behalf. Where permitted or required by applicable law, Accenture Federal Services HR may collect information about prospective, current, and former employees without their knowledge or consent.
How Does Accenture Federal Services Use Employee Personal Information?
Accenture Federal Services collects and uses Employee Personal Information solely for lawful business purposes, including but not limited to functions related to employment relationships. For example, Accenture Federal Services collects and/or utilizes Employee Personal Information for the following purposes:
- Determining eligibility for employment, including the verification of references, education and qualifications, administering pay and benefits;
- Coordinating borrowed resources, transfers, and similar activities with other Accenture entities;
- Processing work-related claims (e.g., worker compensation and leaves of absences);
- Conducting performance reviews and determining performance requirements;
- Establishing a point of contact in the event of an emergency (such as next of kin);
- Complying with applicable labor or employment laws;
- Compiling directories;
- Ensuring the security of Accenture Federal Services HR information; and
- Other purposes as are reasonably necessary to comply with Accenture Federal Services legal and contractual obligations.
Accenture Federal Services HR may use Employee Personal Information for any additional purpose for which the employee has been notified, to the extent required by law, and/or where Accenture Federal Services HR has obtained an employee’s consent to use or disclose her or his personal information. Accenture Federal Services HR may also use an employee’s information in accordance with a written request from that employee or an authorized representative of the employee.
Accenture Federal Services HR may use an employee’s personal information without the employee’s knowledge or consent where permitted or required to do so by applicable law.
When does Accenture Federal Services HR share or disclose Employee Personal Information?
Accenture Federal Services HR does not share Employee Personal Information with third parties for marketing or any other non-Accenture Federal Services business purposes. Accenture Federal Services HR may share Employee Personal Information with other Accenture Federal Services and Accenture entities, employees, contractors, consultants and other parties to the extent necessary to assist Accenture Federal Services HR with establishing, managing Accenture Federal Services’ employment relationships. Accenture Federal Services HR may also share Employee Personal Information to the extent necessary to establish Accenture Federal Services qualifications and eligibility for contracting, billing, performance assessments, and other Accenture Federal Services business activities.
Employee Personal Information may also be disclosed in various other situations, including without limitation (i) as permitted or required by applicable law; (ii) to comply with valid legal processes such as search warrants, subpoenas or court orders; (iii) as part of Accenture Federal Services’ regular reporting activities to others within Accenture Federal Services or Accenture; (iv) to protect Accenture Federal Services’ rights and property; (v) during emergency situations; or (vi) with an employee’s consent where such consent is required by law.
Accenture Federal Services HR may share Employee Personal Information within Accenture Federal Services, with Accenture Federal Services subsidiaries, with Accenture and Accenture affiliates, and with third parties for the purposes described in this HR Privacy Statement. As a result, Employee Personal Information may be collected, used, processed, stored, or disclosed in the United States, and in some cases, in other countries. Accenture Federal Services will receive Employee Personal Information from another country and transfer it to another country only to the extent required or permitted under applicable laws and only subject to agreements that provide assurances that the transfers will be secure and will maintain at least the same level of data protection that is provided by Accenture Federal Services HR, including but not limited to agreements and undertakings by, between, and among Accenture Federal Services, Accenture Federal Services subsidiaries, Accenture, and Accenture entities.
When Accenture Federal Services HR shares Employee Personal Information with third parties, it does so only in conjunction with a written agreement that requires the third party to, among other things, protect the personal information at least as well as Accenture Federal Services HR does, use Employee Personal Information only to the extent necessary to accomplish the purposes for which Accenture Federal Services HR is sharing the information, notify Accenture Federal Services promptly of any incidents involving Employee Personal Information, and require vendors, service providers, and other third parties acting on its behalf to provide the same level of privacy and data security.
How does Accenture Federal Services HR protect Employee Personal Information?
Accenture Federal Services HR incorporates the physical, technical and procedural safeguards developed, implemented, and maintained by the Accenture Federal Services Information Security team and Records Management team to protect Accenture Federal Services non-public information, including Employee Personal Information, against loss and unauthorized access, copying, use, modification, disclosure, retention and disposal. Accenture Federal Services HR also complies with the Accenture Federal Services Incident Response Procedures.
In addition, Accenture Federal Services HR maintains HR-specific physical and other access controls to limit direct access to HR Personal Information to HR staff and to other authorized individuals, including by
- Applying role-based, need-to-know, least-privilege access controls
- Working with and sharing Employee Personal Information in aggregated, excerpted, deidentified, or otherwise anonymized personal information to the extent possible
- Using secure transmission techniques, including but not limited to encryption, when transmitting Employee Personal Information internally and externally
- Treating all Accenture Federal Services materials that include or incorporate Employee Personal Information as Employee Personal Information
- Including a protection reminder notice on all emails, cover letters, transmission sheets, storage media labels, and other means of transmitting or sharing Employee Personal Information with non-HR recipients (including within Accenture Federal Services staff, with LLP and other Accenture entities, and with vendors, service providers, and other third-party entities)
Accenture Federal Services HR retains Employee Personal Information only for as long as it believes is necessary to fulfill the purposes for which the personal information was collected and to comply with Accenture Federal Services legal and business obligations. Accenture Federal Services HR retains or securely disposes of Employee Personal Information in accordance with Accenture Federal Services Records Retention and Records Management requirements. Alternatively, Accenture Federal Services HR may aggregate, excerpt, deidentify, or otherwise anonymize Employee Personal Information and keep the resulting non-personal information for historical, research, analytic, and other purposes.
