The partial or even comprehensive outsourcing of the processing of employee data is generally recognised and corresponds to common practice. The FDPIC also considers this to be permissible in principle. Accordingly, the outsourcing of the processing of employee data does not require a legal basis in the employment contract.

Centralised data processing often involves the transfer of employee data to other group companies outside Switzerland. Considering that data may be forwarded to other group companies in various locations, the scope of the transfer outside Switzerland may be significant. Intra-group processing must always be carefully examined for its lawfulness on a case-by-case basis. Appropriate precautions will need to be taken to ensure compliance with the FADP in this respect (see Data Transfers Abroad).