POSCO E&C is a trustworthy win-win partner that forms stable industrial ecosystem.
Strategy for Shared Growth
Five Major Brand Programs
POSCO E&C operates various win-win growth programs to foster substantial mutual cooperation with its small and medium-sized Enterprises business partners, categorizing its major initiatives into five key brands.
Process
Establishment of "fair trade culture" by protecting the rights and interests of subcontractors and operating a fair trade compliance program
Use of standard subcontract agreement recommended by the Fair Trade Commission
Immediate reflection of amendments to the Fair Transactions in Subcontracting Act and standard subcontract agreement
Time of first introduction
Construction: December 27, 2017
Equipments/materials/services: April 5, 2019
Subcontract Win-Win Cooperation CommitteeNewly established 2020.04
Able to quickly and amicably resolve disputes between the field and partners through
company-wide decision-making
- Establishment of win-win cooperation procedure regarding dispute settlement
- Partners are able to directly apply for dispute settlement in case of a conflict
Compliance Program (CP)Implementation Date: 2003.07
A comprehensive internal compliance system established and operated by the company to ensure adherence to fair trade regulations, encompassing training, oversight, and monitoring.
POSCO E&C CP Framework
POSCO E&C has established a systematic Compliance Program (CP) for the effective prevention, detection, and response to legal risks. We adhere to the 8 core elements recommended by the Korea Fair Trade Commission (KFTC) and operate a dedicated Compliance Council.
8 Core Requirements of the CP
① Establishment and implementation of CP standards and procedures
② Commitment and support from top management
③ Appointment of a Compliance Officer to oversee CP operations
④ Development and utilization of a Compliance Manual
⑤ Provision of continuous and systematic compliance training
⑥ Establishment of an internal monitoring system
⑦ Disciplinary actions against employees violating fair trade laws
⑧ Effectiveness evaluation and continuous improvement measures
Compliance with the Four Major Action Items between Large and Small-Medium EnterprisesImplementation Date: 2009.09
The Four Major Action Items
① Guidelines for Contract Execution
② Guidelines for the Selection and Operation of Partner Companies
③ Guidelines for the Establishment and Operation of an Internal Subcontract
Review Committee
④ Guidelines for the Issuance and Retention of Documents
Incorporation into Contract Procedures: Reflected directly in the company's contract administration workflows and procedures.
Win-Win
Operation of "win-win-based bidding system" to ensure fair profits for partners
Operation of the Appropriate Price Bidding SystemIntroduction of 2020.04
A system introduced to address issues such as quality deterioration and safety
accidents caused by bleeding competition.
It aims to foster win-win cooperation with subcontractors facing difficulties due to
the downturn in the construction economy and rising raw material prices, by
abolishing the lowest bid system.
Operation overview
Sets a baseline "appropriate price amount" and excludes bidders who submit bids below this threshold. The bidder with the bid closest to and just above this baseline is selected as the successful contractor.
Case of "XX site" Window construction (budget : KRW X billion; the set lowest
price: KRW 1.1 billion)
Company A would have won the contract; however, through the
application of the appropriate price system, Company C was selected as the
successful bidder by filtering out abnormally low bids.
| Cateogry | Company A | Company B | Company C | Company D | Company E |
|---|---|---|---|---|---|
| Bidding amount (KRW 100 million) | 9 | 10 | 12 | 13 | 15 |
Bid System of Market Price CompetitionIntroduction of 2017.09
Exclusion of Lowest-Price Bidding & Application of Market Price Competitive Bidding: To ensure win-win cooperation with subcontractors, the lowest-price bidding system is excluded for interior architecture, landscaping, and wallpapering work types in steel mill projects and architectural projects, and the Market Price Competitive Bidding System is applied instead. Exclusive Bidding for Local Enterprises: In particular, among steel mill projects, certain work types are restricted exclusively to local enterprises (in Pohang, Gwangyang, and Suncheon) to foster mutual cooperation with regional partner companies.
Operation overview
Among the bidders within the budget, the bidder closest to the market price* is
selected as the successful bidder.
* [(average of
bidders within budget + order budget) ÷ 2] x (93%–97%)
Case of "XX site" mechanical construction (budget: KRW X billion; market
price: KRW 2.68 billion)
Company A would win the bid when the
lowest price is applied; however, Company C became the successful bidder with the
application of the market price.
| Category | Company A | Company B | Company C | Company D | Company E |
|---|---|---|---|---|---|
| Bidding amount (KRW 100 million) | 24 | 25 | 27 | 28 | 29 |
Proposal-based Bidding System Operation Newly Established in 2026.07
· An innovative bidding system that moves away from price-centric evaluations by
accepting diverse proposals from partner companies and comprehensively evaluating
both their capabilities and pricing.
