Privacy Statement Training Management System (TMS) Honeywell Automation College EMEA 1. Registrar Honeywell Automation College EMEA 2. Contact persons and persons responsible for register-related matters Person responsible for the register Michel Jennes Automation College Manager - HPS EMEA E-mail: michel.jennes@honeywell.com Tel: +32 2 728 2731 Address: Hermes Plaza Hermeslaan 1H 1831 Diegem Belgium Register contact person Jari Luukkonen Regional Training Manager E-mail: jari.luukkonen@honeywell.com Tel: +358 2 728 3500 Address: Navitas 1 Block C 3 rd floor Wredenkatu 2 78250 VARKAUS Finland 3. Name of register Training Management System, referred to by the abbreviation TMS in this Privacy Statement.
4. Purpose and grounds for handling personal information In general, Honeywell uses personal information to deliver services or carry out transactions requested by the Customer, such as providing information on Honeywell products and services, registering students to training courses, processing services orders, handling quality issues, invoicing services, answering customer service requests and facilitating the use of Honeywell websites. In order to offer the Customer a more consistent experience in interactions with Honeywell, information collected by Honeywell websites may be combined with information collected by other means - so as to learn about the Customer and how he or she interacts with and uses Honeywell products and services; to develop and manage Honeywell products, services and customer care, and to provide the Customer with information about Honeywell products and services that the Customer may be interested in. The handling of personal information collected by Honeywell Automation College is based on Honeywell s justified benefit in fulfilling the obligations of customer relationships. In this particular register (TMS), personal information is used for the purpose of fulfilling and managing training services required in customer relationships, for invoicing and developing training services, and for statistical and marketing purposes. The training-related Customers recorded in the TMS system may be external Customers, i.e. end Customers of Honeywell deliveries, Honeywell subcontractors and partners, or internal Customers, in other words Honeywell s own employees. 5. Information contained in the register Among other information, the following items may be stored pertaining to a registered person: Name, job title, phone number and mobile phone number, address, e-mail address, Customer s company name, plus data indicating whether the Customer is the company s training contact person towards Honeywell. The name and e-mail address of the internal Customer s (Honeywell employee) direct manager is stored as his or her supervisor data. Regarding Honeywell employees, the following information is also stored: the employee s personal identity code, departmental LOB/SBE identifier, department name, cost center and profit center. In cases where the Customer has been certified through a certain training session and the expiry of the certification must be announced to him or her by e-mail, then the name and e-mail address of the Customer s closest or second closest superior may also be recorded. In addition, the name and e-mail address of another contact person essentially involved in the certification, such as the Customer company s safety manager, may also be recorded as necessary.
Pertaining to all internal and external Customers, any training course they have completed at Honeywell Automation College will be recorded as soon as the Customer completes each respective course. In cases where a certification or test is linked to a course, the data indicating its approved completion is also recorded. For the part of internal Customers (Honeywell employees) any technical or industrial safety courses relating to their work duties and imposed by the employer for their performance, may also be recorded. 6. Storage period for personal information Honeywell Automation College keeps personal information in its training register up until the date on which the customer relationship between the registered person s employer, which is regarded as a Honeywell customer company, may be regarded as having been terminated. Among other things, the purpose of this storage period is to safeguard the archival of significant history data with regards to the customer company s personnel administration and occupational safety. 7. Normal sources of information Information collected directly from Customers. Generally, you can visit the websites of Honeywell Automation College without entering any personal information. When selecting a training event site, enrolling in a training event waiting list, or inquiring additional information as a Customer, you may be asked for personal information to obtain the requested service or transaction. A Customer can also provide personal information when contacting Honeywell directly (e.g. with a comment, inquiry or Customer support request). The personal information collected or received by Honeywell Automation College may contain: contact details, such as the Customer s name, title, company/organization name, e-mail address, telephone and fax numbers and physical address information about the Customer s company and job function Customer s e-mail marketing preferences Customer s location information, such as his or her nationality and country of residence, which allows Honeywell to determine the availability of specific technological information or its legality based on export regulations. information on products and services information that assists Honeywell in identifying the products and services that best meet the Customer s requirements training event registration information
feedback from the Customer about Honeywell websites and Honeywell products in general. The Customer is not required to provide any of this information, but if he or she does not, Honeywell may not be able to provide the requested service or complete the transaction. Information collected automatically. Honeywell collects information about the Customer s visits to its websites, including which pages are viewed, the time of the visit, and other actions taken within Honeywell s websites. This standard information is not combined with other personal information, however. 8. Normal handover and transfer of information outside the European Union or the European Economic Area Honeywell Automation College may hand over Customer information within the confines and obligations of currently valid legislation, to comply with the mandatory industrial safety purposes and authority regulations, for example. However, Customer information is never handed over to companies external to the Customer relationship, for marketing purposes, among others. Within Honeywell Automation College, Customer information may be transferred to offices located outside the European Union or the European Economic Area, in accordance with the information security legislation and its confines. By submitting information via websites of Honeywell Automation College, the Customer agrees to the transfer of the information in question to locations outside his or her country of residence. 9. Description of the register protection principles Potential manual materials are stored at the lockable premises of Honeywell Automation College offices that may be accessed by separately authorized persons only. Access to digital material is exclusively gained by the personal user ID and password of a specifically authorized person, or those of an authorized subcontractor. There are various levels of TMS system user authorization, and each user is provided with an authorization that is as limited as possible but sufficient for the performance of his or her duties. The Honeywell internal network servers with firewalls are located within lockable premises and provided with access control and alarm systems for safety. The servers register data is appropriately backup copied on a regular basis.
