EFFECTIVE DATE: 1 January, 2015
This Policy governs the personal information collected by Tupperware Brands Corporation and its subsidiaries ("Tupperware") from our employees residing in nations that have adopted either the European Commission’s Directive on Data Protection or the Swiss Federal Act on Data Protection.
This Policy is intended to ensure that Tupperware is in compliance with, and meets the “adequacy” standards of, the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce, the European Commission and the Federal Data Protection and Information Commissioner of Switzerland regarding the collection, use, and retention of personal information from EU member countries and Switzerland. Tupperware has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity and access, and enforcement as set forth in this Policy.
Tupperware is a global company, based in the United States. Tupperware employees are asked to provide personal data at hiring, and throughout employment, to permit Tupperware to compensate them for their work, provide fringe benefits, plan for succession and career development, and perform other tasks related to the operation of the company. While most data processing for employee compensation and benefits is done locally, special incentive programs (such as performance bonuses) are calculated at our headquarters in the U.S. In addition, we transfer data relating to career planning and management of our succession plan to our U.S. headquarters. Therefore, portions of your personal data may be transferred to our headquarters in the U.S. for these purposes. Furthermore, Tupperware engages, from time to time, third parties that process personal data solely on behalf of and under the instructions of Tupperware, and we may transfer your data to these third parties for these purposes. We will attempt to transfer to the U.S. and to third parties only the personal information necessary for administration of these programs.
For all uses not included above, at the time when employees are first asked to provide personal data (or as soon thereafter as is practicable), Tupperware will inform employees about the purposes for which we collect and use personal data about them, how to contact us, the types of third parties to which we disclose the information and the choices and means we offer for limiting its use and disclosure.
Tupperware will give you the opportunity to choose (opt out) whether your personal information will be disclosed to a third party (other than a third party that processes personal data solely on behalf of and under the instructions of Tupperware) or used for a purpose incompatible with the purpose for which the data was originally collected or subsequently authorized by you. For sensitive information, Tupperware will give an employee an affirmative or explicit (opt in) choice, if the information is to be disclosed to a third party or used for a purpose other than those for which it was originally collected or subsequently authorized by the individual.
As stated above, Tupperware transfers certain employee information to third parties for compensation, benefits and career and succession planning purposes. We may choose in the future to engage a third party for additional purposes, and we will comply with the “Notice” and “Choice” principles above for all such new third party transfers. If your personal data is transferred to a third party in the U.S., that third party will be required to either 1) certify its compliance with the EU and/or Swiss Safe Harbor principles as we have, or 2) enter into a written agreement containing privacy protection clauses approved by your home government for such transfers. Provided these transfers are incidental to your employment, and are all within EU or Swiss-approved guidelines, we will not request your prior consent to these transfers.
Tupperware is serious about the security of your personal data. Both in your local country and in the U.S., we provide various security features. Access to both paper and electronic information is limited by the employee's job function. Paper records are protected by lock and key. Electronic records are protected by user name and password verification. Our processing applications are housed in our firewall-protected networks.
DATA INTEGRITY AND ACCESS
Our Human Resources and compensation functions include checks and procedures to keep your personal data accurate, complete, and current. Employees may review their personal data by submitting a written request to their local HR representative. If your personal data is inaccurate, you may submit a written request and we will correct, amend, or delete the information, as appropriate.
As part of our annual certification process, we will review our compliance with this Policy. Any complaints or disputes regarding personal data protection may be sent to your local HR Representative. Complaints or disputes that cannot be remedied by the local HR Representative should be forwarded to the General Counsel at email address email@example.com. Tupperware also agrees to cooperate with your local data protection authorities to resolve disputes, and has agreed to participate in the dispute resolution program provided by the European Data Protection Authorities Panel and to cooperate and comply with the Federal Data Protection and Information Commissioner of Switzerland.
CHANGES TO POLICY
Tupperware may change or terminate this Policy in whole or in part at its discretion, and without prior notice to or the consent of any employee. Tupperware retains sole and absolute discretionary authority to resolve all questions arising in the administration, interpretation and application of this Policy (consistent with the requirements of the U.S.-Swiss and U.S.-EU Safe Harbor frameworks). This authority includes construing the terms of this Policy, including any disputed or doubtful terms, and determining the eligibility of any individual to receive any Policy benefit. Tupperware’s adherence to this Policy may be limited to the extent required to meet a legal, governmental, national security or public interest.
SAFE HARBOR PROGRAM
To learn more about the Safe Harbor program, and to view Tupperware’s certification, please visit http://www.export.gov/safeharbor/.
Data Transfer Policy
EUROPEAN UNION AND SWISS DATA TRANSFER POLICY
EFFECTIVE DATE: 1 January, 2015