· Selects the optimal contractor by reflecting site-specific needs across areas such
as safety, quality, schedule (construction period), and design innovation.
· Applied to High-Risk, High-Complexity Work Types: Targets work types with high
impact on safety, quality, schedule, and design (initiated by the site).
Operation Overview
The successful bidder is selected based on the highest combined score: Proposal Evaluation (50%) + Price Evaluation (50%)
| Proposal Evaluation | Average score given by evaluation committee members through a blind review process (excluding the highest and lowest scores). |
|---|---|
| Price Evaluation | Scores are converted in proportion to the bidding rate relative to the 1st-ranked amount that meets the appropriate price baseline amount. |
Note: Evaluation weightings and items may be adjusted depending on site conditions and work characteristics.
Evaluation Committee
Composed of a total of 6 to 8 members, including Site representatives (within 50%), Related departments (technology, estimation, etc.), and the Procurement department
Purchase Preferential System for Social Enterprises & Companies of Persons With DisabilitiesIntroduction of 2020.07
Expansion of trade with society-friendly companies to participate in solving social problems and go beyond creating economic profit in the purchasing process
Society-Friendly Companies
A concept independently defined by POSCO Group by compiling companies related to social problem-solving
Benefits
Preferential registration and bidding, fee reduction
| Category | Details |
|---|---|
| Preferential evaluation for new registration | Additional 10 points are given when evaluating new registrations |
| Preferential bid price evaluation | 5% preferential treatment when evaluating the bid amount (orders with a budget of less than KRW 1 billion) |
| Reduction of contract deposit | 5% reduction of contract deposit (10% → 5%, preferential level for excellent companies) |
| Shortening the payment period | Shortening the payment period (tax invoice issuance +50 → 15 days) |
Operation of "financial support system" to enhance the financial liquidity of partners
Shared Growth/ESG FundIntroduction of 2011.06
Low-interest loan assistance for subcontractors by establishing a Shared Growth Fund of KRW 52 billion with Woori Bank starting in June 2011
1% to 2% preferential rate compared to market interest rate
Target and period
- Target : Regularly registered partners of POSCO E&C - Limit and Term : KRW 500 million per year (extendable in 1-year increments if registration is maintained) - Application and Repayment : Available any time / Early or lump-sum repayment at maturity * Note: A fee applies for early repayment
Win-Win LoansIntroduction of 2018.06
- Concluded an MOU with Korea Commission for Corporate Partnership and financial
institutions for financial support for the first time in the construction
industry
* June 2018
(Shinhan Bank), August 2020 (Hana Bank)
- Signing a contract with POSCO E&C makes it available for a partner to borrow money and reduce interest costs
Target and period
- Target : Officially registered partners of POSCO E&C (contracts in KRW, with a contract period of at least 6 months and before 50% of the contract period has elapsed) - Limit and Term : Within the contract period, up to 100% of the contract amount (considering deductions for paid advances, interim payment limits, and credit rating) - Repayment Method : Installment repayment (deduction from interim payments) or full repayment at maturity
Empathy
"Creating a happy workplace” by operating a welfare system to build a sense of unity with subcontractors
Support for Funeral Supplies for Employees of PartnersIntroduction of 2019.01
Target: Employees of PHPs and employees of partners working at a POSCO site and
their lineal ascendants and descendants and spouse.
Item: Funeral supplies engraved with POSCO logo (12 items, including bowls,
paper cups and plates, for 500 people)
Selection process
-
Occurrence of bereavement
-
Field manager of the partner
-
Person in charge of construction in POSCO
-
Person in charge of win-win cooperation in funeral goods companies
Documents to be submitted
Funeral supplies application form, employment certificate, national pension or health insurance subscription certificate
Rewarding Excellent Employees of PartnersIntroduction of 2017.12
Selection process
-
Selection of top partners in performance evaluation
-
Recommendation of outstanding employees from partner companies by the business division
-
Confirmation of excellent employees
Reward and prize
Certificate of commendation and gift certificate worth KRW 1 million
The
selected partner is given 1 additional point in the comprehensive performance
evaluation.
