ABB Code of Conduct

MAY 2020

Privacy Policy

ABB Code of Conduct

ABB is fully committed to protecting your privacy and respecting your rights to control how your personal data is used. This notice explains why and how ABB collects and uses your personal data and the rights you have in relation to that data.

Who is responsible for the processing of your personal data

ABB Asea Brown Boveri Ltd Affolternstrasse 44 Zurich 8050 Switzerland will be the "Controller" of your personal data - this company is responsible for the privacy of your data. The Controller is located outside of the European Union (EU), but we have appointed a representative for
EU data privacy matters. The Controllers representative in the EU is ABB B.V. George Hintzenweg 81 3068 AX Rotterdam We have obtained your personal data from you, from existing ABB managed data source, from an external third party data provider.

The types of information we collect and use

We collect the following categories of personal data:

  • First Name
  • Last Name
  • Personal Email
  • Business Email
  • IP Address
  • Cookie, Certificate, etc.
  • Digital Alias/Signature
  • Employee Number
  • Training Records
  • Job/Position/Title
  • Posts by Individuals in Discussions/Social Media like Yammer, etc
  • Tracking/Analytics data

Why we use your personal data

We use the personal data that we collect for the following purposes:

  • detect, prevent, investigate or remediate, crime, illegal or prohibited activities or to otherwise protect legal rights (including liaison with regulators and law enforcement agencies for these purposes)
  • train staff and/or suppliers and contractors
  • carry out regulatory checks and meet obligations to regulators
  • develop and improve services or products through assessment and analysis of the information compliance with the law, law enforcement, court and regulatory bodies’ requirements; such as for example the accountability requirement under the General Data Protection Regulation to maintain records of processing activities
  • gathering input from employees and contractors, e.g. surveys, polls, questionnaires

We only collect the personal data that we need for these purposes.

Group Code of Conduct mobile application is used to inform ABB employees, suppliers and customers about code of conduct and it makes the trainings available for both ABB internal and external users. The application will track who and which of the trainings have been completed. After its second deployment, there will be a possibility for senior managers to perform the code of conduct re-acknowledgments through it. The application is going to be integrated with the ABB Beekeeper application. Moreover, the analytical insights will be gathered to see how widely the application is used, which content is the most popular and how much time is spent on each screen. The data will be sent to ABB Asea Brown Boveri Ltd. In the process we use the Microsoft AppCenter with anonymized personal data. The external third party data provider is Microsoft Ireland Operations Ltd, from whom we receive data such as e-mail address, name and surname of the Data Subject.

We process your personal data for the purposes described in this notice because of our legal obligation that exist in many different countries. In other countries where there is no legal obligation, we rely on our legitimate interest.

Parties we share your personal data with

We only share your personal data as described in this notice. Your personal data is being transferred to ABB affiliates and subsidiaries in the following countries:

  • Switzerland
  • Poland

How long we keep your personal data

Based on mandatory legislation, ABB must keep certain personal data for a minimum period of time. We only keep your personal data for as long as necessary for the purposes described in this privacy notice. In general, personal data is kept for up to 1 month.

Your personal data might be kept for longer period only if required by local laws and regulatory requirements. At the same time, applicable data protection laws require that we do not keep personal data in an identifiable form for any longer than is necessary for the purpose for which the personal data is being processed. Through the setting of IT applications and policies we ensure that your personal data is deleted when we no longer need it.

What are your rights

Depending on the jurisdiction in which you are located and in which your personal data is processed, you may also have the right to:

  • access your data - you are entitled to ask ABB for an overview of or to obtain a copy of the personal data we hold about you;
  • have your data corrected - you may request immediate correction of inaccurate or incomplete personal data we hold about you;
  • have your data erased - you may request that personal data be erased when it is no longer needed, where applicable law obliges us to delete the data or the processing of it is unlawful;
  • restrict data processing - can request to restrict processing of your personal data in specific circumstances;
  • port your data - you have a right to receive a copy of your data in a structured, commonly used and machine-readable format for your own purposes, or to request us to transfer it to a third party;
  • object to data processing - you can object to our processing of your personal data where we rely on our legitimate interests as the basis for our processing, where your data protection rights outweigh our reasoning for legitimate interests.
  • consent withdrawal - you may withdraw your consent at any time. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

Please note that the rights described above are not absolute, and that your request cannot always be met entirely. For example, sometimes we cannot delete or restrict the processing of your personal data as we may have legal obligations or contractual obligations to keep certain such personal data.

You may request to enforce your data privacy rights at www.abb.com/privacy.

Contact and further information

If you want to access your personal data, make use of any of your other rights mentioned above or if you have any questions or concerns about how ABB processes your personal data, please contact our Group Data Protection Officer at privacy@abb.com, or submit your complaint at www.abb.com/privacy.

Should you not be satisfied with our response or believe we are processing your personal data against the law, you may also have the right to file a complaint with the Data Privacy Authority in your country of residence or work, or seek a remedy through the courts where you believe an infringement of data privacy laws may have taken place.