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Employee Privacy Policy (Nike Global)

Last updated: June 2019.

Nike collects and processes the Personal Information that you provide to us as part of our employee on-boarding process. We also collect and process additional types of Personal Information about you throughout your employment with Nike to administer our human resources program, to comply with employment contracts and applicable law in the field of employment, social security, workplace health and safety, and to manage your participation in voluntary employee programs.Your Personal Information may be stored in Nike’s databases in the United States and may be processed by third party service providers acting on Nike’s behalf. If you would like to access, delete, correct your Personal Information, or exercise any other rights you may have under this Policy, please contact directly your local HR manager. You may also contact Nike’s Privacy Office or Data Protection Officer by emailing privacy.office@nike.com.

 

1. Introduction and Scope

1.1 Nike Inc., Converse Inc., their affiliates, including your employer (collectively “Nike”, “we”, “our”) respect your privacy. We are committed to processing the Personal Information of our employees in compliance with applicable law and Nike’s policies. For the purpose of this Policy, “Personal Information” means any information relating to an identified or identifiable natural person.

1.2 This Employee Privacy Policy (“Policy”) describes the types of Personal Information we collect and process about our employees, how we use the Personal Information, with whom we share it, how long we keep it, and your rights in relation to your Personal Information. This Policy also describes the measures we take to safeguard the Personal Information and how employees can contact us about our privacy practices and in case of questions. The entity responsible for the collection and processing of your Personal Information is your employer of record. You can access the full details of your employer by checking your employment contract or by reaching out to HR Direct.

1.3 This Policy applies to current and former employees and interns of Nike (collectively “employees”).  If you are an External Temporary Worker (“ETW”) or an independent contractor providing services to Nike, please contact your direct employer to inquire about their data protection practices.1.4 Nike may provide additional privacy or data protection notices and policies to employees in specific functions, as appropriate. Nike may also provide additional privacy or data protection policies in jurisdictions where this is required for compliance with local law.1.5 This Policy applies in addition to all other corporate policies of Nike, including Code of Conduct ("Inside the Lines")Acceptable Use PolicySocial Media Policy, and Applicant Privacy Policy, available on Zero. 

 

2. Types of Personal Information We Collect and How We Use It

2.1 We collect and process Personal Information about you as far as necessary to manage the terms of your employment agreement and to comply with legal obligations to which we are subject. This includes Nike’s legal defense and compliance with tax, finance, labor and social security laws, or laws and orders requiring the disclosure of data to competent authorities in accordance with applicable law or court order. We also process your Personal Information to pursue the legitimate business interests of Nike. When processing Personal Information for our legitimate interests, we take appropriate measures to ensure that the interests we pursue are balanced with your interests, rights and freedoms, which we are happy to explain to you upon request. We use manual or automated methods to process your Personal Information.

2.2 ONBOARDING

We collect and process your Personal Information through the onboarding process to set up and administer your employment relationship and to comply with the legal obligations to which we are subject. This includes:

  • the information that you provided to us during the recruitment process, including your resume or curriculum vitae, application form, work history, education, degrees, academic records, languages and qualifications, references and any professional licenses, memberships, or certifications
  • your basic contact information, including your name, address, telephone numbers (home, mobile/cell, work), email address, citizenship/nationality, date and place of birth, gender, work permit information if applicable
  • your government issued identifiers subject to the conditions of applicable law, such as your national ID details, tax identification number, social security or national insurance number, passport number, and, where required for your job, your driver’s license number
  • your bank and financial details for salary/payroll purposes, such as your salary, other remuneration, your IBAN number or bank account number, bank name and details
  • information about your job and position, including the employee identification number, badge number, job title and description, department and manager, reporting lines, work location, cost center, business unit or group, work status such as full time or part time, working hours, probation period if applicable, and employment contract terms
  • information for use of company network and devices if applicable, such as username, password, contact details, work telephone number and device data (computer, telephone, tablet ID number), company photo, if provided; and
  • information about your personal or family life, including marital status, dependents, beneficiaries and partner/spouse, and emergency contact information
  • We may maintain the information we collect when we conduct pre-employment verification of your identity, address, or references and, where permitted by local law, the verification of background checks (including criminal or judicial data) about you, in accordance with Nike’s Background Checks Policy.
2.3 HUMAN RESOURCES MANAGEMENT

Furthermore, we collect Personal Information that is generated during your employment as this is necessary for the performance of your contract and to help manage your working relationship with Nike. This includes:

