ELECTRONIC MONITORING AND MANAGEMENT OF EMPLOYEES New risks and new topic of negotiations within the services sector

Size: px
Start display at page:

Download "ELECTRONIC MONITORING AND MANAGEMENT OF EMPLOYEES New risks and new topic of negotiations within the services sector"

Transcription

1 3-5 Rue de Metz PARIS SA à capital variable RCS Paris B Tél. : Fax : SIRET : ELECTRONIC MONITORING AND MANAGEMENT OF EMPLOYEES New risks and new topic of negotiations within the services sector European ADAPT Project Ministry for Employment and Solidarity Labour Relations Directorate Aslaug JOHANSEN Serge GAUTHRONET 1999

2 Electronic monitoring and management of employees 2

3 Electronic monitoring and management of employees 3 CONTENTS Introduction...5 I) - Monitoring and surveillance technologies...9 I.1) - Management by objectives...9 I.2) - Scheduling...10 I.3) - Security software...11 I.4) - Infocentres and data warehouses...12 I.5) - EDM and Workflow Management...13 I.6) - Mobile data processing...14 I.7) - Telephone platforms...15 I.8) - Internet and Intranet...16 II) - The legal framework...19 II.1) - The Act dated January 6, 1978 concerning data processing, data files and liberties...19 II.1.1) - Prohibition of automated decisions...19 II.1.2) - Prior disclosure to employees...20 II.1.3) - The right to object to and dispute the reasoning applied to such data...20 II.I.4) - Compliance with purpose...21 II.2) - The Act dated December 31, 1992, otherwise called the Aubry Act...22 II.3) - The EEC directive concerning occupations involving the use of visual displays and its enactment under French law (Decree N) )...23 II.4) - The 95/46/EC directive of the European Parliament and Council dated October 24, II.5) - Compendium of practical guidelines for the protection of workers' personal data (ILO)...25 III - Toilsome negotiation of company-level agreements Four case studies...27 III.1) - Case study overview...27 III.1.1) - The background to the agreements...27 III.1.2) - The negotiating policies and strategies of trade unions...30 III.1.3) - Scope and limitations of these agreements...32 III.I.4) - The prospects for negotiations at branch level...33 III.2) - Caisse d'epargne de Paris...37 III.2.1) - The background against which the agreement was negotiated - deep-rooted changes at the Bank...37 III.2.2) - Strong trade union involvement regarding new technologies...42 III.2.3) - Protracted negotiations...46 III.2.4) - Outlook - successful completion may be at hand...47

4 Electronic monitoring and management of employees 4 III.3) - Crédit Mutuel de Bretagne...51 III.3.1) - Salient features of the business...51 III.3.2.) - The background against which negotiations are set...53 III.3.3) - Main items in the agreement...58 III.3.4) - Application of the agreement...60 III.4) The Mornay Europe Group...65 III.4.1) - Salient features of the company...65 III.4.2) - The background to the negotiation...68 III.4.3) - Salient features of the agreement...72 III.4.4) - Application of the agreement...76 III.5.) - An insurance company...79 III.5.1 ) Salient features of the company...79 III.5.2) - A work and technology scheme with highly structuring effects...80 III.5.3) - Strong fears among the trade unions...81 III.5.4) - Interruption of negotiations and freezing of the project...83 IV) - The legal framework in a number of European countries...85 IV.1) Overview...85 IV.1.1) - Two sources of law...85 IV.1.2) - Highly complementary legal instruments...87 IV.1.3) - Encouragement to negotiate locally...88 IV.1.4) - The scope of negotiations - considerable differences from one country to another...89 IV.2) - Germany...91 IV.2.1) Overview...91 IV.2.2) - Legal framework...91 IV.2.3) - Company-level agreements...94 IV.2.4) - Practice...94 IV.3 Norway...96 IV.3.1) - Overview...96 IV.3.2) - Legal instruments...97 IV.3.3.) - Labour agreements...98 IV.3.4.) - Application IV.4) - The Netherlands IV.4.1) - Overview IV.4.2) - Legal framework IV.4.3) - Collective negotiations IV.4.4) - Policies and practice - the Government's attitude IV.5.) - Sweden IV.5.1) - Overview IV.5.2) - Legal framework IV.5.3) - Labour agreements IV.5.4) - Practice CONCLUSION

5 Electronic monitoring and management of employees 5 Introduction Preliminary observation It is more difficult to perceive changes in work organization and working conditions in large companies that operate in the services sector than in the industrial sector. These changes come about gradually and do not generally involve a complete transformation of production equipment. However, in recent years, it has become quite clear that some major changes have occurred at the "heart" of relationships between services sector employees and their employers. With increased automation, methods for planning, allocating, monitoring and supervising work are changing. Management methods are moving from a conventional approach hinging on control and hierarchy to electronic management. To properly grasp the significance of the changes in process, it is worth recalling that although major processing chains have long been computerized, control and monitoring tools have largely remained manual or semi-manual. It is significant that in many companies, task assignment, tracking and supervision of pending business continues to be a major part of the work done by first-line supervisors. Company executives complain that, in contrast with the industrial sector, they do not have the necessary tools to compute the cost of processing a file. For a long time, control and monitoring tools were painfully lacking. Ongoing developments in new technologies are now bringing about changes in this situation at various levels. Monitoring and surveillance tools are increasingly included in production software. Workflow management makes it possible to control document flows and job sequences. This type of software is highly effective when used in conjunction with image processing. In this way, not only can files be distributed automatically, but who does what within a given process is determined on the basis of a pre-established model. Applications of this type allow for a variety of work organization patterns to be implemented but, once they are set up, have a highly structuring effect. These packages generally have powerful built-in monitoring tools which provide professional staff with real time data on production and backlog. As a result, the traditional role and status of supervisory staff are changing. Major changes for employees are also occurring in another area - sales. Staff that handles customers in banks are equipped with far more powerful workstations that cater for a broad range of functions (including sales aids). The

6 Electronic monitoring and management of employees 6 schedule manager is one instance, enabling employees to plan their schedule and make appointments regardless of their whereabouts. Because of the power of portable equipment and the development of public networks, the internal flows of businesses can be redesigned - home-based work, entering data at source, doing away with intermediary functions, abolishing time and space constraints to gain direct access to sources of information. These new technologies along with new management practices have led to even more elaborate subdivision of tasks in businesses. For some employees, this means more resources and greater potential for initiative, for others it entails increased job specialization. What is common to all these developments is that employees can be far more readily monitored than in the past. Computer-based systems for performance monitoring are not easy to identify : they often consist in secondary, derived functions that are embedded in the functional software. The introduction of these applications creates tensions, or even open conflicts in businesses. For employees, there are a variety of risks involved - setting objectives on an individual basis, unfair assessment of employee work load and performance based solely on the number of computerized transactions processed, spread of "electronic management", etc. Although, more and more, employees are willing to use advanced tools and thereby maintain their employability, the rapid development of new automated tools for performance monitoring can act as a hindrance to modernization. To solve this difficulty, several companies have entered into agreements that regulate the use of such devices in particular and work organization more broadly. Purpose of the study The aim of this study is to gain a better understanding of this recent trend in the traditional areas that belong to the services sector - the rapid development of new technologies that permit automated monitoring of the workplace - and investigate the way in which the social partners in France have attempted to minimize the risks of abuse and misuse by entering into company level agreements. Based on a selected number of case studies, it examines: the nature of the guarantees obtained and actual practice (extent to which agreements are complied with), the reasons for the breakdown of some of the negotiations on this topic.

7 Electronic monitoring and management of employees 7 This study was conducted on behalf of the Ministry for Employment and Solidarity and is also part of the European ADAPT Initiative entitled "Employee participation in modernization processes". It includes a comparative analysis of legislative developments in this area in a number of European countries. Method This study was carried out using conventional methods of observation and comparison. It was led by a transnational steering committee and emphasized interaction with the businesses that actively participated in the project. In France, four company monographs were drafted based on interviews conducted with senior management and trade union representatives. The comparative study involved four countries - Germany, Norway, the Netherlands and Sweden. In each of these countries, many contacts were made with representatives of the social partners, the national authority that supervises data protection, consultancy firms and university research institutes. The transnational steering committee met on three occasions during the year. It is made up of the members of the EESUN (European Employee Support Network) whose specificity is to bring together a number of independent firms that have considerable experience working together for the social partners in each of the countries. The following firms took a particularly active part in the steering committee's work - Arbetstagarkonsult AB for Sweden, CASA for Denmark and STZ Advies and Onderzoek for the Netherlands. We would like to express our thanks to all those who contributed to accomplishing this study. Paris, 1998 This report was translated into English in 1999.

