DEFINITION OF PERSONAL DATA & CATEGORIES – STATUS 24 JAN 2018

“Personal Data”: means any information relating to an identified or identifiable private

individual (“Data Subject”).
An identifiable private individual is one who can be identified, directly or indirectly, in
particular by reference to an identifier such as a name, an identification number, location
data, an online identifier or to one or more factors specific to the physical, physiological,
genetic, mental, cultural or social identity of that private individual.
Personal Data includes Personal Identifiable Information (PII) as defined by US law.
Data Subjects can be our employees, contractors, temporary workers, students and trainees,
applicants, as well as individuals employed or engaged by customers, distributors, partners
and vendors.

Guidance: when Personal Data is anonymized and aggregated without reference to the
individual Data Subjects, this information no longer qualifies as Personal Data, with the
exception that the keys to revert back to the Individual Data need to be carefully controlled by
the data owner and with the caution that the aggregated information may require special
protection and handling pursuant to our Safeguarding Sensitive Information Policy.

Below are a number of examples of Personal Data classified in accordance with the
Safeguarding Sensitive Information Policy.

SENSITIVITY DESCRIPTION EXAMPLES

RESTRICTED
Can only be used Sensitive Personal Data Data concerning physical and mental health,
for strictly In certain countries or conditions or treatments; disability data; medical
defined, justified regions, processing of records; protected health information (PHI, as
business such sensitive Personal defined by HIPAA)
purposes. Can Data may be Data revealing racial or ethnic origin, political
only be accessed prohibited, may be affiliation or opinions, religious or philosophical
and processed by subject to special beliefs, trade union membership
a limited number regulations and/or may Genetic data; biometric data for the purpose of
of specifically be subject to explicit uniquely identifying a Data Subject
designated consent of the Data
people. Can only Data concerning a Data Subject’s sex life or sexual
Subjects.
be shared by or orientation
Guidance: even if an
after approval of Judicial data: data relating to criminal or
individual may disclose
the data owner. administrative convictions, offences and related
or share some of this
Requires tracking security measures; criminal background checks
information (eg. in an
of the disclosure affinity group), we will
and use of the
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data. use this information

Require highest discretely in line with
level of our values of integrity
protection and
strict retention/
destruction rules
National Identifiers; Social security numbers, national identification
national and other numbers and other government-issued identifiers
security related Passport numbers
information Driver license numbers
Individual security clearance information (eg.
obtained from authorities to be authorized to
enter certain restricted facilities)
Individual username, password and access codes
information
Employee monitoring Information and records obtained in the context of
and investigation data monitoring employees and contractors (eg. for
physical or information protection reasons; for
fraud detection purposes; for verification of
compliance with Rockwell Automation policies)
Information and records obtained in the context of
investigations of employees and contractors (eg. in
the context of an Ombudsman investigation; for
verification of compliance with Rockwell
Automation policies)
Sensitive financial data Individual bank accounts details; payment and
credit history; financial transactions data
concerning Data Subjects; charitable donations
Customer credit card information

CONFIDENTIAL
Can only be Confidential Job/HR Salary, compensation and benefit data; company
processed for related Personal Data pension scheme information
justified business provided to or Performance evaluation data; designations and
reasons and generated by the information relating to leadership potential,
shared on a company succession planning and promotion or other job
“need to know” Guidance: even if some opportunities readiness
basis; require of this information may
reasonable be publicly available,
privacy risk we will use this
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management and information discretely Private home address and contact information;
protection and confidentially personal phone numbers; personal e-mail and IP
measures Guidance: even if some address; emergency contact details
of this information may Gender; birth year, age and place of birth; marital
be provided by an and parental status; family situation; data about
individual to you, this spouse, children and other dependents in relation
does not allow you to to our employees (note: in certain circumstances
freely share this this information may reveal Restricted
information and you Information) ; nationality; personal tax class
are expected to use this Job level, ID, band and code (job catalogue)
information discretely Work permit, visa application and relocation
information (other than restricted information)
Detailed attendance records
Company car fleet management data
Business travel and expenses (T&E) data; travel and
geo-location information
Data provided by job applicants
Skills, experience, education, grades and
certifications gained or obtained during and prior
to employment with Rockwell Automation (other
than language skills, official certifications and
professional memberships)
Military and veteran status
Employee Assistance Program information (other
than Restricted Information, such as mental and
emotional health)
Images captured by video surveillance at work;
telephone call recordings at or related to work
(subject to possible more restrictive requirements
of local telecommunication laws); entry badge
picture; pictures taken or provided for company
organizational purposes (to the extent these do not
reveal Restricted Information, eg. biometric data)
Logs relating to the use of company IT and
communication infrastructure or tools (subject to
possible more restrictive requirements of local
telecommunication laws)
Other confidential Dietary preferences (unless this information
personal data reveals medical, ethnic or religious Restricted
Information)
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Profiling, cookies information and call recordings

concerning Data Subjects working for customers

INTERNAL
Can be used Business related Name of the Data Subject (employees of company,
internally in the contact information as well as of customers, vendors, partners and
company for Guidance: the use of other third parties)
normal business business contact Work address, work e-mail, telephone and mobile
reasons. External information of our phone contact details; business card info of the
disclosure only customers for external Data Subject (employees of company, as well as of
for usual business purposes may be customers, vendors, partners and other third
reasons and may subject to ant-spam, e- parties)
require marketing and e-
confidentiality privacy regulations
undertakings by Guidance: even if some
the third party of this information may
recipient be or become publicly
available, we will not
make this info public
without involving the
affected person
Rockwell Automation Job and position title; reporting lines; direct
internal organizational reports; business, plant, department or functional
designations and association; work location
information relating to Language skills; official certifications; professional
its employees memberships
Information on company training followed
Employment start date, career and seniority in the
company; service anniversaries; month and day of
birth; recognition information shared on BRAVO
Internal employee number; SAP ID; cost centre;
company entry badge identification number
Other employee information legitimately made
available on RAIN
Statements of out of office or absence (eg. for
travel, holiday or medical reasons, provided that
details of the absence may qualify as restricted (eg.
details on the health condition) or confidential (eg.
travel details))