Our company is a Swiss subsidiary/branch of a multinational corporate group. Our parent company's headquarters in Norway intends to centralise the human resources data file of the whole group in Norway. Are there any restrictions applicable to such centralisation?
Yes. The intended centralisation involves a disclosure and transfer of personal data abroad which is – even within the same group of companies – only permitted under certain circumstances (see section B above). Further, under Swiss employment law, employers may only collect and process data about employees which is necessary for the performance of the employment relationship. As files of human resources data often contain sensitive personal data or personality profiles, employees may have to give explicit consent to the transfer of their data abroad. Additionally, a registration of the data file with the Swiss Data Protection and Information Commissioner might be necessary (see Registration of Data Files).