8 Electronic monitoring and management of employees 8

9 Electronic monitoring and management of employees 9 I) - Monitoring and surveillance technologies In the last decade, among the range of modern technologies for monitoring employee performance in businesses, the only commonplace advanced technology were PBXs (business telephone switchboards), access control systems that use passes and video monitoring. In the last few years a variety of technical solutions for supervising and monitoring the workplace have very gradually entered the market in the form of additional functionalities built into computerized work systems. The presence of these functionalities in application softwares is not always readily visible in as much as they are often secondary to and embedded in the main information processing applications whose purpose is altogether different. This appears to be an inevitable phenomenon. Moreover, the more recent the technology, the more likely it is to incorporate explicit reporting and tracking functions, as advertised in the accompanying sales pitch. This technological development is in line with a deep-seated trend in corporate sales strategies which use information technologies as a tool for handling customer relationships on a highly individual and customized basis. We have now entered the "one to one" marketing era where the customer and associated customer administrator are seen as an economic entity in its own right, whose performance must be assessed. There will be a growing tendency, particularly in the services sector, for the work plan and technology to be entirely built around this principle. As shown below, this will clearly have an impact in terms of monitoring and surveillance in the workplace. Without claiming to be comprehensive, we decided to consider eight families of applications in detail - management by objectives systems, time management, security packages, infocentres, EDM and workflow management, telephone platforms, 'roaming' DP systems and the Internet. To varying degrees, these highly diverse computer applications all support employee activity monitoring, assessment of their performance, and are able to track their every transaction including when and how long it took to accomplish them. I.1) - Management by objectives Employees are increasingly being asked to work towards individual or team objectives. A conspicuous example of this is sales staff who are assigned annual targets expressed as turnover, number of appointments or quantities of

10 Electronic monitoring and management of employees 10 products to be sold. Another is programmers whose objectives are expressed in terms of work load absorbed and lead times. There are now specific packages and softwares available for the purpose of monitoring individual activity, measuring possible deviations, both ahead of and behind initial schedule. As a general rule, they are based on the principle of statement -- i.e., the users themselves enter the information concerning their activity instead of the sheets they previously filled in by hand at the end of the working week or month. Naturally, this method presents no problem in terms of prior notification of employees and fair data collecting procedures, as they themselves are the originators. Computerized monitoring of objectives presents the benefit, for the business, of offering an instantaneous consolidated view of how far an employee, team or work unit has progressed towards the annual objectives. Hence, corrective action can be taken during the course of the year and impetus is maintained. However from the employees' standpoint, there is a problem with who gains access to such data and in what format. Generally, only intermediate management has access to the detailed data, while more senior managers one and two levels above are only entitled to consolidated, nameless data. I.2) - Scheduling Office automation systems that are built into the central system (e.g., the Office Vision type by IBM) or in a network of PC's set up in a client/server environment (such as Notes) support calendar management and personal diary functions. They are used with varying degrees of effectiveness, but they are convenient e.g., for establishing a common time slot for several people to join into a work session together. They are also useful for employees to make appointments while away from their base. These softwares, however, also generally support a supervisory function which provides the person responsible, i.e. the applications administrator, with a broad range of possibilities, e.g., analyzing and publishing data relating to operations performed during a given time interval, appointments taken, meetings, movements, etc. It is therefore theoretically possible to actually audit how working time is spent by an employee or group of employees. Electronic diaries also raise the fundamental issue of loss of autonomy felt by the employees concerned. Frequently, a central department of the business is in charge of planning the schedules of their sales staff. That nearly always leads

11 Electronic monitoring and management of employees 11 to controversy as to whether a department with little or no knowledge of the realities of the sales profession has the necessary competence. Naturally the duration of an appointment will largely depend upon the matter being dealt with. Similarly, in the case of travelling employees, it is important to properly compute and consider the time spent going from one destination to the next. I.3) - Security software Businesses are bound to take steps to protect data processing systems against crime, fraud and malevolence. This need has been sharpened by the development of on-line international networks such as the Internet. More and more European countries are passing data protection laws that require businesses to implement high level security systems for protecting their central EDP systems from unauthorized access. Vendors have gradually developed a range of packages aimed at this particular market segment. The earliest of these softwares and the most common for IBM mainframe environments are RACF and CA-TOP Secret. which have set the standards for this market. They control connections made with the central system, handle a user-accreditation system, authorize access to various resources and guarantee the privacy of the company's data files. These are sensitive applications because they may be used to perform what might at first sight appear to be highly detailed audits of a particular person's earlier activity. This is referred to as traceability, i.e., identification of users, duration of connections, resources used in read or update mode, types of transactions performed, etc. Two sets of problems pertaining to fairness and relevance are raised by practices such as these. Special attention needs to be paid to the way in which the purpose for implementing these procedures is worded (as contained in the declaration filed with the National Commission on Data Processing and Liberties [CNIL] under appendix 7 in principle). Without wishing in any way to prejudge companies' intentions in this respect, the possibility exists that processes may be unfairly conducted from a legal standpoint to the detriment of employees, under cover of data protection requirements. Furthermore, it would be wrong to assess an individual's efficiency at work on the basis of the statistics and workstation transactions volumes derived from these applications. Not only would to do so be in contradiction with the spirit of the French privacy law (Informatique et Libertés), specifically

12 Electronic monitoring and management of employees 12 article 2 ( 1 ) but also with common sense. A few lines of transactions statistics recorded by a security and data access control application afford little more than a very narrow and unreliable view. I.4) - Infocentres and data warehouses Infocentres are very powerful, all-purpose packages which are set up as an additional layer of superstructure on top of the business's data processing system. They support extensive, customized sorting and statistical processing functions for all types of information recorded in the central system's files and data bases. These tools are widely used in marketing departments, but also in financial and accounting departments. They can be directly operated by trained users thanks to their advanced query language. This raises one of the problems relating to application of the Data Processing and Liberties Act since, like PC's, the use of such tools is widely disseminated, unrestricted and largely unstructured. As such they offer extensive possibilities for multithreading between all sorts of data. These possibilities need not be defined at the outset and, as a result, it is difficult to apply the principle of prior notification as stipulated by article 16 of the Act. Infocentres and data warehouses can be used for employee monitoring, e.g., analyzing individual performance of employees who have been assigned a portfolio of customers. More and more businesses are using systems that equate the employees to micro profit centers with their own resources, a customized work station and individualized customer management. In this type of work environment, infocentre software is an essential technological tool. Individual portfolio turnover can be assessed at any time by simply comparing the initial volume with measurements made at regular intervals. This affords a fairly accurate estimate of the sales efficiency of the portfolio's administrator. Infocentre software can also be used to compute the variable item in an employees' compensation. As a result, employees need no longer fill in statements handled by a separate performance management application since the infocentre uses objective data generated from within the production stations. 1 Article 2 of the Act dated January 6, "No court decision involving the appreciation of human conduct shall be founded on automated processing of information that provides a definition of the person's profile or personality. No administrative or private decision involving the appreciation of human conduct shall be founded solely on automated processing of information that provides a definition of the profile or personality of the person concerned.".