Establishment of standards for the installation of on-site sanitation and rest facilities
1) Contract conclusion
2) Selection/management of partners
3) Establishment/operation of internal deliberation committee on subcontract
4) Issuance and preservation of written forms
* Reflecting
four major practices in contract work procedure
"Creating a Happy Workplace" that communicates and empathizes with partners and workers
Operation of Field Workers' Opinion ChannelIntroduction of 2019.05
Establishment of a mobile communication channel to report workers’ inconvenience,
matters to be improved, and unfair treatment
* Scan the QR
code, log in to the "Field Workers Opinion Channel" in the "POSCO E&C Report &
Consultation Center" and register opinion
Transfer Fee Support for "Nomubi.com“Introduction of 2021.06
Introduction of a proactive payment arrear prevention system to prevent wage delays
and fund misappropriation by workers of subcontractors (Nomubi.com, since
2016).
Provision of support by waiving Nomubi.com transfer fees for. partners
- Target : Small and medium-sized partners doing business with POSCO E&C (excluding
middle-standing enterprises)
- Method of Support : Automatic fee waiver within the Nomubi.com system
※ Nomubi.com
Payment Process (Primary Contractor → Workers' Accounts)
1. Preparation of Billing Statement
2. Review of Billing Statement
3. Disbursement of Progress Payment
4-1. Transfer (Labor Costs, Equipment Costs, Material Costs
4-2. Transfer (Other Costs)
5. Review of Payment Details
Share
Expansion of the "Performance Sharing System" to share technology and performance by resolving issues at construction fields
Performance Sharing SystemIntroduction of 2008
How to make a proposal of technology
1) Good ideas from partners can be proposed at any time through the "Win-Win Cooperation Technology Suggestion Center" (http://winwin.poscoenc.com)
2) Excellent ideas from partners that are creative and can be applied to the field are selected by holding the "Technology Cooperation Contest"
Annually 1-2 times
Announcements made in advance on the POSCO E&C website
and partner portal
Submission of ideas following the announcement of required topics by POSCO
E&C
- Topics related to new businesses such as nuclear energy, secondary
batteries, offshore wind power, hydrogen, etc.
- Topics related to new
technologies and methods such as cost reduction,
construction period
shortening, and safety/environmental improvements
For partners selected for excellent ideas,
upon proving performance through joint technology development,
incentives
such as unit price contracts, Private contracts, and joint patent applications
will be provided.
Coexistence
Operation of the "Shared Growth Support Team" for coexistence with partners by providing support in the necessary areas
Shared Growth Support TeamIntroduction of 2019.08
Overview
The Shared Growth Support Team helps SME partners to improve their safety, skills and job competency through a two-track system, one being a support team using POSCO E&C’s capabilities and infrastructure and the other being a support team tailored to partner needs.
Support target
PHPs and SME partners who wish to participate in the program or have been recommended internally.
Program
- Training : Offering capacity-building training in areas such as new business, safety, and quality (including mandatory Safety Academy courses and training for areas needing improvement). - Consulting : Providing complimentary consulting and system establishment support using external organizations (for example, safety diagnostics and ready-mix concrete vehicle management systems).
Operation method
[Track 1] POSCO E&C organizes a support team and matches partners to the program by selecting them or receiving their applications. [Track 2] POSCO E&C listens to the needs of partners and matches them to our own program or outside entities.
100% Cash Payment of Subcontract Amount
To secure cash liquidity and foster win-win growth for partner companies, POSCO E&C became the first in the construction industry to implement 100% cash payments for subcontracting fees in October 2010.
Early Payment of Holiday Funds
Early payment of subcontract amounts for smooth financial activities of partners who have a high demand for funds during the Lunar New Year and Chuseok holidays every year
Donation to fund for mutually beneficial cooperation of large enterprises & small-medium enterprises
Donating funds for the integrated management and effective usage of activity costs for various shared growth programs run by POSCO E&C
-
What is a mutually beneficial cooperation fund?
