Why Should U.S. Headquarters Worry About A New European Employment Law?
For 15 years, the 15 (now 25) countries in the Brussels-based European Union have been actively coordinating (“harmonizing”) their national employment laws. Many of the EU coordinating laws (“directives”) simply present local compliance issues for local European HR to worry about (for example, there are EU coordinating laws on maternity leave, part-time employment, worker safety). But certain other EU-coordinating laws actually reach across the Atlantic, to multinational headquarters stateside. A key example: the EU data privacy law (Council Directive 95/46/EC), which regulates transmissions of HR (and other) data to the U.S. (and elsewhere), affecting HRISystems (PeopleSoft, SAP). For years now, American headquarters, not local European HR staffs, have been driving U.S. multinationals’ data-privacy compliance efforts (launching, for example, “safe harbor” and “model contracts” projects). Having conquered European data privacy requirements, U.S. “best practices” multinationals will be