13 Electronic monitoring and management of employees 13 I.5) - EDM and Workflow Management EDM and Workflow Management applications are a new generation of computerized tools designed to enhance processing of paper files and productivity in a wide range of businesses with these types of needs. Strictly speaking, EDM eliminates paper flows whereas workflow management supervises job distribution and work processes. An EDM/workflow management system generally comprises four major subsets: Document Acquisition -- documents are digitized using scanners and can be displayed directly on the operators' workstations. Scanning is done in the support units (incoming mail) where operators must index the documents so that they are routed to ad hoc mailboxes attached to the appropriate department, or else to a named destination operator. Routing -- routing is performed by a digitized mail delivery application to mailboxes which can be opened from the workstations. This is the workflow application, a key element in the system as a whole, because it is on this that depends the capacity of the system to adapt to the company's organization. Applications that are too rigid will tend to have a structuring effect that requires a fixed work plan. Ideally, the product should be openended and customizable so that documents can be delivered into to a whole range of mailboxes -- general department mailbox, dedicated mailboxes for particular processes or tasks, personal mailboxes. However, the more differentiated the mailboxes, the more complex the indexing and file allocation procedures are at the initial scanning stage. Access and display -- the required documents are generally retrieved through a network of PCs equipped with 21-inch screens. Mail is displayed on one half of the screen, while the other part of the window is used by the operator to enter the transactions to actually process the file. If the user does not have the material required to process the file as it is displayed, he or she can put it on standby so that it is automatically displayed again within a given time interval, or else reassign it to another operator who does have the necessary information or accreditation. These functionalities too are handled by the workflow management application. These applications platforms, the most well-known of which are IBM's VisualInfo and Flowmark, and Filenet, usually include monitoring and reporting functionalities built into a control system. They enable intermediate managers to control execution of processes, the status of tasks and compliance with lead times practically instantaneously.

14 Electronic monitoring and management of employees 14 Monitoring - this consists in monitoring how files are being processed at any time and at any level within a work unit. A special accreditation technique allows the manager in charge to visualize any of the processes being conducted in his or her department and take steps to reallocate work if the file backlog is found to be unbalanced. Reporting - two forms of reporting are supported by EDM platforms. One is the traditional reporting function whereby various paper or screen reports on operations in process are published periodically. As a rule, any event occurring during the course of any part of a process is recorded in a job log. This introduces a high degree of security and allows errors, and more broadly malfunctions, in the process to be subsequently identified. Some of these applications also offer advanced reporting functions in the form of warnings displayed on the supervisor's workstation which can be programmed so that they trigger when certain conditions occur, e.g., when authorized lead times are overshot. Depending on how they are used, these systems can greatly affect labour relations. They can generate a tendency by management to implement automated decisions (both technical and disciplinary), intensify pressure to raise productivity, give employees the impression of being under continuous scrutiny and create a general feeling of discomfort. I.6) - Mobile data processing For a growing number of employees, laptop computers are becoming their major link with the company. Those most concerned are sales staff, field inspectors, medical travelling salespersons, maintenance engineers, etc. Very soon, all these professions will be carried out using laptop computers connected to the company's central hosts via modems. In some professions that involve constant travel, GSM (radio link) modems are already being used. From a remote location, employees can link up to: - the business's information resources (e.g., product data base, simulation systems, inventory data) - communication and electronic mail (the Notes application for instance), - centralized schedules for the purpose of taking orders, - central data processing chains into which roamers can enter data collected in the field To a certain extent, employees see these laptops as responsible for them losing some of their freedom of decision, although they do recognize that they are

15 Electronic monitoring and management of employees 15 very practical and efficient work tools. For businesses, the data exchanges they support establish closer links with a category of employees which so far were difficult to supervise. It is now possible to instantly know exactly where company employees are located, how long their interventions last, the results they achieve, etc. Another feature of these tools is that they tend to obscure the line that separates working life and working hours from private life and private undertakings. As a result, providing guarantees of transparency and fair treatment of employees concerned becomes of paramount importance. I.7) - Telephone platforms Businesses now tend to centralize the telephone function with both incoming and outgoing connections handled by dedicated operators working on fully equipped technical platforms. Telephone platforms are equipped with a PBX of a special type, called Automatic Call Distributors (ACDs). They support advanced technical functionalities not only for call handling but also interconnection with the company's information system and reporting features. PBXs used on telephone platforms must be capable of managing and routing large numbers of telephone calls. To fulfill that purpose, groups of operators can be configured to match a queuing scheme. As soon as a call is over, the next call in line is presented to the operator in the corresponding group. In the meantime, the caller has been kept on the line with a variety of hold messages, some of which permit some degree of interaction and therefore an initial response. This generation of PBXs also supports an overload management function, so that when the operators' stations have reached saturation point, surplus calls are automatically re-routed to back-up operators. Furthermore, priority rules for the allocation of calls can be customized. In this way, an incoming call will be assigned to the operator who has been off-line for the longest period and calls which has been queuing the longest will be taken first. These PBXs also have supervisory functions that enable managers to reconfigure groups and queues in real time so as to balance out the work load. As described further on, these supervisory features are packaged along with reporting features that publish detailed reports on the platform's activity and quantify incoming and, if required, outgoing connections. The advanced supervisory features in ACDs allow a whole series of data on the telephone traffic processed by the platform to be collected almost instantaneously. This includes, among others:

16 Electronic monitoring and management of employees 16 individual operator activity (using the personal number the user keys in at the beginning of each work session) performance of the operator groups individual performance of each operator time elapsed before a call is taken volume of calls dealt with through standby facilities volume of incoming calls reallocation of calls in queues, volume of aborted calls time spent on-line by operators time spent off-line (i.e., an indirect measurement of the length of breaks) where calls originate from On the basis of this information, platform supervisors and managers can reconfigure the ACD and queuing scheme in real time to enhance performance. They can customize the system to issue warnings that are automatically triggered as soon as a specified threshold is reached, i.e. accomplish the monitoring function. All these data can be itemized, aggregated, arranged into a daily, weekly or monthly format, and published in the form of reports by the built-in supervisor, thereby by fulfilling the reporting function. I.8) - Internet and Intranet In spite of the enthusiasm and appeal the Internet generates among users, there is no guarantee of privacy. Each transaction is recorded in a register on the company's Intranet server - that indeed is the whole purpose of the Proxy Server. Sessions can be traced back to the user, usually without the latter knowing, and even the particular services consulted and the detail of the pages downloaded can be ascertained. The underlying risk is that these registers might be used to discipline a person, on the grounds that the Internet sessions were unrelated to the person's professional activity. Some cases of this type have been reported in businesses that have these resources. Clearly, all these technologies affect the traditional employment relationship and entail risks for personal freedoms at the workplace. Four considerations need to be mentioned in this respect: Computerized workplace surveillance systems give the impression they are objective and infallible because they are performed by a computer. Machine records are seen as more reliable than the employee's good faith. However, it is quite obvious that these systems are incapable of

17 Electronic monitoring and management of employees 17 appreciating the full complexity and diversity of an employee's work day. Even in a workflow management environment, where as many processes as possible have been included, there are always some activities that escape computerization and quantification. Systems such as these are sometimes unfairly implemented - either the employees are unaware of the existence of processing pertaining to their activities, and only find out one day at their own expense, when administrative action, or worse, disciplinary measures are taken against them; or else, they know of their existence - this is clearly the case when applications require data to be entered by the employees - but are not necessarily aware of how the data is handled, what sort of assessments are made on the basis of the data, how conclusions are drawn or what decisions they entail. These tools alter the conventional employment relationship based on direct dialogue between employees and management. It has been reported that intermediate management has on occasions used the workflow management application to modify work flows and loads by reconfiguring individual accreditations, altering the rules for job allocation and redistributing pending files without any prior consultation with the persons concerned. This type of conduct can cause uneasiness in as much as it reflects an authoritarian, underhand attitude where users are given no opportunity to provide justification and are simply faced with the fait accompli. The expansion of this generation of computer applications may also be partly responsible for a sharp reduction in the number of levels of management in many businesses, particularly in the United States, and for their wholehearted adoption of the flat organization chart approach. Lastly, these systems amplify the tendency to itemize tasks in the services sectors and to apply the Taylorist model dating back to the Industrial Revolution to this very different environment. Under cover of advanced management techniques, in particular those that hinge on the notion of micro profit centre, the implementation of these productivist technologies becomes a factor of social regress.

