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PRIVACY NOTICE
The McDonald's Business Integrity Line
The McDonald's Corporation Standards of Business Conduct ("the Standards") can be found here. The Standards are a guide to the ethical and legal responsibilities we share as members of the McDonald's family.
At McDonald's we speak honestly and openly and listen for understanding. We raise questions or issues, even if they are difficult. If you know of any violation of the Standards or of any applicable law, you are responsible for reporting the violation immediately. One of the ways you can raise an issue, or report misconduct, is by calling the McDonald's Global ethics reporting number or by using the McDonald’s online reporting platform, collectively called the "Business Integrity Line". This Privacy Notice provides more detail about how you can use the Business Integrity Line and how your information, including your personal information, might be processed through the Business Integrity Line.
Use of the Business Integrity Line is voluntary. If you choose to use it to report an issue we will need to process your personal information in order to consider, investigate or review your report and meet our regulatory requirements. If you choose not to use the Business Integrity Line there will be no consequence for you. The Business Integrity Line generally enables people to report anonymously, however, there may be some countries where this is discouraged or not permitted by law. Please refer to the applicable country specific Annex for local law requirements.
If you believe that the Standards or any applicable a law has been violated, consult with the Global Compliance Office or the Legal Department immediately. For other matters, you can talk to your direct supervisor or another member of management, or contact Human Resources or the Global Compliance Office: Phone: 630-623-3522; business.integrity@us.mcd.com
Local law requirements
Local laws can impact the way that the Business Integrity Line should be operated and used for people in a particular country, including the types of issues that can be reported. For further information on local variations, please refer to the Annex.
Scope and Application
We have prepared this Privacy Notice (or "Notice") for employees of McDonald’s Corporation and its wholly owned subsidiaries. You should also refer to the McDonald's Human Resources Privacy Statement applicable to you ,for more information about the standards we apply when collecting and handling your personal information, including information about: (1) the types of personal information that we process; (2) your rights in relation to your personal information; and (3) which third parties we may share your personal information with (both within McDonald's and externally).
This notice is not intended to cover the information of individuals that are employed by our franchisees, which are independently owned and operated. Our franchisees maintain separate business integrity policies and practices.
When we say "we" or "us" in this document, we mean your employing company, which is part of McDonald's Corporation, and which is a data controller of any of your personal information processed for the Business Integrity Line. That is the entity with which you have an employment contract. If you do not know it, please contact your local HR representative for the full name and address of your employing entity.
You will also see a number of references to the "McDonald's", which includes McDonald's Corporation and all wholly owned subsidiaries globally. As with many other McDonald's policies, this Notice does not form part of your contract of employment, and we may update it from time to time.
How can I use the Business Integrity Line?
The McDonald's Business Integrity Line is staffed 24 hours a day, 7 days a week, 365 days a year by an outside company experienced in handling sensitive calls. McDonald's Corporation has engaged a third party service provider (the "Business Integrity Line Operator") to provide an online platform and a call center where you can make reports to the Business Integrity Line.
You may file online (written) reports through the Business Integrity Line website operated by NAVEX [here].
Alternatively, reports may be submitted by calling the Business Integrity Line Operator (a list of the telephone numbers for each country is available here).
All information received through the online platform, the call center, or through the Global Compliance Office is maintained on a database provided by NAVEX called Ethics Point.
Who is NAVEX?
The current Business Integrity Line Operator is a company called NAVEX, (who is a data processor on behalf of McDonald's). Your personal information will be shared with NAVEX. NAVEX provides the reporting platform and Business Integrity Line that you can use to raise issues and is subject to contractual obligations to implement appropriate security measures to safeguard your personal information, and to process the personal information only as instructed by the McDonald's. NAVEX is registered and self-certified with the US-EU Privacy Shield and the US-Swiss Privacy Shield for HR and non-HR data. For more information, please refer to the EU-US Privacy Shield or Swiss–US Privacy Shield website available under: https://www.privacyshield.gov/.
What types of matters can I report via the Business Integrity Line?
The Business Integrity Line is set up in order to report any of the following issues:
However, local laws in some countries limit the types of issues that can be reported through the Business Integrity Line. Please refer the applicable country specific Annex for local law variations.
Why does McDonald's need to use this information about me?
We collect and use your personal information via the Business Integrity Line for several reasons linked to our regulatory obligations, our legitimate business interests and your employment. The lawful bases that we rely on to process your personal information in this context are:
When relying on the legitimate interests basis for processing your personal information, we will carry out a balancing exercise between the reason for the processing of your personal information on the one hand, with your rights and freedoms on the other, to ensure it is appropriate for us to go ahead. We will also identify any extra steps we need to take to protect your rights.
Questions?
If you have questions regarding this Notice, please contact us at dataquestions@us.mcd.com or by telephone at (800) 244-6227.
Remember, if you want to make a report to the Business Integrity Line you can do so on the online platform here, or by calling the Business Integrity Line using your local toll-free number which can be found here.