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Employee Privacy Policy

Lippert Components, Inc.

Privacy Policy Relating to Personal Data of Employees

Last Updated: October 28, 2020

  1. The Controller

In order to enter into and manage an employment relationship with you, Lippert Components, Inc., 3501 CR 6 East, Elkhart, IN 46514, privacy@lci1.com (hereinafter the “Company”), shall be the Controller of personal data collected in the course of your employment with the Company, as provided by GDPR (General Data Protection Regulation) and/or other applicable global privacy laws and regulations.

Any communication relating to the processing of your personal data and the exercise of the rights described in this Privacy Policy may be sent to the above-mentioned address.

  1. Other Covered Entities
  1. LCI Industries Pte. Ltd.
  2. LCI Holding B.V.
  3. LCI Canada Group, Inc.
  4. Kinro Texas, Inc.
  5. Zieman Manufacturing Company
  6. Lippert Components International Sales, Inc.
  7. Lippert Components Manufacturing, Inc.
  8. LCI Transit Corp.
  9. Taylor Made Group, LLC
  10. Curt Acquisition Holdings, inc.
  11. Curt Manufacturing, LLC
  12. Curt Manufacturing Ltd.
  13. Haulgauge, Inc.
  14. The Hitch Store, LLC
  15. Taylor Made Glass & Systems Limited
  16. Taylor Made Holdings UK Limited
  17. Taylor Made Credit LLC
  18. Trend Marine Products Limited
  19. CS Rail Interiors Inc.
  20. LCI Service Corp.
  21. Innovative Design Solutions, Inc.
  22. LCI Industries B.V.
  23. LCI Industries UK Ltd.
  24. LCI Italy Srl
  25. Lippert Components India Private Limited
  26. Polyplastic Group B.V.
  27. Polyplastic Property B.V.
  28. doubleCOOL B.V.
  29. Delta Glass B.V.
  30. Polyplastic B.V.
  31. Ciesse S.p.A.
  32. Ciesse Med SUARL
  33. Lavet S.r.l.
  34. Femto Engineering S.r.l.
  35. Ke-Star S.r.l.
  36. Lewmar Marine Ltd.
  37. Lewmar Europe Ltd.
  38. Lewmar Marine Trustees
  39. Lewmar Group Ltd.
  40. Lewmar Ltd.

  1. Purposes of the processing

The collection and the processing of your personal data shall be carried out solely to fulfil the following purposes:

  1. for your employment with the Company;
  2. for the processing and payment of your salary, bonus, equity grants, healthcare, life insurance, etc.;
  3. for your contractual benefits and statutory payments;
  4. to carry out all the procedures imposed by the laws concerning the safety, privacy, and the health and environment regulations;
  5. to fulfil any and all legal and contractual obligations linked to your employment;
  6. to provide tools necessary for your employment, a non-exhaustive list of examples of such tools are a Company issued email address, employee identification number, phone number, and security credentials;
  7. for the legitimate interests of the Company, but only if these are not overridden by your interests, rights or freedoms; and
  8. talent management, performance reviews, and career development.

The processing of your personal data shall be based on the principles of fairness, lawfulness, transparency and protection of your privacy and of your rights.  The Company seeks to ensure that personal data collection and processing is always proportionate.  The Company will notify you of any material changes to personal data collected or to the purposes for which the Company collects and processes personal data.

Your personal data shall be processed for the entire duration of your employment and also after your employment with the Company ends in order to fulfil any and all obligations imposed by the law.

In relation to your employment with the Company it may process personal data defined as “sensitive” under GDPR and/or other applicable global privacy laws and regulations and therefore provides notice of processing for the following personal data:

  1. a general health condition (sick leave, maternity leave, injury, or other compulsory matters under applicable labor laws), the suitability for particular job (which may be determined by medical doctors pursuant periodic medical examinations, requested by either the Company or by you);
  2. the ownership of an elective public office (permits or time off work) or a religious conviction (religious celebrations guaranteed by the law).

The sensitive data concerning the health status (set out in C.a above) shall be processed at the employer headquarters by a medical doctor with whom the Company signed a separate confidentiality agreement which imposes him or her to take measures aimed to protect your personal data.

Any judgment concerning the suitability to carry out a task or a job shall be communicated by the above-mentioned medical doctor to the Company.

  1. Method of processing

The processing of the personal data for the above-mentioned purposes will be processed both automatically and manually as required by the applicable laws and as the situation dictates and in compliance with the laws concerning the confidentiality and safety as well as with the relating regulations.

  1. Place of processing

The data shall be processed and stored at Lippert Components, Inc.

