12. Personal Data Protection
Hyundai is committed with the privacy of its customers, partners, service providers and employees, and respects the privacy and data protection laws and regulations that govern the processing of personal data, in particular the General Data Protection Law (Law number 13.709/2018 – “LGPD”).
Hyundai takes all necessary measures to make its data processing activities compliant with the standards set by the LGPD, and requires its partners and service providers to take equivalent measures. Personal data must always be processed only to the extent necessary to achieve a legitimate and legally authorized purpose. Any personal data processing activity carried out by Hyundai or on behalf of Hyundai must occur only if there is a legal basis that justifies it and with adequate security measures. If you have any doubts about the legality of any personal data processing activity, please contact the DPO through the email dpo@hyundai-brasil.com.
The LGPD also establishes the rights that people can exercise over their personal data, such as the right of access, correction, anonymization, blocking, deletion, revocation of consent, portability, information, opposition and confirmation of the existence of treatment. Hyundai’s internal and external processes have been designed to respect these rights, and any new process or project developed by Hyundai must take into account the need to comply with these rights. Likewise, whenever there is processing of personal data on behalf of Hyundai by partners or service providers, they must guarantee the same rights to the data subjects.
Whenever it is necessary to share personal data controlled by Hyundai with third parties, a specific contractual provisions to address the rules applicable to the personal data processing activities that will be carried out by the third party, must be formalized through an Attachment or Data Protection Agreement (“DPA”), or through personal data protection contractual clauses in the main contract. Among other safeguards, the document must provide, at least, confidentiality obligations in relation to such personal data, limitations on processing activities, and obligations to implement appropriate administrative, technical and organizational measures to prevent security incidents or any other undesired episode related to personal data shared by Hyundai.
The processing of personal data by Hyundai, its service providers and partners, as well as any possible transfer of this data must always be done with maximum security and in compliance with the laws and regulations in force. Among the various internal processes established to ensure such practices, Hyundai establishes, for example, minimum conditions for the processing of personal data, information security standards, technical standards, periodic training to understand and comply with obligations in relation to personal data protection, allocation of responsibilities and obligations to all employees, partners and service providers involved in processing activities, educational actions, internal mechanisms for supervision and mitigation of risks, procedures for responding to security incidents, among others.
A person in charge of Hyundai’s personal data processing activities (DPO) has been appointed, under the terms of the LGPD, who will act as a communication channel on the processing of personal data between Hyundai, the data subjects and the National Data Protection Authority (ANPD). In addition to external communication activities, the DPO shall be Hyundai’s focal point for all inquiries from employees, partners or service providers regarding the protection of personal data.
ALL HYUNDAI EMPLOYEES, DELAERS, PARTNERS AND SERVICE PROVIDERS ARE RESPONSIBLE TO ENSURE THE PROTECTION OF PERSONAL DATA.
In Pratice:
Allowed:
Understand and comply with national and international laws and regulations, as well as the above guidelines and other company policies, regarding the protection of personal data;
Have all your department’s personal data processing activities mapped and aligned with the Data Protection team;
Be extremely aware of and take appropriate action when collecting, processing, using, disclosing, storing and transferring personal data, giving them treatment of personal information;
Consider the purpose for which data can be used before collecting the data and inform the data subject of each of these relevant purposes when collecting the data;
Pay attention to the processing of personal data in the recruitment processes of new employees: (i) delete excessive personal data as soon as possible, when identified; (ii) collect sensitive data (such as a photo, data on racial or ethnic origin, religious conviction, political opinion, membership of a trade union or organization of a religious, philosophical or political nature, data relating to health or sex life, genetic or biometric data) only when strictly necessary, and delete them as soon as they are no longer needed; (iii) ensure that, in case of recruitment through third parties (such as employment platforms or headhunters), a DPA or data protection clause is formalized with these third parties;
When a data subject claims any of his rights guaranteed by the LGPD, instruct him to send his request to dpo@Hyundai-brasil.com;
Participate in periodic trainings provided by Hyundai on personal data processing, good practices and security;
Follow the Security Incident Response Policy and immediately notify the DPO at dpo@Hyundai-brasil.com, in the event of unauthorized disclosure/access or leakage of personal data, as well as in case of suspected personal data breach;
Ensure that all third parties processing personal data for Hyundai have signed the Attachment or Data Protection Agreement (“DPA”), are located in a country that provides an adequate level of data protection, or that there is a level of sufficient security to ensure that personal data is processed at least in compliance with the LGPD.
Keep in mind that Hyundai’s compliance with LGPD depends on a collective effort – we count on your collaboration!
Not allowed:
Do not collect, process, use, disclose or store personal data other than for legitimate purposes that require it and still inform the persons whose data are being obtained;
Do not use personal data for a purpose that was not communicated to the owner at the time the data was collected;
Do not collect or register sensitive personal data (racial or ethnic origin, sexual orientation, religion, health status, genetic data, etc.) unless absolutely necessary and, in this case, redouble your care in handling this data;
Do not transfer personal data to third parties without thinking and considering the requirements of this Code of Ethics and Conduct and the law.
Prezada Família Hyundai,
Nossas ações, individuais e coletivas, são cruciais para que a Hyundai mantenha sua excelência e compromisso em produzir os melhores veículos, oferecer as mais modernas soluções em mobilidade e prover o melhor atendimento aos nossos clientes.
Para abraçar e reforçar este compromisso, criamos a mentalidade de UM SÓ TIME, UMA SÓ VOZ, em que todos são responsáveis pelos resultados da empresa, não só em termos de lucratividade,mas de valores éticos e de integridade, visando a longevidade e a prosperidade da presença da Hyundai nos mercados do Brasil e das Américas Central e do Sul.
E é com este espírito de UM SÓ TIME, UMA SÓ VOZ, que tenho a satisfação de apresentar a nova versão do nosso Código de Ética e Conduta da HMCSA, um dos principais pilares que sustenta nosso Programa de Ética e Compliance.
Todos nós, colaboradores, concessionárias, fornecedores, prestadores de serviço e demais parceiros de negócios da Hyundai, temos que estar fortemente comprometidos em seguir os princípios deste Código de Ética e Conduta e usá-lo como guia para as nossas ações e decisões em nome e em benefício de nossa empresa e da marca Hyundai
Contamos com a colaboração de cada um de vocês para juntos, como um único time e com uma única voz, agirmos em unidade para alcançarmos nossos objetivos, sempre seguindo os mais elevados padrões de ética e integridade!
Obrigado
