Table of Contents Chapter 10: Information Classification Chapter 12: Segregation of Duties
Chapter 11: Personal Data Protection

1. Introduction

2. Policy Statement

3. Standards

4. Collection Limitation

5. Data Quality

6. Purpose Specification

7. Use Limitation

8. Security Safeguards

9. Openness

10.Individual Participation

11.Accountability

12.Monitoring

13.Relevant US Laws


Introduction

Personal data of employees and customers is collected, transferred, and stored throughout True Value. In order to protect the privacy rights of those individuals and to reduce the risk of misuse of that information, proper care must be taken. This policy provides international guidelines for personal data protection.

Data is considered "personal" if it is unique to an individual or company, such as name, address, telephone number, credit card number, birth date, etc.


Policy Statement

All personal data of employees, members, customers, etc. must be obtained, processed, and protected in accordance with the standards outlined in this policy. In addition, employees must comply with any current or future privacy laws found in their resident countries.

All data systems remain the property of True Value Company. There is no personal right of privacy maintained for any electronic equipment assigned to employees or the data stored on or created by that equipment. True Value Company reserves the right to access and review any data retained or transmitted by its systems without prior notice, and disclose any information obtained to appropriate parties.


Standards

Collection Limitation

There should be limits to the collection of personal data and any such data should be obtained by lawful and fair means and, where appropriate, with the knowledge or consent of the data subject.


Data Quality

Personal data should be relevant to the purposes for which they are to be used, and, to the extent necessary for those purposes, should be accurate, complete and kept up-to-date.


Purpose Specification

The purposes for which personal data is collected should be specified at the time of collection.


Use Limitation

Personal data should not be disclosed, made available or otherwise used for purposes other than those specified at the time of collection, except:


Security Safeguards

Personal data should be protected by reasonable security safeguards against such risks as loss or unauthorized access, destruction, use, modification or disclosure of data.


Openness

There should be a general policy of openness about developments, practices, and policies with respect to personal data. Means should be readily available for establishing the existence and nature of personal data, and the main purposes of its use, as well as the identity and location of the person responsible for safeguarding the data.


Individual Participation

All employees, members and customers have the right to:

• within a reasonable time
• at a charge, if any, that is not excessive
• in a reasonable manner, and
• in a form that is readily intelligible to him/her


Accountability

The person(s) responsible for collecting, transferring, and storing personal data should be held accountable for complying with the principles stated in the above standards.


Monitoring

All data systems remain the property of True Value Company. There is no personal right of privacy maintained for any electronic equipment assigned to employees or the data stored on or created by that equipment. True Value reserves the right to access and review any data retained or transmitted by its systems without prior notice, and disclose any information obtained to appropriate parties in compliance with applicable privacy laws and regulations.


Relevant US Laws

Privacy Act 1074
HIPPA Act
Sarbanes-Oxley Act 2001
California SB – 1386


Table of Contents Chapter 10: Information Classification Chapter 12: Segregation of Duties