MODEL POLICY ON ELECTRONIC MONITORING

1. Personal Use of Equipment
   Computers, telephones, and other equipment are intended for business use. We understand that situations will arise in which employees need to use equipment for personal reasons. Personal use of company equipment should be kept to a minimum and not abused. If personal use involves more than incidental cost (such as volume photocopying or making long distance telephone calls), this must be reported to your supervisor. The company reserves the right to require reimbursement for these costs. Reimbursement will be made at the company’s actual out of pocket cost, not at commercial rates.



2. No Secret Monitoring
   Managers need to keep track of the work of the employees for whom they are responsible. Sometimes the best way of doing this will be through electronic data collection rather than through direct observation of the work by the supervisor. We will review all proposed programs of this type with you before they are approved. A complete written description of all programs which are approved will be given to employees before the program is begun. Except for investigations into serious misconduct, there will be no secret monitoring.



3. No Personal Monitoring
   All electronic monitoring will be confined to employees’ work. We will not monitor personal telephone calls, electronic mail, or other personal communications. We may, however, conduct call accounting for expense allocation purposes and to ensure that the bulk of your communications at work involve company business. Such monitoring will reveal only the identity of the party with whom you communicated, not the content of your communication. Nor will we monitor break rooms, cafeterias, or other areas in which work is not ordinarily performed except in areas where monitoring is needed to protect your safety, such as stairwells and parking lots.



4. Notice of Monitoring
   If we monitor a business related telephone call or other form of communications, we will inform you of this monitoring at the time the monitoring takes place. In the case of telephone conversations or electronic mail, this notice will take the form of a blinking light on your telephone or computer screen. Someone have urged us not to give this notice because they believe that employees will not consistently do their best if they know when their work is being monitored. We think more highly of our employees than this, and do not believe that we have to keep you in the dark about your monitoring schedule for you to do your best. If we need to access a document that is stored in your computer or other location which is not generally accessible, we will ask you to retrieve the document. Only if you are not available will we access your hard drive or other storage area directly. In this event, we will let you know when we accessed your records and the document we retrieved.



5. No Monitoring in Private Areas
   We will not conduct video monitoring of locker rooms, bathrooms, or similar private areas under any circumstances.



6. Personal Information
   We will collect personal information about you only to the extent it is necessary to comply with the law or for essential business operations such as benefits administration. All personal information we collect about you will be kept confidential. We will reveal information about you within the company only to those who need it to perform their jobs. We will release information to parties outside the company only with your consent or when legally required to do so. If we are legally compelled to release information about you to a third party, we will inform you.