NOTE: Klauke is a member of the Textron Inc. enterprise. Klauke adheres to the Textron Inc. Personal Data Protection Policy, which is set forth below.
It is Textron policy that employees must process personal data fairly and lawfully. Textron operations are responsible for collecting personal data only for specific, lawful, explicit and legitimate purposes, and for further processing of personal data consistent with those purposes. It is Textron policy that personal data be adequate, relevant and not excessive to the purpose for which they are collected or further processed. Textron operations are responsible for making every reasonable effort to maintain such data accurately, provide reasonable means to correct, delete, or rectify any inaccurate data, and store such data for periods no longer than is necessary. If a Textron operation or facility falls within the jurisdiction of more than one governmental body, it is responsible for complying with the higher or highest data protection standard in effect should there be any variance in those standards.
Confidentiality & Security
Textron operations are responsible for taking prudent steps to safeguard the confidentiality and security of all personal data, including appropriate procedural, organizational and technical steps to protect personal data from accidental or unlawful destruction or accidental loss, alteration or disclosure. These steps include entering into written agreements with subcontractors who process personal data in accordance with Textron's instructions incorporating Textron's own data protection standards as a minimum.
Notification to Government Agencies
Textron operations will comply with required governmental agency notification requirements.
Data Subject Access, Corrections & Deletions
Textron recognizes the right of data subjects to obtain without constraint at reasonable intervals and without excessive delay or expense:
1. Confirmation concerning whether Textron, any representative or agent is holding or processing personal data relating to him or her;
2. Information on the purpose(s) of the processing, the categories of data concerned, and the recipients or categories of recipients;
3. Information in an intelligible form concerning the data relating to him or her being processed and the source of such data; and
4. Information, as appropriate, concerning the logic underlying the data processing.
Further, Textron recognizes the data subject's right to require, as appropriate, the rectification, erasure or blocking of data whenever the processing of such data does not comply with applicable laws and regulations. Textron operations will alert, to the extent practicable, third parties to whom the data have been disclosed of any such rectification, erasure or blocking.
Data Collection, Transfer & Processing
Textron operations are responsible for collecting, processing and transferring personal data in compliance with the law. Only in very limited and rare circumstances, will Textron operations pass on personal data to healthcare professionals, e.g. where the data subject's health and well-being would otherwise be adversely affected and the data subject is unable to give formal consent.
It is Textron policy that except as allowed or required by law, personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union memberships, health or sex life or alleged commission of any offense not be processed and the collection and storage of such 'sensitive' personal data be particularly safeguarded.
For personal data obtained directly from the data subject, Textron operations are responsible for informing the data subject of the identity of those controlling the data, the purpose for which the data is being collected and processed and any further information the data subject may need for fair processing. This same standard applies to personal data not obtained directly from the data subject, except as allowed by law for statistical purposes.
Textron operations are responsible for informing the data subject prior to any initial transfer or processing of personal data for direct marketing purposes and, upon request, for blocking such action.
It is Textron policy not to transfer personal data to any entity, individual, or organization, particularly entities within third countries without adequate data protections, that does not meet the standards established by this policy without ensuring that:
1. The data subject has given his/her unambiguous consent;
2. The transfers are needed for the performance of a contract between the data subject and the controller or to implement a pre-contractual commitment made at the request of the data subject;
3. The transfers are needed for the conclusion or performance of a contract concluded in the interest of the data subject between the controller and a third party;
4. The transfers are needed to protect the vital interests of the data subject; or
5. The transfers are made from a register established pursuant to laws and regulations as being open for consultation by members of the general public or by any person who can demonstrate a legitimate interest.
Adherence to Safe Harbor Privacy Principles with Respect to Human Resource Data
Textron adheres to the Safe Harbor privacy principles developed by the U.S. Department of Commerce in coordination with the European Commission. Textron's Safe Harbor Policy applies to all human resource data transmissions from the European Union to the United States. The principles provide guidance for U.S. organizations on how to provide adequate protection for personal data from Europe as required by the European Union's Directive on Data Protection. Textron's Safe Harbor Policy is available for viewing at www.textron.com/legal/safe_harbor.html and can also be obtained from the Textron Director, Privacy or from each Segment Privacy Officer.
Consent - the freely given and informed agreement by a person (i.e., the "data subject") to the processing of his/her personal data. The data subject may withdraw his/her consent at any time and may attach any condition or limitation he/she believes to be appropriate.
Personal Data - any information relating to an identified or identifiable natural person (i.e., a private individual as opposed to a corporation or other comparable entity). An identifiable person is someone who can be identified, directly or indirectly, in particular by reference to an identification number or the person's physical, physiological, mental, economic, cultural or social characteristics. Personal data may relate to employees or other natural persons, including customers, clients, investors, suppliers, contractors or other individuals.
Data Subject -a natural person, a private individual about whom information is collected, stored or processed.
This policy applies to all Textron operations and business units. To the extent any Textron operation or business unit already has a data protection policy in place, this policy shall supersede any inconsistencies and/or supplement any such policies. Textron's financial services businesses, Textron Financial and Cessna Finance, are subject to privacy regulations with respect to their customers. These operations will continue to follow their own privacy policies regarding their customers and will follow this Textron policy in all other respects, including the personal data of their employees.
The Textron Director, Privacy is responsible for the administration of this policy and monitoring enterprise wide compliance. Each segment is responsible for appointing a Segment Privacy Officer responsible for segment compliance. A Reference Guide containing more detailed guidance is available from the Textron Director, Privacy.
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This policy is effective July 2012.