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Pay Equity Philippines

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Basic Summary

Pay equity in the Philippines is anchored in the principle of equal remuneration for work of equal value, prohibiting discrimination in compensation based on sex and other protected characteristics. While there is no mandatory public pay gap reporting regime, employers remain legally obliged to ensure non-discriminatory pay practices and may face administrative, civil, and criminal exposure for violations. The Philippines observes regional minimum wage setting and statutory benefits such as 13th-month pay, which shape baseline compensation and must be reflected in equitable pay structures.

Total Rewards and Payroll professionals should operationalize pay equity via robust job evaluation, standardized total compensation calculations (including 13th-month pay and common allowances), and statistically sound internal monitoring. International frameworks, notably ILO Convention No. 100 and CEDAW, inform interpretation of domestic obligations. Practical compliance hinges on meticulous data stewardship under the Data Privacy Act, disciplined documentation of job-related pay rationales, and prompt remediation of unjustified gaps.

Summary

The Philippine legal framework prohibits compensation discrimination and requires equal pay for work of equal value across sexes, reinforced by broader anti-discrimination statutes (age, disability, HIV status) and jurisprudence. Enforcement occurs through the Department of Labor and Employment (DOLE), the National Labor Relations Commission (NLRC), and regular compliance inspections. Although there is no Philippine equivalent to the EU’s or UK’s gender pay gap reporting, employers are expected to maintain fair, defensible pay structures, especially where regional wage orders, job classification, and benefit practices differ.

Organizations should establish a formal, repeatable pay equity methodology: standardized data capture and normalization to annualized, full-time equivalent (FTE) terms; consistent inclusion of statutory cash (e.g., 13th-month) and prevalent allowances; and rigorous comparison groups aligned to work of equal value using factor-based job evaluation. Regression and complementary tests identify statistically and practically significant disparities. When gaps lack a lawful, job-related basis (seniority, merit, productivity, geographic wage differentials), employers should implement timely adjustments, pay differentials retroactively where required by law, and strengthen governance. Strong data privacy controls under Republic Act No. 10173 (Data Privacy Act) are integral to lawful processing of sensitive HR data.

  • Primary legislation and instruments
    • Labor Code of the Philippines (as amended; renumbered by DOLE Department Order No. 183-17): Prohibits discrimination and recognizes equal pay for work of equal value; prescribes wage and hour entitlements for rank-and-file employees (overtime, holiday pay, night shift differential).
    • Republic Act No. 6725 (1989), An Act Strengthening the Prohibition on Discrimination Against Women: Amends the Labor Code to prohibit paying a female employee less than a male employee for work of equal value and bars discrimination in terms, conditions, or privileges of employment on account of sex.
    • Republic Act No. 9710 (2009), Magna Carta of Women: Broadly prohibits sex-based discrimination; mandates gender mainstreaming across government and supports equal opportunity principles.
    • Republic Act No. 10911 (2016), Anti-Age Discrimination in Employment Act: Prohibits compensation and employment discrimination based on age.
    • Republic Act No. 7277 (1992), Magna Carta for Persons with Disability: Prohibits discrimination against persons with disability, including in compensation and conditions of employment.
    • Republic Act No. 11166 (2018), Philippine HIV and AIDS Policy Act: Prohibits discrimination in employment (including compensation) based on HIV status.
    • Presidential Decree No. 851 (1975), 13th-Month Pay: Requires payment of 13th-month pay to covered employees; implemented and clarified by DOLE issuances.
    • Republic Act No. 6727 (1989), Wage Rationalization Act: Establishes the National Wages and Productivity Commission (NWPC) and Regional Tripartite Wages and Productivity Boards (RTWPBs) that set regional minimum wages via Wage Orders.
  • Regulatory bodies
    • Department of Labor and Employment (DOLE): Policy, inspections, compliance orders; issues rules and advisories (e.g., wage and hour, 13th-month).
    • National Wages and Productivity Commission (NWPC) and RTWPBs: Regional minimum wage setting and guidance.
    • National Labor Relations Commission (NLRC): Adjudication of labor disputes and money claims.
    • National Privacy Commission (NPC): Enforcement of the Data Privacy Act in HR data processing.
  • International frameworks
    • ILO Convention No. 100 (Equal Remuneration), and ILO Convention No. 111 (Discrimination): Ratified by the Philippines; inform work of equal value and non-discrimination standards.
    • UN CEDAW: The Magna Carta of Women operationalizes CEDAW domestically, reinforcing equal pay principles.
  • Penalties and remedies
    • Administrative inspections under DOLE’s Labor Laws Compliance System may result in compliance orders requiring back wages/differentials, plus fines.
    • Criminal penalties apply for certain discrimination offenses under the Labor Code as amended by RA 6725, with fines and potential imprisonment; RA 10911 imposes fines (PHP 50,000–500,000) and imprisonment (3 months–2 years) for age discrimination.
    • Civil money claims for wage differentials, damages, and attorney’s fees may be pursued before the NLRC. Money claims generally prescribe in three (3) years from accrual (Labor Code, prescriptive periods).
  • Jurisprudence
    • International School Alliance of Educators v. Quisumbing, G.R. No. 128845 (June 1, 2000): Equal pay for equal work requires substantial equality of work; nationality per se is not a valid basis to pay local hires less than foreign hires absent substantial distinctions relevant to the job.
  • Recent updates / pending initiatives
    • As of August 2025, there is no enacted national pay transparency or mandatory gender pay gap reporting statute. DOLE and NWPC continue to issue Wage Orders regionally. Several anti-discrimination and equality bills have been periodically introduced; monitor DOLE and Congress updates.

