1. Responsible party for personal data processing
NIKE is the responsible party for the processing of your personal data. NIKE may use third parties to process personal data on NIKE’s behalf. NIKE will establish or confirm appropriate contractual protections to safeguard the personal data that is shared with such third parties.
2. Purposes of processing and types of personal data
NIKE processes personal data for various legitimate business and compliance purposes, as follows:
• To support the application process and organizational management
using name, wage, position, department, job characteristics (e.g., position level, exemption status), location, start date, compensation, whether position or applicant has a restrictive covenant, and whether position or applicant are eligible for transfer or secondment.
• To support personnel administration
using name, address, date of birth, gender (consistent with applicable law and with consent where required), nationality (consistent with applicable law and with consent where required), type of employment contract, payment structure (e.g., hourly or salaried), ethnicity (consistent with applicable law and with consent where required), fax number, internet address , and full-time or part-time status.
• To conduct employee relations, talent management, and talent mapping functions
using name, ID, organization (not to include trade union membership), start date, jurisdiction, expat status, language, position, status, full-time/part-time, gender (if permitted by applicable law and with your consent, if required), ethnicity (if permitted by applicable law and with your consent, if required), email, phone number, performance rating for each qualification, licenses or certification required to hold the position.
• To provide technical support,
including password retrieval.
• To expedite the management of your employment relationship
by providing your manager with direct access to limited personal data about you.
• To fulfill government requirements
using information such as tax information, social security information and other statutory information.
• To conduct monitoring and enforcement of company policies and procedures, and compliance with legal requirements
, including issues related to ethics, health and safety. And,
• To assist NIKE Inc., its aﬃliates, or others to exercise legal rights
, including to support any claim, defense, or declaration in a case or before any jurisdictional and/or administrative authority, arbitration, or mediation panel, or to monitor and prevent sexual harassment, discrimination, and/or criminal oﬀenses.
The data elements listed above for each purpose are not necessarily a complete list but should be used as a guide and may need to vary from time to time to fit into the corporate needs and strategy.
3. Special kinds of personal data
NIKE will generally not process certain types of personal data that are regulated as highly sensitive under data protection law unless (i) you have consented, or (ii) the processing is required or permitted by applicable law. These special kinds of personal data include data about a person’s religion or philosophy of life, race, political persuasion, health and sexual life, or personal data concerning trade union membership as well as personal data concerning a person’s criminal behavior, or unlawful or objectionable conduct connected with a ban imposed with regard to such conduct.
4. international data transfers
Your personal data will be stored in databases used by the human resources department, which are part of NIKE’s global human resources information management system (“HRIS”). Although HRIS is the primary system of record for personal data about employees, it is not the only system or tool used. Departments or managers also may use manual files, spreadsheets, access databases, and the like, to manage and store personal data. However, the primary system of record remains the HRIS.
The personal data in the HRIS is maintained (either primarily or as a back up system) on a server by NIKE in the United States of America (“USA”). Your personal data will therefore be transferred to and accessible by NIKE and its global affiliatesfor the purposes outlined above. NIKE may also hire third party processors to process your personal data, including NIKE’s human resources operations located in Regional Shared Service Centers in the Netherlands (primarily servicing the Europe and the Middle East region) and Singapore (primarily servicing the Asia-Pacific region). Your personal data may be located in countries other than the country in which your personal data originally was collected. The laws in those countries may not provide the same level of data protection compared to the country in which you initially provided your data. Nevertheless, when we transfer your personal data to recipients in other countries, including the USA, we will protect that information as described in this Policy and in compliance with applicable law.
If you are located in the European Economic Area (“EEA”) or Switzerland, we take measures to comply with applicable legal requirements and ensure adequate protection for the transfer of personal data to recipients in countries outside of the EEA or Switzerland.
If you have questions about how NIKE handles your personal data, or you would like to access personal data that NIKE holds about you, please contact NIKE as described at the end of this Policy. Any questions that cannot be resolved with NIKE may be raised with local data protection authorities where applicable.
5. Data security
Access to your personal data is strictly controlled through the extensive system security within the HRIS and other tools and systems, and in the Company network. Access is limited to specific human resources professionals and other NIKE personnel and their agents who need your personal data to accomplish their jobs (an example is the recruiter or recruitment company).
6. Data storage
NIKE will record your personal data for as long as necessary to achieve the purposes specified above, unless additional data is required to fulfill legal obligations. Your data will continue on the HRIS system for the period in which NIKE must use it (for example, to prepare government tax statements), and then be archived or deleted, with specific timeframes determined by local laws and good business practice.
7. Access and other rights
You may have rights under applicable data protection law, including, in some instances rights to view personal data that NIKE maintains about you, and to correct or delete inaccurate personal data, and oppose the processing of personal data in some circumstances. If you wish to request access to your personal data or otherwise exercise data protection rights, please contact NIKE as described below. NIKE will respond to your request as soon as reasonably possible, and if your request is not complied with, NIKE will explain to you the reasons for not complying.
If you have questions about your personal data or NIKE’s privacy practices, please contact firstname.lastname@example.org.