7.9 Confidentiality Policy



Policy brief & purpose

We designed our company confidentiality policy to explain how we expect our members to treat confidential information. Members will unavoidably receive and handle personal and private information about clients, partners, and our company. We want to make sure that this information is well-protected.

We must protect this information for two reasons. It may:

  • Be legally binding (e.g. sensitive customer data.)

  • Constitute the backbone of our business, giving us a competitive advantage (e.g. business processes.)

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Scope

This policy affects all employees, members including board members, investors, contractors, and volunteers, who may have access to confidential information.

Policy elements

Confidential and proprietary information is secret, valuable, expensive, and/or easily replicated.

Common examples of confidential information are:

  • Unpublished financial information

  • Data of Customers/Partners/Vendors

  • Patents, formulas, or new technologies

  • Customer lists (existing and prospective)

  • Data entrusted to our company by external parties

  • Pricing/marketing and other undisclosed strategies

  • Documents and processes explicitly marked as confidential

  • Unpublished goals, forecasts and initiatives marked as confidential

Members may have various levels of authorised access to confidential information.

What members should do:

  • Lock or secure confidential information always

  • Shred confidential documents when they are no longer needed

  • Make sure they only view confidential information on secure devices

  • Only disclose information to another member when it is necessary and authorised

  • Keep confidential documents inside our company’s premises unless it is necessary to move them

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What members should not do:

  • Use confidential information for any personal benefit or profit

  • Disclose confidential information to anyone outside of our company

  • Replicate confidential documents and files and store them on insecure devices

When a member ceases membership or stops working for our company, they are obliged to return any confidential files and delete them from their personal devices.

Confidentiality Measures

We will take measures to ensure that confidential information is well protected. We will:

  • Store and lock paper documents

  • Encrypt electronic information and safeguard databases

  • Ask members to sign non-compete and/or non-disclosure agreements (NDAs)

  • Ask for authorisation by senior management to allow members to access certain confidential information

Exceptions

Confidential information may occasionally have to be disclosed for legitimate reasons.

Examples are:

  • If a regulatory body requests, it as part of an investigation or audit

  • If our company examines a venture or partnership that requires disclosing some information (within legal boundaries)

In such cases, members involved should document their disclosure procedure and collect all needed authorisations. We are bound to avoid disclosing more information than needed.

Disciplinary Consequences

Members who do not respect our confidentiality policy will face disciplinary and, possibly, legal action.

We will investigate every breach of this policy. We will terminate any member who wilfully or regularly breaches our confidentiality guidelines for personal profit. We may also have to punish any unintentional breach of this policy depending on its frequency and seriousness. We will terminate members who repeatedly disregard this policy, even when they do so unintentionally.

This policy is binding even after separation of employment or membership.

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