Private finances provided by a domestic corporation to the Korea Foundation for Cooperation of Large & Small Business, Rural Affairs for mutual cooperation with SMEs
Donated toKorea Foundation for Cooperation of Large & Small Business, Rural Affairs
Contribution amountKRW 2-3 billion
Purpose of contributionOperating shared growth programs of POSCO E&C -
Key programs for the mutually beneficial cooperation fund
ㆍSupply of funeral supplies for suppliers’ on-site employees
ㆍSupport for hygiene facilities at construction sites
ㆍSupport for ESG assessment and safety consulting
ㆍEducational assistance for enhancing the suppliers’ competencies
Operation of the PHP (POSCO Honored Partner) program
Discovering more PHPs and establishing long-term partnerships by increasing transactions with them
Target
ㆍRegistered company in Construction, Equipment, Material and Logistics
Selection criteria
ㆍExcellent scoring partner in comprehensive performance evaluation and safety management
[Example]| Category | On-siteevaluation | Contractperformance | Biddingrate | Merit/demerit |
|---|---|---|---|---|
| Performance score | 70 points | 20 points | 10 points | -9~+10 points |
Benefits
[Construction] - Priority rights for bid participation
- [Best PHP Awardee] Priority for Private Contracts (Applying Guaranteed Annual Work Volume)
Incentives for Site Managers of Zero-Accident Partner Companies (KRW 1 million / quarter)
[All Sectors] - Reduction of performance bond rate (10% → 5%)
-
Provision of Cash Incentives (KRW 2 million per company, excluding Best PHP awardees) and Offering of Funeral Wreaths, etc.
ESG assessment and safety consulting
Improving ESG capabilities and preventing safety accidents for sustainable management. Target: Officially registered partners in construction areas. Benefits: Support for ESG assessment and safety consulting fees.
Electronic import stamp tax support
Exemption of Electronic Revenue Stamp for Contract Signing to Foster Win-Win Growth with SME Partners (POSCO E&C bears 100% of the cost)
Electronic revenue stamp issuance process
Technical Data Escrow Program
POSCO E&C provides SMEs with the option to securely deposit their critical technical information with a trusted third-party organization, the Korea Foundation for Cooperation of Large & Small Business, Rural Affairs (KOFCA).
-
Eligible Participants
- Officially registered partners of POSCO E&C
-
Depositable Items
- Production and manufacturing processes, design drawings and manuals, formula ratios, etc.
-
Support Details
- Full coverage of technical data escrow service fees
※ Procedure:
① Submit application → ② Pay service fee → ③ Submit deposit
materials → ④ Apply electronic signature → ⑤ Execute escrow agreement
Free Transfer of Patent Rights
Free transfer of POSCO E&C's unused patents to small and medium-sized partners to enhance their technological competitive edge and spread win-win cooperating culture
Contribution to the Agricultural and Fishing Villages Collaborative Cooperation Fund
Supporting Revitalization and Sustainable Development and Growth of Local Economies in Rural Areas
Agricultural and fishing villages collaborative cooperation fund
A fund established to support agriculture, fisheries, and rural communities that have suffered or are likely to suffer damage from the implementation of Free Trade Agreements (FTAs), and to promote win-win cooperation between private enterprises and agricultural and fishery workers (Paragraph 1, Article 18-2 of the Act on Support for Agriculture and Fisheries, etc. in Connection with the Implementation of Free Trade Agreements)
Operator of the Fund : Korea Foundation for Cooperation of Large & Small Business,
Rural Affairs (KOFCA)
Contribution Amount : KRW 1 billion (subject to change
based on annual support activities)Purpose of Contribution : Linked to
community volunteer and sharing activities
Bidding Recommendation System for Local Companies
Expansion of participation of local companies in construction under a certain amount
| Construction type | Existing | Improved |
|---|---|---|
| Machine installation (PLANT) | Less than KRW 1 billion | Less than KRW 2 billion |
| Electrical Work (PLANT) | Less than KRW 700 million | Less than KRW 1 billion |
| Reinforced Concrete Work (PLANT) | Less than KRW 500 million | Less than KRW 1 billion |
Introduction of the Mutual Growth Mall
An online shopping platform designed to expand sales channels for SMEs and enhance
employee welfare for partner companies by providing quality products from excellent
SMEs at reasonable prices.
Eligible Users: Officially registered partners of POSCO E&C
Product Range : Includes food, electronics, daily necessities, furniture, and
fashion & beauty items, featuring well-known SME brands such as Cuckoo, Shinil, and
Dimchae.
How to Use : Visit the URL below, register as a member, and purchase freely
- Online: (http://www.dongbanmall.com/poscoenc
- Mobile: (http://m.dongbanmall.com/poscoenc)
Mobile Operation of the Partner Portal for Procurement Tasks
Enhancing work efficiency for partner company employees through mobile access to core procurement portal tasks such as bidding, contracting, and progress payment
* Installation QR
Participation in Innovative Technology Procurement Consulting Sessions
Participation in purchasing consultation sessions co-hosted by the Shared Growth Committee, local governments, and related organizations, aimed at promoting product purchases and pioneering sales channels for small and medium-sized enterprises.
