This Privacy Notice (“Notice”) explains how Honeywell International, Inc. and its affiliates, (“Honeywell”, “we” or “us”), the controller, collects, uses, and shares your personal data when you submit information through EthicsPoint to reporting concerns, issues and suspected violations of laws or regulations or company policies.
Unless you choose to remain anonymous (if permitted by your country), we may collect the following information from you:
You may also choose to voluntarily provide special categories of personal information such as race, ethnicity, health data or sexual orientation.
We may use your personal information: (i) to contact you for additional information on the alleged misconduct and/or suspected violation of Honeywell’s Code of Business Conduct, other policies, and applicable laws and regulations; (ii) to conduct interviews during the investigation process; (iii) to conduct a thorough investigation of alleged misconduct and/or suspected violations and issue disciplinary action where appropriate; (iv) monitor and investigate irregularities; (v) to report to appropriate authorities; and (vi) perform other functions or serve other purposes, as disclosed to you at the point of collection, or as required or permitted by law.
We will share your personal information within Honeywell and its affiliates on a “need-to-know” basis for the purpose of investigating your report or concern. This will be the case where the investigation must be carried out in a specific country. Your information will be collected by a third-party service provider (such as ‘NAVEX’, an ethics and compliance expert) when you submit a report via telephone or the online form. The personal data and information you share will be stored in a database which is located on servers hosted and operated by NAVEX in the United States and Europe. We may share your personal information with third party service providers that perform specific services on our behalf such as HR Acuity. It may also be necessary for us to share your personal information with law firms, criminal or competition authorities
Your personal data may be transferred to the USA. This means that when we collect your personal information it may be processed in countries that may have data protection laws that are different to the laws of your country. However, Honeywell will always take reasonable steps to protect your privacy and to provide a level of protection of personal information that is comparable to that of your country of residence which include implementing the European Commission's Standard Contractual Clauses. We will take all appropriate technical and organizational measures to safeguard the personal information that we transfer.
Our legal basis for processing your personal information will be based on your consent. If you refuse consent or withdraw your consent, to the extent permitted by applicable law, Honeywell may still be able to process your personal information based on a relevant legal basis other than consent (for e.g. it is necessary for compliance with a legal obligation to which Honeywell is subject or it is in Honeywell’s legitimate interest. Please note that withdrawing your consent does not affect the lawfulness of the processing based on consent before its withdrawal.
You may have, among others, the following rights under applicable law to: (i) right to access, rectify, erase, object, restrict or withdraw your consent to the processing of your personal information; (ii) the right to not have a decision made about you that is based solely on automated processing, including profiling, if that decision produces legal effects about you or significantly affects you, and (iii) a right to lodge a complaint with a supervisory authority. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
If you have any questions about the type of personal data that we hold about you or if wish to exercise any of your data subject rights, please contact us through the data subject request form found at https://honeywellhub.secure.force.com or send an email to the Data Protection Officer at HoneywellPrivacy@honeywell.com. Employees may also contact us through HRHelp.
We will retain your personal data as necessary in connection with the purposes described in this Notice, and in accordance with Honeywell’s retention policies and applicable law. Additionally, the third party service provider, ‘NAVEX’ will retain the data for the duration of the contract, upon termination of the contract, the data will be deleted within 45 days.
Under certain circumstances, we may anonymize your personal data so that they can no longer be used to identify you. We may collect, use and share anonymized information for any purpose. Anonymized information is not considered personal information and is therefore not subject to this Notice.
If you would like to contact us for any reason regarding our privacy practices, please email us at:
I consent to the collection, use, transfer, disclosure, and processing of my personal information in accordance with the Honeywell EthicsPoint Privacy Notice. |
|
I separately consent to the collection, use, transfer, disclosure, and processing of my sensitive personal information in accordance with the Honeywell EthicsPoint Privacy Notice |
|
I separately consent to the transfer of my sensitive personal information to recipients located locally and outside of my country of residence in accordance with the Honeywell EthicsPoint Privacy Notice. |