CWT Responsible Business Report 2012 - Carlson Wagonlit Travel

ContentsChapter 3 - Ethics, Compliance, Data Protection2012 Responsible Business Report -chapter 3Our commitmentto ethical businesspracticesWe are committed to protect thepersonal data of our clients’ travelersCWT global data protection and privacy program forprocessing travel dataCode of BusinessEthics and ConductPrevention of corruptionand anti-competitivepracticesGlobal dataprotection andprivacy programTo provide businesstravel and meetingsand events services toits corporate clients,CWT receives individualdata from the client’s travelers. Forinstance, CWT holds traveler data inthe database of CWT Portrait, CWTProgram Management Center andother global products, as well as itsback-office systems.Laws known as “data protection”or “data privacy” seek to safeguardindividual data and create obligationsfor the collecting and processing ofpersonal data. By collecting andprocessing traveler data for purposesof making travel reservations, CWTmust therefore comply with thesedata protection/privacy laws.CWT has had a Data Protection andPrivacy Program for over a decade(see pages 27-28). The program isreviewed on a regular basis to reflectchanges in the law and in internalprocesses at CWT. The cornerstoneof the program is the CWT DataProtection Policy, published on theCWT global website.There are over 60 countries with dataprotection/privacy laws. CWT musttake into account, in particular, theprovisions set forth in the US SafeHarbor regulations, the Directive ofthe European Commission, the IndianPrivacy Rules, and the laws of Brazil.Other countries, such as Singapore,are enacting new data protection acts.Because of changes in existing lawsand introductions of new laws, CWTregularly reviews its Data Protectionand Privacy Program.CWT has had a Data Protection andPrivacy Program for over a decade.The program is reviewed on a regularbasis to reflect changes in the lawand internal processes at CWT. Thecornerstone of the program is the CWTData Protection Policy , published on theCWT global website.Benedicte Bayi, Vice President & Assistant General CounselCopyright © 2013 CWT26