Confidentiality

1Protecting client information

UGG takes every measure to keep confidential the proprietary information and trade secrets of our clients that we access during assessment activities.

2Declarations and conflicts of interest

1. All assessing staff, including subcontracted assessment personnel and technical experts, and members of the Impartiality Committee sign the Impartiality and Confidentiality Declaration Form (UGG-FM(MSPO)-01A and 01B). They agree to abide by UGG's confidentiality and impartiality requirements and will not release any information, directly or indirectly, other than what the client authorises or the law requires.
2. They inform UGG of any conflict of interest from the previous two years and take no part in assessment activities or certification decisions where one exists, unless there are exceptional circumstances approved by the Managing Director. A conflict of interest may arise through, but is not limited to:
   1. Previous employment
   2. Previous business interests
   3. Family interests

3Handling records

1. The Administration Manager makes sure that clients' confidential information, data and records kept in the office are access-controlled. All staff handle this information with the utmost care.
2. Auditors return management system documents to the client after the documentation review. While those documents are in our office for review, they are treated as confidential.
3. At the opening meeting of every assessment visit, auditors assure the client that all proprietary information and trade secrets gathered during the assessment are treated as strictly confidential.
4. Hard-copy client records are destroyed when they are no longer required.

4Release only with consent or where the law requires

No information, data or records are released to an external party without the client's prior consent. Where the law requires us to release information to a third party, the Operation Manager writes to the client officially about the information provided.