SpeakUp Line Privacy Notice

  1. Version

    This privacy notice was updated in August 2022 as part of continuing efforts by DXC Technology (“DXC” or “the Company”) to provide best-in-class privacy and data protection.

  2. Purpose

    2.1.

    This Privacy Notice is designed to inform you as a user of DXC’s SpeakUp Line reporting channel about:

    1. The types of personal information that may be collected by or on behalf of DXC during use of this service.
    2. Why and how your personal information may be collected, processed, used and stored by or on behalf of DXC.
    3. Your rights in connection with personal information collected in this way.

    This Notice is intended to satisfy the requirements of applicable privacy regulations in the jurisdictions in which DXC does business, including the EU Whistleblowing Directive. Most of these regulations require proper notification to anyone making a report via a ‘whistleblower system.’ In addition, this Notice establishes the requirement for users of the SpeakUp Line to acknowledge and accept the terms and conditions for the use of the service.

  3. Definitions

    3.1.

    Good Faith

    Acting in good faith means acting with an honest belief or purpose, without malicious intent. In the context of reporting a concern, acting in good faith does not mean you have to know all the facts and be completely certain that misconduct occurred. It means that you have sensible reasons to believe misconduct may have occurred, and you are respectful and truthful in reporting it.

    3.2.

    Personal Information

    Also known as personally identifiable information (PII) and personal data, personal information is any information that can be used to identify, locate or contact an individual, alone or when combined with other personal or identifying information. Examples are provided in subsection 4.1 below.

  4. SpeakUp Line Terms and Conditions of Use

    By your continued use of the SpeakUp Line, you acknowledge and accept the terms and conditions outlined further below. If you do not wish to accept the terms below, we are unable to accept any information from you through this system. In that case, we would encourage you to report this matter directly to your management or to a representative of DXC Integrity or Human Resources, depending on the nature of the matter.

  5. About the SpeakUp Line

    5.1.

    The SpeakUp Line is a web- and phone-based intake system. It is provided by DXC to allow DXC employees, contractors and others to report suspected violations of law, the DXC Code of Conduct or corporate policy and other workplace misconduct.

    5.2.

    You may report concerns anonymously using the SpeakUp Line. While it makes it easier for DXC to investigate and follow up on concerns if you identify yourself, we understand there may be situations where you would prefer not to do so.

    5.3.

    The SpeakUp Line, and the database used to store personal data and information that you may report, are operated by NAVEX. NAVEX is a third-party service provider, unaffiliated with DXC, and located in the United States.

  6. Use of the SpeakUp Line

    6.1.

    Use of the SpeakUp Line is entirely voluntary.

    6.2.

    We want to promote a positive, open and ethical culture in which concerns are identified and addressed in a timely and appropriate way. We therefore want to make it easy to report concerns. If you are unsure whether the SpeakUp Line is the most appropriate channel to use, and you cannot or do not want to consult your supervisor, you should use it anyway.

    6.3.

    Please be aware that the information you supply about yourself, your colleagues or any aspect of the Company’s operations may result in decisions that affect others. Therefore, we ask that you act in good faith, only providing information that you believe is true. You will not face negative consequences for any report of a suspected violation that is made in good faith, even if it later turns out to be factually incorrect. Knowingly providing false or misleading information will not be tolerated and will result in disciplinary action.

    6.4.

    The information you submit will be treated confidentially except in cases where this is not possible because of legal requirements or the needs of an investigation. In that case the information will be handled as sensitively as possible. We encourage you to identify yourself in order for us to follow up with questions we might have.

  7. Collection and Processing of Personal Data

    7.1.

    So that we can properly identify, understand, investigate and resolve issues and concerns reported through the SpeakUp Line, it is necessary for DXC to collect certain types of personal information. When you make a report via the SpeakUp Line, DXC captures the following personal information:

    1. Your name and contact details (unless you report anonymously).
    2. The name(s) and other personal data of the person(s) you name in your report, if you provide such information (e.g., description of functions and contact details).
    3. A description of the alleged misconduct and circumstances of the incident.
    7.2.

    Please note that the laws of some countries may not allow anonymous reporting. Even in that case, your personal information will be treated confidentially and will only be disclosed as set out below.

  8. Storage and Access to Personal Data and Information

    8.1.

    Any personal information you provide will be stored in a database which is located on servers hosted and operated by NAVEX in the United States. NAVEX has entered into contractual commitments with DXC to secure the information you provide in accordance with applicable law.

    8.2.

    Personal data and information provided in a report may be transferred outside of the United Kingdom, the European Union and/or the European Economic Area for the purpose of providing interpretations or administration of this service (by NAVEX) and for the purpose of processing your request and related investigations (by DXC Integrity and other stakeholders engaged by them). NAVEX is committed to maintaining compliance with applicable data protection requirements and adheres to stringent privacy and security practices.

    8.3.

    For the purpose of processing and investigating your report and subject to the provisions of local law, the personal data and information you provide may be accessed, processed and used by the relevant personnel of DXC, including Human Resources, Finance, Internal Audit, Legal, management, external advisors (e.g., legal advisors) or, in limited circumstances, by technical staff at NAVEX. Those individuals may be located in the United States or elsewhere.

    8.4.

    Personal data and information you provide may also be disclosed to the police and/or other enforcement or regulatory authorities. The relevant bodies that receive and process personal data may be located in the United States or in another country that may not provide the level of data protection available in the European Union or other jurisdictions with more stringent data protection laws.

    8.5.

    Subject to applicable laws, the personal data you provide will be kept as long as necessary to process your report or, if applicable, as long as necessary to initiate sanctions or to meet our legal or financial needs.

  9. Accessing Information Concerning a SpeakUp Line Report

    You have the right to request access to or, in case of inaccurate or incomplete information, correction or erasure of your personal data held by or on behalf of DXC in connection with the SpeakUp Line. Any such request should be directed to DXC’s Privacy Office at Privacy@dxc.com. You also have the right to lodge a complaint with the relevant supervisory authority. For more information, please refer to DXC’s Enterprise Employee Privacy Notice available in DXC Policy Central: https://dxcportal.sharepoint.com/sites/policy/_layouts/15/viewer.aspx?sourcedoc=6baa174f-ccc7-41b9-9c4c-13d939bf70ba