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This Avantor, Inc. Data Privacy Notice (“Notice”) provides a comprehensive overview of the practices of Avantor, Inc. and its affiliated global companies (collectively referred to below as “Avantor”, “we”, “us” and “our”) with respect to the collection, use, storage and disclosure of personal information collected and processed in the context of the employment relationship (“Human Resource Data”). This Notice applies to Avantor associates and contract workers (past or present), prospective employees, and our employees’ and contract workers’ dependents, beneficiaries and emergency contacts. All such individuals (referred to below as “you” and “your”) should carefully read this Notice.
Commitment to Privacy
We respect your privacy and as a result, we constantly strive to comply with applicable data protection laws and regulations in all countries in which we have operations. To safeguard Human Resource Data and to maintain compliance with applicable data protection laws, regulations and other international standards, we have revised our Global Data Privacy Standard (the “Data Privacy Standard”; please visit this link), which establishes a comprehensive set of privacy principles applicable to the processing of Human Resource Data by all of our business units worldwide. We have also continued to update our privacy and security control measures internally and in our relations with third parties to ensure that the Data Privacy Standard is followed.
Human Resource Data That May Be Collected and Processed
We collect your Human Resource Data from a variety of sources, including information obtained directly from you (for example, through a job application or a change in your home address), information provided by others (for example, by supervisors, co-workers, external service providers or government agencies) and information generated automatically by your activities in the workplace (for example, the number of hours you work, your work history or when you access Avantor computer networks). In the event of a natural disaster or other life/safety emergency, we may rely on public social media posts or other public sources to account for employees if otherwise unable to contact them. Additionally, if there is an investigation of an employee matter, we may obtain information relevant to the incident from external sources including private parties, law enforcement or public sources like news sources and public social media posts.
The Human Resource Data collected and processed by Avantor may include without limitation:
We recognize that some countries and jurisdictions may classify some of the above Human Resource Data as “Sensitive Data,” which includes identifiable information revealing or containing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, criminal history, government-issued identification numbers, geolocation data, genetic data, biometric data, or data concerning health or a person’s sex life or sexual orientation. Avantor commits to abide by applicable data privacy laws in its collection and processing of Human Resource Data, and we will only collect from you Human Resource Data classified as Sensitive Data where required by law or with your explicit consent and/or as necessary to fulfill legal requirements.
Why We Collect Human Resource Data and How We Use This Data
Avantor collects and processes your Human Resource Data for employment-related purposes and business-operation purposes, including to carry out functions and related activities such as: recruiting; personnel administration, records and communications; compensation, incentive, reward, retention, and benefits administration; performance management; training; career development, mentoring and succession planning; management of associate travel and corporate credit cards; operation of an ethics reporting system; investigations concerning possible breaches of law or Avantor policy; business and workforce planning; property management; information systems management; security, including protecting and securing Avantor systems, technologies, confidential information, personnel, customer data and other resources and assets; insurance activities; invoicing, accounting and audit; environmental, health and safety record keeping and compliance; compliance with tax and labor laws or union agreements; establishing and defending against legal claims; satisfying government reporting requirements; responding to and defending against regulator inquiries, investigations and enforcement actions; and as otherwise required by applicable law (all such purposes, functions and activities shall collectively be referred to as, the “Specified Purposes”). We will not process or disclose your Human Resource Data for marketing or advertising purposes without your express authorization and where your consent is sought, we will ensure your consent is knowing, truly voluntary, and that you suffer no adverse consequence from any decision to withhold or revoke your consent.
Transfer, Storage and Disclosure of Human Resource Data
Transfers to the United States
Avantor has implemented global and local human resources information systems and processes (“HRIS”) to maximize the effectiveness and efficiency of our human resources management programs, functions and activities. The HRIS tracks and manages the Human Resource Data associated with all Avantor associates, contract workers and prospective employees via databases stored both inside and outside the European Union. Accordingly, Avantor may transfer your Human Resource Data across borders to these database locations for the Specified Purposes. Although the databases that store the Human Resource Data may be accessible to associates outside of the country where you work (e.g. if your manager is located in another country or your payroll is processed in another country), the majority of your Human Resource Data will be accessed only by authorized staff and managers in your country who need it to carry out their responsibilities in connection with the Specified Purposes.
