Introduction

Moog Inc., and its subsidiaries (collectively, “Moog”), are required to collect and maintain information about its employees in order to comply with a myriad of governmental and contractual obligations, including providing for the payment of taxes, employee benefits, wages, etc.  However, Moog also recognizes the importance of protecting your privacy, and therefore complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework, including the Safe Harbor Privacy Principles (the “Principles”1).  Moog certifies on an annual basis that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement.  To learn more about the Safe Harbor program, and to view Moog’s certification, please visit http://www.export.gov/safeharbor/.  This Notice of Data Privacy Policy for Employees (“Policy”), updated March 6, 2013, describes the information collected by Moog from its employees and how Moog uses that information.

Note: It is incumbent on the Operating Groups and Business Units to identify additional local and /or regional regulations and ensure compliance.
Collection of Information

 

Collection of Information

In connection with your employment, Moog may ask you to provide certain information, including, but not limited to, your name, mailing address, telephone numbers, citizenship, country of residence, country of origin, gender, birth date, marital status, name of dependents, birth date of dependents, occupation of dependents and national identification number.  Additionally we may maintain information relating to your employment with the Company including, but not limited to, your employee identification number, business unit/division of employment, department, physical work location, job code, compensation rate, supervisor, work shift, hire and termination date, appraisal dates and ratings, training, skills, educational background, language proficiency, certifications and licenses (collectively, “Employee Information”).

 

Use of Information

The information collected by Moog will be used for various administrative and record keeping purposes by Moog.

 

Disclosure of Employee Information

Employee Information will be disclosed to a limited number of Moog employees whose job necessitates that they maintain, compile, or otherwise have access to Employee Information; these employees are authorized by Moog and have specific employee data responsibilities.  Moog may also disclose Employee Information to a third party when it believes, in good faith, that such disclosure is reasonably necessary to comply with any law or to protect the rights, property or safety of another person.  Additionally, Moog may disclose Employee Information to a third party employee benefit provider, including but not limited to, employee benefit providers and payroll services.  If Moog does disclose information to third party, Moog will ensure that the third party either subscribes to the Principles or is subject to the Directive or Moog will enter into a written agreement with such third party which requires the third party to provide at least the same level of privacy protection as is required by the relevant Principles.  Lastly, Moog may transfer or otherwise disclose Employee Information in connection with the sale of its business to a third party.

 

Transfer of Employee Information

Employee Information will be transferred, transmitted and accessed electronically by a limited number of Moog employees (as discussed above) at various Moog locations around the world.  Moog has taken, and will continue to take, appropriate technical and organizational measures to protect all Employee Data from destruction, loss, alteration, or unauthorized disclosure or access.  Further information as to how Employee Information is transferred, transmitted and accessed electronically and how Moog protects such Employee Information can be found in the policy, Practice for Protection and Transmission of Employee Data, updated March 6, 2013, as well as the Moog Policy Statements referred to therein.

 

Employee Consent

Unless you withdraw your consent, in writing, you agree to and accept the proposed use, disclosure and transmission of your Employee Information by Moog as set forth in this Policy.  Upon any modification of this Policy, Moog will prominently post a revised Policy within five (5) business days of its adoption and provide employees with an opportunity to withdraw his or her consent to any new use or disclosure of his or her Employee Information.  If any employee objects to Moog’s collection, use, disclosure or transmission of certain Employee Information, Moog will make reasonable efforts to address the concerns of the employee.  In no case will an employee be subject to sanction or retaliation for objecting to the collection, use, disclosure or transmission of Employee Information.  Any employee who withholds Employee Information or prohibits its collection, use, disclosure or transmission, however, may be disadvantaged as a result of not making the information available.  For example, unwillingness to provide information required to use a service or receive a benefit may make an employee ineligible for that service or benefit.

 

Your Rights Regarding Your Employee Information

Although your Employee Information is the physical property of Moog, the information contained in the record belongs to you.  Upon request in a reasonable notice period, each employee has the right to:

  • Obtain a copy of Moog’s Policy upon request.  
  • Inspect his or her Employee Information and be able to correct or amend information where it is inaccurate, except where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, or where the rights of persons other than the individual would be violated.  All requests to inspect, correct, amend, or delete information must be submitted in writing to the local Human Resources Manager.
  • Review Moog’s process and procedures for electronically transmitting Employee Information, as set forth in Practice for Protection and Transmission of Employee Data as well as the Moog Policy Statements referred to therein.
  • Withdraw his or her consent to the continued or future use and disclosure of his or her Employee Information, except as to that Employee Information that Moog determines to be necessary for continued employment.

 

Moog’s Responsibilities Regarding Protecting Employee Information

Moog is required to:

  • Provide employees with notice of Moog’s Policy regarding the collection, maintenance, use and disclosure of Employee Information
  • Ensure that Moog’s published Policy is current, accurate, comprehensive, prominently displayed, completely implemented, accessible, and conforms to the Principles.
  • Abide by the terms of this Policy. In the event that Moog modifies the terms of this Policy, Moog will prominently post a revised Policy which describes all intended uses and disclosures of Employee Information, within five (5) business days of its adoption, and provide employees with an opportunity to withdraw his or her consent to any new use or disclosure of his or her Employee Information.
  • Notify the employee if the Company is unable to agree to the employee’s requested restriction on the use or disclosure of his or her Employee Information.
  • Maintain the privacy of your Employee Information by taking reasonable precautions to protect the data from loss, misuse, unauthorized access, disclosure, alteration and destruction.
  • Comply with all laws regarding the privacy of Employee Information.

 

Complaints

If you believe Moog has breached its Policy by permitting an unauthorized use, disclosure or transmission of your Employee Information, you may contact or file a complaint with your supervisor.  If you are not satisfied with the response or action taken by your supervisor, all such complaints and concerns may then be directed to the local Human Resources Manager.  Additionally, Moog employees located in the European Union may also contact their national E.U. Data Protection authorities.  You will not be penalized for filing a complaint.

 

Further Information

Questions regarding the transmission of Human Resource Data from the European Union (EU) to the United States or any other non-EU location, or any further transmission of the personnel data once received in the United States, should be referred to Kons Muhtaris at Moog in Northbrook, IL. kmuhtaris@moog.com or 847-498-0700. This individual is also responsible for maintaining this internal Web page and any changes made to our employee data privacy practices will be prominently posted on our internal and external Web sites. To learn more about the Safe Harbor program, and to view Moog’s certification, please visit http://www.export.gov/safeharbor/.

 

[1] The European Commission’s Directive on Data Protection (October, 1998) prohibits the transfer of personal data to non-European Union nations that do not meet the European “adequacy” standard for privacy protection. In order to provide a streamlined means for U.S. organizations to comply with the Directive, the U.S. Department of Commerce in consultation with the European Commission developed a "Safe Harbor" framework. The Safe Harbor - approved by the EU in July of 2000 - allows U.S. companies to avoid experiencing interruptions in their business dealings with the EU or facing prosecution by European authorities under European privacy laws. Certifying to the Safe Harbor assures that EU organizations know that our company provides “adequate” privacy protection, as defined by the Directive.