18 Electronic monitoring and management of employees 18

19 Electronic monitoring and management of employees 19 II) - The legal framework II.1) - The Act dated January 6, 1978 concerning data processing, data files and liberties The applicability of the Act dated January 6, 1978, - la Loi Informatique et Libertés (Data Processing and Individual Liberties Act) - does not of course stop at the doorstep of firms. Indeed, the National Data Processing and Liberties Commission (CNIL) has considered it appropriate to set out special provisions to facilitate the procedure whereby businesses file prior declarations as to the processing of data connected with personnel management or the operation of PBXs. As for performance monitoring and surveillance, four guiding principles and legal provisions provide for employee protection -- the prohibition of automated decisions, prior disclosure, the right to object and the obligation to file a prior declaration. These four provisions are briefly described below. II.1.1) - Prohibition of automated decisions One of the fundamental articles of the French privacy law virtually bans automatic decision-making procedures based on processing of personal data. Article 2 reads as follows: Article 2: «(...) No court decision involving the appreciation of human conduct shall be founded solely on automated processing of information that provides a definition of the person's profile or personality.» In practical terms, this provision means that no decisions against employees, whether administrative or, moreover, disciplinary, may be taken solely on the basis of statistics generated by software of any type. Under this provision, transferring or dismissing a member of staff on the basis of unsatisfactory performance could be disputed if it is shown that the decision relies solely on computerized data collected through the reporting function of a production program. Effectively, this article of the act protects employees against the imprecision and the risks attached to the arbitrary nature of automated systems which are as yet unable to account for the entire work situation, and in particular qualitative aspects of an activity, exogenous constraints, contingencies and anything that is not objectively computable and measurable through computerized transaction volumes, I/O's or a variety of counters.

20 Electronic monitoring and management of employees 20 II.1.2) - Prior disclosure to employees The privacy act makes the principle of transparency with regard to collection and processing of personal data compulsory. Naturally, this principle applies to data on employees, and not only with respect to commercial files. Articles 25 and 27 specify the requirements as to prior disclosure and fairness: Article 25: «Collection of data by all fraudulent, unfair or illicit means is prohibited.» Article 27: «Persons from whom named information is collected must be informed of: - the mandatory or optional character of the answers; - the consequences for them if they fail to answer; - the natural persons or legal entities on behalf of whom the information is being collected; - the existence of the right to access and to correct (...).» These two articles of the Act clearly spell out that no collection or processing of personal data may be performed unbeknown to the employees. However, there are unfortunately a great many businesses that do not all together abide by these provisions. On this point, the CNIL's position and caselaw are very strict and unequivocal. Indeed, businesses are as routinely sentenced for failing to provide advance notice to employees. In some cases, the courts also award damages and interest to the employees ( 2 ). There have also been a few cases where the company decisions have been annulled (a dismissal, in one instance) because the information on which the firm based itself on was collected by unfair means (tailing by a private detective) ( 3 ). II.1.3) - The right to object to and dispute the reasoning applied to such data The January 1978 Act also contains four specific provisions that enable individuals, in this case company employees, to dispute the rationale applied on the basis of automated processes, to object to the processing of personal data relating to them, to gain access to the data, to require correction in the event the information is incorrect. The four articles in the Act that provide these guarantees are the following: 2 See Court of Cassation, Chambre Sociale - Award dated June 7, See Court of Cassation, Chambre Sociale - Award dated May 22, 1995

SUPPLEMENTARY INTERNAL RULES IMPLEMENTING REGULATION (EC) N 45/2001 IN RELATION TO THE DATA PROTECTION OFFICER

SUPPLEMENTARY INTERNAL RULES IMPLEMENTING REGULATION (EC) N 45/2001 IN RELATION TO THE DATA PROTECTION OFFICER SUPPLEMENTARY INTERNAL RULES IMPLEMENTING REGULATION (EC) N 45/2001 IN RELATION TO THE DATA PROTECTION OFFICER 10 September 2009 page 1 / 8 SUPPLEMENTARY INTERNAL RULES IMPLEMENTING REGULATION (EC) N 45/2001

More information

Recommendations for companies planning to use Cloud computing services

Recommendations for companies planning to use Cloud computing services Recommendations for companies planning to use Cloud computing services From a legal standpoint, CNIL finds that Cloud computing raises a number of difficulties with regard to compliance with the legislation

More information

Personal Data Act (1998:204);

Personal Data Act (1998:204); Personal Data Act (1998:204); issued 29 April 1998. Be it enacted as follows. General provisions Purpose of this Act Section 1 The purpose of this Act is to protect people against the violation of their

More information

LEGISLATION COMMITTEE OF THE CROATIAN PARLIAMENT

LEGISLATION COMMITTEE OF THE CROATIAN PARLIAMENT LEGISLATION COMMITTEE OF THE CROATIAN PARLIAMENT 2300 Pursuant to its authority from Article 59 of the Rules of Procedure of the Croatian Parliament, the Legislation Committee determined the revised text

More information

Corporate Policy. Data Protection for Data of Customers & Partners.

Corporate Policy. Data Protection for Data of Customers & Partners. Corporate Policy. Data Protection for Data of Customers & Partners. 02 Preamble Ladies and gentlemen, Dear employees, The electronic processing of virtually all sales procedures, globalization and growing

More information

Processor Binding Corporate Rules (BCRs), for intra-group transfers of personal data to non EEA countries

Processor Binding Corporate Rules (BCRs), for intra-group transfers of personal data to non EEA countries Processor Binding Corporate Rules (BCRs), for intra-group transfers of personal data to non EEA countries Sopra HR Software as a Data Processor Sopra HR Software, 2014 / Ref. : 20141120-101114-m 1/32 1.

More information

Align Technology. Data Protection Binding Corporate Rules Processor Policy. 2014 Align Technology, Inc. All rights reserved.

Align Technology. Data Protection Binding Corporate Rules Processor Policy. 2014 Align Technology, Inc. All rights reserved. Align Technology Data Protection Binding Corporate Rules Processor Policy Confidential Contents INTRODUCTION TO THIS POLICY 3 PART I: BACKGROUND AND ACTIONS 4 PART II: PROCESSOR OBLIGATIONS 6 PART III:

More information

on Electronic Signature and change to some other laws (Electronic Signature Act) The Parliament has hereby agreed on this Act of the Czech Republic:

on Electronic Signature and change to some other laws (Electronic Signature Act) The Parliament has hereby agreed on this Act of the Czech Republic: 227/2000 Coll. ACT of 29 th June 2000 on Electronic Signature and change to some other laws (Electronic Signature Act) Amendment: 226/2002 Coll. Amendment: 517/2002 Coll. Amendment :440/2004 Coll. Amendment:

More information

Act on the Protection of Privacy in Working Life (759/2004)

Act on the Protection of Privacy in Working Life (759/2004) NB: Unofficial translation Ministry of Labour, Finland Chapter 1 - General provisions Section 1 Purpose of the act Act on the Protection of Privacy in Working Life (759/2004) The purpose of this Act is

More information

SCOPE OF APPLICATION AND DEFINITIONS

SCOPE OF APPLICATION AND DEFINITIONS Unofficial translation No. 398/1995 Act on Foreign Insurance Companies Issued in Helsinki on 17 March 1995 PART I SCOPE OF APPLICATION AND DEFINITIONS Chapter 1. General Provisions Section 1. Scope of

More information

Align Technology. Data Protection Binding Corporate Rules Controller Policy. 2014 Align Technology, Inc. All rights reserved.

Align Technology. Data Protection Binding Corporate Rules Controller Policy. 2014 Align Technology, Inc. All rights reserved. Align Technology Data Protection Binding Corporate Rules Controller Policy Contents INTRODUCTION 3 PART I: BACKGROUND AND ACTIONS 4 PART II: CONTROLLER OBLIGATIONS 6 PART III: APPENDICES 13 2 P a g e INTRODUCTION

More information

Checklist for Customer Protection Management

Checklist for Customer Protection Management Checklist for Customer Protection Management I. Development and Establishment of Customer Management System by the Management Checkpoints - Customer Protection as referred to in this checklist covers (1)

More information

Do you have a private life at your workplace?

Do you have a private life at your workplace? Do you have a private life at your workplace? Privacy in the workplace in EC institutions and bodies Giovanni Buttarelli In the course of his supervisory activities, the EDPS has published positions on

More information

Policy Statement. Employee privacy, data protection and human resources. Prepared by the Commission on E-Business, IT and Telecoms. I.

