Data privacy, confidentiality and information security

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We consider data privacy laws, maintain the confidentiality of all commercially sensitive information, trade secrets and other confidential information relating to the Group and its business

Data privacy

Personal data is information that directly or indirectly identifies an individual. As a global company holding a significant volume of information about individuals, Group companies and employees must ensure that they handle personal data in accordance with local data protection laws and the Group Data Privacy Policy.

Data privacy laws govern the handling and processing of personal data and the ways in which it may be transferred between companies or countries. It applies to all individuals including customers, employees, contractors and employees of suppliers or other third parties we do business with.

We are committed to handling personal data responsibly and in compliance with applicable data privacy laws worldwide. Please see the Group Data Privacy Policy available on The Hub. The Policy is designed to provide a global minimum standard with respect to the protection of personal data. We must be mindful that in some jurisdictions certain laws may impose additional requirements and we will handle personal data in accordance with all such applicable laws.

Confidential information

Our confidential information is any information or knowledge which may prejudice the Group‘s interests if disclosed to third parties, such as:
  • sales, marketing and other corporate databases
  • pricing and marketing strategies and plans
  • confidential product information and trade secrets
  • research and technical data
  • new product development material
  • business ideas, processes, proposals or strategies
  • unpublished financial data and results
  • company plans
  • personnel data and matters affecting employees
  • software licensed to or developed by a Group company

Disclosing confidential information

We must not disclose confidential information relating to a Group company or its business outside the Group without authorisation from higher management and only:

  • to agents or representatives of a Group company owing it a duty of confidentiality and requiring the information to carry out work on its behalf
  • under the terms of a written confidentiality agreement or undertaking
  • under the terms of an order of a competent judicial, governmental, regulatory or supervisory body, having notified and received prior approval from local LEX Counsel

If confidential information is to be transmitted electronically, then technical and procedural standards should be agreed with the other party.

We should be mindful of the risk of unintentional disclosure of confidential information through discussions or use of documents in public places.

Access to and storage of confidential information

Access to confidential information relating to a Group company or its business should only be provided to employees requiring it in order to carry out their work.
We must not take home any confidential information relating to a Group company or its business without making adequate arrangements to secure that information.

For further guidance, please see the Group‘s Security Policy Statement on The Hub.

Use of confidential information

We must not use confidential information relating to a Group company or its business for our own financial advantage or for that of a friend or relative .

See Conflicts of interest

Particular care must be taken if we have access to ‘inside information’, which is confidential information relevant to the price of shares and securities in public companies.

For further details, see Insider dealing and market abuse

Third party information

We must not solicit or wilfully obtain from any person confidential information belonging to another party.

If we inadvertently receive information which we suspect may be confidential information belonging to another party, we should immediately notify our line manager and local LEX Counsel.

Who to talk to

Your line manager
Higher management
Your local LEX Counsel
Head of Compliance: