- Purpose
Technical Precision is committed to protecting the privacy of Personal Data of its Workers, Customers, Business Partners, and other identifiable individuals. Technical Precision has, therefore, implemented a global data protection and privacy program to establish and maintain high standards for collecting, using, disclosing, storing, securing, accessing, transferring, or otherwise processing Personal Data. This Global Personal Data Protection & Privacy Policy is the foundation of that data protection and privacy program and describes the approach taken by Technical Precision when processing Personal Data anywhere in the world.
- Scope
All employees, contractors, consultants, temporary, and other workers at Technical Precision and its subsidiaries must comply with this policy, including all personnel affiliated with third parties who may have access to any applicable Technical Precision resource, including cloud-based services, hosted inside or outside of Technical Precision.
This Global Personal Data Protection & Privacy Policy applies globally to Technical Precision’s processing of Personal Data, whether by electronic or manual means (i.e., in hard copy, paper, or analog form). All Technical Precision entities and Technical Precision Workers shall comply with this Global Personal Data Protection & Privacy Policy.
With respect to HR Personal Data and Business Personal Data specifically, this Global Personal Data Protection & Privacy Policy is supplemented by Technical Precision’s Global HR Data Protection Policy and Technical Precision’s Business Personal Data Protection & Privacy Policy. These internal policy documents describe in more detail how this Global Personal Data Protection & Privacy Policy applies to HR Personal Data and Business Personal Data, respectively, and provide guidance to Technical Precision Workers on the proper handling of Personal Data.
This Policy applies to any Personal Data that is created, collected, processed, used, shared, or destroyed for or by Technical Precision.
- Policy Statement(s)
3.1 Adequate Safeguards for Processing of Personal Data
In conjunction with the Global HR Data Protection Policy and Business Personal Data Protection & Privacy Policy, this Global Personal Data Protection & Privacy Policy is also intended to provide adequate safeguards for the processing of Personal Data entrusted to Technical Precision and transferred from countries requiring such protections. This is to enable Technical Precision to transfer Personal Data wherever it is needed around the globe to enable and support its internal business processes or enable services and product functionality. In order to do this, each of the Global HR Data Protection Policy, EEA HR Data Protection Policy and the Business Personal Data Protection & Privacy Policy describe certain additional obligations and legal rights in circumstances where European Data Protection Law, American, APEC, and other countries or regions’ data protection law or requirements differ and are applicable.
3.2 Compliance with Applicable Law
Technical Precision shall comply with applicable local data protection laws and requirements worldwide.
Where applicable data protection laws require a higher standard of protection for Personal Data than that set out in this Global Personal Data Protection & Privacy Policy, the requirements of applicable data protection law shall prevail. Where applicable data protection laws establish a lower standard of protection for Personal Data than that set out in this Global Personal Data Protection & Privacy Policy, the requirements of this Global Personal Data Protection & Privacy Policy shall prevail.
Where Technical Precision Workers have reason to believe that applicable law prevents Technical Precision from fulfilling its obligations under this Global Personal Data Protection & Privacy Policy, they shall promptly inform the Global Privacy Office – privacy@TechnicalPrecision.com and/or Technical Precision Legal – generalcounsel@TechnicalPrecision.com. Where there is a conflict between applicable law and this Global Personal Data Protection & Privacy Policy, the Chief Privacy Officer and Technical Precision Legal shall make a responsible decision regarding what action to take to resolve such a conflict and shall consult with the relevant regulatory authority in cases of doubt.
3.3 Privacy Principles
The following sets out the high-level principles that underlie Technical Precision’s practices for collecting, using, disclosing, storing, securing, accessing, transferring, or otherwise processing Personal Data.
- Fairness
Technical Precision shall process Personal Data lawfully, fairly, and in a transparent manner.
- Purpose Limitation
Technical Precision shall only collect Personal Data for a specific, explicit, and legitimate purpose(s). Any subsequent processing should be compatible with such purpose(s), unless Technical Precision has obtained the individual’s consent or the processing is otherwise permitted by law.