Policy Statement. Employee privacy, data protection and human resources. Prepared by the Commission on E-Business, IT and Telecoms. I. International Chamber of Commerce The world business organization Policy Statement Employee privacy, data protection and human resources Prepared by the Commission on E-Business, IT and Telecoms I. Introduction

More information

Consolidated Insurance Mediation Act 1

Consolidated Insurance Mediation Act 1 Consolidated Insurance Mediation Act 1 Act no. 930 of 18 September 2008 This is an Act to consolidate the Insurance Meditation Act, cf. Consolidated Act no. 401 of 25 April 2007, as amended by section

More information

Internal Code of Conduct on Matters Relating to the Stock Market and Policy on the Use of Relevant Information

Internal Code of Conduct on Matters Relating to the Stock Market and Policy on the Use of Relevant Information Internal Code of Conduct on Matters Relating to the Stock Market and Policy on the Use of Relevant Information 1. Objective This "Internal Code of Conduct on Matters Relating to the Stock Market and Policy

More information

CROATIAN PARLIAMENT 1364

CROATIAN PARLIAMENT 1364 CROATIAN PARLIAMENT 1364 Pursuant to Article 88 of the Constitution of the Republic of Croatia, I hereby pass the DECISION PROMULGATING THE ACT ON PERSONAL DATA PROTECTION I hereby promulgate the Act on

More information

*** CHAPTER VI Length and Organization of Working Time. Section I Normal Working Time. ARTICLE 96 (Length of working time)

*** CHAPTER VI Length and Organization of Working Time. Section I Normal Working Time. ARTICLE 96 (Length of working time) NATLEX Database ISN 56677 Unofficial translation prepared by the International Labour Office. This translation is intended for information purposes only and does not substitute consultation of the authoritative

More information

Communication for undertakings that distribute nonmainstream financial products (such as CFD s, binary options, etc.) online

Communication for undertakings that distribute nonmainstream financial products (such as CFD s, binary options, etc.) online Communication FSMA_2014_05 of 25/07/2014 Communication for undertakings that distribute nonmainstream financial products (such as CFD s, binary options, etc.) online Scope: This Communication is addressed

More information

Code of Practice. for Inspecting and Certifying Buildings and Works. Building Control Regulations 2014

Code of Practice. for Inspecting and Certifying Buildings and Works. Building Control Regulations 2014 for Inspecting and Certifying Buildings and Works Building Control Regulations 2014 February, 2014 Table of Contents 1. Introduction 1 1.1 Status and Purpose of Code 1 1.2 Overview of Code 1 1.3 Application

More information

PRINCIPLES OF CORPORATE GOVERNANCE FOR SUPERVISED INSTITUTIONS

PRINCIPLES OF CORPORATE GOVERNANCE FOR SUPERVISED INSTITUTIONS PRINCIPLES OF CORPORATE GOVERNANCE FOR SUPERVISED INSTITUTIONS Content of principles I. ORGANISATION AND ORGANISATIONAL STRUCTURE 1. 1 The organisation of a supervised institution should enable meeting

More information

Information Resources Security Guidelines

Information Resources Security Guidelines Information Resources Security Guidelines 1. General These guidelines, under the authority of South Texas College Policy #4712- Information Resources Security, set forth the framework for a comprehensive

More information

1/ The project presented by the IPSAS cannot be examined without recalling the context as to the operation and principles of French social security:

1/ The project presented by the IPSAS cannot be examined without recalling the context as to the operation and principles of French social security: Response of the French social security board concerning the consultation of the IPSAS Board on the information pertaining to the long-term sustainability of public finances 1/ The project presented by

More information

Qualified Electronic Signatures Act (SFS 2000:832)

Qualified Electronic Signatures Act (SFS 2000:832) Qualified Electronic Signatures Act (SFS 2000:832) The following is hereby enacted 1 Introductory provision 1 The purpose of this Act is to facilitate the use of electronic signatures, through provisions

More information

www.lawsociety.org.uk/lexcel Lexcel International v5 Excellence in legal practice management and client care

www.lawsociety.org.uk/lexcel Lexcel International v5 Excellence in legal practice management and client care www.lawsociety.org.uk/lexcel Lexcel International v5 Excellence in legal practice management and client care Lexcel International v5 Contents About Lexcel... 3 1 Structures and policies... 4 2 Strategic

More information

Lexcel England and Wales v6 Standard for in-house legal departments Excellence in legal practice management and client care

Lexcel England and Wales v6 Standard for in-house legal departments Excellence in legal practice management and client care www.lawsociety.org.uk/lexcel Lexcel England and Wales v6 Standard for in-house legal departments Excellence in legal practice management and client care Lexcel England and Wales v6 Contents About Lexcel...

More information

Bates Technical College. Information Technology Acceptable Use Policy

Bates Technical College. Information Technology Acceptable Use Policy Bates Technical College Information Technology Acceptable Use Policy Consistent with policy adopted by the Board of Trustees, Bates Technical College, hereinafter referred to as the College, has a commitment

More information

www.lawsociety.org.uk/lexcel Lexcel England and Wales v6 Standard for legal practices Excellence in legal practice management and client care

www.lawsociety.org.uk/lexcel Lexcel England and Wales v6 Standard for legal practices Excellence in legal practice management and client care www.lawsociety.org.uk/lexcel Lexcel England and Wales v6 Standard for legal practices Excellence in legal practice management and client care Lexcel England and Wales v6 Contents About Lexcel... 3 Glossary

More information

Merchants and Trade - Act No 28/2001 on electronic signatures

Merchants and Trade - Act No 28/2001 on electronic signatures This is an official translation. The original Icelandic text published in the Law Gazette is the authoritative text. Merchants and Trade - Act No 28/2001 on electronic signatures Chapter I Objectives and

More information

COUNCIL OF EUROPE COMMITTEE OF MINISTERS. RECOMMENDATION No. R (95) 4 OF THE COMMITTEE OF MINISTERS TO MEMBER STATES

COUNCIL OF EUROPE COMMITTEE OF MINISTERS. RECOMMENDATION No. R (95) 4 OF THE COMMITTEE OF MINISTERS TO MEMBER STATES COUNCIL OF EUROPE COMMITTEE OF MINISTERS RECOMMENDATION No. R (95) 4 OF THE COMMITTEE OF MINISTERS TO MEMBER STATES ON THE PROTECTION OF PERSONAL DATA IN THE AREA OF TELECOMMUNICATION SERVICES, WITH PARTICULAR

More information

ELECTRONIC COMMERCE AND ELECTRONIC SIGNATURE ACT (ZEPEP-UPB1) (Official consolidated text)

ELECTRONIC COMMERCE AND ELECTRONIC SIGNATURE ACT (ZEPEP-UPB1) (Official consolidated text) ELECTRONIC COMMERCE AND ELECTRONIC SIGNATURE ACT (ZEPEP-UPB1) (Official consolidated text) On basis of article 153 of the National Assembly of Slovenia Rules of Procedure the National Assembly of the Republic

More information

CCBE POSITION WITH RESPECT TO THE FREE CHOICE OF A LAWYER IN RELATION TO LEGAL EXPENSES INSURANCE

CCBE POSITION WITH RESPECT TO THE FREE CHOICE OF A LAWYER IN RELATION TO LEGAL EXPENSES INSURANCE CCBE POSITION WITH RESPECT TO THE FREE CHOICE OF A LAWYER IN RELATION TO LEGAL EXPENSES INSURANCE CCBE position with respect to the free choice of a lawyer in relation to legal expenses insurance The Council

More information

Corporate Guidelines for Subsidiaries (in Third Countries ) *) for the Protection of Personal Data

Corporate Guidelines for Subsidiaries (in Third Countries ) *) for the Protection of Personal Data Corporate Guidelines for Subsidiaries (in Third Countries ) *) for the Protection of Personal Data *) For the purposes of these Corporate Guidelines, Third Countries are all those countries, which do not

More information

YOUR PRIVACY IS IMPORTANT TO SANDERSONS ARCHIVING SOLUTIONS LIMITED

YOUR PRIVACY IS IMPORTANT TO SANDERSONS ARCHIVING SOLUTIONS LIMITED YOUR PRIVACY IS IMPORTANT TO SANDERSONS ARCHIVING SOLUTIONS LIMITED SANDERSONS ARCHIVING SOLUTIONS LIMITED WEB SITE PRIVACY POLICY Policy last updated: 22 nd December 2014 This Policy is adopted by Sandersons

More information

Compliance Management Systems

Compliance Management Systems Certification Scheme Y03 Compliance Management Systems ISO 19600 ONR 192050 Issue V2.1:2015-01-08 Austrian Standards plus GmbH Dr. Peter Jonas Heinestraße 38 A-1020 Vienna, Austria E-Mail: p.jonas@austrian-standards.at

More information

The Manitowoc Company, Inc.