  • information about your working hours and leaves, including attendance, holiday/vacation, leaves or absences, travel and mobility
  • economic and financial information for compensation and benefits, including your banking and account details for remuneration and compensation, information on raises and bonuses, your benefits package and information and details associated with pensions or insurance programs that may be offered in your country
  • information related to your work evaluations and performance, including regular evaluation details, reviews and feedback, details about performance plans, and information associated with professional development such as trainings (both internal and external), courses, seminars and conferences, and succession planning information
  • information collected for travel and expense purposes, such as credit card, bank details (account number, IBAN, etc.), booking and itinerary details, passport information (number, expiration, issuing authority, etc.) and visa and immigration information, and travel preferences (seat preference, dietary restrictions, frequent flyer and corporate memberships, if provided)
  • information associated with mobility, transfers and relocation (either upon hiring or as part of a transfer or work assignment), including family details, immigration status and nationality/citizenship, tax and social security information, etc. and
  • information about your participation and the administration of the Nike Inc. Employee Stock Purchase Plan (ESPP – which is a voluntary incentive program, please also see paragraph 2.6) and bonus grants, including your contact information, national tax information (including national identifier), nationality, job title, shares and position, details of purchases and entitlements to shares awarded, cancelled, exercised, (un)vested or outstanding for implementing, administering and managing the ESPP.
2.4 SAFETY AND SECURITY
  • Our facilities use CCTV for employee safety, security and other legitimate business purposes (for example, loss prevention). The facilities that use CCTV display visible signage and we make available additional information about these practices where this is required by applicable law. We therefore may need to use camera footage or recordings in those facilities to protect the legitimate interests or to defend the legal rights of Nike as permitted by applicable law.
  • We also process Personal Information associated with the protection of employee health and safety in workplaces, including contact details and Personal Information (such as driver’s license details) and a description of accident or injury and any remediation.
  • Additionally, we process information about your use of Nike devices, technology and network to pursue our legitimate interest in securing our information and information systems. More information about these practices is described in Nike’s Acceptable Use Policy.
  • In exceptional cases, we may need to process your Personal Information if it is necessary to protect your vital interests such as in case an accident happens at work or during work business travel.
2.5 OFFBOARDING

We collect and process Personal Information during offboarding to finalize the employment relationship and to comply with our legal obligations. This includes information associated with retirement and termination, such as details of retirement, resignation, layoffs/reorganization, including notice period, termination date, reason for leaving and termination, retirement, and pension administration arrangements.

2.6 VOLUNTARY PROGRAMS

From time to time, we may offer voluntary employee programs that process Personal Information in which you may freely agree to participate.

2.7 SENSITIVE DATA PROCESSING

During onboarding and throughout your employment relationship, we may collect sensitive Personal Information subject to the conditions of applicable law. For example, you may need to provide us or our company doctor with medical information to allow us to manage illness, incapacity, or disability issues. In some countries, you may provide us voluntarily with your race, ethnicity, religion or sexual orientation for diversity and equal opportunities purposes and where required or permitted by law. We also may be required to collect sensitive data to comply with our legal requirements in the field of employment, social security and social protection law (e.g., wage liens, tax or social security number).

2.8 OTHER LEGITIMATE BUSINESS PURPOSES

We may need to use your Personal Information based on our legitimate interest as necessary to conduct investigations, defend Nike’s legal interests, exercise claims or litigation and comply with judicial or regulatory orders. We may also need to maintain disciplinary and grievance records (such as records of allegations, investigations or audits), as permitted or required by law. We process Personal Information as necessary to operate Nike’s Alertline in accordance with Nike’s Code of Conduct ("Inside the Lines").

3. Sources of Personal information

3.1 We strive to obtain Personal Information directly from you to keep it accurate, up to date and relevant. Collection of Personal Information may occur during the job application process, during the employee on-boarding process, or on an ad hoc basis throughout your employment.

3.2 We also receive Personal Information about you from your line manager (for example, for performance or annual reviews) or from other colleagues (for example, in the context of periodic reviews, evaluations or if conducting a disciplinary investigation). From time to time, we may receive Personal Information about you from other third parties, for example clients, store partners, members of the public and regulatory bodies.

4. Disclosures of Personal information

4.1 We share your Personal Information with other entities of Nike for administrative purposes where required to run global processes, carry out group wide reporting, or take decisions about senior hires or promotions based on our legitimate interest to administer our HR operations. This is typically administered by our HR Direct service centers serving Asia, Europe, and the rest of the world; these are located in Singapore (Nike Trading Company B.V., Singapore Branch), the Netherlands (Nike European Operations Netherlands B.V.) and the U.S.A (Nike, Inc.) respectively.

