January 31, 2017

UTC Modifies Ombuds Program to Comply with French Law

United Technologies Corporation has published a Supplement for its Ombudsman program to explain how it satisfies current the law in France protecting employee privacy. The document offers a rare glimpse into how a multinational, U.S.-based corporation implements a Organizational Ombuds program in another country.   

UTC's Ombuds program is modified in several respects to ensure adequate protections for employees covered by French law. For example, inquiries will be accepted by UTC Ombuds in France only if they relate to one of four specific categories of matters. In addition, UTC Ombuds are strictly limited in the type of personal information that can be "collected or processed." Moreover, the Supplement makes it clear that information and materials will be "deleted or archived within two months."  Nonetheless, UTC asserts that its Ombuds program complies with IOA standards and also satisfies its obligations under the U.S. Sarbanes-Oxley Act to provide employees with a confidential and anonymous feedback avenue.  (UTC Supplement for Ombuds in France.)

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