Moreover, several professionals and/or companies contracted to carry out technical, developing, management, or administrative activities may process your personal data on behalf of the Company. These professionals/companies included, but are not limited to:

LCI

  • Delta Dental
  • Fratarcangeli Wealth Management
  • Lockton
  • UNUM
  • Wage Works
  • Wells Fargo
  • VSP
  • Key Benefits Administrators
  • Cerpass RX
  • ADP
  • Benelogic
  • Principal Mutual
  • Lincoln National
  • UltiPro

CURT

  • Anthem
  • Guardian
  • Cigna
  • Key Benefits Administration
  • Lockton
  • Concur

Europe

  • Workgenda
  • Cobra
  • SDWorx
  • KORU Srl
  • ECO-VERDE SRL
  • INTERCONSULTING SRL
  • EMASEC SERVIZI  SRL
  • ANDREA RISTORI
  • E & S sas di Martino A. A. & C.
  • ROBERTO GIANNINI
  • MASSIMO CHEZZI
  • SYNLAB MED Srl
  • MARCELLA GORI
  • ISTITUTO SAN LORENZO
  • CENTRI MEDICI CAMPUS MAIOR
  • MAURO GLIORI
  • PIERO BARBIERI
  • MURGOLO FLORA ISABELLA
  • SERVIZI SANITARI INTEGRATI srl
  • Sei2sei Di Barzini Patrizia
  • GI GROUP SPA
  • ORIENTA
  • SYNERGIE
  • TEMPORARY
  • AREAJOB
  • ALI AGENZIA PER IL LAVORO SPA
  • HUMANGEST
  • RANDSTAD ITALIA S.P.A.
  • ADHR GROUP SPA
  • LIFE IN SPA figline
  • OPENJOMETIS
  • ADECCO
  • STUDIO NENCINI CONSULTING
  • VANNI ASSOCIATI
  • STUDIO CASAVECCHI MORENO
  • EXECUTIVE S.R.L.
  • STUDIO CAMERINI - RODRIGUEZ
  • STUDIO BALLEGGI
  • ADP
  • LABORALIA
  • UNIVA SERVIZI
  • EDENRED ITALIA SRL
  • L'OROLOGIO SOCIETA' COOPERATIVA
  • Scottish Widows
  • Horncastle
  • Locktons
  • Aviva
  • Moorepay
  • ABS (pegasus Opera)
  • Howdens
  • Aviva Solutions
  • Canada Life
  • Norfolk & Norwich University Hospital Trust Health and Wellbeing
  • RBS Natwest
  • Birketts Solicitors
  • Sage Micropay
  • Time Point
  • Willis Towers Watson
  • LAYA Healthcare
  • Drayton Medical Services
  • CSM Ascent
  • Howden Employee Benefits & wellbeing
  • Aon
  • Aviva
  • Innervate/Dataware
  • Wexas Travel Managerment

The aforementioned providers have all signed agreements which impose the responsibility to take measures aimed to protect your personal data.

  1. Provision of your personal data and consequences of any eventual refusal to provide them

The Company may collect information during your employment, including, but not limited to:

  • your name, contact details (address, phone numbers, email address), and emergency contacts;
  • marital status and family member information;
  • information collected during the recruitment process;
  • details of salary and benefits, insurance and tax information, and other financial details;
  • your nationality and immigration status and data from related documents (like passport or other identification);
  • details of pension arrangements and information necessary to implement and administer them;
  • information about sickness and/or absence records (likely include sensitive personal information);
  • your racial or ethnic origin;
  • criminal record information;
  • trade union membership (if applicable);
  • details arising out of your employment like appraisals and performance reviews, performance management or improvement plans, attendance records, and applications for other positions internally; and
  • information of any grievances or disciplinary action.

Personal data may be collected from you, your personnel records, your company email, company issued equipment (such as computers), pension administrators, doctors or medical professionals, your trade union (if applicable), and other employees.

The provision of certain personal data is mandatory in relation to your employment as it is required by the governmental and contractual obligations to enable us to verify your right to work and suitability for the position, to pay you, to provide you with your contractual benefits, and to administer statutory payments (like statutory sick pay). Any refusal to provide all, or part, of your personal data may result in the inability for the Company to perform its obligations under your employment agreement and/or to carry out the relative obligations, including but not limited to, the payment of your salary, benefits, and insurance obligations and may mean we are unable to employ you.

  1. Communication of your personal data

With the exclusion of the communication carried out to fulfil obligations legally and contractually imposed upon the Company, any and all of the personal data collected and processed may be communicated nationally or internationally exclusively for the above mentioned purposes to:

  • Governmental authorities;
  • Payroll processors;
  • Medical clinics pursuant the obligations concerning hygiene and safety in the workplace;
  • Insurance companies and credit institutions;
  • Trade unions specifically appointed by you;
  • Supplementary funds;
  • Affiliated entities of the Company which are a subsidiary of LCI Industries;
  • Third parties that the Company or its affiliated company uses for business purposes including, but not limited to, email and security verification; and
  • Business organizations of which the Company is a member.

