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Global HR Data Privacy Policy

Varian Semiconductor Equipment Associates, Inc.
Global HR Data Privacy Policy
(Effective September 24, 2010)


Varian Semiconductor Equipment Associates, Inc. is the leading producer of ion implantation equipment used in the manufacture of semiconductors and is a provider of precision material modification solutions. The company is headquartered in Gloucester, Massachusetts, U.S.A. and operates worldwide.

This Policy Statement relates to Varian Semiconductor Equipment Associates, Inc. also referred to as “VSEA.” The policy describes how information about employees, contractors, consultants, and job applicants is collected, used, and disclosed to fulfill VSEA’s business requirements, responsibilities to these individuals, and legal obligations.

U.S. - EU Safe Harbor Privacy Statement

VSEA adheres to the Safe Harbor Agreement concerning the transfer of personal data of employees, contractors, consultants, and job applicants from the European Union (“EU”) and Switzerland to the United States. Accordingly, we follow the Safe Harbor Principles published by the U.S. Department of Commerce (the “Principles”) with respect to all such data. If there is any conflict between the policies in this privacy policy and the Principles, the Principles shall govern. This privacy pol­icy outlines VSEA’s general policy and practices for implementing the Principles, including the types of information VSEA gathers, how VSEA uses it, and the notice and choice affected individuals have regarding VSEA’s use of and their ability to correct that information. This privacy policy applies to all personal information received by VSEA whether in electronic, paper or verbal format.

VSEA’s Safe Harbor certification can be found at For more information about the Safe Harbor Principles, please visit the U.S. Department of Commerce’s Website at


“Personal Information” or “Information” means information that (1) is trans­ferred from the EU to the United States; (2) is recorded in any form; (3) is about, or pertains to a specific individual; and (4) can be linked to that individual.

“Sensitive Personal Information” means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosoph­ical beliefs, trade union membership, consumer credit, criminal records or that concerns an individual’s health.

Safe Harbor Principles


The multinational reach of VSEA’s human resources information system means that information relating to employees, contractors, consultants, and job applicants is transferred to and accessible to authorized personnel in the United States and other countries where VSEA operates. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Information to VSEA, or as soon as practicable thereafter, and before VSEA uses or discloses the Personal Information for a purpose other than for which it was originally collected.

What Information Is Maintained

VSEA maintains an enterprise resource planning system that provides electronic communications among locations in different countries. This capability facilitates product development, business planning, compliance with corporate policies, and administration of human resources and employee benefits programs.

To fulfill its responsibilities as an employer, VSEA maintains several types of individually identifiable information for each employee, as illustrated below:

  • Basic information, such as the employee's name; date of birth; citizenship; veteran status; security or social insurance number; education; gender; home address and telephone number; emergency contact information; photograph; and immigration and passport information. Additional information such as the voluntary self-identification of race and ethnic origin is maintained for US employees and job applicants.
  • Administrative information, such as internal employee numbers, job title and department, computer network username and e-mail address; work location and telephone number; dates of hiring/separation; work hours; and leave status.
  • Employment and performance information, such as hiring and recruitment records; performance appraisals and assessments; date of assignments; transfers; and promotions; training records; attendance records; disciplinary actions; and records of work accidents.
  • Compensation and benefits administration information, such as salary or wage data; tax and benefits accounting records; dependent and beneficiary information; benefits enrollment status; and leave records.

In accordance with applicable local legal requirements, VSEA may hold and process Sensitive Personal Information for purposes related to your employment.

The same types of information may be held in relation to other workers of VSEA, such as independent contractors and consultants.

In addition, applicants for jobs at VSEA will provide Personal Information in application forms they submit, whether directly to VSEA, or to one of VSEA’s recruitment partners for use on VSEA’s behalf. Such information is likely to include details of previous employment and basic information of the type described above. In addition, VSEA or a third party verification agency on its behalf may undertake background checks on job applicants. The results of those checks, which may include sensitive data in the form of consumer credit or criminal records, may also be held by VSEA as part of the recruitment process.