Accenture Federal Services HR establishes, implements, and maintains processes for providing individuals and entities outside of HR with access to HR systems, files, and Employee Personal Information, including requests for reports based on Employee Personal Information. These processes permit HR to verify that the access is lawful, for an authorized Accenture Federal Services business purpose, and compliant with Accenture Federal Services policies and procedures, including that the request is limited in scope to the least amount of personal information necessary to accomplish the specified business purpose(s), and that the personal information is aggregated, excerpted, deidentified, or otherwise anonymized to the extent feasible. Accenture Federal Services HR reviews, approves, and documents any authorized departures from those processes.
A. HIPAA-Protected Data
Employee Personal Information relating to coverage under Accenture group health plans is subject to specific privacy and data security requirements imposed by the Health Insurance Portability and Accountability Act (HIPAA). Accenture Federal Services HR implements HIPAA-compliant internal controls to safeguard HIPAA-protected personal information when accessing or using such information.
B. EEA Personal Data
Accenture Federal Services complies with international data transfer requirements regarding Employee Personal Information that it collects from and about prospective, current, and former employees located in the European Economic Area (EEA, which consists of the EU Member States, Iceland, Lichtenstein, Norway) and in Switzerland. Specifically,
- Accenture Federal Services has entered into a Data Transfer Agreement with Accenture LLP that permits Accenture LLP to transfer Employee Personal Information from and about individuals located in the EEA and Switzerland to Accenture Federal Services in the United States.
- Accenture Federal Services enters into EU Standard Contractual Clauses with third parties that will be providing Accenture Federal Services with, or receiving from Accenture Federal Services, Employee Personal Information from and about individuals located in the EEA and Switzerland.
- Accenture Federal Services provides a copy of this Accenture Federal Services HR Statement when it collects Employee Personal Information directly from prospective, current, and former employees who are located in the EEA and Switzerland.
What rights do prospective, current, and former employees have regarding Accenture Federal Services HR’s collection and use of Employee Personal Information?
To the extent permitted by applicable law, Accenture Federal Services HR may refuse to honor an individual’s assertion of the following rights where doing so would reveal non-public information about entities and individuals other than the requester, would compromise the privacy of another individual, or would violate Accenture Federal Services legal or contractual obligations. Where Accenture Federal Services can, consistent with its legal and contractual obligations, provide some but not all of the requested information, it will attempt to provide as much of the requested information as possible.
A. Right of Transparency
To the extent practicable and in compliance with applicable laws, Accenture Federal Services HR shall provide information to individuals about how it collects, processes, protects, shares, discloses, and disposes of their Employee Personal Information. This Accenture Federal Services HR Privacy Statement constitutes Accenture Federal Services HR’s notice regarding Employee Personal Information. This Privacy Statement is made available to Accenture Federal Services employees online, and a link or a copy is provided to prospective and new employees and referenced during data training and awareness activities.
B. Right of Access
Upon receiving a request from a prospective, current, or former employee or their authorized representative, together with sufficient information to validate the identity of the individual making the request, Accenture Federal Services HR shall determine whether Accenture Federal Services holds Employee Personal Information about the requester and will, unless prohibited by law or contractual obligation:
- inform that individual whether Accenture Federal Services HR holds Employee Personal Information about him or her;
- describe the Employee Personal Information that Accenture Federal Services HR holds, the reason for holding that Employee Personal Information, and, where required by law, the categories of person to whom it may disclose that Employee Personal Information (e.g. service providers); and
- Provide the individual with copies of the Employee Personal Information held about him or her, together with an indication of the source(s) of the data, if known.
C. Right of Correction
An individual may request that Accenture Federal Services HR correct the Employee Personal Information it holds about him/her. If Accenture Federal Services HR agrees that the Personal Information is incorrect, it will delete or correct the Employee Personal Information. If Accenture Federal Services does not agree that the Employee Personal Information is incorrect, it will, nevertheless, record in the relevant file(s) the fact that the individual considers the Employee Personal Information to be incorrect.
D. Right to Object to Marketing
Accenture Federal Services HR does not currently share Employee Personal Information for third-party marketing purposes and does not permit service providers or others acting on Accenture Federal Services HR’s behalf to use Employee Personal Information for any purposes other than authorized Accenture Federal Services HR business purposes. However, in the unlikely event that Accenture Federal Services HR changes its practices in the future to permit marketing, Accenture Federal Services HR will honor a request from a prospective, current, or former employee not to use his/her Employee Personal Information for marketing purposes, shall do so free of charge to the individual, shall maintain a list of individuals who have submitted these “no marketing” requests, and shall provide that list to all contractors and data processors who engage in marketing on its behalf of all such requests.
E. Right to Withdraw Consent Previously Given
Employee consent is generally not required under applicable law for Accenture Federal Services HR to collect, use, or disclose Employee Personal Information for the purposes of establishing, maintaining, or terminating an employment relationship. However, to the extent, if any, that Accenture Federal Services HR is collecting and using Employee Personal Information based solely on an employee’s consent, Accenture Federal Services HR shall permit that individual to withdraw consent at any time, to the extent consistent with Accenture Federal Services HR legal and contractual obligations. Accenture Federal Services HR will, within 10 days of receiving a withdrawal of consent, cease processing that individual’s Employee Personal Information to the extent practicable and consistent with Accenture Federal Services legal and contractual obligations and shall also notify all vendors and data processors acting on Accenture Federal Services HR’s behalf to cease relying on that consent to process the individual’s Employee Personal Information.
F. Other Rights Under Applicable Privacy Laws
An individual may have additional rights under other applicable federal, state, and international privacy laws.
How do prospective, current, and former employees get more information about Accenture Federal Services HR’s practices regarding Employee Personal Information?
Any questions about how Accenture Federal Services HR collects, uses, and discloses Employee Personal Information, assertions of rights, or other issues regarding this Accenture Federal Services HR Privacy Statement, and Policy AFS-0090 should be addressed to at AFS.Data.Privacy@accenturefederal.com