Detailed Data Requirements

Field / Data Element Description and Philippine-specific notes
Unique Employee ID Persistent, non-PII identifier used for linkage and de-duplication. Avoid using government ID numbers for analytics extracts under RA 10173.
Legal Entity / Employer Registered employing entity in the Philippines; needed for doledomestic compliance and entity-level analysis.
Work Location (Country=PHL, Region/Province/City) Exact worksite and RTWPB Region (e.g., NCR, Region III, CALABARZON, BARMM). Regional Wage Orders drive minimum rates and geographic comparators.
Job Title Local title as used in contracts and payroll.
Global Job Family / Function Broad function (e.g., Finance, Sales, Manufacturing) for grouping similar work.
Job Level / Grade Internal grade/band aligned to a factor-based job evaluation system to enable work of equal value comparisons.
Employment Category Rank-and-file, supervisory, managerial. Rank-and-file are covered by overtime, holiday pay; managerial employees are exempt from certain wage-hour entitlements.
Employment Type / Status Regular (permanent), probationary, project, fixed-term, casual. Include start date and, if applicable, regularization date.
Hire Date / Company Seniority Used to measure tenure-based differentials. Capture breaks-in-service.
Scheduled Hours / Workweek Hours per day and days per week (e.g., 8 hours x 5 or 6 days). Necessary for FTE normalization (40- or 48-hour baselines).
FTE Percentage Contracted FTE (e.g., 1.0, 0.8). Required for pro-rating.
Pay Frequency Monthly, semi-monthly, bi-weekly, weekly, daily, hourly.
Base Pay Rate Type Monthly salary, daily rate, hourly rate. For daily-paid workers, capture whether monthly equivalents use 313/261 factors.
Base Pay Amount Current base rate. Retain history for time-slice analyses.
Allowances (Cash) Detailed components: transportation, meal, rice subsidy, cellphone, communication, housing, assignment/hardship, hazard, shift differential. Indicate taxable vs de minimis for tax purposes; include all as cash compensation for equity analysis unless uniformly provided across comparators.
Statutory COLA If applicable under regional Wage Orders; include in base or as a separate line per payroll practice.
13th-Month Pay Track actual amount paid YTD and year-end. For annualization, compute 1/12 of basic salary actually earned within the year per PD 851 (overtime/premiums/allowances excluded unless integrated into basic).
Variable Pay: Sales Incentives / Commissions Capture plan type, period earned, payout currency, and actual payout. Annualize based on plan design and target opportunity where needed.
Variable Pay: Short-Term Bonus Discretionary or formulaic (e.g., STI). Include performance period and payout timing; map to performance cycle.
Long-Term Incentives / Equity RSUs, stock options, PSUs, cash LTI. Record grant date, grant-date fair value (IFRS 2), vesting schedule, and value realized/recognized for the analysis period. Use amortized grant-date fair value or realized value methodology consistently.
Overtime (OT) Pay Actual OT hours and pay. Distinguish OT on ordinary day vs rest day/special day (different multipliers); include in total cash only for roles where OT is inherent and comparable across groupings, or analyze separately to avoid job-mix noise.
Premium Pay (Rest Day / Special Day / Holiday) Capture hours and premium amounts (special non-working day, regular holiday) and night shift differential (10%). Enables normalization and exclusion from base-based comparisons if needed.
Benefits in Kind / Employer-Paid Benefits Company car, meal provision, medical coverage upgrades. Assign a fair annual value for equitable comparisons where benefits differ by cohort; exclude statutory employer contributions (SSS/PhilHealth/Pag-IBIG) from employee total comp unless provided as cash substitutable benefits.
Statutory Contributions (Employer) Employer SSS, PhilHealth, Pag-IBIG contributions are generally excluded from employee compensation comparisons (not directly received by the employee), but document for completeness and global benchmarking.
Education / Certifications Highest degree, job-related certifications; used to justify differences if relevant to role demands.
Experience Total relevant years of experience; prior role level. Must be consistently defined across roles.
Performance Rating Most recent and prior cycle ratings; calibration level. Documentation is critical if used to justify pay differences.
Critical Skills / Scarcity Premium Internal designation of scarce skills and approved market premiums; keep policy and approval artifacts.
Union / CBA Coverage Collective agreement coverage and wage scale step; required for justification and group formation.
Protected Characteristics (for analysis) Sex assigned in HRIS (male/female); age (in years or brackets); disability status (self-identified or as accommodated); marital status (if lawfully collected); nationality. Treat as sensitive personal information under RA 10173; collect only what is necessary, with appropriate legal basis and safeguards.
Leaves and Absences Unpaid leaves affecting earnings; maternity/paternity leave; relevant where annualization is required.
Termination Date (if applicable) For leavers in scope period; enables pro-ration and survival bias checks.
Exchange Rate (if multi-currency) PHP as base; record monthly average and spot rates used for equity valuation if grants are in foreign currency.
Job Evaluation Score / Grade Linkage Factor points and grade linkage; central for work of equal value comparators (skill, effort, responsibility, working conditions).
Exclusion Flags Data integrity issues, new hires under X months, extraordinary payouts; maintain defensible criteria and audit trail.