The Manitowoc Company, Inc. The Manitowoc Company, Inc. DATA PROTECTION POLICY 11FitzPatrick & Associates 4/5/04 1 Proprietary Material Version 4.0 CONTENTS PART 1 - Policy Statement PART 2 - Processing Personal Data PART 3 - Organisational

More information

-«Trustee Authority»: Entity that defines and regulates the conditions of assignment and use of Domain Names, applying to each particular Extension.

-«Trustee Authority»: Entity that defines and regulates the conditions of assignment and use of Domain Names, applying to each particular Extension. NETIM - GENERAL TERMS AND CONDITIONS OF DOMAIN NAMES CG-ND version 2.1-15 th November 2015 NETIM, limited liability company under french law, with head office located 165 avenue de bretagne 59000 LILLE

More information

ACC AUDIT GUIDELINES - INJURY MANAGEMENT PRACTICES

ACC AUDIT GUIDELINES - INJURY MANAGEMENT PRACTICES ACC AUDIT GUIDELINES - INJURY MANAGEMENT PRACTICES Guidelines to understanding the audit standards for the Injury Management Section of the ACC Partnership Programme Please note: There is a separate guideline

More information

Legislative Language

Legislative Language Legislative Language SECTION 1. DEPARTMENT OF HOMELAND SECURITY CYBERSECURITY AUTHORITY. Title II of the Homeland Security Act of 2002 (6 U.S.C. 121 et seq.) is amended (a) in section 201(c) by striking

More information

Pierce County Policy on Computer Use and Information Systems

Pierce County Policy on Computer Use and Information Systems Pierce County Policy on Computer Use and Information Systems Pierce County provides a variety of information technology resources such as computers, software, printers, scanners, copiers, electronic mail

More information

CULTURE PROGRAMME (2007-2013) Guidance Notes for Experts. Strand 1.3.5

CULTURE PROGRAMME (2007-2013) Guidance Notes for Experts. Strand 1.3.5 Education, Audiovisual and Culture Executive Agency Culture CULTURE PROGRAMME (2007-2013) Guidance Notes for Experts Strand 1.3.5 Version January 2012 Education, Audiovisual & Culture Executive Agency

More information

INFORMATION TECHNOLOGY MANAGEMENT CONTENTS. CHAPTER C RISKS 357-7 8. Risk Assessment 357-7

INFORMATION TECHNOLOGY MANAGEMENT CONTENTS. CHAPTER C RISKS 357-7 8. Risk Assessment 357-7 Information Technology Management Page 357-1 INFORMATION TECHNOLOGY MANAGEMENT CONTENTS CHAPTER A GENERAL 357-3 1. Introduction 357-3 2. Applicability 357-3 CHAPTER B SUPERVISION AND MANAGEMENT 357-4 3.

More information

Act on Insurance Mediation and Reinsurance Mediation

Act on Insurance Mediation and Reinsurance Mediation Act on Insurance Mediation and Reinsurance Mediation The full wording of Act No. 340/2005 Coll. dated 23 June 2005 on insurance mediation and resinsurance mediation and on amendments to certain laws, as

More information

INTERNAL REGULATIONS OF THE BOARD OF DIRECTORS. Updated by decisions of the Board of Directors dated 16 January 2015

INTERNAL REGULATIONS OF THE BOARD OF DIRECTORS. Updated by decisions of the Board of Directors dated 16 January 2015 CERENIS THERAPEUTICS HOLDING Limited liability company with share capital of 679,078.10 Headquarters: 265, rue de la Découverte, 31670 Labège 481 637 718 RCS TOULOUSE INTERNAL REGULATIONS OF THE BOARD

More information

STATUTORY INSTRUMENTS. S.I. No. 336 of 2011

STATUTORY INSTRUMENTS. S.I. No. 336 of 2011 STATUTORY INSTRUMENTS. S.I. No. 336 of 2011 EUROPEAN COMMUNITIES (ELECTRONIC COMMUNICATIONS NETWORKS AND SERVICES) (PRIVACY AND ELECTRONIC COMMUNICATIONS) REGULATIONS 2011 (Prn. A11/1165) 2 [336] S.I.

More information

Data Protection. Processing and Transfer of Personal Data in Kvaerner. Binding Corporate Rules Public Document

Data Protection. Processing and Transfer of Personal Data in Kvaerner. Binding Corporate Rules Public Document Data Protection Processing and Transfer of Personal Data in Kvaerner Binding Corporate Rules Public Document 1 of 19 1 / 19 Table of contents 1 Introduction... 4 1.1 Scope... 4 1.2 Definitions... 4 1.2.1

More information

City of Venice Information Technology Usage Policy

City of Venice Information Technology Usage Policy City of Venice Information Technology Usage Policy The City of Venice considers information technology (IT) resources to be city resources. It shall be the policy of the city to maintain these resources

More information

Ministry of Public Administration, Employment and Social Security

Ministry of Public Administration, Employment and Social Security Ministry of Public Administration, Employment and Social Security GENERAL LABOUR LAW 2000 CHAPTER VI Length and Organization of Working Time Section I Normal Working Time Article 96º (Length of working

More information

on the transfer of personal data from the European Union

on the transfer of personal data from the European Union on the transfer of personal data from the European Union BCRsseptembre 2008.doc 1 TABLE OF CONTENTS I. PRELIMINARY REMARKS 3 II. DEFINITIONS 3 III. DELEGATED DATA PROTECTION MANAGER 4 IV. MICHELIN GROUP

More information

Valid as of January 29, 2013

Valid as of January 29, 2013 1 (10) Contractual terms of RAY Valid as of January 29, 2013 These contractual terms replace the contractual terms of RAY that entered into force on August 28, 2012. These terms shall also be applied to

More information

Consultation Paper. ESMA Guidelines on Alternative Performance Measures. 13 February 2014 ESMA/2014/175

Consultation Paper. ESMA Guidelines on Alternative Performance Measures. 13 February 2014 ESMA/2014/175 Consultation Paper ESMA Guidelines on Alternative Performance Measures 13 February 2014 ESMA/2014/175 Date: 13 February 2014 ESMA/2014/175 Responding to this paper The European Securities and Markets Authority

More information

Version 0.3 25 September 2014

Version 0.3 25 September 2014 Guide for Grant Agreement Preparation Version 0.3 25 September 2014 Disclaimer: This document is aimed at assisting applicants and beneficiaries for Horizon 2020 funding. Its purpose is to explain the

More information

Terms of Service. These Terms of Service form a legally binding contract between the Users and the Society.

Terms of Service. These Terms of Service form a legally binding contract between the Users and the Society. Terms of Service Article 1: Introduction These Terms of Service (the Terms) govern the relationship between the society Many Players (the Society) whose registered office is at 88 Ter, avenue du Général

More information

Information Security and Electronic Communications Acceptable Use Policy (AUP)

Information Security and Electronic Communications Acceptable Use Policy (AUP) Policy No.: AUP v2.0 Effective Date: August 16, 2004 Revision Date: January 17, 2013 Revision No.: 1 Approval jwv / mkb Information Security and Electronic Communications (AUP) 1. INTRODUCTION Southwestern

More information

DRAFT GUIDANCE DOCUMENT ON THE LOW VOLTAGE DIRECTIVE TRANSITION

DRAFT GUIDANCE DOCUMENT ON THE LOW VOLTAGE DIRECTIVE TRANSITION EUROPEAN COMMISSION Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs Industrial Transformation and Advanced Value Chains Advanced Engineering and Manufacturing Systems DRAFT

More information

AIRBUS GROUP BINDING CORPORATE RULES

AIRBUS GROUP BINDING CORPORATE RULES 1 AIRBUS GROUP BINDING CORPORATE RULES 2 Introduction The Binding Corporate Rules (hereinafter BCRs ) of the Airbus Group finalize the Airbus Group s provisions on the protection of Personal Data. These

More information

MANAGING SICKNESS ABSENCE POLICY

MANAGING SICKNESS ABSENCE POLICY MANAGING SICKNESS ABSENCE POLICY Policy Devised: March 2013 Adopted on: 5 th December 2013 Review date: December 2014 1. BACKGROUND 1.1 From time to time employees may suffer ill health and it is essential

