INTEGRITY POLICY

Through appropriate leadership at all levels, CSfD is pledged to promoting and sustaining a culture where ethical conduct is recognized, valued and exemplified by all employees.

CSfD recognises that its employees may be privileged to know information and data about our customers’ businesses that could be considered as sensitive in nature. CSfD will take all fair and reasonable steps to ensure that such information is safeguarded from inappropriate or unauthorised use and not disclosed to a third party either intentionally or unintentionally.

Employee conduct:

Employees are required to accept, as part of their contract of employment, the following statements that:

‘Confidentiality of all Company source codes must be maintained at all times.’

‘The Customer's right to confidentiality must be observed at all times.’

All CSfD employees are under an obligation to report to a director of the company any breach of this policy. Any person/s found to be in breach of this policy, or any person who victimises another for reporting a breach of this policy, will face disciplinary action in accordance with the CSfD Disciplinary and Grievance Procedure.

Company use of sensitive data:

CSfD will undertake not to use in any sales, marketing or public relations promotions in which it might engage, any customer information, including disclosure of names, products and services relating to a customer directly or indirectly, without their express written consent.

CSfD will strive to ensure that, where it is believed that a conflict on interest may arise due to contractual commitments for competing customers, all necessary precautions will be taken as is reasonable to take under the circumstances, to protect the privacy of all parties concerned.

CSfD Records:

CSfD recognises that sensitive information and data may reside within its systems and as such, takes all reasonable precautions to ensure the security of access to that data by authorised persons only.

Intellectual Property Rights:

The intellectual property rights of any application and any subsequent development undertaken by CSfD on behalf of a customer will normally reside with CSfD unless there is a specific business case for which an agreement will have to be made in advance.

If a situation arises where customers’ intellectual property rights are acknowledged, either through a specific written agreement or where software is provided by a customer or by a third party on the customer’s behalf, then CSfD will observe these at all times and such steps as may be necessary will be taken to preserve that property and respect the ownership rights.

In situations where we are loaned personal data by our customers for the purpose of development or testing of their systems, then we will endeavour to take all reasonable steps to protect that data in accordance with the Data Protection Act 1998.

Above all else CSfD is committed to developing an honest, fair and trustworthy relationship with all of its customers and in all its activities within the marketplace.

The aim of this policy is to encourage good practice amongst all CSfD employees but is not intended to replace or supplement any contractual agreements in place with individual customers.