POSCO E&C is a trustworthy win-win partner that forms stable industrial ecosystem.
Philosophy and Strategy
POSCO E&C intends to continuously change and innovate while communicating and sympathizing with all our stakeholders, including partners and customers.
We ultimately aim at creating greater corporate value and sustainable growth
under the management philosophy of "Corporate Citizenship: Building a Better Future Together."
- Management Philosophy Corporate Citizenship: Building a Better Future Together
Creating a strong construction industry ecosystem
through win-win cooperation with small and medium-sized partners
- Values Fair Trade ˙ Value Creation ˙ Performance Sharing
Strategy for Shared Growth
- Build VALUE Together
- Practical Strategies
- [Purchase Division]
Fair Trade and
- Compliance with fair trade
- Operation of bid system for win-win value
- Technological support for partners
- Financial support for partners
- Shared Growth Support Team (Joint technical development, consulting, training)
- Contribution for Mutual Benefit Cooperation Fund between Large Enterprises & Small-Medium Enterprises
- Mobilization of purchasing business
- Introduction of e-Catalog system within POSCO Group
- Operation of PHP (POSCO Honored Partner) program
- Participation in Innovative Technology Buyer Conference
- ESG assessment and safety consulting
- Bidding recommendation system for local companies
- Contribution to the agricultural and fishing villages collaborative cooperation fund
- POSCO Youth Dream job matching program
- Support for funeral supplies and wedding halls for partners
- Operation of a mobile app as field workers' opinion channel
- Operation of a grievance handling center on the purchasing portal
- Establishment of standards for the installation of on-site sanitation and rest facilities
- Reward system for excellent employees of partners
- Online on-site (specification) briefing session
- Wage arrears management system (nomubi.com)
- Awareness innovation campaign for no power abuse
- Sending a letter of win-win cooperation
Five Major Brand Programs
In order to practice the corporate citizen slogan, "Build Value Together," various programs are operated in the three areas of win-win, sharing, and happiness. Among them, major programs are classified into five major brands.
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
Establishment of Automatic Detection System of Illegal Special Contracts (Pos-Compli)Introduction of 2020.06
Detection of illegal special contracts in the purchase specification, an annex to the contract, using AI
Illegal special contract detection process
Prepare purchase specification and request for review (using standard form)
Automatically detect illegal special contract and notify detection resultuse the review contents to generate learning data -> improve AI detection accuracy
Correct illegal special contract in purchase specification and request purchaseattach standard subcontract agreement, individual agreement, and purchase specification
Work Order Issuance Confirmation SystemIntroduction of 2018.12
In case where a partner requests a monthly completed amount, it can directly check on the system through the pop-up window whether a work order is issued and whether additional construction costs are reflected.
System screen when requesting completed amount by partners
1) Did you perform additional construction work other than what is described on the screen this month?
2) Have you been issued a work order for additional construction?
3) Have you been paid for the additional construction this month?
YES / NO
If you select “No,” it will be notified to our Fair Trade Group and whether the Fair Transactions in Subcontracting Act has been violated will be confirmed.
Verbal work order is inappropriate
appropriate and timely payment for construction will be made.
Operation of "win-win-based bidding system" to ensure fair profits for partners
Bid System With Limited Low PriceIntroduction of 2020.04
Resolving problems such as quality deterioration and safety accidents due to bleeding competition
A system that was introduced for win-win cooperation with subcontractors suffering from COVID-19 after abolishing the lowest bid system
Bidders who offered lower than the low price limit threshold* are excluded, and bidders directly above the threshold are selected.
*[(average excluding the lowest bid amount within budget + budget) ÷ 2] x 85%
Case of "XX site" window construction (budget: KRW X billion; the set lowest price: KRW 1.1 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 limited low price.
|Cateogry||Company A||Company B||Company C||Company D||Company E|
|Bidding amount (KRW 100 million)||9||10||12||13||15|
* Guaranteed fair profits for partners by increasing the amount of successful bids by approximately KRW 14 billion per year
Bid System of Market Price CompetitionIntroduction of 2017.09
For win-win cooperation with subcontractors, POSCO PJT excludes the lowest price and applies the market price competition in bid system
In particular, for win-win cooperation with local companies in Pohang, Gwangyang, and Suncheon, the bid for specific types of construction are only open to local companies.