Human Resource Data transferred from the European Union to the U.S. and to countries other than the United States will be subject to the terms of the “Standard Contractual Clauses” for the transfer of personal data to controllers established in third countries pursuant to Commission Decision 2004/915/EC.
With respect to Human Resource Data transferred to the United States from all other countries and jurisdictions, such Human Resource Data will be treated in accordance with the Data Privacy Standard, which may not be equivalent to the data privacy laws in your country of residence.
Other Transfers and Disclosures
We may also disclose your Human Resource Data as necessary for the Specified Purposes: (1) to other Avantor affiliates worldwide (e.g., if you apply to temporarily or permanently relocate to another Avantor affiliate or your supervisor is employed by another Avantor affiliate); (2) to third-party agents, vendors or contractors who perform services on behalf of Avantor; (3) to an acquiring organization, auditors and other relevant advisors if Avantor becomes insolvent, is involved in a sale or transfer of some or all of its business or there is a change in control; (4) to government authorities for reporting purposes; (5) as necessary for the establishment of legal claims or defenses; (6) as necessary to protect your vital interests (i.e., your health or safety) or the vital interests of another person; (7) to auditors and other relevant advisors in connection with an audit of Avantor; and (8) where legally required to do so. Where a disclosure referenced above requires us to transfer your Human Resource Data to a jurisdiction other than your country of residence, such data will be treated in accordance with the Data Privacy Standard, which may not be equivalent to those in your country of residence.
With respect to disclosures and transfers of your Human Resource Data to third-party agents, vendors or contractors, Avantor will ensure that such agents are obligated by contract to process your Human Resource Data only for the purposes and time periods reasonably necessary to provide the applicable services and to provide adequate security for your Human Resource Data. For transfers to agents, VWR shall remain responsible and liable if a third-party agent that Avantor engages to process your Human Resource Data on its behalf does so in a manner inconsistent with applicable law and our Data Privacy Standard, unless Avantor proves that it is not responsible for the event giving rise to the damage.
Limiting Use or Disclosure
In most cases, processing your Human Resource Data is necessary to conduct our business or to meet legal requirements. However, as more fully described in our updated Data Privacy Standard (please visit this link), in some limited circumstances, you shall have the right to limit our use and disclosure of your Human Resource Data. For example, if we want to use your Human Resource Data for a purpose that is materially different from the Specified Purposes, we will first provide you with notice of the new purpose and provide you with a clear, conspicuous and readily available mechanism to opt-out from our use of your Human Resource Data for such new purpose. In any event, where you have the right to limit our use and disclosure of your Human Resource Data, we shall inform you of such right and provide you with clear, conspicuous and readily available mechanisms to exercise such right. If and to the extent you choose to limit our use and disclosure of your Human Resource Data, we will not engage in any adverse actions against you and such decision will have no prejudicial effect on your employment with us.
Please review our updated Data Privacy Standard (please visit this link) for more information regarding your ability to limit our use and disclosure of your Human Resource Data.
Security
We take reasonable and appropriate measures, including administrative, organizational, technical, and physical measures, to safeguard your Human Resource Data against loss, misuse, theft, and unauthorized access, disclosure, alteration and destruction.
Access and Correction of Human Resource Data
In accordance with applicable law, you may have the right to access, correct, amend, copy or delete your Human Resource Data maintained by Avantor, and to determine if your Human Resources Data is inaccurate or improperly processed. Your right to access your Human Resource Data is conditional and may be refused in certain circumstances. If you wish to exercise this right to access your Human Resource Data, please e-mail dpo@avantorsciences.com.
Retention of Human Resource Data
Your Human Resource Data will be maintained for the duration of your employment at VWR, and then for a variable period, generally six years from the end of your employment or a different period where required by local law and consistent with the Avantor’s then-current records management policies. In addition, certain Human Resource Data will be maintained, as necessary, for longer periods in order to administer Avantor’s continuing obligations to you (e.g., administration of retirement benefits) and where required by local law.
Questions or Complaints
We provide means for you to ask questions or express concerns about our processing of your Human Resource Data, and we also provide a fair process for investigating and resolving complaints regarding matters covered by this Notice at no cost to you. Any questions or concerns you may have regarding your Human Resource Data should be sent to the following email address: dpo@avantorsciences.com.