Step-by-Step Calculation Methodology

  1. Data Standardization: Establish a single, analysis-ready dataset, harmonizing pay elements and timeframes.
    1. Consolidate HRIS, payroll, and compensation planning data at the employee-period level. Use a stable Employee ID and a consistent analysis period (e.g., fiscal year or calendar year).
    2. Convert all amounts to Philippine peso (PHP). For cross-border grants, use grant-date fair value in currency of record translated to PHP at grant date for valuation, or use IFRS 2 amortized expense translated at reporting date; apply one method consistently.
    3. Normalize pay element taxonomy: base pay, allowances (cash), 13th-month, variable pay (sales/bonus), overtime/premiums, LTI/equity, benefits in kind. Clearly flag statutory vs discretionary elements.
    4. Handle missing/erroneous data via defined rules (e.g., imputation for minor gaps; exclusion with flag for material gaps). Maintain a data issue log for auditability.
  2. FTE Adjustments: Convert all compensation to a full-time equivalent basis to enable comparability.
    1. Determine standard FTE baseline. Common practice is 1.0 FTE = 40 hours/week (5x8) for corporate roles; in manufacturing/retail contexts, 48 hours/week (6x8) may be standard. Document the chosen baseline.
    2. For employees with scheduled hours H per week, compute FTE fraction as FTE = H / baseline_hours. If contract specifies days, convert to hours (8 hours/day unless policy differs).
    3. FTE-normalize fixed pay components: FTE_Normalized_Amount = Reported_Amount / FTE. Do not FTE-normalize overtime and premiums if they are inherently hours-driven; instead consider excluding them from base comparisons or model them explicitly.
    4. For daily-paid employees, compute Equivalent Monthly Rate (EMR) before FTE normalization:
    5. • Monthly-paid (entitled to all days, including rest and holidays): EMR = ADR × (365 / 12)
    6. • Daily-paid, 6-day schedule: EMR = ADR × (313 / 12) where 313 = 365 − 52 rest days
    7. • Daily-paid, 5-day schedule: EMR = ADR × (261 / 12) where 261 = 365 − 104 rest days
    8. Annualize using the corresponding day factors or multiply Monthly Rate × 12. Be consistent within each category.
  3. Total Compensation Calculations: Compute standardized annual totals and sub-totals for analytical lenses.
    1. Annual Basic Salary = Monthly Base × 12 (or EMR × 12 for daily-paid). Exclude overtime/premiums from basic salary.
    2. 13th-Month Pay (PD 851) = Sum of basic salary actually earned within the calendar year ÷ 12. Exclude overtime, premium pay, and allowances unless contractually integrated into basic salary.
    3. Annual Allowances (Cash) = Sum of taxable and de minimis cash allowances received during the year. Include rice subsidy, transportation, meal, communication, hazard, shift, housing, assignment premiums.
    4. Variable Pay – Sales/Commissions: Annualize actual earned payouts in period; where volatility distorts, consider two-year rolling average for stability, documented and applied consistently.
    5. Variable Pay – Short-Term Bonus: Use payout received for performance year under analysis; align to performance cycle (e.g., FY2024 bonus paid in 2025 belongs to FY2024 analysis).
    6. Long-Term Incentives/Equity: Choose one approach and apply consistently:
    7. • Realized Value Approach: Include value at vesting/settlement during the year.
    8. • Amortized Grant-Fair-Value Approach: Include IFRS 2 grant-date fair value amortized over vesting; preferred for smoothing and cross-market comparability.
    9. Benefits in Kind: Include fair annualized value where benefits materially differ across groups (e.g., company car personal use value). Exclude employer statutory contributions (SSS/PhilHealth/Pag-IBIG) from employee total unless substitutable as cash.