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|
* Guaranteed fair profits for partners by increasing the amount of successful bids by approximately KRW 2.5 billion per year
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
A concept independently defined by POSCO Group by compiling companies related to social problem-solving
Preferential registration and bidding, fee reduction
|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
Interest-Free Management Fund Loan to Excellent PartnersIntroduction of 2020.12
A financial support system for partners that lends POSCO E&C's funds without interest to practice the management philosophy of "Corporate Citizenship: Building a Better Future Together" and to improve their liquidity
Target and period
- Target: Excellent partners of POSCO E&C
- Limit: KRW 500 million (a total of KRW 10 billion/year)
- Repayment and term: One-time repayment (1 year)
Shared Growth/ESG FundIntroduction of 2011.06
Low-interest loan assistance for subcontractors by establishing a Shared Growth/ESG Fund with Woori Bank starting in June 2011
1.5% preferential rate compared to market interest rate * Additional preferential rate for excellent partners in ESG assessment (1-4 grades)
Target and period
Target: PHP (POSCO Honored Partner) Limit and term: KRW 500 million per year (maximum 2 years) Application and repayment: May, December / Early or bullet 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 (contracting in KRW) Limit: Less than 100% of the contract amount (subject to the deduction of paid advance and interim payment limit and credit rating). Loan application window: Before 50% of the contract period has passed; minimum contract period of 6 months required. Repayment and term: Deduction of interim payment or bullet repayment / within the contract period.
"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 E&C site and their lineal ascendants and descendants and spouse.
Item: Funeral supplies engraved with POSCO E&C logo (12 items, including bowls, paper cups and plates, for 500 people)
Occurrence of bereavement
Field manager of the partner
Person in charge of construction in POSCO E&C
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 of top partners in performance evaluation
Recommendation of excellent employees of partners
Confirmation of excellent employees
Reward and prize
Certificate of commendation and gift certificate worth KRW 2 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
Workers’ Wage Arrears Management Systemnomubi.com, Introduction of 2016
Preemptive payment arrear prevention system to avoid late payment of wages and money misappropriation by workers of subcontractors (primary contractor → workers’ accounts)
Reward and prize
Target: Small and medium-sized partners doing business with POSCO E&C (excluding middle-standing enterprises)
How to apply: Automatic fee waiver through the nomubi.com system
* Applicable to payments made through nomubi.com from June 1, 2021.
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"
[First Half] Reception: February to March; evaluation and final selection: April
[[Second half] Reception: August to September; evaluation and final selection: November
[First half] Proposals are received after topics are announced by POSCO E&C
[Second half] All improvements/development proposals related to the construction industry are applicable
In case where a company selected for excellent ideas proves their performance after joint technologies development,
incentives such as private contracts, long-term supply rights and joint patent applications will be provided.
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
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.
PHPs and SME partners who wish to participate in the program or have been recommended internally.
Joint technical development: Transfer of our design and construction knowhow and provision of financial rewards in connection with our benefit sharing program. Consulting: Operation of consulting programs using our own capabilities or outside entities in various areas, including safety, finance and ESG. Training: Operation of training programs designed to improve the job competency of employees of our partners in various areas, including safety, design and labor.
[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.
Value of win-win with customers
100% Cash Payment of Subcontract Amount
Starting in October 2010, 100% cash payment of subcontract amount was made to secure cash flow and shared growth with partners for the first time in the construction industry
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 SMEsDonated 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
ㆍProvision of on-site sanitation facilities and rest areas
ㆍProvision of supplies for protection against COVID-19 and hot packs during winter
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
ㆍRegistered company in Construction, Equipment, Material and Logistics
ㆍExcellent scoring partner in comprehensive performance evaluation and safety management[Example]
|Performance score||70 points||20 points||10 points||-6 to +5points|
※ Merit/demerit points: Corporate citizenship activities, overdue payment control system, defect management, etc.
[Construction] Grant the right to participate in the bidding Entitled for bidding for key projects (Bidders will be chosen among only PHP companies)
[Construction, Equipment, Material and Logistics] Reduction of performance bond rate (10% → 5%)
* Requires credit rating of BB- or higher, debt ratio of not greater than 200%, and risk rating of R4 or lower Interest-free business loan, provision of funeral products for PHP employees
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
Changed the distribution ratio of e-revenue recognition for the practice of corporate citizenship management philosophy and win-win growth with business partners
Electronic revenue stamp issuance process
Conducting joint R&D by selecting a technology necessary for field application, quality assurance, and cost reduction as a development task once a year
• Project title: Development of ultra-high-strength end-extended PHC pile
Making the pile's main body ultra-high-strength (80 Mpa → 110 Mpa) and end-extended (Ø50 increase) leading to augmentation of ground supporting force of the main body
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
Smartization competency enhancement consulting (QSS consulting)
Productivity improvement such as management/manufacturing innovation and process improvement of SMEs through QSS (Quick Six Sigma) innovation activity, POSCO’s unique innovation methodology, and pre-consulting for smart factory construction (free support)
Consulting to strengthen innovation capacity
1. QSS Consulting*
2. Energy Consulting
3. Smart level diagnosis
Innovation competency strengthening education
1. Overseas Benchmarking for Executives
2. CEO Workshop
3. Innovation leader training
Smart factory construction support
Implementation of a waste-free factory by using IT technology in small and medium-sized manufacturing plants to intelligently optimize the production process, and promotion to improve the structure and productivity of SMEs (construction cost is supported by the Ministry of SMEs and Startups)
Implementation of partial smartization such as ICT-linked simple production system (barcode-based LOT tracking, etc.) or simple automation
Implementation of smartization of all processes including enterprise resource management (ERP), factory operation, supply chain management (SCM), manufacturing automation (loT sensor grafting), and process simulation
Mobilization of Purchasing Business
- Additional introduction of mobile purchasing system for partners other than PC-based one
- Sharing real-time purchasing tasks without restrictions on time and place with partners
Partner registration procedure, bid announcement and results, order and delivery confirmation, payment status, etc.