- Proportionality
Technical Precision shall only process Personal Data that is adequate, relevant, and not excessive for the purpose(s) for which it is processed.
- Data Integrity
Technical Precision shall keep Personal Data accurate, complete, and up-to-date as is reasonably necessary for the purpose(s) for which it is processed.
- Data Retention
Technical Precision shall keep Personal Data in a form that is personally identifiable for no longer than necessary to accomplish the purpose(s), or other permitted purpose(s), for which the Personal Data was obtained.
- Data Security
Technical Precision shall implement appropriate and reasonable technical and organizational measures to safeguard Personal Data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure, use, or access. Technical Precision shall instruct and contractually require third parties processing Personal Data on behalf of Technical Precision, if any, to: (a) process it only for purposes consistent with Technical Precision’s purpose(s) for processing; and (b) implement appropriate technical and organizational measures to safeguard the Personal Data.
- Individual Rights
Technical Precision shall process Personal Data in a manner that respects individuals’ rights under applicable data protection laws.
- Accountability
Technical Precision shall implement appropriate policies, processes, controls, and other measures necessary to enable it to demonstrate that its processing of Personal Data is in accordance with this Global Personal Data Protection & Privacy Policy and applicable data protection laws.
3.4 Updates to this Policy
Technical Precision may from time to time review and revise its data protection practices, policies, and procedures including this Global Personal Data Protection & Privacy Policy. If any significant changes are made, Technical Precision shall:
- Take reasonable steps to inform all Technical Precision entities, Technical Precision Workers, Business Partners, and other data subjects affected by the amendments; and
- Post appropriate notices referring to the changes on the relevant websites – both internal and external, as appropriate.
- Policy Compliance
Technical Precision is committed to ensuring that this Global Personal Data Protection & Privacy Policy is observed by all Technical Precision Workers. Technical Precision Workers must comply with this Global Policy. Policy compliance requirements are as follows:
4.1 Compliance Effective Date
This Policy is effective upon approval.
4.2 Compliance Measurement
Compliance with this Global Personal Data Protection & Privacy Policy is verified by various means, including reports from available business tools, internal and external audits, self-assessment, and/or feedback to the policy owner(s). Technical Precision will monitor its compliance with this Policy on an ongoing basis. Technical Precision will periodically verify that this Global Personal Data Protection & Privacy Policy continues to conform to the applicable data protection laws and is being complied with.
4.3 Compliance Exceptions
Any exceptions to this Global Personal Data Protection & Privacy Policy requires the written approval of the Chief Privacy Officer and Technical Precision Legal.
Any records of exceptions should be archived according to the Technical Precision Records Management Process and not on an individual’s laptop.
4.4 Non-Compliance
Compliance with Technical Precision policies is required. Deviations or non-compliance with this Policy, including attempts to circumvent the stated policy/process by bypassing or knowingly manipulating the process, system, or data may result in disciplinary actions, including termination, as allowed by local laws.
In some countries, violations of regulations designed to protect Personal Data may result in administrative sanctions, penalties, claims for compensation or injunctive relief, and/or other civil or criminal prosecution and remedies.
- Supporting Documents
Technical Precision Global HR Data Protection Policy
Technical Precision Business Personal Data Protection & Privacy Policy
- Definitions
The following terms and definitions are used in this document:
| Technical Precision | Technical Precision and its subsidiaries, worldwide. |
| Personal Data | Any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural living person. |
| HR Personal Data | Personal Data processed by Technical Precision in an employment context. |
| Business Personal Data | Personal Data processed by Technical Precision in a business context that is not HR Data. |
| European Data Protection Law | EU Data Protection Directive 95/46/EC and Privacy, the Electronic Communications Directive 2002/58/EC, and all laws and regulations giving binding legal effect to them in an EEA country, together with any successor or replacement legislation and regulation, including the General Data Protection Regulation (2016/679). |
| Technical Precision Worker | A person who provides personal services to Technical Precision in exchange for payment, including employees and contractors, consultants, and interns. |
| EEA | European Economic Area |
| APEC | Asia Pacific Economic Cooperation |