10. Profiling As part of handling the registered customer training information, Honeywell Automation College may also use the information for profiling purposes. The purpose of profiling is to clarify Customer behaviour and the demand for services, and to assist resource planning so as to ensure delivery reliability and customer satisfaction. 11. Registered persons right to check their personal information in register Each Customer has the right to learn what information about him or her has been stored in the Customer training register, including the checking of the non-existence of such information in the register. A request to check the information must be made to the Honeywell Automation College office located in the Customer s country of residence, or, in cases where the Automation College has no office in the country, to the Honeywell Automation College EMEA office in Belgium. The right to check will be implemented without delay, free of charge. A written certificate on the denial of the request to check shall be provided by the person responsible for the register, stating the reasons why the right to check has been denied. The person in question may submit a denial of the request to check to be resolved by the Data Protection Supervisor. 12. Registered persons right to claim information rectification In accordance with the European Union s General Data Protection Regulation, register-contained personal information, which is erroneous regarding the purpose of handling, unnecessary, incomplete or obsolete, shall be rectified, deleted or completed. A rectification request shall be made by means of a personally undersigned written request to the Honeywell Automation College office located in the country that person is a citizen of. In cases where the country in question has no Honeywell Automation College, contact the head office of the Honeywell Automation College EMEA in Brussels. The matters to be rectified, and the grounds thereof, shall be itemised in the request. Rectification or removing shall be implemented without delay and communicated to the person who requested rectification or removing, and to the training contact person of his or her company. A written certificate on the denial of the rectification request shall be provided by the person responsible for the register, stating the reasons why the request to rectify has been denied. The person in question may submit the denial to be resolved by the Data Protection Supervisor.
13. Registered persons additional rights concerning the handling of personal information Honeywell Automation College keeps personal information in its training register up until the date on which the customer relationship between the registered person s employer, which is regarded as a Honeywell customer company, may be regarded as having been terminated. However, a registered person may have his or her personal information fully deleted from the Customer training register, even if he or she still works for a Customer company of Honeywell Automation College, provided that the person in question agrees upon such a deletion with his or her employer, and if the request is presented as having been approved by the employer. A registered person shall have the right to lodge a complaint to a competent control authority in cases where the registrar has not observed the applicable privacy regulation in its activities. 14. Contacts In all issues relating to the personal information collected by Honeywell Automation College, the primary requirement is to contact the Honeywell Automation College unit located in the Customer s own country, and if there is no such unit, contact the Honeywell Automation College EMEA in Belgium. Please find the contact information for the Honeywell Automation College units below: Europe Brussels, BELGIUM Phone: +32 27282589 Email: HPS-Training-Belgium@honeywell.com Varkaus, FINLAND Phone: +358 207522275 Email: HPS-Training-Finland@honeywell.com Paris, FRANCE Phone: +33 173629300 Email: HPS-Training-France@honeywell.com Brandenburg, GERMANY Phone: +49 3381749328 Email: HPS-Training-Germany@honeywell.com
Amsterdam, NETHERLANDS Phone: +31 205656818 Email: HPS-Training-Netherlands@honeywell.com Rosmalen, NETHERLANDS (SMS) Phone: +31 205656818 Email: HPS-Training-SMS@honeywell.com Moscow, RUSSIA Phone: +7 4957969800 Email: HPS-Training-Russia@honeywell.com Manchester, UNITED KINGDOM Phone: +44 1612514000 Email: HPS-Training-UK@honeywell.com Middle East Dubai, UNITED ARAB EMIRATES Phone: +971 44505801 Email: HPS-Training-MiddleEast@honeywell.com Jubail, SAUDI ARABIA Phone: +966 33427444 Email: HPS-Training-MiddleEast@honeywell.com Dhahran, SAUDI ARABIA Phone: +966 38133777 Email: HPS-Training-MiddleEast@honeywell.com Mina Abdulla, KUWAIT Phone: +965 22243743 Email: HPS-Training-MiddleEast@honeywell.com
Africa Secunda, SOUTH AFRICA Phone: +27 176319000 Email: HPS-Training-SouthAfrica@honeywell.com Johannesburg, SOUTH AFRICA Phone: +27 116958070 Email: HPS-Training-SouthAfrica@honeywell.com