4.2 As a global company, Nike relies on service providers and vendors that provide products and services; your Personal Information will be disclosed to these third-parties based on our legitimate interest to engage third parties where necessary for the purpose of achieving the objectives outlined above. These include accountants, law firms and legal service providers, tax or financial professionals, payroll and benefits providers, relocation companies, pension and insurance companies, human resources specialists, consultants, contractors, IT support and storage providers. Many of our global HR service providers are located in the U.S.A. and in countries outside of your country of employment.

4.3 Our third party service providers may have access to your Personal Information to perform certain functions, or may host your Personal Information as part of a “cloud based” solution used by Nike employees. Nike uses third party service providers that provide sufficient guarantees for the protection of your Personal Information. All vendors are to undergo Nike’s vendor risk assessment. Nike requires third party service providers by contract to implement appropriate data security and confidentiality obligations, in accordance with applicable law.

4.4 Some third parties to whom we may disclose Personal Information, for instance health insurance providers and pension scheme trustees, are data controllers in their own right, and you should refer to their own privacy policies in respect of how they use your Personal Information.

4.5 We may be required to disclose your Personal Information to third parties in response to orders or requests from courts, regulators, government agencies, parties to a legal proceeding or public authorities, or to comply with regulatory requirements.

4.6 Your Personal Information may also be disclosed to advisors, potential transaction partners or interested third parties in connection with the consideration, negotiation or completion of a corporate transaction or restructuring of the business or assets of any part of Nike.

5. Cross-border Data Transfers

5.1 The global nature of our business means that your Personal Information may be disclosed to Nike entities or to third party service providers or partners, located outside the country where you work. For internal administration purposes, your Personal Information will be stored on Nike servers in the United States or other databases used by Nike’s human resources departments locally or regionally. We also use backups to maintain the integrity of your Personal Information and our systems, depending on your location.

5.2 We rely on an Intra-Group Data Transfer Agreement(s) to ensure your Personal Information receives an adequate level of protection throughout the Nike entities. Subject to applicable law, we enter into data transfer agreements with our service providers or verify that our service providers are certified under appropriate data protection schemes.

6. Security of Personal information

6.1 Nike implements physical, technical and administrative security measures designed to protect your Personal Information from loss, misuse, alteration, destruction or damage. Please see Nike’s Information Security Program (“NISP”) for more information. We make reasonable efforts to ensure the level of security is appropriate to the risk associated with the processing of Personal Information.

6.2 We also implement access controls to ensure that access to Personal Information is limited to Nike personnel who need to have access to perform their duties.

7. Retention of Personal information

We retain employee Personal Information for as long as is required to satisfy the purpose for which it was collected. In certain cases, legal or regulatory obligations require us to retain specific records for a designated period of time, including beyond the conclusion of your employment. In other cases, we retain records to resolve queries or disputes that may arise from time to time and where permitted by applicable law. For more information about Nike's data retention practices, including in respect of employee records, please refer to Nike’s Records Retention Policy

8. Your Rights

8.1 Depending on where you are located in the world and on applicable law, you may have certain rights with respect to your Personal Information. You may request:

  • access and obtain a copy of the Personal Information we maintain about you
  • correction of your Personal Information that is inaccurate, incomplete or outdated
  • erasure of your Personal Information in certain circumstances provided by law, such as where your Personal Information is no longer necessary for us to have it
  • restriction the use of your Personal Information in certain circumstances provided by law, such as while we consider another request that you have submitted
  • export the Personal Information we process based on your employment contract and transmit it to another company where technically feasible

You may also have the right to object to the processing of your Personal Information on grounds relating to your particular situation and may withdraw your consent, if you have previously consented. These rights are not absolute.

8.2 We will comply with your request to the extent required by applicable law taking into account any applicable timeframes and exceptions.

8.3 You may also consult or lodge a complaint with the supervisory authority in your country.

9. Contact Information

If you have questions regarding this Policy or would like to exercise your rights, please contact your local HR manager. You may also contact Nike’s Privacy Office or Data Protection Officer by emailing privacy.office@nike.com.

 

MAINLAND CHINA ADDENDUM

Date: June 2019

If you reside in mainland China, the following additional mainland China-specific provisions apply to the processing of your Personal Information:We collect and process the following additional categories of your Personal Information:

  • In addition to those listed under Section 2.2 of the Nike Global Employee Privacy Policy - your health information when you participate in a pre-employment health check.

Finally, in addition to the service centers listed in Section 4.1 of the Nike Global Employee Privacy Policy, there is an additional center serving Greater China located in Shanghai (Nike Sports (China) Co., Ltd.).

Agreement Type: 
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