Privacy of Employee Information
This policy applies to all employees of IHG who have access to, control or management of employee records, including personally identifiable or non-public information. The Policy covers all personally identifiable, non-public information related to employees, whether manually or electronically collected, processed or stored, regardless of whether such information is transferred out of the country of residence of each employee.
The purpose of this policy is to ensure legal compliance throughout IHG business operations in various countries. The focus of privacy regulation is to protect customers and employees from identity theft or fraud, possible embarrassment resulting from indiscretion with their private details, unfair treatment or deceptive marketing.
Collection and Use of Employee Information
Employee information is collected for the purposes of employment, including the provision of any health, retirement or other benefits, and information generated by IHG relating to performance, compensation or other employment related matters. The collection and disclosure of this information, and the employees? ability to access it, is subject to the law of the jurisdiction of the IHG work location.
Collection of information for purposes unrelated to employment can only be done with the informed permission of the employee with the option to decline contribution of such information.
Transfer of Information
IHG management has the discretion to use third party services to carry out business operations. Such third parties must conform to IHG policies and provide sufficient assurance of safeguards. Such third parties must also comply with applicable legal regulations.
Retention of Information
Employee information will be retained for the minimum period of time required by government authorities and extended only if necessary for business operations.
Personally identifiable information of employees will be treated as confidential.
Reasonable and adequate safeguards must be provided to protect against loss, misuse, unauthorized access, disclosure or alteration.
Employees Right of Access
Employees will be provided with prompt access to his or her personal information during normal working hours and IHG will endeavor to respond in a timely manner with the employee?s request. However, unless prohibited by applicable law in the employee?s country of residence or work location, IHG may choose to withhold access to information related to pending decisions related to that employee?s compensation, benefits or continuation of employment. In addition, unless prohibited by applicable law in the employee?s country of residence or work location, IHG may withhold information that would be protected under law by the attorney-client or attorney work product privileges, and may remove some information from an employee?s file before providing access if necessary, in IHG?s judgment, to protect the privacy of another employee.
If any employee concludes that any personal information is inaccurate, they will be provided with procedures for updating, deleting or changing information, with appropriate documentation to verify the inaccuracy.
IHG may disclose personally identifiable information relating to its employees if required to do so by law or in the good faith belief that such action is necessary to:
a) Comply with applicable law or with legal process served on IHG;
b) Protect and defend the rights or property of IHG; and,
c) Act under exigent circumstances to protect the personal safety of IHG employees or the public.
Failure to adhere to this policy may result in disciplinary action by IHG. In addition, data protection authorities in various countries may have jurisdiction to impose legal penalties on individuals.