Privacy Notice Customer Screenings

Last updated: 30 April 2020

Koninklijke Philips N.V., including its affiliates (“Philips”), wants you to be familiar with how we collect and use your personal data in the context of our customer due diligence process (the “Initiative”).

What Personal Data will be collected?

“Personal Data” is data that identifies an individual or relates to an identifiable individual.

In this Initiative, we will collect: names and aliases, date of birth, nationality, copy of passport (or other valid photo ID), contact details (residential/business address/ email address), current job title, current and prior directorships, information about ownership of a company, current and prior shareholdings, pending bankruptcy proceedings, bankruptcy declarations, information on being barred or suspended from contracting with any government (optional), criminal offense data (optional), information on being linked to the government or a state owned company, public profiles, previous or ongoing political affiliations, history of sactions or barring by international regulatory agencies, international blacklists, government blacklists and potential previous employment with Philips.

How is Personal Data collected?

We and our service providers collect Personal Data by means of the Standard Data Request Form (SDRF). This relates to data that you provide to us yourself. In addition, we may collect and process Personal Data from publicly available information from databases and search engines. If you disclose any Personal Data about people to us or to our service providers in connection with the Initiative, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Notice.

What is the purpose of the collection of Personal Data?

We and our service providers will use Personal Data only for our legitimate business purposes and to comply with applicable law and to protect our rights. Philips has a legal obligation to perform a third party screening, to verify the identity of third parties it deals with and to identify and mitigate the risks associated with such dealings.

Our legal basis for processing your Personal Data

It is in our legitimate business interest to process your Personal Data, and necessary for doing business in a responsible and ethical manner. The screening process is essential for Philips in its efforts to fully comply with local and international anti-bribery and anti-corruption laws, corporate laws, international and local export-import controls and sanctions and local and international fraud related laws and regulations. The DDP also ensures that Philips identifies any risks associated with engaging a third party, and is able to mitigate these risks, or decide that the third party should not be engaged in the risk is too high.

How long will the Personal Data be kept?
We will retain your Personal Data for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; or (iii) whether retention is advisable in light of our legal position.

With whom is Personal Data shared?
We will disclose your Personal Data only in limited cases described here. If it is necessary for achieving the purposes described above we may disclose your data to the following recipients: 1) Philips’ affiliates and employees, 2) our trusted third party service providers who provide services in relation to the Initiative, 3) public and governmental authorities (when required by law) and 4) our professional advisors.

Cross-border transfer
Due to our global nature, data you provide to us may be processed in several countries. Where required, we have put in place the legally required adequate measures, such as our Binding Corporate Rules and/or standard contractual clauses to protect your Personal Data.

Security
We seek to use reasonable organizational, technical and administrative measures to protect Personal Data within our organization.

Privacy rights
If you have any questions about this Privacy Notice, about the way Philips uses your Personal Data or if you would like to exercise your privacy rights (such as the right to access, delete, rectify your data), please contact our Data Protection Officer via our webform.

If you are not satisfied with Philips’ response or believe that your Personal Data is not being processed in accordance with law, you may contact or lodge a complaint with the competent data protection authority or seek other remedies under applicable law.