    10. Define comparison constructs:
    11. • Total Cash Compensation (TCC) = Annual Basic Salary + 13th-Month + Cash Allowances + Variable Pay (Sales + STI) + Overtime/Premiums (if included for that comparator design)
    12. • Adjusted Base Cash (often preferred for equity testing) = Annual Basic Salary + 13th-Month + Fixed Cash Allowances (exclude overtime/premiums and production commissions to reduce job-mix noise)
    13. • Total Direct Compensation (TDC) = TCC + LTI/Equity (per method) + Benefits in Kind valuation
  4. Comparison Group Formation: Build groups reflecting work of equal value and limit confounding.
    1. Primary grouping by Job Family/Function × Job Level/Grade × Employment Category (rank-and-file vs managerial) × Location (RTWPB Region; NCR vs non-NCR). Use factor-based job evaluation scores to validate that roles in a group are of equal or substantially equal value (skill, effort, responsibility, conditions).
    2. Segment union/CBA roles separately due to collectively bargained scales. Do not pool job groups where overtime entitlements systematically differ (rank-and-file vs managerial).
    3. Require minimum group sizes (e.g., n ≥ 30 for regression; n ≥ 8–12 for non-parametric/t-tests). Where groups are too small, aggregate cautiously (e.g., adjacent grades within same family) or use pooled regression with fixed effects.
    4. Address incumbency and new-hire effects via tenure bands or covariates. Consider excluding new hires with <3 months in role if pay practices include onboarding variance.
  5. Statistical Testing: Apply appropriate methods to detect disparities and quantify risk.
    1. Within homogeneous groups, test mean/median differences by sex (and other protected traits where lawfully collected) using:
    2. • Two-sample t-test for means (with Welch’s correction for unequal variances) and Mann–Whitney U for medians (n ≥ 8 per cohort).
    3. For multi-factor analysis, fit OLS regression on log compensation (e.g., log Adjusted Base Cash or log TCC). Model specification example:
    4. • log(Comp) = β0 + β1(Female) + β2(Tenure) + β3(Performance_Rating) + β4(Education) + β5(Experience) + β6(Location_FE) + β7(Job_Level_FE) + β8(Job_Family_FE) + ε
    5. Use robust (HC) or clustered standard errors (e.g., by job family) to account for heteroskedasticity/grouping. Ensure no prohibited variables (e.g., age) are used unless for disparity testing, not as a control to justify gaps.
    6. Significance thresholds: statistical significance at p < 0.05; practical significance threshold commonly 2–5% of pay depending on risk appetite. Flag cohorts where Female (or other protected group) coefficient is both statistically and practically significant.
    7. Conduct intersectional checks (e.g., sex × age band) in aggregated models, subject to Data Privacy Act minimization and safeguards. Apply multiple-testing corrections (e.g., Benjamini–Hochberg) when scanning many cohorts.
  6. Gap Analysis: Diagnose drivers and assign remediation actions with documentation.
    1. For each flagged cohort, decompose gaps by covariates: tenure distributions, performance, education, scarce skills premiums, hire-in rates, and location effects.
    2. Validate job equivalence: confirm that work of equal value holds using job evaluation documentation; if misalignment exists, correct job classification rather than pay.
    3. Determine legality of differences. Acceptable differences must be tied to documented, consistently applied, job-related factors (seniority, merit, productivity, geographic wage orders/market).
    4. Quantify adjustment amounts to bring affected employees to target position (e.g., compa-ratio to midpoint, or to close modeled gap). Prioritize immediate corrections for the most material and highest-risk cohorts. Plan retroactivity where legal exposure exists.