How Information Is Used

VSEA holds and processes information about employees, contractors, and consultants for all necessary and customary business purposes, such as to pay and review compensation; provide and administer benefits; determine fitness to work for VSEA or entitlement to sick pay or parental or other leave of absence; comply with applicable taxation or other legal obligations; cooperate with law enforcement or other governmental authorities; protect the rights, interests, or property of VSEA; administer contracts and other business relationships; administer and maintain personnel records (including sickness or other absence records); carry out performance reviews; make assignment and promotion decisions; conduct disciplinary or grievance procedures; and facilitate compliance with VSEA’s policies, industry standards, and legal requirements.

Information about job applicants will be processed as part of the recruitment process to determine applicants' ability and suitability for the positions for which they have applied.


Except as described in this policy, VSEA will not share your Personal Information with third parties without your consent. You may choose whether or not your Personal Information will be disclosed to a third party or used for a purpose incompatible with the purpose for which it was originally collected or subsequently authorized. Unless required by law, Sensitive Personal Information will not be disclosed to a third party or used for a purpose other than its original purpose or the purpose subsequently authorized by the individual without the individual’s consent.

Onward Transfers (Transfers to Third Parties)

Personal Information may sometimes be disclosed to third parties in furtherance of the primary employment-related purposes described above, or as otherwise required by law. These recipients may include third parties acting as an agent to perform tasks on behalf of and under the instructions of VSEA, such as, for example, payroll processors, benefits administrators, legal advisers, or consultants. Personal Information may also be disclosed, as appropriate, to taxation authorities, law enforcement authorities, other regulatory bodies, or potential purchasers or customers of VSEA or of a business area in which you work. Information furnished by job applicants may be supplied to verification agencies for the purposes of undertaking background checks. Upon request, VSEA may confirm an employee's name, job title, and dates of employment by way of reference or testimonial. Individuals have the ability to opt out of such disclosures. VSEA shall ensure that any third party which receives Personal Information subscribes to the Safe Harbor Principles or is subject to law to provide the same level of privacy protection as is required by the Principles and agrees in writing to provide an adequate level of privacy protection.


Employees, contractors, and consultants have a right to access and correct reasonably available individually identifiable information maintained about themselves, subject to restrictions under applicable local laws and regulations. Employees, contractors, and consultants may review and update their information by contacting the Human Resources representative responsible for their work location. If an error is noticed in the information provided, a request that it be corrected, and appropriate changes made may be submitted.

Data Security

VSEA has adopted policies and procedures to protect information relating to employees, contractors, consultants, and job applicants from loss; misuse; or unauthorized access, disclosure, alteration, or destruction. These measures include administrative, technical, and physical safeguards including restrictions on employee access to human resources databases; password-restricted access; encryption of in-transit data between vendors and VSEA; and physical locks, where appropriate, on offices, files, and systems containing employee information.

Data Integrity

In order to be useful, information relating to employees, job applicants and other workers must be accurate and up to date. Where possible, information is updated periodically. Other information loses value over time and is periodically deleted, in accordance with applicable local legal requirements. VSEA will take reasonable steps to ensure that Personal Information is accurate, complete, current, and reliable for its intended use.


VSEA uses a self-assessment approach to assure compliance with this privacy policy and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented, and accessible and in conformity with the Principles. VSEA encourages interested persons to raise any concerns using the contact information provided and VSEA will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Information in accordance with the Principles.

If a complaint or dispute cannot be resolved through our internal process, VSEA agrees to dispute resolution using the EU Data Protection Authorities as a third party resolution provider.

Employees of EU countries who have concerns about violations of their data protection rights and are not satisfied with the results of the internal review process may contact the EU Data Protection Authorities in the jurisdiction where the employee works.


This privacy policy may be revised periodically to reflect changes in organization, business, or legal requirements or to comply with changes to the Safe Harbor re­quirements. We will post any revised policy on this website. Such revisions will apply to information maintained at the time of the consistent.

VSEA is committed to following the Principles for all Personal Infor­mation within the scope of the Safe Harbor Agreement. However, certain information is subject to VSEA’s policies that may differ in some respects from the general policies set forth in this privacy policy.

Contact Information

Questions, comments or complaints regarding VSEA’s Safe Harbor Policy or data collection and processing practices can be mailed or emailed to:

Varian Semiconductor Equipment Associates, Inc.
Attn: VP Human Resources
35 Dory Rd
Gloucester, MA 01913
Effective date: Sept 24, 2010