Momentive Specialty Chemicals Inc.
Data Protection Policy
This Data Protection Policy is intended to provide assurance that any personal data which Momentive Specialty Chemicals Inc. (the "Company") receives is handled with appropriate care. The Company needs to hold and use information about its associates in connection with their employment. Some of this information is "personal data" and possibly "sensitive personal data", as these terms are defined in various laws governing the collection and processing of personal information. The Company also occasionally collects personal information about customers and suppliers for legitimate business purposes. As a company with business operations around the world, the Company's subsidiaries are obliged to comply with the requirements of the local regulations governing the collection, processing and transfer of personal data and sensitive personal data. The corporate policy on data protection is a general policy and to the extent the laws in some jurisdictions may vary, the Company's subsidiaries in such jurisdictions are expected to comply with local requirements. All of the Company's associates and third party contractors working on the Company's behalf must comply with this policy even if local law is less restrictive.
2. Data Protection Principles
The Company will strive to ensure that your personal data is:
- collected only with your written consent, if and in so far as legally required;
- processed fairly and lawfully;
- processed only for specific purposes;
- adequate, relevant and not excessive;
- accurate and kept up to date;
- kept for no longer than is necessary;
- kept in accordance with your rights; and
- kept securely.
In essence, this means as a Company we aim to tell you what information we hold about you, why and for what purpose we hold it, from whom we have obtained it and to whom we will disclose it. We also aim to ensure that all your personal data is up to date and held securely and we will afford you the right to opt-out of providing data.
3. Purposes for Collection of Personal Data
As your employer, the Company will hold, use and otherwise process personal data relating to you for any purposes which reasonably arise out of and/or in connection with your employment, including without limitation, for the following purposes:
- considering your suitability for employment;
- administration of the payroll;
- administration of incentive program provision of employee benefits;
- compliance with legal requirements;
- performance monitoring;
- Company directories;
- effective management of the Company's business;
- in connection with disciplinary matters;
- to establish your training and/or development requirements;
- to establish a contact point in an emergency;
4. Sensitive Personal Data
Certain personal data is considered to be "Sensitive Personal Data." Sensitive Personal Data has been defined to include such things as, (i) your racial or ethnic origin; (ii) your political opinions; (iii) your religious or similar beliefs; (iv) your membership or otherwise in a trade union; (v) your physical or mental health or condition; (vi) your sexual life; (vii) your commission or alleged commission of any offence or (viii) proceedings relating to such offence. For the most part, the Company has no need for and does not collect Sensitive Personal Data. To the extent Sensitive Personal Data must be collected, it will be handled in accordance with applicable laws, handled carefully and with particular protection.
5. Obligations to Protect Personal Data
The Company's obligation. Personal data and Sensitive Personal Data relating to you will be held by the Company both manually and electronically. Such data shall only be kept for as long deemed necessary, in accordance with our policies. Personal data, particularly Sensitive Personal Data, is typically kept by the HR Department. Other members of staff or third parties will only have access to your personal data if required to fulfil their functions and in compliance with applicable laws. The Company is required to ensure that all personal data and sensitive personal data it holds is accurate and where necessary kept up to date. In order to enable us to comply with this obligation, you should immediately notify your HR representative of any changes to the personal information you have provided, including any changes to your name, address, emergency contacts and bank details.
Associates' Obligations. In the course of your duties, should you be required to process personal data which relates to other associates, you must comply with the data protection principles set out above and with any specific instructions given to you regarding such personal data. In particular, you must not, save in the proper performance of your duties, make use of, or communicate to any person (including any person working for or with the Company) or company, firm, business, or organisation any personal data or Sensitive Personal Data relating to any current or former applicant for employment, associate, former associate, agency workers, casual workers or contract workers. Breach of this requirement will be treated very seriously and, where appropriate, disciplinary action will be taken. You should also be aware that in certain circumstances by making an unauthorised disclosure of personal data you could be committing a criminal offence.
6. Disclosure of Personal Data
There are, of course, circumstances in which Personal Data must be disclosed. These are (i) When required by applicable law or regulatory requirements; or to comply with valid legal processes; ; or (ii) after careful weighing the impact on the subject data during emergency situations or where necessary to protect the safety of a person or group of persons or (iii) personal data may be disclosed with your consent. Should Personal Data be provided to third parties, we will contractually require such third parties to maintain similar safeguards.
7. Privacy Officer
The Company's policy on data protection is designed to ensure that your personal data is protected. If you have any questions about this policy, would like information about your personal data which we hold or wish to update the data, please send a written request to the Privacy Officer:
Momentive Specialty Chemicals Inc.
Attn: General Counsel
180 E. Broad Street
Columbus Ohio 43215
Updated: June 2014