Overview and purpose
Due to the nature of our business, it is essential that all of our employees fully understand how to treat confidential information. Accordingly, this employee confidentiality policy has been crafted and implemented to ensure that everyone who works for us knows and complies with our expectations regarding sensitive information.
We want to make sure that any relevant information pertaining to our company, clients, and partners is properly secured because it may be:
- Legally binding (such as contractual material)
- Essential to our successful business operations (such as proprietary information pertaining to our goods/services/production/methods and methodology)
Scope
This is a blanket policy. As such, this employee confidentiality policy applies to anyone who works for us in any capacity that actually has or could potentially have access to confidential and/or sensitive information.
Confidential and Sensitive Information — Defined
For the purposes of this policy, confidential and/or sensitive information is defined as:
- Uncirculated financial information
- Records pertaining to customers/partners/clients/customers
- Patents, formulas or new methods/methodologies
- Customer and/or client lists (existing and prospective)
- Written/electronic documents or similar material entrusted to our company by outside parties
- Pricing/marketing and other unrevealed strategies
- Any material explicitly marked as confidential
- Uncirculated material pertaining to goals, predictions and proposals marked as confidential
Depending on their job title/responsibilities, seniority and other factors, our employees may have differing levels of authorized access to this type of material.
Employee Obligations Under this Policy
In accordance with this policy all employees must:
- Take reasonable steps to ensure that confidential material is never left in plain view or otherwise unsecured.
- Shred confidential material when it is no longer needed.
- Ensure that any confidential information in a digital format is only viewed on secure devices.
- Refrain from making authorized disclosures to co-workers unless absolutely necessary.
- Refrain from taking confidential documents off of company property unless absolutely necessary.
- Surrender all confidential documents and material to the company upon resignation, termination or at any time upon the request of their supervisor.
- Take reasonable steps to ensure that they do not mistakenly disclose any confidential informationto any unauthorized persons in or outside the company.
- Report any inadvertent disclosures of confidential information to their direct supervisor as soon as possible.
Prohibited Conduct and Activities
Employees are prohibited from doing the following:
- Using confidential information for financial or personal gain.
- Removing or making copies of confidential material; or facilitating the reproduction of confidential material relating to the company in any manner.
How we Safeguard Confidential Information
We take the following steps to safeguard confidential information:
- Store hardcopies in secured filing cabinets.
- Encrypt electronic information and ensure databases are protected
- Ask anyone who works for us to sign non-compete and/or non-disclosure agreements (NDAs).
- Require senior management to authorize access to confidential information.
Exceptions to this Policy
From time to time, some circumstances may warrant disclosure of confidential or sensitive information. We reserve the right to disclose said information when:
- A regulatory/law enforcement/or other government agency requests it as part of an investigation or audit.
- If we consider a venture or partnership requiring the disclosure some information (within legal parameters)
When this happens, employees who receive such requests or are privy to such considerations should carefully document their disclosure procedure and gather required authorizations. We’re legally obligated not to disclose more information than absolutely necessary to accommodate such requests or make relevant business decisions.
Consequences for Failure to Comply
Any employee or other such person obligated to comply with this policy who deliberately or unintentionally fails to do so will be disciplined. The type of discipline will depend on the severity and frequency of the violation(s). Anyone found to be using confidential/sensitive information for personal gain in violation of this policy will be terminated.
This policy is binding even after an employee resigns or is fired.
