ANALOG DEVICES GLOBAL DATA PRIVACY POLICY STATEMENT FOR EMPLOYEES, INDEPENDENT CONTRACTORS, CONSULTANTS AND JOB APPLICANTS (Effective April 16, 2008)

This Policy Statement relates to Analog Devices, Inc., and other affiliated companies, collectively referred to as "Analog Devices" or the "company." The policy describes how information about Analog Devices' employees, contractors, consultants, and job applicants is collected, used and disclosed to fulfill the company's business requirements, responsibilities to these individuals, and legal obligations.

What Information Is Maintained

Analog Devices is a multinational family of companies with over 9,000 employees worldwide. Like many multinational companies, Analog Devices maintains an enterprise resource management system that provides immediate electronic communications among locations in different countries. This capability facilitates product development, business planning, compliance with corporate policies, and more efficient administration of human resources and employee benefits programs.

To fulfill its responsibilities as an employer, Analog Devices maintains several types of individually identifiable information for each employee, as illustrated below:

  • Basic information, such as the employee's name; date of birth; nationality and citizenship; social security or social insurance number; education; gender; home address and telephone number; emergency contact information; and photograph.
  • Administrative information, such as internal employee file numbers, job title and department, computer network login and e-mail address, work location and telephone number, dates of hiring/termination, work hours, and leave status.
  • Employment and performance information, such as hiring and recruitment records, performance appraisals and assessments; date of assignments, transfers, and promotions; training records; attendance records; disciplinary actions; and records of work accidents.
  • Compensation and benefits administration information, such as salary or wage data; tax and benefits accounting records; dependent and beneficiary information; benefits enrollment status; and leave records.
  • In accordance with applicable local legal requirements, Analog Devices may hold and process sensitive personal data (including, for example, information relating to ethnic or racial origin, trade union membership, or health condition) for purposes related to your employment.

    The same types of information may be held in relation to other workers of the company, such as independent contractors and consultants.

    In addition, applicants for jobs at Analog Devices will provide personal information in application forms they submit, whether directly to Analog, or to Taleo Corporation for use on Analog's behalf, as part of the company's global online recruitment system. Such information is likely to include details of previous employment and basic information of the type described above. In addition, the company or a third party verification agency on its behalf may undertake background checks on job applicants. The results of those checks, which may include sensitive data in the form of medical reports and/or criminal records, may also be held by the company as part of the recruitment process.

    How Information Is Used

    Analog Devices holds and processes information about employees, contractors and consultants for all necessary and customary business purposes, such as to pay and review compensation; provide and administer benefits; determine your fitness to work for the Company or your entitlement to sick pay or parental or other leave of absence; comply with applicable taxation or other legal obligations; cooperate with law enforcement or other governmental authorities; protect the rights, interests, or property of the Company; administer contracts and other business relationships involving business areas in which you work; administer and maintain personnel records (including sickness or other absence records); carry out performance reviews; make assignment and promotion decisions; conduct disciplinary or grievance procedures; and facilitate compliance with Company policies, industry standards, and legal requirements.

    Information about job applicants will be processed as part of the recruitment process to determine applicants' ability and suitability for the positions for which they have applied.

    How Information Is Disclosed

    Personal information may sometimes be disclosed to third parties in furtherance of the primary employment-related purposes described above, or as otherwise required by law. These recipients may include third parties acting as an agent to perform tasks on behalf of and under the instructions of Analog Devices, such as, for example, payroll processors, benefits administrators, legal advisers, or consultants. Personal information may also be disclosed, as appropriate, to taxation authorities, law enforcement authorities, other regulatory bodies, or potential purchasers or customers of Analog Devices or of a business area in which you work. Information furnished by job applicants may be supplied to verification agencies for the purposes of undertaking background checks. Upon request, Analog Devices may confirm an employee's name, job title, and dates of employment by way of reference or testimonial.

    The multinational reach of Analog Devices' human resources information system means that information relating to employees, contractors, consultants, and job applicants is transferred to and accessible to authorized personnel in the United States and other countries where Analog Devices operates. The privacy laws in your work location may be different from the laws in these other countries. For personal information concerning employees, contractors, consultants, and job applicants located in the countries of the European Union, Analog Devices adheres to the "Safe Harbor Privacy Principles" (http://www.export.gov/safeharbor/). These Principles restrict the use and disclosure of EU-origin personal information maintained in the U.S. Personal information may also be transferred internationally in accordance with applicable privacy laws, under special data transfer agreements, or with the consent of the individual, if required.

    How Personal Information Is Protected

    Analog Devices has adopted policies and procedures to protect information relating to employees, contractors, consultants, and job applicants from loss; misuse; or unauthorized access, disclosure, alteration, or destruction. These measures include administrative, technical, and physical safeguards including restrictions on employee access to human resources databases; password-restricted access; encryption of stored and in-transit data; and locks, where appropriate, on offices, files, and systems containing employee information.

    Access and Amendment of Employee Information

    You have a right to access and correct reasonably available individually identifiable information maintained about yourself, subject to restrictions under applicable local laws and regulations. You may review your file by contacting the Human Resources Representative responsible for your work location. If you notice an error in the information provided, you may request that it be corrected, and appropriate changes will be made.

    Accuracy and Retention of Employee Information

    In order to be useful, information relating to employees, job applicants and other workers must be accurate and up to date. Where possible, information is updated periodically. Other information loses value over time and is periodically deleted, in accordance with applicable local legal requirements.

    Changes to Policy

    Like other company policies, this Policy Statement may be revised periodically to reflect changes in organization, business, or legal changes. Such revisions will apply to information maintained at the time of the change.

    Questions and Complaints

    If you believe that information pertaining to you may have been used or disclosed in an improper manner, or if you have questions about this Policy Statement, please contact your Human Resources Representative for further assistance.

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