Safeguarding Employee Information
We value our employees’ personal information. We try to limit the personal information we collect and use about employees to information necessary to fulfill our legitimate legal or business objectives, and we take steps to ensure our information practices comply with all applicable laws. In addition, we limit disclosure of confidential employee records or personal information outside of Realogy, except as authorized by the employee, to fulfill a legitimate purpose, or as permitted or required by law, regulation, subpoena or order issued by a court or tribunal of competent jurisdiction. Employees with access to confidential employee records bear a special responsibility to avoid unauthorized disclosure of confidential information in those records. This duty of confidentiality, however, does not prohibit you from disclosing or discussing your own wages, hours or other working conditions.
Safeguarding Client and Customer Information
We also value our customer and client information and comply with all laws that apply to its collection, use and disclosure. We strive to protect the confidential information of our clients and customers and safeguard their confidential personal information against unauthorized access, use or disclosure. We will consult our Legal department with any questions about the use and handling requirements of our customers’ and clients’ confidential and personal information.
“Personal information” is a broad term for any information that uniquely identifies an individual. Examples of personal information include an individual’s name, birthdate, email address, telephone number, home address, government-issued identification number, payment card numbers, financial account information or even a persistent identifier (e.g., customer number) held in a cookie or a processor serial number. Certain demographic information, including gender, education or political affiliation, when combined with personal information, also becomes personal information. Laws governing the definition and treatment of personal information vary by jurisdiction.
For questions about how to handle personal information, refer to Realogy’s Information Management Policy and Information Security Policy for a full explanation of personal information, examples and handling requirements.
Are we required to maintain all personal information as “confidential”?
Personal information is a broad term for information related to a person. As a service provider, we may be required to use and disclose (even advertise) personal information, such as contact information, for our clients and customers. But we must always be mindful when using personal information that laws around the world may impose restrictions on our collection, use and disclosure of personal information. You should consult the Information Management Policy for more detail on your use of personal information in performing your job.
In the U.S., certain categories of personal information must be treated with heightened sensitivity to protect the privacy and identity of our customers and employees. Examples include an individual’s name, plus any of the following data elements: (1) Social Security number; (2) payment card information; and (3) medical or health information, to name a few. We maintain the confidentiality of this information for all customers, clients and employees.
Protecting Confidential Information
In addition to employee and client information, your job may also give you access to other confidential information that belongs to Realogy. This information must be safeguarded and you may not share it with anyone including your family members, unless authorized by Realogy. Realogy’s confidential information belongs to the company and cannot be used for your own benefit or the benefit of any party other than Realogy, either during or after your employment. If you leave the company, you must return all materials containing confidential information to Realogy. Refer to Realogy’s Information Management Policy, which further defines confidential information.
Additionally, do not share or use confidential information from your prior employers for Realogy’s benefit.
None of our policies or practices, including the confidentiality obligations discussed above, is intended to or will limit, prevent, impede or interfere with an employee’s right, without prior notice to Realogy, to provide information to the government, participate in investigations, testify in proceedings regarding Realogy’s past or future conduct, or engage in any activities protected under whistleblower statutes.
Information that is restricted from the public. Confidential information includes materials that you may regularly encounter in your work, such as vendor pricing information, sales data, franchisee or client lists, client financial information, unannounced products or services, or unreleased marketing materials. It also includes more sensitive information, which requires greater protections, like non-public financial information, company secrets and significant projects such as proposed acquisitions or the sale of company assets or divisions.
Data or facts in any form (printed or electronic) received or generated by or on behalf of Realogy.
As an employee…
Only share Realogy’s confidential information with those who have a legitimate business reason to know and are authorized to receive it.
I will not:
Use Realogy’s confidential information in my employment with another company.
|Avoid discussing confidential information in public areas where it may be overheard.||Share confidential information from my former employers with Realogy.|
|Safely store and dispose of confidential information according to the Information Management Policy.||Solicit confidential information about another company from employees, clients, customers or vendors.|
Diligence in Information Security
Our company’s confidential information must be kept secure, whether in paper or electronic format. As an employee, you are a caretaker of confidential information and you should take steps to ensure that all confidential information is handled securely, including hardcopy records as well as all devices and software that are used for Realogy business or to store confidential information, such as computers, cell phones and smart phones (often called Realogy Information Technology Resources). We are all responsible for keeping passwords secure, not sharing them with others and immediately reporting any unauthorized access or loss of information to the Ethics & Compliance and Information Security departments. We do not permit any person to attempt to destroy, circumvent, compromise or undermine Realogy systems, security measures or audit measures. You may not access, modify, remove or destroy files, data or systems without the authority to do so.
We maintain an Information Security Policy that identifies how employees must maintain information. Our Secure Work Environment Policy provides additional information about how information must be maintained within your workspace.
Sound Information Management
We are each responsible for the information that we create, possess, collect, use and manage on behalf of Realogy. This responsibility requires each of us to use common sense and professionalism in the content we create. To that end, you should retain all information under your control, whether in paper or electronic format, consistent with Realogy’s Information Management Policy. You may not destroy any information that is potentially relevant to any pending, threatened or foreseeable litigation or investigation (whether internal or external) related to a violation of law, the Code of Ethics or company policy.
When I am on vacation, my coworker often needs access to certain systems using my password. Can I provide the password in this situation?
No. Your department should have procedures in place to address work coverage for any employee who is out of the office, which may include designating a delegate access to certain systems during your time out of the office. Sharing your password with another employee, while well-intentioned, is never the right way to ensure that business continues as usual in your absence. Report any password-sharing violations to the Ethics & Compliance department.
REALOGY INFORMATION TECHNOLOGY RESOURCES
Refers to, but is not limited to, networks and servers, desktop PCs, laptops, personal digital assistants (PDAs), mobile phones, smart phones, printing devices, telephones, facsimile machines, voice mail and any other electronic device capable of storing or transmitting information, including email, instant messaging and Internet access provided by Realogy. The software installed on such devices and resources is also included. The term also refers to non-Realogy host or server computers, stand-alone computers, laptops and any other communication devices, software, data files and networks when used to perform Realogy business.
Under the Defend Trade Secrets Act of 2016, an employee will not be held criminally or civilly liable under trade secret laws for disclosing a trade secret in confidence to a government official or an attorney for the sole purpose of reporting or investigating a violation of law. Employees may disclose trade secrets in a complaint or other document filed in a lawsuit (or other proceeding), if the filing is made under seal. And, an employee alleging retaliation for reporting a suspected violation of the law may disclose a trade secret to his or her attorney and use the trade secret in court proceedings, if the document containing the trade secret is filed under seal and the employee does not otherwise disclose the trade secret, except under court order.