In compliance with the applicable data privacy laws, we are committed to resolve complaints about your privacy and our collection and use of your Human Resource Data.
If you are located in the European Union, if we do not timely acknowledge a complaint or inquiry regarding your Human Resource Data processed, or do not fully resolve such a complaint or inquiry within 30 days of receipt thereof, you may raise your complaint with the applicable data protection authorities in the European Union (“DPA”), the Swiss Federal Data Protection and Information Commissioner and in other countries as applicable at no cost. The DPAs and the Swiss Federal Data Protection and Information Commissioner will establish a panel to investigate and resolve complaints brought under the applicable data privacy laws and we will cooperate with this panel. We will comply with the advice given by the applicable DPA and Commissioner and take necessary steps to remediate any non-compliance with the applicable data privacy laws. To find the applicable DPA in the European Union, please visit this link. To contact the Swiss DPA, please visit this link.
In addition to cooperating and complying with the DPAs and any other applicable dispute resolution mechanisms or competent ttauthorities, we are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
Limitations on this Notice
Notwithstanding anything to the contrary set forth in this Notice, adherence to this Notice and to the Data Privacy Standard may be limited: (1) to the extent necessary to meet national security, public interest or law enforcement requirements; and (2) by statute, government regulation or case law that creates conflicting obligations or explicit authorizations, provided that, in exercising any such authorization, we can demonstrate that our non-compliance is limited to the extent necessary to meet the overriding legitimate interests furthered by such authorization.
Changes to this Privacy Notice
If changes in laws, business practices or other factors require, we will provide you with a new privacy notice.
Commitment to Privacy
We respect your privacy and as a result, we constantly strive to comply with applicable data protection laws and regulations in all countries in which we have operations. To safeguard Human Resource Data and to maintain compliance with applicable data protection laws, regulations and other international standards, we have revised our Global Data Privacy Standard (the “Data Privacy Standard”; please visit this link), which establishes a comprehensive set of privacy principles applicable to the processing of Human Resource Data by all of our business units worldwide. We have also continued to update our privacy and security control measures internally and in our relations with third parties to ensure that the Data Privacy Standard is followed.
Human Resource Data That May Be Collected and Processed
We collect your Human Resource Data from a variety of sources, including information obtained directly from you (for example, through a job application or a change in your home address), information provided by others (for example, by supervisors, co-workers, external service providers or government agencies) and information generated automatically by your activities in the workplace (for example, the number of hours you work, your work history or when you access Avantor computer networks). In the event of a natural disaster or other life/safety emergency, we may rely on public social media posts or other public sources to account for employees if otherwise unable to contact them. Additionally, if there is an investigation of an employee matter, we may obtain information relevant to the incident from external sources including private parties, law enforcement or public sources like news sources and public social media posts.
The Human Resource Data collected and processed by Avantor may include without limitation:
- Your Name & Contact Information (e.g., home and business addresses, telephone, mobile, fax numbers, email addresses, business instant messenger identity)
- Your Date & Place of Birth
- Your Education & Training (e.g., education level, field and institution, competency assessments, professional licenses and certifications, training courses)
- Your Employment, Performance, & Compensation and Benefits Information (e.g., hire date, employee identification number, job title, position/grade, attendance, department, business unit, supervisor, site, career objectives, performance reviews, performance and leadership ratings, salary, bonus, long term incentives, awards, retirement, family members/dependents, and beneficiaries)
- Your Gender
- Your Marital Status
- Your Race, Ethnicity, & Nationality
- Your Religious Affiliation & Information (only where required by applicable law or with your explicit consent)
- Your Languages
- Your Bank Account Information
- Your Social Security Number or National identifiers e.g., your national ID/passport, residency and work permit status, or other taxpayer/government identification number
- Your Corporate Credit Card Information
- Your Computer, Device & Facilities Access, Use and Authentication Information, Applications usage (e.g., identification codes, log-in passwords, IP address)
- Your Electronic communications transmitted within Avantor corporate network.
