This Notice should be read in conjunction with the Overview and the Definitions, including, in particular, the table of categories of information.
What processing activities do you undertake that include my information?
We maintain processes and procedures which allow you to speak up about concerns or issues related to suspected or actual illegal or unethical conduct, or violations of our Code of Conduct or Company policies you may have and report them for guidance or further investigation.
In support of these processes and to comply with our compiance obligations, we operate a third party provided Ethics Reporting line, which allows you to raise any concerns through either telephony or web reporting.
What categories of information are included in these processing activities?
To administer and maintain the process set out above, depending on your relationship with us and the type of concern raised, we process identity information, staff related data, data related to your engagement with the Company, recruitment data, regulatory data, vetting data, remuneration and benefits data, leave information, HR processes data, monitoring data (to the extend permitted by applicable laws) and employment claims, complaints and disclosures data.
We may also process sensitive information (such as criminal records information) to the extend permitted by applicable laws.
What is the reason for these processing activities?
To investigate any reports received and take remedial action, as required.
We carry out these activities to ensure that our business, clients, staff members and systems are protected. This includes responding appropriately to ethics concerns which are raised to it.
We also undertake these processes to ensure compliance with applicable laws and Company policies and procedures, to monitor use of the Company's IT system and to manage the activities and behaviour of our employees.
To the extent that you did not get this information from me, how did you collect it?
Some of this information will come from internal sources. This includes a variety of stakeholders included in the investigation of any concern raised, for example your BAE Systesm contact, HR, Legal, line management, Security and Ethics Officer(s)/Managers.
Other information may come from the relevant customer or contact, your employer, other customers, suppliers and other business partners.
We may also receive information from other sources as set out in this Notice.
Who do you share this information with?
As necessary and appropriate in the circumstances of a particular investigation, your information may be shared internally for the purposes described above. This would usually include our Ethics Officer(s)/Managers and/or Administrators, legal advisers, HR or other internal investigators or subject matter experts as may be appropriate in the consideration and/or investigation of an ethics concern raised. Where necessary, your information may also be shared with our parent company BAE Systems Plc.
Depending on the nature of the report, we may also share some of your information externally with our customers, and any suppliers or partners as needed (including our external legal advisers and our Ethics Reporting line provider), external agencies (including the Police or law enforcement, as appropriate) and as otherwise set out in this Notice.