More information

Advisory Guidelines of the Financial Supervisory Authority. Requirements regarding the arrangement of operational risk management

Advisory Guidelines of the Financial Supervisory Authority. Requirements regarding the arrangement of operational risk management Advisory Guidelines of the Financial Supervisory Authority Requirements regarding the arrangement of operational risk management These Advisory Guidelines have established by resolution no. 63 of the Management

More information

SOUTHERN SLOPES COUNTY COUNCIL COMPUTER & INFORMATION TECHNOLOGY USE POLICY

SOUTHERN SLOPES COUNTY COUNCIL COMPUTER & INFORMATION TECHNOLOGY USE POLICY SOUTHERN SLOPES COUNTY COUNCIL COMPUTER & INFORMATION TECHNOLOGY USE POLICY OBJECTIVE To provide users with guidelines for the use of information technology resources provided by Council. SCOPE This policy

More information

The Role and Function of a Data Protection Officer in the European Commission s Proposed General Data Protection Regulation. Initial Discussion Paper

The Role and Function of a Data Protection Officer in the European Commission s Proposed General Data Protection Regulation. Initial Discussion Paper The Role and Function of a Data Protection Officer in the European Commission s Proposed General Data Protection Regulation 1. Introduction Initial Discussion Paper The data protection officer ( DPO )

More information

Code of Conduct. Code of Conduct, 2009 Version 1.0

Code of Conduct. Code of Conduct, 2009 Version 1.0 Code of Conduct Code of Conduct, 2009 Version 1.0 Contents A. Introduction... 3 B. Application of the Code... 3 C. Basic Rules of Conduct... 4 Avoidance of Conflicts of Interest... 5 Mutual Respect...

More information

INSPECTION MANUAL FOR CREDIT RATING AGENCIES

INSPECTION MANUAL FOR CREDIT RATING AGENCIES Tentative translation Only Japanese text is authentic INSPECTION MANUAL FOR FINANCIAL INSTRUMENTS BUSINESS OPERATORS (SUPPLEMENT) INSPECTION MANUAL FOR CREDIT RATING AGENCIES Executive Bureau, Securities

More information

injury management practices

injury management practices audit guidelines injury management practices guidelines to understanding the audit standards for the injury management section of the acc partnership programme ACC2465 Printed September 2006 These guidelines

More information

Fairness at Work (Grievance Policy & Procedure)

Fairness at Work (Grievance Policy & Procedure) Fairness at Work (Grievance Policy & Procedure) Publication Scheme Y/N Department of Origin Policy Holder Author Related Documents Can be Published on Force Website HR Operations Head of HR Operations

More information

Ministry of the Economy, Finance and Industry OFFICIAL TAX BULLETIN. General Tax Directorate 4 A-8-99. No. 171 of 17 September 1999 4 A/1211

Ministry of the Economy, Finance and Industry OFFICIAL TAX BULLETIN. General Tax Directorate 4 A-8-99. No. 171 of 17 September 1999 4 A/1211 Ministry of the Economy, Finance and Industry OFFICIAL TAX BULLETIN General Tax Directorate 4 A-8-99 No. 171 of 17 September 1999 4 A/1211 Instruction of 7 September 1999 Instruction on the Advance Pricing

More information

7.08.2 Privacy Rules for Customer, Supplier and Business Partner Data. Directive 7.08 Protection of Personal Data

7.08.2 Privacy Rules for Customer, Supplier and Business Partner Data. Directive 7.08 Protection of Personal Data Akzo Nobel N.V. Executive Committee Rules 7.08.2 Privacy Rules for Customer, Supplier and Business Partner Data Source Directive Content Owner Directive 7.08 Protection of Personal Data AkzoNobel Legal

More information

Official Journal of RS, No. 86/2006 of 11. 08. 2006 REGULATION

Official Journal of RS, No. 86/2006 of 11. 08. 2006 REGULATION Official Journal of RS, No. 86/2006 of 11. 08. 2006 Pursuant to Articles 10, 23, 36, 40, 43, 47, 53, 54, 63, 71, 72, 73, 74, 88 and 91 of the Protection of Documents and Archives and Archival Institutions

More information

INERTIA ETHICS MANUAL

INERTIA ETHICS MANUAL SEVENTH FRAMEWORK PROGRAMME Smart Energy Grids Project Title: Integrating Active, Flexible and Responsive Tertiary INERTIA Grant Agreement No: 318216 Collaborative Project INERTIA ETHICS MANUAL Responsible

More information

Nuclear Safety Council Instruction number IS-19, of October 22 nd 2008, on the requirements of the nuclear facilities management system

Nuclear Safety Council Instruction number IS-19, of October 22 nd 2008, on the requirements of the nuclear facilities management system Nuclear Safety Council Instruction number IS-19, of October 22 nd 2008, on the requirements of the nuclear facilities management system Published in the Official State Gazette (BOE) number 270 of November

More information

ARTICLE 29 Data Protection Working Party

ARTICLE 29 Data Protection Working Party ARTICLE 29 Data Protection Working Party 11601/EN WP 90 Opinion 5/2004 on unsolicited communications for marketing purposes under Article 13 of Directive 2002/58/EC Adopted on 27 February 2004 This Working

More information

HIPAA COMPLIANCE PLAN. For. CHARLES RETINA INSTITUTE (Practice Name)

HIPAA COMPLIANCE PLAN. For. CHARLES RETINA INSTITUTE (Practice Name) HIPAA COMPLIANCE PLAN For CHARLES RETINA INSTITUTE (Practice Name) Date of Adoption 1/02/2003 Review/Update 10/25/2012 Review/Update 4/01/2014 I. COMPLIANCE PLAN A. Introduction This HIPAA Compliance Plan

More information

DECISION PROMULGATING THE PAYMENT SYSTEM ACT

DECISION PROMULGATING THE PAYMENT SYSTEM ACT THE CROATIAN PARLIAMENT 3247 Pursuant to Article 88 of the Constitution of the Republic of Croatia, I hereby issue the DECISION PROMULGATING THE PAYMENT SYSTEM ACT I hereby promulgate the Payment System

More information

QAHC Feedback and Conflict Management Policy and Procedures

QAHC Feedback and Conflict Management Policy and Procedures QAHC Feedback and Conflict Management Policy and Procedures Prepared By Erica Waters Consulting June 2000 Revised & Endorsed October 2000 Revised by QAHC September 2007 Policy Statement The Queensland

More information

Whitepapers on Imaging Infrastructure for Research Paper 1. General Workflow Considerations

Whitepapers on Imaging Infrastructure for Research Paper 1. General Workflow Considerations Whitepapers on Imaging Infrastructure for Research Paper 1. General Workflow Considerations Bradley J Erickson, Tony Pan, Daniel J Marcus, CTSA Imaging Informatics Working Group Introduction The use of

More information

Code of Conduct. Corporate Data Protection. We make ICT strategies work

Code of Conduct. Corporate Data Protection. We make ICT strategies work Corporate Data Protection Code of Conduct for the Protection of the Individual s Right to Privacy in the Handling of Personal Data within the Deutsche Telekom Group 2010 / 04 We make ICT strategies work

More information

GRTGAZ NETWORK TRANSMISSION CONTRACT

GRTGAZ NETWORK TRANSMISSION CONTRACT Page 1 of 9 GRTGAZ NETWORK TRANSMISSION CONTRACT APPENDIX A3 STANDARD EVIDENCE AGREEMENT English translation for information. Disclaimer The present translation is not binding and is provided by GRTgaz

More information

The primary responsibility for the data processing lies within the Administration Department, which the FINCOP Unit is part of.