Mobile system login and main page
Participation in the Innovative Technology Buyer Conference
A buyer conference co-hosted by Korea Commission for Corporate Partnership, local governments and other related organizations, aimed at promoting product purchase and developing sales channels.
One-on-one consulting with SMEs who wish to transact with POSCO E&C
[Buyer conferences we participate in] ㆍConglomerate-SME shared growth buyer conference ㆍInnovation growth tour buyer conference in Daegu, Chungnam, and Ulsan ㆍBuyer conference for materials, parts and equipment business
Introduction of e-Catalog System Within POSCO Group
Products introduction available on-line without a supplier directly visiting the product use department and giving explanation
How to access and use
Suppliers who wish to introduce their products can access the system by clicking the "e-catalog" banner on the main page of the POSCO E&C purchasing portal and use the system after registering as a member.
"e-catalog" system main page* Partners headquartered in Pohang or Gwangyang (Suncheon) or members of the Korea Specialty Contractors Association
Value of Sharing With Local Communities
Contribution to the Agricultural and Fishing Villages Collaborative Cooperation Fund
Practicing “With POSCO” as a corporate citizen and contribution to the local community
Agricultural and fishing villages collaborative cooperation fund
A fund to support the promotion of win-win cooperation between businesses and agricultural and fishing villages that have suffered or are likely to suffer damage from the implementation of a free trade agreement (Article 19-2 (1) of the Special Act on Assistance to Farmers, Fishers, Etc. Following the Conclusion of Free Trade Agreements)
Operator of the fund: L & SMEs Cooperation Foundation
Contribution amount: KRW 5 million (1 year contract)
Purpose of contribution: Purchasing NongHyup gift certificates to distribute to residents in rural areas
Bidding Recommendation System for Local Companies
Expansion of participation of local companies in construction under a certain amount
|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|
POSCO Youth Dream Job Matching Program
Providing high-quality vocational training for young job seekers (high school graduates and vocational college graduates) based on POSCO Group’s excellent education and training infrastructure which leads to employment by partner companies
Target: Partners in the field of steelmaking in Pohang and Gwangyang that wish to participate
Training content: Basic knowledge as a member of society and practical skills centered on management of steelmaking such as welding and crane
Liberal arts/character (2 weeks)
Trust, communication, and vision design
Positive mind, volunteering activities
Field experience, conversation with seniors
Common vocational skills (2 weeks)
Steel production process
General machinery, hydraulic/lubrication
Equipment diagnosis, heavy cargo handling
Advanced welding (3 weeks)
Electric welding (general)
Electric welding (practice)
Intensive crane operation (2 weeks)
Overhead crane (general)
Overhead crane (practice)
Value of Happiness With Employees
Establishment of Standards for Installation of Sanitation and Rest Facilities
Establishment of minimum guidelines for sanitation and rest facilities to guarantee the basic rights of workers whose living environment is the construction fields.
Installation and operation standards
1) Establishment of installation standards for urinals and toilets
|Urinal||1 unit per 5 floors||1 unit per 5 floors|
|Toilet||1 unit per 10 floors||1 unit per 3 above-ground restrooms, additional installation after securing an evacuation floor|
2) Provision of drinking water, beds or chairs, and air conditioners in rest facilities
3) Contract with a cleaning company (full cost paid by POSCO E&C)
Improvement of the cleanness state of on-site sanitation facilities
4) Immediate disposal of unusable temporary toilets (regardless of years of use)
Awareness Innovation Campaign for No Power Abuse
Establishment of a field culture of respect and consideration by removing the tendency of power abuse permeated in the words and deeds of executives and staff members
Chanting "With POSCO" slogan in unison at the end of TBM
Host: With POSCO! Keep the field safe with respect and consideration!
All: Keep it safe, safe, safe!
Awareness improvement education for preventing power abuse (education for new employees and ethics education for all group employees)
Operation of a Grievance Handling Center on the Purchasing 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
Improving work efficiency and bidding participation rate by omitting on-site visits by partners through pursuing non-face-to-face business due to COVID-19
* Target orders: Small orders, orders involving long-distance travel, simple condition orders, etc.
Online on-site briefing process
Sending a Letter of Win-Win Cooperation
Promotion and introduction of shared growth programs operated by POSCO E&C, such as eligible targets for new system, how to apply and how to participate in contests Used as a communication channel with partners; improving the utilization and participation rates of partners in various programs by sending win-win cooperation letters
Sent to: Regular registered partners and aspirant partners of POSCO E&C
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.