* 1:1 consultations with small and medium-sized enterprises wishing to do business with POSCO E&C
[Participation in purchasing consultation sessions]Participation in regional and specialized purchasing consultation sessions, such as the Daegu, Chungnam, and Ulsan Innovation Growth Tours, large-small business win-win growth events, and materials/parts/equipment (So-Bu-Jang) business consultation sessions.
Activation of the Right to Stop Work and Provision of Performance-based Incentives
Substantially guarantee workers' rights to safety activities—the core agents of disaster prevention—and link them to disaster prevention effectiveness to reward best practices based on their level of contribution.
Operation of a Grievance Handling Center on the Partner Portal
Receipt and handling of various grievances of partners, such as inquiries on partner
registration process, bidding contract system, and how to use the system
* Grievance
Handling Center : https://ild.poscoenc.com/pgm/board/QnA.asp
Online on-site (specification) briefing session
Enhance operational efficiency and bidding participation rates by omitting on-site visits from partners through non-face-to-face operations.
* Target
orders: Small orders, orders involving long-distance travel, simple condition
orders, etc.
Online on-site briefing process
CCTV Operation policy
CCTV Policy for the Protection of Personal Information
CHAPTER I GENERAL PROVISIONS
Article 1 (Purpose)
The purpose of this Policy is to fulfill appropriate duties and comply with applicable laws by setting matters POSCO E&C Ltd. (the “Company”) must comply with in relation to the installation and operation of closed-circuit televisions and protection of footages.
Article 2 (Definitions)
The terms used in this Policy shall be defined as follows:
- 1. The term closed-circuit television (“CCTV”) is a type of communication network, in which the footages recorded from the CCTVs located in specific sites are collected and transmitted to exclusive receivers through wired/wireless closed-circuit channels.
- 2. The term “footage” refers to CCTV recordings of which the recorded subject can be identified.
- 3. The term “data subject” refers to an individual who can be identified from the footage; that is, the subject of footage.
- 4. The term “processing” refers to the act of handling data collected through CCTVs, such as inputting, saving, editing, deleting, playing, and other similar acts, excluding the collection of such data.
Article 3 (Scope of Application)
- (1) In relation to the installation and operation of CCTVs needed for crime prevention, facility security, and fire safety, as well as the protection of footages that are collected and processed by the aforementioned reasons, the provisions of this Policy shall be observed, unless special provisions are stipulated in other laws.
- (2) Use of auxiliary cameras for CCTVs installed and operated by the Company shall also comply with this Policy, regardless of the fact whether their recordings are treated as actual footages or not.
Article 4 (Protection of Footages)
- (1) The Company shall collect minimum scope of footages that meets the purpose of CCTV installation.
- (2) The Company must have the data subject clearly aware of the installation purpose as mentioned in paragraph (1) of this Article. The footages shall not be used for other purposes than the said purpose.
- (3) The Company shall secure accurate and the latest footages and manage them in a safe manner.
- (4) The Company shall disclose general matters in relation to the handling of footages and protect the rights of data subjects.
CHAPTER II REQUIREMENTS FOR CCTV INSTALLATION
Article 5 (Notification of Installation Plans, etc.)
In the event of installing a CCTV, the Company shall prepare a CCTV installation and operation plan (“Plan”) that includes the following items:
- 1. Purpose of CCTV installation;
- 2. Division in charge of CCTV control: Handling officer and contact details;
- 3. Number of cameras, locations, performance, and scope of recording of the CCTV to be installed and operated;
- 4. Standard of the caution sign to be installed and the installation location in accordance with Article 7(1);
- 5. Contents, procedures, and methods regarding the data subject's exercise of rights and means of objection;
- 6. CCTV recording time, retention period of footages, methods of storage, management, and deletion of footages, and storage location of footages;
- 7. Actual location where footages transmitted from CCTVs are accessed and played, and access control to the said location;
- 8. Grounds, procedures, and methods of providing or granting access to footages to a third party; and
- 9. Other matters recognized to be necessary for the protection of footages
Article 6 (Designation of CCTV Managers)
- (1) The head of the division in charge of the installation and operation of CCTVs shall be designated as the CCTV General Manager, while his or her staff shall be designated as CCTV Operation Manager(s) (“CCTV Manager(s)”).
- (2) The CCTV Manager shall take charge of duties in relation to the installation and operation of CCTVs, reception and handling of complaints, and collection and processing of footages.
- (3) The CCTV Manager shall designate and manage a separate Personal Information Handler and inform the CCTV General Manager of relevant information in the event of CCTV installation and/or other changes.
