In some situations, we process the personal information of third parties, including the general public.
This notice should be read in conjunction with the Overview.
What processing activities do you undertake that include my personal information?
We maintain a records of potential legal risks or concerns. For example, we maintain records of any request for a facilitation payment, bribe or extortion request made by a third party, community interests (including possible conflicts of interest), gifts and hospitality and political interests.
What categories of personal information are included in these processing activities?
We process Identity information, Business information, Contact information, information about the risk (which may amount to criminal records information or political affiliation) in order to undertake this activity.
What is the reason for these processing activities?
We hold this database in order to keep a record of these requests and to comply with applicable anti-bribery and corruption laws.
What are the legal grounds you rely on to carry these out?
This processing is necessary for the compliance with legal obligations to which the Company is subject.
This processing is necessary for the purpose of the legitimate interests pursued by the Company.
(See “What are the legal grounds for processing personal information?” in the Overview section.)
What are the 'legitimate interests' referred to above?
The Company considers that it has a legitimate interest in complying with all applicable laws it is subject to in any jurisdiction.
As this processing may include special categories of personal information or information relating to my criminal record, in addition to the above, what are the additional legal grounds you rely on to justify this processing?
This processing is necessary for reasons of substantial public interest.
The processing is needed for legal claims.
(See “What are the legal grounds for processing special category personal information?” in the Overview section.)
To the extent that you did not get this personal information from me, how did you collect this information?
The personal information may have been generated internally by the Company, for example through an employee report (see “Where do you get my personal information from?” in the Overview section).
We receive personal information from our customers, suppliers and our partners. We may receive information from other sources as set out in this Notice (see “Where do you get my personal information from?” in the Overview section).
In addition, we may also gather some personal information from publicly available sources.
Who do you share this personal information with?
Your personal information is shared internally, as set out in this Notice (see “When do you share my personal information with others?” in the Overview section).
In addition, some of your personal information will be shared externally with law enforcement agencies as needed and as otherwise set out in this Notice (see “When do you share my personal information with others?” in the Overview section).