The primary responsibility for the data processing lies within the Administration Department, which the FINCOP Unit is part of. Opinion on a Notification for Prior Checking received from the Data Protection Officer of the European Training Foundation Regarding the Processing Operations to Manage Calls for Tenders Brussels, 22 April

More information

COMPUTER NETWORK FOR EDUCATION REGULATION

COMPUTER NETWORK FOR EDUCATION REGULATION COMPUTER NETWORK FOR EDUCATION REGULATION 4526-R The following rules and regulations govern the use of the district's computer network system and access to the Internet. I. Administration The Superintendent

More information

Information Technology Security Policies

Information Technology Security Policies Information Technology Security Policies Randolph College 2500 Rivermont Ave. Lynchburg, VA 24503 434-947- 8700 Revised 01/10 Page 1 Introduction Computer information systems and networks are an integral

More information

FIRST DATA CORPORATION SUMMARY: BINDING CORPORATE RULES FOR DATA PRIVACY AND PROTECTION

FIRST DATA CORPORATION SUMMARY: BINDING CORPORATE RULES FOR DATA PRIVACY AND PROTECTION FIRST DATA CORPORATION SUMMARY: BINDING CORPORATE RULES FOR DATA PRIVACY AND PROTECTION SUMMARY: BINDING CORPORATE RULES FOR DATA PRIVACY AND PROTECTION v 1.3 Supersedes: v 1.2 Summary Owner: Corporate

More information

CHARTER OF ETHICS AND BEHAVIOUR

CHARTER OF ETHICS AND BEHAVIOUR CHARTER OF ETHICS AND BEHAVIOUR Behaviour Principles and Rules P.02 Deployment P.07 The Charter of Ethics was adopted at the meeting of the Groupe Eurotunnel Board Meeting of 28/01/2013 Groupe Eurotunnel

More information

CODE OF CONDUCT Ethical rules and guidelines

CODE OF CONDUCT Ethical rules and guidelines CODE OF CONDUCT Ethical rules and guidelines CONTENT Introduction... 3 Our customers... 5 Employees... 7 The world around us... 9 Communication & dialog... 11 Security, theft & loss... 13 Environment...

More information

INTERNATIONAL STANDARDS FOR THE PROFESSIONAL PRACTICE OF INTERNAL AUDITING (STANDARDS)

INTERNATIONAL STANDARDS FOR THE PROFESSIONAL PRACTICE OF INTERNAL AUDITING (STANDARDS) INTERNATIONAL STANDARDS FOR THE PROFESSIONAL PRACTICE OF INTERNAL AUDITING (STANDARDS) Revised: October 2012 i Table of contents Attribute Standards... 3 1000 Purpose, Authority, and Responsibility...

More information

Guidelines for processing requests for access to documents/information or amendment of records under the FOI Act

Guidelines for processing requests for access to documents/information or amendment of records under the FOI Act RTA Guidelines: PN 069G for (Policy Number PN 069) Guidelines for processing requests for access to documents/information or amendment of records under the FOI Act 1. Purpose These guidelines are issued

More information

EMMANUEL CE VA MIDDLE SCHOOL. IT Security Standards

EMMANUEL CE VA MIDDLE SCHOOL. IT Security Standards EMMANUEL CE VA MIDDLE SCHOOL IT Security Standards 1. Policy Statement The work of Schools and the County Council is increasingly reliant upon Information & Communication Technology (ICT) and the data

More information

Derbyshire Constabulary REORGANISATION, REDUNDANCY AND REDEPLOYMENT POLICY POLICY REFERENCE 05/001. This policy is suitable for Public Disclosure

Derbyshire Constabulary REORGANISATION, REDUNDANCY AND REDEPLOYMENT POLICY POLICY REFERENCE 05/001. This policy is suitable for Public Disclosure Derbyshire Constabulary REORGANISATION, REDUNDANCY AND REDEPLOYMENT POLICY POLICY REFERENCE 05/001 This policy is suitable for Public Disclosure Owner of Doc: Head of Department, Human Resources Date Approved:

More information

INTERNATIONAL STANDARD ON AUDITING 260 COMMUNICATION WITH THOSE CHARGED WITH GOVERNANCE CONTENTS

INTERNATIONAL STANDARD ON AUDITING 260 COMMUNICATION WITH THOSE CHARGED WITH GOVERNANCE CONTENTS INTERNATIONAL STANDARD ON AUDITING 260 COMMUNICATION WITH THOSE CHARGED WITH GOVERNANCE (Effective for audits of financial statements for periods beginning on or after December 15, 2009) CONTENTS Paragraph

More information

EMPLOYMENT CONTRACTS ACT

EMPLOYMENT CONTRACTS ACT Proclaimed by Resolution No. 421 of the President of the Republic of 12 January 2009 EMPLOYMENT CONTRACTS ACT Passed on 17 December 2008 (RT I 2009, 5, 35), entered into force 1 July 2009. Amended by the

More information

Pursuant to Article 95, item 3 of the Constitution of Montenegro I hereby pass the ENACTMENT PROCLAIMING THE LAW ON BANKS

Pursuant to Article 95, item 3 of the Constitution of Montenegro I hereby pass the ENACTMENT PROCLAIMING THE LAW ON BANKS Pursuant to Article 95, item 3 of the Constitution of Montenegro I hereby pass the ENACTMENT PROCLAIMING THE LAW ON BANKS I hereby proclaim the Law on Banks, adopted by the Parliament of Montenegro at

More information

Act on Investment Firms 26.7.1996/579

Act on Investment Firms 26.7.1996/579 Please note: This is an unofficial translation. Amendments up to 135/2007 included, May 2007. Act on Investment Firms 26.7.1996/579 CHAPTER 1 General provisions Section 1 Scope of application This Act

More information

Staff Investigation Protocol

Staff Investigation Protocol Version: 3.0 Document author(s): Stuart Selkirk Approved by: Executive Partnership Forum Date approved: 17 July 2014 Review date: 30 September 2016 Document scope: Trust-wide Version History Log Use this

More information

INFORMATION REQUIRED FOR EMPLOYEE HANDBOOK

INFORMATION REQUIRED FOR EMPLOYEE HANDBOOK INFORMATION REQUIRED FOR EMPLOYEE HANDBOOK Registered Company Name Company Trading Name Address Email Address Contact number We have enclosed a standard employee handbook. You should read through the details

More information

Mapping of outsourcing requirements

Mapping of outsourcing requirements Mapping of outsourcing requirements Following comments received during the first round of consultation, CEBS and the Committee of European Securities Regulators (CESR) have worked closely together to ensure

More information

Council of the European Union Brussels, 12 September 2014 (OR. en)

Council of the European Union Brussels, 12 September 2014 (OR. en) Council of the European Union Brussels, 12 September 2014 (OR. en) Interinstitutional File: 2013/0409 (COD) 13132/14 NOTE From: To: Presidency DROIPEN 104 COPEN 218 CODEC 1799 Working Party on Substantive

More information

Network Security Policy

Network Security Policy Network Security Policy I. PURPOSE Attacks and security incidents constitute a risk to the University's academic mission. The loss or corruption of data or unauthorized disclosure of information on campus

More information

Sample Policies for Internet Use, Email and Computer Screensavers

Sample Policies for Internet Use, Email and Computer Screensavers Sample Policies for Internet Use, Email and Computer Screensavers In many of its financial management reviews, the Technical Assistance Section has encouraged municipalities to develop and adopt policies

More information

These terms and conditions were last updated on 30 September 2015.

These terms and conditions were last updated on 30 September 2015. Game Rules The website www.mafiacontrol.com (hereinafter referred to as Website ) allows you to manage a text-based online multi-player mafia game (the Game ), and to also play Games managed by others.

More information

FIRST DATA CORPORATION PROCESSOR DATA PROTECTION STANDARDS

FIRST DATA CORPORATION PROCESSOR DATA PROTECTION STANDARDS FIRST DATA CORPORATION PROCESSOR DATA PROTECTION STANDARDS As a world leader in electronic commerce and payment services, First Data Corporation and its subsidiaries ( First Data entity or entities ),

More information

TERMS OF ELECTRICITY SALES 2010. as recommended by Finnish Energy Industries

TERMS OF ELECTRICITY SALES 2010. as recommended by Finnish Energy Industries TERMS OF ELECTRICITY SALES 2010 as recommended by Finnish Energy Industries Content: A. General, concluding an electricity sale contract, the prerequisites for electricity sales, commencement of electricity

More information

INTERNATIONAL STANDARDS FOR THE PROFESSIONAL PRACTICE OF INTERNAL AUDITING (STANDARDS)

INTERNATIONAL STANDARDS FOR THE PROFESSIONAL PRACTICE OF INTERNAL AUDITING (STANDARDS) INTERNATIONAL STANDARDS FOR THE PROFESSIONAL PRACTICE OF INTERNAL AUDITING (STANDARDS) Introduction to the International Standards Internal auditing is conducted in diverse legal and cultural environments;

More information