Article 7 (Installation of Caution Signs)
- (1) In the event of installing a CCTV, the Company shall put up caution signs regarding CCTV operation and the collection of footages for the recognition of data subjects.
- (2) The signs in relation to paragraph (1) of this Article shall mention the following items:
- 1. Purpose of CCTV installation;
- 2. Recording scope and time; and
- 3. Information on the CCTV handling division, CCTV Manager, and contact details
- (3) The signs in relation to Paragraph (1) of this Article shall be installed within the recording scope where they are easily visible and understood by data subjects.
- (4) Notwithstanding Paragraph (2), in the event of installing several CCTVs in the Company’s building, the sign that complies with Paragraph (1) may mention that the whole building is within the recording scope and can be attached only on the building exits.
CHAPTER III REQUIREMENTS FOR HANDLING FOOTAGES
Article 8 (Limitation on Collection)
- (1) CCTVs shall not be arbitrarily manipulated or shoot other places beyond the purpose of their installation during collection of footages.
- (2) Footage rotation and zooming features that have no relation to the purpose of CCTV installation may not be used during collection of footages.
Article 9 (Limitation on Processing)
Footages of a data subject may not be used for other purposes than the CCTV installation purpose or be granted access or provided to a person who has no access authority: Provided, That this shall not apply in any of the following circumstances:
- 1. Where consent is obtained from the data subject;
- 2. Where the data is given access or provided to the data subject;
- 3. Where special provisions exist in other laws;
- 4. Where the data is provided in a pseudonymized manner when it is required for the purposes of reporting by the media through newspapers or broadcasting;
- 5. Where there is an urgent reason for not obtaining the data subject's consent when the risk that the rights and interests of the data subject may be infringed is clear and present;
- 6. Where it is necessary for the investigation of a crime, indictment, and/or prosecution; or
- 7. Where it is necessary for the enforcement of punishment, probation, and custody.
Article 10 (Safeguards, etc.)
- The Company shall designate a place where footages transmitted by CCTVs are actually accessed and played (“Control Center”) as a restricted zone and strictly limit the access of individuals apart from those who have been granted the authority.
- (2) The Company shall limit the authority to access footages to CCTV Managers and the minimum number of designated personnel.
- (3) The Company shall regularly inspect and check the normal operation of CCTVs and keep an accurate record regarding the matters.
- (4) The Company shall seek for technical and managerial safety measures in response to illegal access, alteration, leakage, and damage of footages.
- (5) The Company shall prepare a training course on the personal information protection of data subjects for those who are granted authority to access footages.
Article 11 (Request for Access, etc.)
- (1) A data subject may request to confirm the existence, access, and/or delete footages to the Company.
- (2) In relation to the request as mentioned in the paragraph (1) of this Article, the Company shall take immediate action in accordance with Article 5(5).
- (3) Notwithstanding Paragraph (2) of this Article, the Company may refuse to take action in the event of any of the following circumstances. In this case, the grounds for refusal and objection method shall be informed (including information and communications networks) to the data subject within seven (7) days.
- 1. Where it may cause grave difficulties in performing investigation of crimes, prosecution, and conduct of trials;
- 2. Where deleting only the footages of a specific data subject is extremely difficult in technical manner;
- 3. Where taking appropriate action as prescribed in Paragraph (1) of this Article may infringe upon other's privacy rights; or
- 4. Where there are appropriate grounds to refuse the request for access, etc., that meet the public interest.
Article 12 (Retention and Deletion)
Footages collected through CCTVs shall be deleted without delay once the data retention period mentioned in the Plan expires: Provided, That when it is difficult to determine the minimum period of time required to achieve the purpose of data retention due to the nature of a division, the retention period shall be within thirty (30) days after the collection of footages.
CHAPTER IV SUPPLEMENTARY PROVISIONS
Article 13 (Consignment of Duties)
- (1) In the event of consigning the duties in relation to the installation, operation, and management of CCTVs, the Company shall take necessary safety measures to prevent the abuse of footages and supervise the consignee.
- (2) The consignee who is granted authority to access footages in relation to paragraph (1) of this Article shall undergo a training course as mentioned in Article 10(5).[lh1]
Article 14 (Confidentiality)
Those who handle or have handled footages shall not use the obtained data for inappropriate purposes, such as revealing, processing without authority, and/or providing for the use of another person.
Article 15 (Exclusion)
This Policy shall not be applied to CCTVs installed and operated to supervise the duties of individuals who are with the military regardless of their duties.