- Your Health Data (e.g., names of general practitioners and any medication and/or medical conditions)
- Your Photographs & Other Visual Images of You
- Your Previous Employers & Work History
- Your Professional References & Letters of Recommendation
- Your Work Restrictions & Accommodations
- Grievance Resolutions
- Industrial Hygiene Exposure Assessment & Monitoring Information
- Names & Contact Information of Your Dependents, Beneficiaries & Emergency Contacts
- Date of Birth, Gender, Government Identification Number, & Other Beneficiary/Dependent Information
We recognize that some countries and jurisdictions may classify some of the above Human Resource Data as “Sensitive Data,” which includes identifiable information revealing or containing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, criminal history, government-issued identification numbers, geolocation data, genetic data, biometric data, or data concerning health or a person’s sex life or sexual orientation. Avantor commits to abide by applicable data privacy laws in its collection and processing of Human Resource Data, and we will only collect from you Human Resource Data classified as Sensitive Data where required by law or with your explicit consent and/or as necessary to fulfill legal requirements.
Why We Collect Human Resource Data and How We Use This Data
Avantor collects and processes your Human Resource Data for employment-related purposes and business-operation purposes, including to carry out functions and related activities such as: recruiting; personnel administration, records and communications; compensation, incentive, reward, retention, and benefits administration; performance management; training; career development, mentoring and succession planning; management of associate travel and corporate credit cards; operation of an ethics reporting system; investigations concerning possible breaches of law or Avantor policy; business and workforce planning; property management; information systems management; security, including protecting and securing Avantor systems, technologies, confidential information, personnel, customer data and other resources and assets; insurance activities; invoicing, accounting and audit; environmental, health and safety record keeping and compliance; compliance with tax and labor laws or union agreements; establishing and defending against legal claims; satisfying government reporting requirements; responding to and defending against regulator inquiries, investigations and enforcement actions; and as otherwise required by applicable law (all such purposes, functions and activities shall collectively be referred to as, the “Specified Purposes”). We will not process or disclose your Human Resource Data for marketing or advertising purposes without your express authorization and where your consent is sought, we will ensure your consent is knowing, truly voluntary, and that you suffer no adverse consequence from any decision to withhold or revoke your consent.
Transfer, Storage and Disclosure of Human Resource Data
Transfers to the United States
Avantor has implemented global and local human resources information systems and processes (“HRIS”) to maximize the effectiveness and efficiency of our human resources management programs, functions and activities. The HRIS tracks and manages the Human Resource Data associated with all Avantor associates, contract workers and prospective employees via databases stored both inside and outside the European Union. Accordingly, Avantor may transfer your Human Resource Data across borders to these database locations for the Specified Purposes. Although the databases that store the Human Resource Data may be accessible to associates outside of the country where you work (e.g. if your manager is located in another country or your payroll is processed in another country), the majority of your Human Resource Data will be accessed only by authorized staff and managers in your country who need it to carry out their responsibilities in connection with the Specified Purposes.
Human Resource Data transferred from the European Union to the U.S. and to countries other than the United States will be subject to the terms of the “Standard Contractual Clauses” for the transfer of personal data to controllers established in third countries pursuant to Commission Decision 2004/915/EC.
With respect to Human Resource Data transferred to the United States from all other countries and jurisdictions, such Human Resource Data will be treated in accordance with the Data Privacy Standard, which may not be equivalent to the data privacy laws in your country of residence.
Other Transfers and Disclosures
We may also disclose your Human Resource Data as necessary for the Specified Purposes: (1) to other Avantor affiliates worldwide (e.g., if you apply to temporarily or permanently relocate to another Avantor affiliate or your supervisor is employed by another Avantor affiliate); (2) to third-party agents, vendors or contractors who perform services on behalf of Avantor; (3) to an acquiring organization, auditors and other relevant advisors if Avantor becomes insolvent, is involved in a sale or transfer of some or all of its business or there is a change in control; (4) to government authorities for reporting purposes; (5) as necessary for the establishment of legal claims or defenses; (6) as necessary to protect your vital interests (i.e., your health or safety) or the vital interests of another person; (7) to auditors and other relevant advisors in connection with an audit of Avantor; and (8) where legally required to do so. Where a disclosure referenced above requires us to transfer your Human Resource Data to a jurisdiction other than your country of residence, such data will be treated in accordance with the Data Privacy Standard, which may not be equivalent to those in your country of residence.
