Govern · jurisdiction
Germany
The works council agreement covering agent-assisted performance and hiring decisions is drafted but not signed. Until it is, German employee records are excluded from three decision points.
Units governed
476
Stamped on the unit itself
Placements here
13
442,270 records
Inbound routes
0
Records arriving from elsewhere
Outbound routes
10
Records leaving this jurisdiction
Breach notice
72 hr
Supervisor: Landesbeauftragte fuer Datenschutz (state-level DPAs)
The regime that applies here
Privacy and artificial intelligence obligations, as they stand.
Privacy regime
EU GDPR
GDPR and BDSG, with Section 26 BDSG on employee data
Artificial intelligence regime
EU AI Act
In force — Binding obligations apply to systems operating here today.
Transfer adequacy
Inside the union
Default mechanism: Intra-EEA - no transfer mechanism required
Supervisory authority
Landesbeauftragte fuer Datenschutz (state-level DPAs)
Local obligations that change how work is run
These are operating constraints, not footnotes.
Localization rule
No statutory localization, but employee data is held in Frankfurt by works agreement.
Employee consultation
Betriebsrat co-determination applies to any system capable of monitoring employee performance. This is the binding constraint on the German estate.
What is stored and processed here
One row per class of record, per role, per system.
| Record class | Role | System | Facility | Volume | Note |
|---|---|---|---|---|---|
| agent-telemetry | Stored | This platform platform-core | AWS eu-central-1, Frankfurt | 1,530 | |
| candidate-applications | Processed | Recruiting and Applicant Tracking ats | Vendor cloud, Singapore | 15,001 | German candidate records are processed outside the EEA. The works council has not cleared this route. |
| compensation | Stored | Core HR and Payroll hcm | Workday EU pod, Amsterdam | 11,750 | |
| compensation | Processed | Core HR and Payroll hcm | Workday EU pod, Amsterdam | 11,750 | |
| customer-contact | Stored | Customer Relationship Management crm | Vendor cloud, Frankfurt | 187,404 | EEA primary. |
| employee-master | Processed | Core HR and Payroll hcm | Workday EU pod, Amsterdam | 11,750 | |
| employee-master | Stored | Core HR and Payroll hcm | Workday EU pod, Amsterdam | 11,750 | Held in region under the works agreement. |
| health-safety | Stored | Occupational health record store ehs | Vendor cloud, Frankfurt | 920 | No agent access. |
| performance-records | Processed | Core HR and Payroll hcm | Workday EU pod, Amsterdam | 11,195 | Excluded from agent-assisted calibration. |
| performance-records | Stored | Core HR and Payroll hcm | Workday EU pod, Amsterdam | 11,195 | |
| research-payloads | Stored | Research Notebook and Experiment Data eln | On-premise, Ludwigshafen | 3,956 | Asserted from the site register. No feed. |
| supplier-bank | Stored | Group ERP — Financials erp-fi | AWS eu-central-1, Frankfurt | 9,989 | |
| support-transcripts | Processed | Contact Center Platform ccaas | Vendor cloud, Frankfurt | 154,080 |
Inbound — records arriving here
Lawful basis and impact assessment state for each route.
No routes recorded.
Outbound — records leaving here
Lawful basis and impact assessment state for each route.
XFER-001DE→SGBlocked
Shared-service HR administration for the non-German population routed through the Singapore hub.
Standard contractual clausesEU SCC Module 2, executed 2024-11-04, Annex III updated 2026-03-12Assessment current0/mo
Route is contractually papered but operationally suspended. German employee records do not leave Frankfurt while the works agreement is unsigned. Volume is zero by design, not by accident.
XFER-002DE→SGCleared with conditions
Candidate screening, assessment scoring and interview scheduling performed at the Singapore hub.
Standard contractual clausesEU SCC Module 2, executed 2024-11-04Assessment in progress1,840/mo
The transfer impact assessment has been in progress for 94 days. Volume continues while it is open. This is the single largest unresolved item on the register.
XFER-004DE→SGCleared with conditions
Follow-the-sun customer service outside European business hours.
Standard contractual clausesEU SCC Module 2, executed 2023-06-30, Annex III last updated 2024-09-02Assessment out of date46,200/mo
Annex III has not been refreshed since two sub-processors were added to the service chain in 2025. The assessment describes a supply chain that no longer matches the register.
XFER-005DE→SGCleared with conditions
Out-of-hours contact center handling and transcript storage.
Standard contractual clausesEU SCC Module 2, executed 2023-06-30Assessment out of date88,400/mo
Free-text transcripts occasionally carry Article 9 data. A transfer assessed for ordinary personal data is carrying special-category data some of the time.
XFER-007DE→USCleared
Marketing automation and campaign attribution on the global instance.
Adequacy decisionEU-US Data Privacy Framework, recipient self-certified, verified 2026-02-19Assessment current128,000/mo
XFER-008DE→USCleared
Platform control plane reads evidence records from every region to serve the cockpit.
Standard contractual clausesIntra-group agreement, EU SCC Module 1, executed 2025-04-08Assessment current1,520/mo
XFER-009DE→USCleared with conditions
Model inference. Prompt and completion content leaves the region for the model provider.
Standard contractual clausesModel provider DPA with EU SCC Module 2, executed 2025-09-22Assessment current412,000/mo
Zero-retention is contracted, and the platform cannot independently verify it. Verification depends on the provider attestation, which is the same weakness the evidence chain has without external anchoring.
XFER-011DE→SGCleared
Supplier master maintenance performed by the Source-to-Pay tower.
Standard contractual clausesEU SCC Module 2, executed 2024-11-04Assessment current940/mo
XFER-013DE→USUnresolved
Joint research program between the Ludwigshafen and Cambridge sites.
No personal dataNot personal data. Export control screening under EAR and EU dual-use.Not required0/mo
The laboratory notebook has no feed, so the platform cannot see whether this transfer happens or at what volume. It is on the register because the site register says the program exists, not because the platform observed it.
XFER-016DE→SGProhibited
No transfer. Recorded as an explicit prohibition so the absence is auditable.
None recordedProhibited by policy POL-DP-004. No mechanism sought.Not required0/mo
The prohibition is enforced by a field-level deny list in the agent context builder, not by a network control. A direct database query from Singapore would not be stopped by it.
Which functions run work here
Rolled up from the jurisdiction stamped on individual units.
AI GBS & Global Business Services41
Information Technology41
Human Resources40
Engineering38
Administration37
Supply Chain37
Customer Service36
Revenue Operations33
Finance31
Marketing31
Research & Development30
Legal29
Sales27
Procurement & Source-to-Pay25