Pulse Electronics Networking BU acknowledges the EU's standard for personal data protection. Pulse Electronics Networking BU has a need to extract and compile the Human Resource Data of employees in the EU. This Policy addresses the privacy concerns of European employees and the business concerns of Pulse Electronics Networking BU.
To affect this Policy, Pulse Electronics Networking BU adheres to the United States Department of Commerce Safe Harbor Principles and self-certifies on an annual basis to the United States Department of Commerce compliance with the Safe Harbor Principles. This Policy applies to all Human Resource Data transmissions from Pulse Electronics Networking BU operations in EU countries to the United States. This includes transmission of data over phone lines, computer lines, and in hard copy, and includes such material as human resources and payroll records, and any material that identifies a particular individual employee.
The use of EU employee personnel data includes global enterprise headcount reporting, statistical analysis, compensation planning and related transactions, staffing, international personal security issues, law enforcement inquiries, U.S. Government agency inquiries and mergers, acquisitions and divestitures.
Pulse Electronics Networking BU has adopted the seven Safe Harbor principles of notice, choice, onward transfer (transfer to third parties), access, security, data integrity and enforcement with respect to Human Resource Data to be transferred to the U.S. from Pulse Electronics Networking Division operations in the EU.
1. Notice: Pulse Electronics Networking BU collects Personal Information for, among other reasons, human resource management such as payroll administration, filling employment positions, maintaining accurate benefits records, meeting governmental reporting requirements, security, company network access, authentication and Global Headcount. Pulse Electronics Networking BU does not request or gather information regarding political opinions, religion, philosophy, or sexual preference. To the extent Pulse Electronics Networking BU maintains information on an individual’s medical health or ethnicity (only for countries where it is legally required) Pulse Electronics Networking BU will protect, secure and use that information in a manner consistent with this Policy and law.
If Pulse Electronics Networking BU collects Personal Information directly from individuals, it will inform them about the purposes for which it collects and uses Personal Information about them, the types of non-Agent Third Parties to which Pulse Electronics Networking BU discloses that information, and the choices and means Pulse Electronics Networking BU offers individuals for limiting the use and disclosure of their Personal Information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Information to Pulse Electronics Networking BU, or as soon as practicable thereafter, and in any event before Pulse Electronics Networking BU uses the information for a purpose other than that for which it was originally collected. Pulse Electronics Networking BU may disclose Personal Information if required to do so by law or to protect and defend the rights or property of Pulse Electronics Networking BU.
2. Choice: Pulse Electronics Networking BU will offer individuals the opportunity to choose (opt-out) whether their Personal Information is: (a) to be disclosed to a Third Party which is not an Agent; or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
For Sensitive Personal Information, Pulse Electronics Networking BU will give individuals the opportunity to affirmatively and explicitly (opt-in) consent: (a) to the disclosure of the information to a non-Agent Third Party; or (b) the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. Pulse Electronics Networking BU will provide individuals with reasonable mechanisms to exercise their choices should requisite circumstances arise.
3. Onward transfer (transfer to third parties): Prior to disclosing Human Resource Data to a third party, Pulse Electronics Networking BU applies the notice and choice principles, enumerated above. Pulse Electronics Networking BU will ensure that any third party keeper of Human Resource Data also subscribes to the Safe Harbor Principles or any other EU adequacy finding. Pulse Electronics Networking BU will also enter into written agreements with such third parties requiring them to provide at least the same level of personal data protection as is maintained by Pulse Electronics Networking BU.
4. Access and Correction: Upon request, Pulse Electronics Networking BU will grant individuals reasonable access to Personal Information that it holds about them. In addition, Pulse Electronics Networking BU will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete (except when the burden or expense of providing access would be disproportionate to the risks of the individual privacy in the case in question or if the rights of persons other than the individual would be violated). Any employee that desires to review or update his or her Personal Information can do so by contacting their local human resources representative. If the employee is not satisfied with the response of the local human resources representative, the employee should submit a written description of the matter to the Global Human Resources Manager.
5. Security: Pulse Electronics Networking BU will take reasonable precautions to protect Personal Information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction. Pulse Electronics Networking BU limits access to Personal Information and data to those persons in Pulse Electronics Networking BU’s organization, or as Agents of Pulse Electronics Networking BU, that have a specific business purpose for maintaining and processing such Personal Information and data. Any individuals who are granted access to Personal Information will have been made aware of their responsibilities to protect the security, confidentiality, and integrity of that information and will have been provided training and instruction on how to do so.
6. Data Integrity: The Company will collect only Personal Information which is relevant for the purposes for which it is to be used. The Company will take reasonable steps to ensure that Personal Information is relevant, accurate, complete, and current, to its intended use.
7. Enforcement: To ensure compliance with these Safe Harbor Principles, Pulse Electronics Networking BU will:
The Pulse Electronics Networking BU Human Resources Director & IT Manager are the internal mechanisms for ensuring compliance with the Safe Harbor Principles and facilitating the independent recourse mechanism referenced in item 7 above of this Policy.
European Union - The European Union (EU) consists of 15 member countries: Austria, Belgium, Denmark, Finland, France, Germany, Greece, Ireland, Italy, Luxembourg, The Netherlands, Portugal, Spain, Sweden and the United Kingdom.
Human Resource Data - (for the purposes of this policy) - Any human resource information relating to an identified or identifiable natural person who is a Pulse Electronics Networking BU employee and who can be identified, directly or indirectly, in particular by a reference to an identification number or to one or more factors specific to his or her physical, physiological, mental, economic, cultural or social identity.
Sensitive Data - Sensitive data is data that pertains to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sexual orientation or alleged commission of any offense. This data may not be transferred unless an individual gives explicit consent.
Questions regarding the transmission of Human Resource Data from the European Union (EU) to the United States or any other non-EU location, or any further transmission of the personnel data once received in the United States, should be referred to the Pulse Electronics Networking BU Human Resources Manager. Pulse Electronics Networking BU must annually, in writing, certify to the Department of Commerce that it adheres to the Safe Harbor Principles.