Data Privacy Policy for Employees
Introduction
Moog Inc., and its subsidiaries (collectively, “Moog”), is required to collect and maintain information about its employees in order to comply with a myriad of governmental and contractual obligations, including providing for the payment of taxes, employee benefits, wages, etc. However, Moog also recognizes the importance of protecting employee privacy, and therefore adheres to the following US-EU Safe Harbor Privacy Principles (the "Principles"): Notice, Choice, Onward Transfer, Security, Data Integrity, Access and Enforcement. As such, Moog publicly declares its adherence to the Principles with respect to individually identifiable information that Moog receives in the United States from the EU. Moog's Notice of Data Privacy Policy for Employees (“Policy”) describes the information collected by Moog from its employees and how Moog uses that information.
Collection of Information
In connection with employment, Moog may ask employees to provide certain information, including, but not limited to, name, mailing address, telephone numbers, gender, birth date, marital status, name of dependents, birth date of dependents, occupation of dependents and national identification number. Additionally Moog may maintain information relating to employment with the Company including, but not limited to, employee identification number, business unit/division of employment, department, physical work location, job code, compensation rate, supervisor, work shift, hire and termination date, appraisal dates and ratings, training, skills, educational background, language proficiency, certifications and licenses (collectively, “Employee Information”).
Use of Information
The information collected by Moog will be used for various administrative and record keeping purposes by Moog.
Disclosure of Employee Information
Employee Information will be disclosed to a limited number of Moog employees whose job necessitates that they maintain, compile, or otherwise have access to Employee Information. Moog may also disclose Employee Information to a third party when it believes, in good faith, that such disclosure is reasonably necessary to comply with any law or to protect the rights, property or safety of another person. Additionally, Moog may disclose Employee Information to a third party employee benefit provider or payroll service. If Moog does disclose information to third party, Moog will ensure that the third party is subject to the Directive and subscribes to the Principles, or Moog will enter into a written agreement with such third party which requires the third party to provide at least the same level of privacy protection as is required by the relevant Principles. Lastly, Moog may transfer or otherwise disclose Employee Information in connection with the sale of its business to a third party.
Transfer of Employee Information
Employee Information will be transferred, transmitted and accessed electronically by a limited number of Moog employees (as discussed above) at various Moog locations around the world. Moog has taken, and will continue to take, appropriate technical and organizational measures to protect all Employee Data from destruction, loss, alteration, or unauthorized disclosure or access.
Employee Consent
Upon any modification of this Policy, Moog will prominently post a revised Policy within five (5) business days of its adoption and provide employees with an opportunity to withdraw his or her consent to any new use or disclosure of his or her Employee Information. If any employee objects to Moog’s collection, use, disclosure or transmission of certain Employee Information, Moog will make reasonable efforts to address the concerns of the employee. In no case will an employee be subject to sanction or retaliation for objecting to the collection, use, disclosure or transmission of Employee Information.
Employee Rights Regarding Employee Information
Each employee has the right to:
- Obtain a copy of Moog’s Policy upon request.
- Inspect his or her Employee Information and be able to correct, amend, or delete information where it is inaccurate, except where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, or where the rights of persons other than the individual would be violated. All requests to inspect, correct, amend, or delete information must be submitted in writing to the local Human Resources Manager.
- Review Moog’s process and procedures for electronically transmitting Employee Information.
- Withdraw his or her consent to the continued or future use and disclosure of his or her Employee Information, except as to that Employee Information that Moog determines to be necessary for continued employment.
Moog’s Responsibilities Regarding Protecting Employee Information
Moog is required to:
- Provide employees with notice of Moog’s Policy regarding the collection, maintenance, use and disclosure of Employee Information.
- Ensure that Moog’s published Policy is current, accurate, comprehensive, prominently displayed, completely implemented, accessible, and conforms to the Principles.
- Abide by the terms of the Policy. In the event that Moog modifies the terms of the Policy, Moog will prominently post a revised Policy which describes all intended uses and disclosures of Employee Information, within five (5) business days of its adoption, and provide employees with an opportunity to withdraw consent to any new use or disclosure of his or her Employee Information.
- Notify the employee if the Company is unable to agree to the employee’s requested restriction on the use or disclosure of his or her Employee Information.
- Maintain the privacy of Employee Information by taking reasonable precautions to protect the data from loss, misuse, unauthorized access, disclosure, alteration and destruction.
- Comply with all laws regarding the privacy of Employee Information.
Complaints
If an employee believes Moog has breached its Policy by permitting an unauthorized use, disclosure or transmission of his or her Employee Information, the employee may contact or file a complaint with a Supervisor or local Human Resources Manager. Additionally, Moog employees located in the European Union may contact their national E.U. Data Protection authorities. Employees will not be penalized for requesting information or filing a complaint.
For further information on Safe Harbor, please contact Diane Reed at Moog in East Aurora, NY. DReed@moog.com
The information above is contained in Moog's Notice of Data Privacy Policy for Employees issued May 19, 2004. The internal document number for this policy is 001-003-001.
Moog acknowledges that the failure of the Company to provide the required annual self-certification to the Department of Commerce will result in the removal of Moog from the list of participants.
