Effective Date: December 1, 2018

Amended: February 16, 2023


United Service Organizations, Inc. (the “USO”) has developed this Human Resources Supplemental Privacy Policy for European Union Employee and Employment Applicant Data Subjects (“Policy”) to help you understand our policies concerning USO’s collection, processing, transfer and use of personal data. USO is committed to protecting the privacy, integrity, and security of your personal information. This Policy supplements other applicable policies for USO employees

Your information

The USO collects and processes certain necessary personal data about employees and applicants for employment. This may include, but may not be limited to:

  • Your name, home address, email, phone number, nationality, race, employee ID number, bank details, national personal ID number; passport details, and where permitted, immigration status;
  • Résumé, CV, application letters, employment history, qualifications and skills, references, and background screening if relevant (this may include details of criminal records);
  • Beneficiaries’ details in relation to life insurance or other benefits, emergency contacts, marital status, additional information about you and your family members (e.g., name, date of birth, photo, gender and national personal ID number) where necessary for the provision of applicable benefits, guarantees or relocation assistance;
  • Employment information such as job title, compensation, benefits, professional experience, education, performance history, training records, employment number;
  • Information concerning performance, career plans, conduct, name of manager, absence records, holiday records, information on hours worked, location of work activity, development goals, and, where permissible, about violation of laws or breach of organizational policies;
  • Financial information and account information related to salary and benefits;
  • Expense records (such as details of out of pocket expenses, corporate credit cards, organizational cars or private cars where an allowance is claimed, and mobile phone costs);
  • Phone, written and electronic communications where permissible; and
  • Medical leave information, medical certificates, other documents required to confer special benefit status, such as information concerning pregnancy status and age of children, etc. where applicable.

The USO receives personal data from you directly or from other employees or third parties. For example, the USO receives personal data from referees, recruiters, previous employers, educational establishments, third-party providers of pre-employment screening, colleagues and managers, customers and business contacts, consultants, members of the public, courts, public authorities or other public sources, etc.


The USO processes this personal data for various purposes, including, but not limited to:

  • As required to establish and perform the terms of employment, to maintain or terminate the employment, and to enable you to perform your job. This includes recruiting and hiring and administration of payroll and benefits, absence, compensation and performance and talent management, training and leadership development, award recognition, employee, medical insurance, occupational health, retirement plans, stock plans, expense management and professional travel.
  • We may also use such information to improve our understanding of your interests, expand our services, or contact you for future support, either by email, postal mail, telephone, social media, or short message service (“SMS”). We may collect demographic information from other sources to help us learn more about your characteristics and interests. We may also use your personal information in other ways, such as to contact you about other USO activities and/or fundraising campaigns, or as otherwise disclosed to you at the point of collection. We may also use your name, postal delivery information, and telephone number to contact you offline. If you do not wish for the USO to use your personal information to contact you offline, or if you do not wish to receive marketing communications from the USO, you can opt out at any time.
  • As required by the USO to enable its business, in particular to provide access to the USO’s offices, management of the USO’s IT systems and infrastructure, inclusion in the USO directories and provision of communication services such as e-mail, telephone and internet access.
  • Protecting the security of the USO’s premises, assets, systems, and intellectual property and enforcing the USO’s policies, including monitoring communications where permitted by local law and in accordance with the USO’s code of business conduct, in protection of the USO property, and for investigations and disciplinary actions.
  • Compliance with applicable laws and protection of the USO’s legitimate business interests and legal rights, including, but not limited to, use in connection with legal claims, compliance, regulatory, investigative and disciplinary purposes (including disclosure of such information in connection with legal process or litigation) and in accordance with the USO’s ethics and compliance reporting tools.
  • To make automated decisions, which may include, for instance, evaluation of skills, experiences, or achievements, as allowable by law. We may make employment decisions based on such analysis.

In addition, we may collect your picture for use with your contact details in USO directories, in internal communications and newsletters and in external news and media in connection with events and updates about the USO. Where permitted by local law and with your consent, we also hold background checks to evaluate eligibility for employment.

Where we intend to process your personal data for a purpose other than the purpose for which it was collected, we will provide you with information regarding the purpose for the processing, as well as other relevant information, prior to processing your personal data for the new purpose.

The USO’s legal basis for processing

We process your personal data when we need to process your application for employment and/or to fulfill your terms of employment (for example, processing your bank account details in order to pay you).

We also process your personal data where we are required by law (for example, to comply with record keeping obligations, tax calculation or salary administration).

We may also process your personal data with your consent. In some cases, the provision of personal data will be a statutory duty, and your failure to provide the personal data in these circumstances, could result in the USO being unable to fulfill the employment relationship.

Retention of your data

The USO will keep this information, together with data retained from the application and selection process, for the course of the employment relationship, and for a period of at least three (3) years after the application process or the termination of employment, for the purposes set forth above. In some cases, we may retain information for review related to other USO job openings and/or to confirm your dates of USO employment and job title for purposes of enabling you to secure other employment with employers who may require confirmation of your employment history.

Transfers outside of the EEA

Personal data is transferred to the USO’s headquarters in the United States, and to USO’s third-party service providers in countries outside the European Economic Area (“EEA”), who are under contract for the above purposes, including facilitating USO’s personnel processes, and is stored and processed manually and electronically through global systems and tools for the purposes outlined above.

Disclosure to third parties

Personal data is shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law, or if required for the legal protection of the USO’s legitimate interests in compliance with applicable laws.

Personal data is also shared with third-party service providers, including, without limitation, software as a service (“SaaS”) providers and cloud-hosted personnel systems for employee and applicant data, who will process it on behalf of the USO for the purposes above.

Your rights

If you wish to access your personal data, then you may contact the USO’s Human Resources Department via the [email protected] email address or by phone at (703) 908-6473.

You have the right to ask the USO to rectify, block, complete, and delete your personal data, and restrict its use. You have the right to request further information about the handling of your personal data. You also have certain rights to data portability.

In addition, you can object to the processing of your data by the USO in some circumstances and, where you have consented to the processing of your data, you may withdraw this consent.

All requests will be dealt with at the earliest opportunity and any delay will be kept to a minimum. Any applicable statutory time limit for our response will not be exceeded.

There are exceptions to these rights, however. For example, access to personal data may be denied in some circumstances if making the information available would reveal personal information about another person or if the USO is legally prevented from disclosing such information. In addition, the USO may be able to retain data even if you withdraw your consent, where the USO can demonstrate that it has a legal requirement to retain and/or process your data.

If you have unresolved concerns, you should contact USO’s Human Resources Department via [email protected] or by phone at (703) 908-6473. If you have a complaint, you may contact the USO’s Senior Vice President, Human Resources:

Tammy Heiser
Senior Vice President, Human Resources
[email protected]
(703) 908-6470
2111 Wilson Blvd., Suite 1200
Arlington VA 22201