The Company is also required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Moreover, the following categories of processors and internal/external officers may have access to your personal data during their processing:

  • Employees of the personnel/human resources office;
  • Consultants and/or companies specialized in the elaboration of pay slips, their employees, collaborator and partners, as processors and external officers;
  • Professionals or companies which provide technical, administrative, and/or management services and which operate on behalf of the Company or an affiliate of LCI Industries.

Information concerning the forgoing personal data and its use may be requested form the Company by sending an email to: privacy@lci1.com. Any refusal by the Company to provide such information may be remedied in accordance with the methods specified in Art. I of GDPR and/or other applicable global privacy laws and regulations.  The Company, and any affiliate of LCI Industries that shares your data with a third party, remains subject to the provisions of GDPR and/or other applicable global privacy laws and regulations for information shared with a third party including any liability provisions for third party transfers.

  1. Transfer of your personal data abroad

In order to allow the performance of your job, some of your personal data may be communicated to the other companies affiliated with LCI Industries, which is headquartered outside the European Union in the United States.  Where information is transferred to companies affiliated with LCI Industries, we have security measures in place to seek to ensure that there is appropriate security for information transferred abroad.

The Company and LCI Industries complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States.  LCI complies with the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from Switzerland, as applicable to the United States in reliance on Privacy Shield. LCI Industries has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. To learn about LCI’s Privacy Shield Policy, please visit https://www.lci1.com/privacy-shield-policy.  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/

  1. Storage of your personal data

The personal data provided by you shall be stored in our archives in accordance with the following parameters:

for activities concerning the administration, the accounting, the management of the payroll, the training of the personnel, contractual, legal, and litigation activities: the duration of your employment and for a period of up to 10 years after the end of your employment.

  1. Rights of the data subject

In relation to your personal data, you may exercise the rights provided to you by GDPR and/or other applicable global privacy laws and regulations and, therefore, you may:

  • access to your personal data stored at Lippert Components, Inc. and obtain a copy of their records;
  • request and obtain the correction of any of your personal data without unjustified delay;
  • taking into account the purposes of the processing, you may have the right to supplement your personal data which is incomplete by providing additional information;
  • obtain the deletion of your personal data without unjustified delay if:
  • your personal data is not necessary for the purposes for which it was collected and processed (therefore the purposes specified above);
  • the legal basis for the processing ceases to exist and you waive your consent to such processing;
  • the processing becomes unlawful; or
  • the cancellation of your personal data is required by the European Union and by all Member States to which the Company is subject.
  • request the restriction of the processing if:
  • there are inaccuracies in your personal data;
  • the processing becomes unlawful, but you object to the cancellation and instead you request the restriction of such processing.
  • oppose the processing of your personal data for reasons related to a particular situation; the Company shall cease to process your personal data if such processing is either not justified by the existence of any legitimate and mandatory reasons which may prevail over your interests, rights, and freedom or is necessary for the verification, prosecution, or defence of any right of the Company in a judicial proceeding.

The above-mentioned rights may not be exercised if the storage of your personal data is necessary for verification, prosecution, or defense of any right of the Company in a judicial proceeding.  Where you exercise any of the above-mentioned rights, we will aim to deal with your request within one month.

  1. Questions & Complaints

If you have any questions regarding this policy or the use of your personal information, please contact the Company at the follow address: privacy@lci1.com.  If not, contact the Information Commissioner at www.oic.ie/contact/ or telephone: +353-1-639-5689 for further information about your rights and how to make a formal complaint.

If you believe that the processing carried out by the Company violates the GDPR and/or other applicable global privacy laws and regulations, or you have any complaint that is not resolved by the Company, you may contact the Information Commissioner at www.oic.ie/contact/ or by telephone: +353-1-639-5689 for further information about your rights and how to make a formal complaint.

Transfers of data abroad are covered by the EU-U.S. Privacy Shield independent dispute resolution body, or Swiss-U.S. Privacy Shield independent dispute resolution body, as applicable, designated to address complaints and provide appropriate recourse free of charge to the individual, this body can be: (1) a panel established in the applicable DPAs, (2) an alternative dispute resolution provider based in the EU, (3) an alternative dispute resolution provider based in the United and authorized by Privacy Shield; the Commissioner.  You may, under certain conditions, have the right to invoke binding arbitration.  LCI Industries is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

In the context of an onward transfer the Company has responsibility for the processing of personal information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. The Company shall remain liable under the Privacy Shield Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless the organization proves that it is not responsible for the event giving rise to the damage

In compliance with the Privacy Shield Principles, LCI Industries commits to resolve complaints about our collection or use of your personal information.  EU or Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact LCI Industries at: 

Lippert Components, Inc.
3501 Co Rd 6 East
Elkhart, IN 46514
United States of America

Email: privacy@lci1.com


LCI Industries has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU or Switzerland, as applicable, in the context of the employment relationship.