In your daily business, you might be exposed to personal and business information about associates, customers, members, suppliers, and our own company. It’s your responsibility to protect this information in accordance with applicable laws, industry best practices, and our corporate beliefs.

Information may be physical (on paper) or electronic. You should only collect or store personal or business information needed to perform your jobs. Manage that information securely through its lifecycle. Information is divided into three classes of data: private (high security), confidential (medium security), and unprotected (low security).

Examples of ways to protect private or confidential information include:

• Accessing the information for business purposes only.
  
• Sharing it with other associates for legitimate business purposes only.
  
• Preventing unauthorized access (for example, locking up private data).
  
• Return all private and confidential information to Walmart along with any other Walmart property upon termination of employment.
  
• If there is no business need, or a hold for legal purposes, for keeping the data, dispose of it by placing it in a shredder or confidential bin; never throw it in the trash.
  

If you believe you have information that needs to be shared outside the company, seek approval from your manager or the Legal Department first.

Trade secrets are an example of business data we must protect. In our pursuit of “striving for excellence,” we have invested in the development of systems, processes, products, business procedures, and technology – our trade secrets – that have made us a leader in the retail industry, and give us a competitive edge. All trade secrets are private data and must be kept secure. In addition to protecting our own trade secrets, it’s our policy to respect the trade secrets of others. No associate may reveal the trade secrets of the companies with which we conduct business, or of their former employers.

Personal information must also be securely managed. If you suspect there may be a breach of customer, member, or associate personal information, notify a member of management, your in-country Ethics Office, or the Global Ethics Office.

Specific departments within our company may have special privacy rules or procedures. Read, understand, and stay current on information that applies to your specific business and job function..

An invoice associate is married to a supplier who works with the buyers at the Home Office. I’ve seen her call her husband and tell him the cost of products we're buying from his competitors. Is this a violation?
Yes. Although she does not have influence over the business he works with at Walmart, she has access to confidential information that may be giving her husband’s company an advantage over other suppliers.

A co-worker of mine has recently given her resignation. Since then, she’s been e-mailing supplier contact information to her home computer so she can start her own business. Is this a violation?
Yes. The supplier information she obtained through her position at Walmart is considered confidential company information. She should not be using it for her personal business.

A friend of mine told me he could give me information regarding a competitor’s upcoming advertising strategy. Should I get the information?
No. We have no desire, or need to know the trade secrets of other companies.

My manager told all my peers about my medical condition when I called in sick yesterday. Is that a violation of the Privacy policy?
It could be. Your peers do not have a business need for knowing your medical condition. Many times the information is shared out of genuine care and concern for you as an important and valued member of the team. Talk to your manager and tell them your concern. If you don’t feel comfortable talking to them, contact your Human Resources manager or the Global Ethics Office.

A pharmacy associate told me a certain customer has a rare medical condition. Is she allowed to share this information?
No. Personal information about our customers (including medical data) is confidential and should not be shared.

I have an anonymous blog that I write on a regular basis. Can I post information I’ve learned based on my job?
While posting information online can be a great way to communicate with others, it’s important to consider some of the risks and rewards that are involved. Maintain the confidentiality of business information related to Walmart and its partners, and the personal information of associates and customers. Don’t reveal anything that is not public. Ultimately, you’re responsible for what you post.