Privacy Notice
We provide this Privacy Notice to inform you about how your personal data will be collected, processed, and safeguarded by us when you choose to use the “Life@Cook App.” This Privacy Notice is in addition to Cook’s regional employee data protection notices and supplier data protection notices which provide information and guidance to Cook employees and contingent workers regarding their personal data and how it is collected and processed by Cook.
Data Collection
The personal data collected and processed as part of the Life@Cook App as per the Processing Purposes listed below includes name, email address, office building/location, country, job title (if in management), department and feedback/responses provided by you via the available Cook forms (if you choose to submit). Technical information such as device type, IP address, browser type and deidentified analytics on content usage are also collected as necessary for security, maintenance, and support. De-identified information on content usage is gathered on an aggregate basis (i.e it does not track the usage of a particular user) and it is used to provide Cook with valuable insights into the content usage on the Life@Cook App and its reach and engagement. Cook does not request or require you to provide any special categories of personal data (otherwise known as sensitive personal data) via the Life@Cook App. If you inadvertently provide special categories of personal data in your feedback/responses to Cook forms or on posts, Cook will take all reasonable steps to ensure this information is deleted on receipt by Cook.
Processing Purposes
The personal data that we collect is limited to that which is necessary to allow Cook:
- To provide a timely, consistent, and measurable way of communicating with its employees and contingent workers,
- To share corporate information with employees and, where relevant, contingent workers in the form of news and company updates,
- To receive, manage and share employee and contingent worker feedback appropriately using the form functionality and the like functionality on posts, and
- Ensure continued maintenance, support and delivery of the services via the Life@Cook App as well as for ensuring security of the Life@Cook App.
Legal Basis for collection
Our legal bases for processing your personal data depend on your location and are as follows:
| AMER | EMEA | APAC |
| Your Consent | Your Consent | |
| Legitimate Interests as necessary to comply with our legal or regulatory obligations | Legitimate Interests Specifically:
|
Data Sharing
Cook limits access to personal data collected via the Life@Cook App to those with a need-to-know basis based on their role. Cook’s Communications team will moderate any feedback provided through the Life@Cook App. Where there is a need to share information, it will be shared with the appropriate stakeholders confidentially or on a de-identified aggregate basis.
Cook has partnered with Staffbase, a third-party service provider, to provide the Life@Cook App to Cook employees and contingent works and Staffbase supports Cook to configure the Life@Cook App to Cook’s requirements. As is necessary for security, maintenance, and support of the Life@Cook App such as identifying load issues and/or troubleshooting log-in issues, Staffbase may have access to limited technical information outlined above. Cook has worked with Staffbase to ensure that an appropriate data processing agreement is in place between the parties and that an international data transfer mechanism is in place where the data is hosted by Staffbase in the US or other location outside of the European Economic Area.
Data Security
Cook has put in place appropriate technical, physical, and administrative security measures to help prevent unauthorized or unlawful disclosure or access to, or accidental or unlawful loss, destruction, alteration, or damage to the personal data that it collects. These measures are intended to ensure an appropriate level of security in relation to the risks inherent to the processing and the nature of the data to be protected. Staffbase has also committed, as a data processor, to having appropriate technical, physical, and administrative security measures in place.
Data Retention
Cook is committed to retaining personal data collected via the Life@Cook App for no longer than is necessary for its Processing Purposes and will dispose of personal data when it is no longer required in accordance with Cook’s Record Retention Schedule. When assessing the data retention period, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the personal data, the purposes for which we process the personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Individual Rights
In accordance with applicable laws, data subjects will have rights in relation to their personal data such as the right to information, right to correct inaccurate data and the right of access/erasure. For further information on your individual rights and how to exercise them, please refer to the appropriate section the regional Data Protection Notice that is applicable to you (i.e., Cook’s European Data Protection Information Notice or Cook’s U.S. Employee Data Protection Notice that U.S. employees sign upon employment) or https://www.cookgroup.com/global-data-protection-notice-for-suppliers/.
Contact Information
For additional information about Cook’s privacy practices or to exercise your rights, please contact:
For AMER region:
Global Director of Privacy
Cook Group Incorporated
P.O. Box 1608
Bloomington, Indiana 47402-1608
USA
- Phone: +1 812.331.1025
- Fax: +1 812.331.8990
- Email: Privacy@CookMedical.com
For EMEA region:
European Data Protection Officer
Cook Medical
O’Halloran Road
National Technological Park
Co. Limerick
Ireland
- Phone: +353 61 334440
- Email: DataProtectionEurope@CookMedical.com
For the Asia-Pacific region:
Room1503, Ascendas Plaza,
No. 333 TianYaoQiao Road,
Shanghai 200030, China
- Phone: +86-13166399378
- Email: DataProtectionAPAC@CookMedical.com