Justifiable Differences

  • Legally acceptable reasons (must be job-related, consistently applied, and documented)
    • Seniority/Tenure: Longer service justifying step progression or longevity increments; maintain service records and pay progression matrices.
    • Merit/Performance: Documented performance ratings from a calibrated process linking to defined merit guidelines; keep calibration minutes and manager justifications.
    • Productivity or Output: Measurable individual output under a neutral system (e.g., piece rates, sales performance) with auditable metrics.
    • Education/Qualifications/Skills: Degrees, certifications, and scarce skills demonstrably required for the role; align to job descriptions and validated skill premiums.
    • Job Level/Grade and Role Scope: Higher responsibility or complexity supported by job evaluation factor points and grade differentials.
    • Geographic Location and Regional Wage Orders: Pay differences based on RTWPB regional minimums and local market rates; keep wage order references and market data.
    • Shift, Hazard, and Working Conditions Differentials: Night shift differential (10%), hazard pay, and other premiums tied to working conditions set by law or policy.
    • Collective Bargaining Agreements (CBA): Wage scale steps and differentials under a valid CBA applicable to covered employees.
  • Non-justifiable reasons (explicitly or effectively discriminatory)
    • Sex/gender or pregnancy status; marital status and family situation; sexual orientation or gender identity/expression where protected by policy or local ordinance.
    • Age (RA 10911), disability (RA 7277), HIV status (RA 11166), union membership or activities (Labor Code), nationality alone (per International School Alliance case), religion, or other protected traits.
    • Manager discretion without job-related criteria; reliance on prior pay without validation; opaque market adjustments unsupported by data.
  • Burden of proof and documentation
    • When a pay disparity is alleged, employers must evidence that differences are based on lawful, job-related factors and that methods are consistently applied. Maintain job evaluation records, pay policies, market data sources, performance calibration documentation, and individualized adjustment rationales.
    • Under RA 6725 and related Labor Code provisions, DOLE/NLRC may order payment of differentials and other remedies where unlawful discrimination is established.

Reporting Requirements

  • Government submissions
    • There is no mandatory pay equity or gender pay gap report filing in the Philippines as of August 2025.
    • 13th-Month Pay Establishment Report: DOLE requires submission of the Establishment Report on Payment of 13th Month Pay via DOLE’s online portal typically by January 15 following the payment year; payment of 13th-month must be made not later than December 24 each year.
  • Internal reporting and governance
    • Quarterly internal dashboards for HR/Compensation Committees summarizing pay equity indicators by job family/grade/location, with action plans.
    • Annual Board or Executive review of pay equity outcomes and remediation budget.
  • Employee and union communications
    • Provide employees with their pay structure components and how pay is determined; share methodology for equal pay assessments in a privacy-safe, aggregate manner.
    • For CBA-covered groups, share pay equity outcomes and remediation aligned with bargaining obligations.
  • Public disclosure
    • No public pay gap disclosure mandate exists; multinational companies may elect to publish a DEI/pay equity statement consistent with global commitments and Philippine data privacy constraints.

Example Employee Statement

Subject: Your Pay and Equal Pay Assurance

We are committed to providing equal pay for work of equal value, consistent with Philippine law. Your current pay reflects your job level, responsibilities, performance, experience, and local market conditions for our work location.

For your role (Job Title, Job Level) in (Location), the current base salary range is PHP [low] to PHP [high]. In addition to base salary, eligible employees receive 13th-month pay as required by law and may receive allowances and performance-based incentives according to company policy. Individual pay within the range is determined using documented, job-related factors and a calibrated performance process.

We regularly review our pay practices to identify and address any unexplained differences. We do not disclose other employees’ personal pay information to protect privacy under the Data Privacy Act. If you have questions about how your pay is determined or wish to raise a concern, please contact [HR Contact/DPO] so we can review promptly and fairly. Retaliation for raising pay concerns is strictly prohibited.

