Provides privacy configuration guidance for SAP SuccessFactors, Workday, and BambooHR including RBAC, data retention automation, cross-border transfers, audit logging, and field-level security.
npx claudepluginhub mukul975/privacy-data-protection-skills --plugin privacy-skills-completeThis skill uses the workspace's default tool permissions.
Enterprise HR systems are the central repository for employee personal data, processing everything from recruitment to retirement. Systems like SAP SuccessFactors, Workday, and BambooHR contain names, addresses, national identifiers, salary data, performance evaluations, absence records, health-related fitness conclusions, disciplinary records, and benefits information. The default configuratio...
Conducts multi-round deep research on GitHub repos via API and web searches, generating markdown reports with executive summaries, timelines, metrics, and Mermaid diagrams.
Dynamically discovers and combines enabled skills into cohesive, unexpected delightful experiences like interactive HTML or themed artifacts. Activates on 'surprise me', inspiration, or boredom cues.
Generates images from structured JSON prompts via Python script execution. Supports reference images and aspect ratios for characters, scenes, products, visuals.
Enterprise HR systems are the central repository for employee personal data, processing everything from recruitment to retirement. Systems like SAP SuccessFactors, Workday, and BambooHR contain names, addresses, national identifiers, salary data, performance evaluations, absence records, health-related fitness conclusions, disciplinary records, and benefits information. The default configuration of these systems is designed for operational efficiency, not GDPR compliance. Privacy professionals must actively configure role-based access controls, data retention automation, cross-border transfer settings, audit logging, and field-level security to ensure that the HR system enforces — rather than merely documents — privacy requirements.
This skill provides configuration guidance for the three most widely deployed HR platforms, focusing on the privacy-critical settings that determine who can see what data, how long data is retained, and how data subject rights are facilitated.
Principle: No employee should have access to more HR data than is necessary for their specific role. Line managers need access to their direct reports' data; HR business partners need access to their client group; payroll needs salary and tax data; IT administrators need system access but not data content.
Standard RBAC Matrix:
| Role | Personal Details | Salary/Compensation | Performance Reviews | Absence Records | Health Data | Disciplinary Records | Recruitment Data |
|---|---|---|---|---|---|---|---|
| Employee (self) | Full | Own salary only | Own reviews | Own absence | Own OH reports | Own records | Own application |
| Line Manager | Direct reports: name, contact, role, start date | No (unless approval workflow) | Direct reports only | Direct reports: dates only (no diagnosis) | No | No (unless involved in process) | Hiring manager: interview candidates |
| HR Business Partner | Client group: full | Client group: full | Client group: full | Client group: dates + fit note status | Fit/unfit conclusion only | Client group: full | Client group: all candidates |
| Payroll | Minimal: name, employee ID, bank details, tax code | Full: all employees | No | Statutory sick pay relevant data only | No | No | No |
| Benefits Administrator | Name, employee ID, enrolment selections | Salary bands (for benefits calculation) | No | No | No | No | No |
| IT Administrator | System access management: name, employee ID, department, email | No | No | No | No | No | No |
| DPO | Audit access to all processing records; no routine access to individual data | Audit only | Audit only | Audit only | Audit only | Audit only | Audit only |
| Senior Leadership | Aggregate reports only | Aggregate/anonymised | Aggregate/anonymised | Aggregate/anonymised | No | No | No |
Principle: Data should be automatically deleted or anonymised when the retention period expires. Manual deletion is unreliable and non-compliant.
Standard Retention Schedule for HR Data:
| Data Category | Retention Trigger | Retention Period | Post-Retention Action |
|---|---|---|---|
| Recruitment — unsuccessful candidates | Application decision date | 6 months (12 months where discrimination claim risk) | Delete application, CV, interview notes, assessment scores |
| Employment contract | Termination date | 6 years post-termination (contractual claim limitation) | Delete or archive to restricted storage |
| Payroll and tax records | End of tax year | 6-7 years (varies by jurisdiction) | Delete |
| Performance reviews | Termination date | 2 years post-termination (unless ongoing dispute) | Delete |
| Absence records | End of absence year | 2 years current + 1 year archive | Delete detail; retain aggregate statistics |
| Disciplinary records | Outcome date | Per policy: warnings expire after 6-12 months; dismissal records 6 years | Delete expired warnings; retain dismissal records for limitation period |
| Health/occupational health records | Termination date or end of health surveillance | Varies: standard employment 6 years; occupational health surveillance 40 years (asbestos, radiation) | Transfer to occupational health archive |
| Training records | Termination date | 3 years post-termination | Delete |
| DSAR response records | Response date | 2 years | Delete copies; retain log entry |
For multinational organisations, HR systems transfer employee data across borders. Each transfer must comply with Chapter V GDPR.
Transfer scenarios requiring configuration:
| Scenario | Transfer Mechanism | System Configuration |
|---|---|---|
| EU headquarters → EU subsidiary | No restriction (intra-EEA) | Ensure data residency within EEA data centres |
| EU headquarters → UK subsidiary | UK adequacy decision (valid until June 2025, extended) | Configure UK entity as adequate recipient |
| EU headquarters → US subsidiary | EU-US Data Privacy Framework (where US entity is certified) or SCCs | Verify DPF certification; configure SCC-based transfer if not certified |
| EU entity → cloud HR provider (US-hosted) | DPF + SCCs + supplementary measures | Verify provider DPF status; enable encryption; configure data residency if available |
| EU entity → India/Philippines shared services | SCCs + TIA | Implement SCCs; conduct Transfer Impact Assessment; enable supplementary measures |
Mandatory audit events:
| Event | Log Content | Retention |
|---|---|---|
| Data access | Who accessed which employee's record, when, from where | 2 years |
| Data modification | Who changed what field, old value, new value, when | 2 years |
| Data export | Who exported data, scope, format, destination | 2 years |
| Report generation | Who ran what report, parameters, number of records | 2 years |
| Access permission changes | Who granted/revoked access, to whom, scope | 3 years |
| Data deletion | What was deleted, by whom, automated or manual | Permanent (audit trail survives data deletion) |
| Failed access attempts | Who attempted to access data they were not authorised to see | 1 year |
SuccessFactors uses a Role-Based Permissions (RBP) framework:
SuccessFactors provides a Data Retention Management module:
Workday uses a Security Group model:
Workday business processes (hire, promote, terminate, compensation change) have their own security:
Workday provides Data Purge functionality:
BambooHR uses a simpler access model suitable for small to medium enterprises:
BambooHR provides:
Atlas Manufacturing Group uses SAP SuccessFactors for 2,400 employees across Germany, France, UK, and the Netherlands. The DPO conducted a privacy configuration audit and identified the following issues:
| Authority | Case | Fine/Outcome | Key Issue |
|---|---|---|---|
| LfDI Hamburg (Germany) | H&M, 2020 | EUR 35,258,707.95 | HR system used to record excessive employee health and personal data; insufficient access controls |
| CNIL (France) | Dedalus Biologie, 2022 | EUR 1,500,000 | Insufficient access controls on health data in information systems |
| ICO (UK) | British Airways, 2020 | GBP 20,000,000 | Insufficient technical and organisational measures — includes system access controls |
| AEPD (Spain) | CaixaBank, 2021 | EUR 6,000,000 | Insufficient granularity in access controls for personal data systems |
| Autoriteit Persoonsgegevens (NL) | 2022 Audit | Corrective measures | HR system retained terminated employee data beyond retention period |