Privacy Information Notice for the Ethics Hotline
As part of its Speak Up program the Ethics Hotline of STMicroelectronics (ST) may collect and process personal information, as provided in whistleblowers’ reports.
This Privacy Information Notice provides information relating to the processing of personal information by the Ethics Hotline.
1/ Personal data we collect:
In principle, the Ethics Hotline can be used, to the extent permitted by law, without providing personal information. You (the whistleblower) may, however, voluntarily disclose personal information as part of the speak up process.
Processed Personal information will generally be limited to: (i) the identity, location and contact details of the reporting person (if the report mentions such information), and (ii) the name(s) of people mentioned in the report.
2/ Legal grounds of the processing by the Ethics Hotline:
A legal obligation – to provide a safe reporting channel to employees and interested third parties. This legal obligation exists within the EU/EEA, based on their national legislation implementing the EU Directive about the protection of whistleblowers, and in many other countries across the world.
A legitimate interest - to allow everyone to express, in good faith, any concerns they might have that ST executives, managers, employees, or ST’s third parties in their business dealings with ST, might not be adhering to business ethics standards expressed in ST’s Code of Conduct and policies.
3/How we process personal data:
ST is using a third-party service provider, People InTouch B.V., located in the Netherlands to deliver the Ethics Hotline.
4/ Data retention within the Ethics Hotline:
- Sound file: Automatic deletion 24 hours after confirmation of receipt, plus 5 days on back-up.
- Connection data/Logging information: 2 days, plus 12 days back-up.
- Case Content: 14 days after case closure plus 14 days back-up.
5/ Contact Information:
If you have any questions about how your personal data is being processed by the Ethics Hotline, please contact us by email at: firstname.lastname@example.org.
6/ Changes to this Privacy Information Notice:
We may need to change this Privacy Information Notice from time to time to ensure it meets the possible changes in the process or the updated laws. Any change will be duly communicated via appropriate channel(s).