With respect to disclosures and transfers of your Human Resource Data to third-party agents, vendors or contractors, Avantor will ensure that such agents are obligated by contract to process your Human Resource Data only for the purposes and time periods reasonably necessary to provide the applicable services and to provide adequate security for your Human Resource Data. For transfers to agents, VWR shall remain responsible and liable if a third-party agent that Avantor engages to process your Human Resource Data on its behalf does so in a manner inconsistent with applicable law and our Data Privacy Standard, unless Avantor proves that it is not responsible for the event giving rise to the damage.
Limiting Use or Disclosure
In most cases, processing your Human Resource Data is necessary to conduct our business or to meet legal requirements. However, as more fully described in our updated Data Privacy Standard (please visit this link), in some limited circumstances, you shall have the right to limit our use and disclosure of your Human Resource Data. For example, if we want to use your Human Resource Data for a purpose that is materially different from the Specified Purposes, we will first provide you with notice of the new purpose and provide you with a clear, conspicuous and readily available mechanism to opt-out from our use of your Human Resource Data for such new purpose. In any event, where you have the right to limit our use and disclosure of your Human Resource Data, we shall inform you of such right and provide you with clear, conspicuous and readily available mechanisms to exercise such right. If and to the extent you choose to limit our use and disclosure of your Human Resource Data, we will not engage in any adverse actions against you and such decision will have no prejudicial effect on your employment with us.
Please review our updated Data Privacy Standard (please visit this link) for more information regarding your ability to limit our use and disclosure of your Human Resource Data.
Security
We take reasonable and appropriate measures, including administrative, organizational, technical, and physical measures, to safeguard your Human Resource Data against loss, misuse, theft, and unauthorized access, disclosure, alteration and destruction.
Access and Correction of Human Resource Data
In accordance with applicable law, you may have the right to access, correct, amend, copy or delete your Human Resource Data maintained by Avantor, and to determine if your Human Resources Data is inaccurate or improperly processed. Your right to access your Human Resource Data is conditional and may be refused in certain circumstances. If you wish to exercise this right to access your Human Resource Data, please e-mail dpo@avantorsciences.com.
Retention of Human Resource Data
Your Human Resource Data will be maintained for the duration of your employment at VWR, and then for a variable period, generally six years from the end of your employment or a different period where required by local law and consistent with the Avantor’s then-current records management policies. In addition, certain Human Resource Data will be maintained, as necessary, for longer periods in order to administer Avantor’s continuing obligations to you (e.g., administration of retirement benefits) and where required by local law.
Questions or Complaints
We provide means for you to ask questions or express concerns about our processing of your Human Resource Data, and we also provide a fair process for investigating and resolving complaints regarding matters covered by this Notice at no cost to you. Any questions or concerns you may have regarding your Human Resource Data should be sent to the following email address: dpo@avantorsciences.com.
In compliance with the applicable data privacy laws, we are committed to resolve complaints about your privacy and our collection and use of your Human Resource Data.
If you are located in the European Union, if we do not timely acknowledge a complaint or inquiry regarding your Human Resource Data processed, or do not fully resolve such a complaint or inquiry within 30 days of receipt thereof, you may raise your complaint with the applicable data protection authorities in the European Union (“DPA”), the Swiss Federal Data Protection and Information Commissioner and in other countries as applicable at no cost. The DPAs and the Swiss Federal Data Protection and Information Commissioner will establish a panel to investigate and resolve complaints brought under the applicable data privacy laws and we will cooperate with this panel. We will comply with the advice given by the applicable DPA and Commissioner and take necessary steps to remediate any non-compliance with the applicable data privacy laws. To find the applicable DPA in the European Union, please visit this link. To contact the Swiss DPA, please visit this link.
In addition to cooperating and complying with the DPAs and any other applicable dispute resolution mechanisms or competent ttauthorities, we are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
Limitations on this Notice
Notwithstanding anything to the contrary set forth in this Notice, adherence to this Notice and to the Data Privacy Standard may be limited: (1) to the extent necessary to meet national security, public interest or law enforcement requirements; and (2) by statute, government regulation or case law that creates conflicting obligations or explicit authorizations, provided that, in exercising any such authorization, we can demonstrate that our non-compliance is limited to the extent necessary to meet the overriding legitimate interests furthered by such authorization.
Changes to this Privacy Notice
If changes in laws, business practices or other factors require, we will provide you with a new privacy notice.