WestGives Privacy Notice


1. Purpose of this notice

Please read this notice from West Pharmaceutical Services, Inc. and its subsidiaries (“West”, “we”, “us” or “our”) carefully. It provides general information in a Q&A format on how the personal data of West employees (“you” and “your”) is collected, processed and retained in strict compliance with the provisions of data privacy laws around the world, including, but not limited to, the EU General Data Protection Regulation, UK General Data Protection Regulation, Serbian Personal Data Protection Law, Israeli Protection of Privacy Law, China Personal Information Protection Law, Korean Personal Information Protection Act, Taiwan Personal Data Protection Act, Singapore Personal Data Protection Act 2012, Australia Privacy Act 1988 , Brazilian General Data Protection Law, and California Consumer Privacy Act of 2018 (collectively, “Data Protection Regulations”) in relation to the WestGives online giving and volunteering portal (“WestGives Platform” or “Platform”). 

In this notice, Personal data means any information relating to you from which you may be personally identified, either directly or in combination with other information.

2. Who will process your personal data?

Your Personal data is collected and processed by West group entities and the Herman O. West Foundation (the “Foundation”) to offer you the opportunity to use the WestGives Platform and for the Foundation to potentially match any donation you make to your chosen charity. 

We utilize the services of a service provider, Benevity, Inc. (“Benevity”), in operating the WestGives Platform. Benevity acts as a processor of personal data on behalf of West, meaning that Benevity’s processing of your personal data may only take place in accordance with our instructions and for the purposes explained in this notice. Please also read Benevity’s Privacy Policy (https://west.benevity.org/privacy). 

3. What categories of personal data are processed?

In order to allow you to log in and use your WestGives Platform account, the following limited amount of your personal data will be processed. This information will be used to create your WestGives account and send you a welcome email, through which you may login to your WestGives account and use the Platform. This will include:

your name;
your employee number;
your West email address; and
your location (West office).

Should you choose to login and make a donation to your WestGives account after receiving the welcome email, additional personal data may be collected and processed, according to your local tax laws, including:

home address (REQUIRED); and
other profile information that you desire to provide (VOLUNTARY).

For more detailed information please read (https://west.benevity.org/privacy).

4. Why do we process your personal data?


West transfers your personal data to Benevity to have your WestGives Platform account created and to enable you to use the WestGives Platform, should you choose to do so. You will receive an email requesting confirmation of whether you wish to log in to your account and make donations via the Platform. You are free to choose whether to log in and use your WestGives account. Upon making a donation to your chosen charity, the Foundation may, after assessing and approving the chosen charity, match your contribution. 

Should you log in to your account and make a donation, your personal data will be processed for a range of purposes in connection with the management and administration of the WestGives Platform, including:

to establish your eligibility to make donations via the Platform: 
to provide you with log-in credentials;
to create and manage your user account;
to process and report upon your donation. It is important that West is notified of your donation and its size, so that we can match your contribution via a donation made by the Foundation; 
to implement payroll giving, if applicable;
to provide client services and related assistance;
if you are a contributor to any third-party donor advised foundations that form part of the WestGives Platform, to facilitate your donation transactions and to prepare tax information slips or other acknowledgments;
to carry out other purposes which are disclosed to you and to which you consent or are permitted or required by applicable law.

For additional information please read (https://west.benevity.org/privacy).

5. What is the legal basis for processing your personal data?


Where we process your personal data so that you may receive an email allowing you to log in for a WestGives account, we do so on the basis of our legitimate interest in managing and operating the WestGives Platform. 

Where you log in and use your WestGives account and the Platform, your personal data will be processed either:

upon the basis that you have provided consent to process your personal data for one or more specific purposes, or
upon the basis of a legitimate interest pursued by West or a third party in administering and managing the WestGives donations Platform. 

When you provided your consent to the processing of your personal data, you can withdraw such consent at any time by writing to integrity@westpharm.com.

6. Who has access to your personal data? Is data transferred outside the EEA?

Your personal data will be shared with Benevity, whose operations are based in Canada which has been deemed to have adequate safeguards for the protection of personal information by the European Commission and the UK. 

Benevity may also transfer your personal data to its third-party providers in third countries such as the United States. Under the terms of our agreement, Benevity is required to implement European Commission or any other approved standard contractual clauses in respect of any international transfer of personal data relating to an EEA or UK based employee of West, where that personal data is transferred outside of the EEA or the UK. In addition, Benevity is required to enter into agreements with any sub-contractors which place obligations of the same standard upon those sub-contractors. 

Limited information about each donation you make will be shared with one approved individual at the Foundation, to assess your chosen charity and determine charitable status before matching your donation. 

7. How long is your personal data retained?


Your personal data will be retained by West for no longer than is necessary for the purposes for which the data is collected and further processed, except to the extent required or prohibited by law. As a rule, your personal data is stored during your employment and for a period of up to seven years after the end of your employment agreement, depending on the category of data and the reason for maintaining it. 

8. What are your rights?

You may have a right of access to and rectification of your personal data in accordance with the Data Protection Regulations. 

Under certain circumstances, you may ask for your personal data to be erased or restrict access to your personal data. In certain cases, West may however refuse to erase or restrict access to your data, for instance for the introduction, execution or in defense of legal claims.

You may also object to the processing of your data, but only as regards data processed based on West’s legitimate purposes. Note that we may refuse this objection insofar as West’s compelling legitimate purposes would override your interests, rights and freedoms or if the data are necessary to defend a legal claim.

If you aware of a violation of the provisions of any Data Privacy Regulations, we invite you to discuss this with your HR manager or the Legal Department. 

You may also have the right to file a complaint with your local data protection authority.

To exercise any of your rights, please contact: integrity@westpharma.com.

9. Whom can I contact?


If you have questions related to this notice or your personal data, please contact the Compliance and Ethics Office at integrity@westpharma.com. We will get back to you as soon as reasonably possible.  

In Germany, our data protection officer, Philipp Herold can be reached at:
Philipp Herold
Rudolf-Diesel-Straße 10
23617 Stockelsdorf, Deutschland
Tel.: +49 (0)451-4988023 / Fax: +49 (0)451-4988024
Email: philipp.herold@hub24.de

10. Status of this Notice

West may amend this Notice from time to time within the limitation of the applicable Data Protection Regulations.