Remediation Framework

  • Trigger and scope
    • Remediation is initiated when statistical testing identifies a legally non-justifiable pay disparity or when DOLE/NLRC orders correction.
    • Define affected cohorts and individuals based on the comparison group and modeled residual gaps.
  • Investigation
    • Validate data accuracy, job evaluation alignment, and application of pay policies. Confirm whether documented, lawful factors explain the variance.
    • Engage Legal, HR, and Compensation governance to assess legal exposure, including the three-year prescriptive period for money claims.
  • Correction actions
    • Adjust current pay to eliminate the unjustified gap effective immediately or at the next pay cycle, with approvals per compensation governance.
    • Where exposure exists, compute retroactive differentials from the date the disparity arose within the three-year look-back (or as ordered by DOLE/NLRC), inclusive of proportionate 13th-month impacts.
    • Update pay ranges, hiring scales, and merit guidelines if systemic patterns are detected.
  • Documentation and employee communication
    • Record the basis for each adjustment, approvals, and calculations. Communicate adjustments to employees in a privacy-safe manner, reiterating equal pay commitments.
  • Monitoring and controls
    • Implement quarterly checks on high-risk cohorts and an annual full-cycle analysis. Embed equal pay checks into offer approvals, promotion reviews, and off-cycle pay changes.
  • Appeals and dispute resolution
    • Provide an internal appeal pathway. Preserve the right to elevate to DOLE/NLRC as provided by law. Maintain non-retaliation protections.

Compliance Calendar

  • January 15: DOLE Establishment Report on Payment of 13th-Month Pay due (via DOLE reporting portal).
  • December 24: Deadline to pay 13th-month pay.
  • Quarterly: Internal pay equity pulse checks and governance reviews.
  • Annually (Q1–Q2): Comprehensive pay equity analysis for prior year; remediation planning and budget incorporation into annual compensation cycle.
  • Rolling: Monitor RTWPB Wage Orders (effective dates vary by region); adjust minimum rate compliance and geographic differentials.
  • Ad hoc: DOLE inspections under the Labor Laws Compliance System; maintain inspection-ready records year-round.
  • Data Privacy: Annual review of NPC compliance (DPO registration, privacy notices, data sharing agreements, breach drills).

GDPR and Data Management

  • The Philippine Data Privacy Act of 2012 (RA 10173) governs HR data processing. Employers must establish a lawful basis to process personal and sensitive personal information used in pay equity analyses. Legitimate interests or necessity for contract/legal compliance are typical bases; explicit consent may be required for certain sensitive attributes. Processing must be proportional, with clear purposes stated in employee privacy notices.
  • Sensitive Personal Information includes age, marital status, health/disability, and other enumerated categories. Sex/gender data, while often collected in HRIS, should be handled with heightened safeguards. Limit collection to what is necessary for compliance and analytics, and prefer aggregated reporting to minimize re-identification risk.
  • Employers must appoint a Data Protection Officer (DPO), implement privacy management programs, and conduct Privacy Impact Assessments (PIAs) for pay equity analytics, especially where profiling and automated decision-support are used.
  • Implement organizational, technical, and physical security measures per NPC requirements, including access controls, encryption of analytics datasets, pseudonymization/anonymization for reporting, role-based access, and secure disposal of data extracts after use. Maintain data processing records and data retention schedules aligned to legal retention and the three-year prescriptive period for wage claims.
  • For data sharing and cross-border transfers (e.g., global HR analytics), execute Data Sharing Agreements consistent with NPC circulars. Ensure foreign recipients provide comparable protection, apply standard contractual clauses, and conduct transfer impact assessments. Obtain consent where required and notify employees via privacy notices.
  • Breach management requires notification to NPC and affected individuals within 72 hours of knowledge or reasonable belief of a breach likely to harm data subjects. Maintain incident response plans, logs, and evidence of remediation.
  • Employees have rights to access, correction, and objection; establish mechanisms for employees to review and correct their data used in pay equity analyses without exposing co-worker information. Provide transparent explanations of models and criteria at an appropriate level without disclosing proprietary algorithms that could compromise security or privacy.

Useful Resources

Important Disclaimer: This guide is based on information available as of August 2025 and is subject to change. The content provided does not constitute legal advice and is for informational purposes only. Total Rewards professionals should seek qualified legal counsel and local employment law expertise before making decisions or taking actions based on this guidance. Laws and regulations vary by jurisdiction and can change frequently. Always consult with local legal experts and relevant government agencies for the most current requirements.

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