Electronic Monitoring Policy

Overview / Policy Statement

Applying the Policy

• Employees should have no expectation of privacy in any electronic communications or computer activities, conducted on or through The Hartford’s Systems. “The Hartford’s Systems” has the meaning set forth in the Electronic Communications Policy. The Company may monitor, intercept, access, collect, or review, at any time and by lawful means, information relating to:
  • Email, messaging and other electronic communications sent, received or stored on The Hartford’s Systems;
  • Telephone calls or transmissions, including call monitoring or recording where permitted by law;
  • Internet access and usage, including websites visited and network traffic;
  • Computer, application, and system usage, including log-in information, activity logs, keystrokes, timekeeping data, and related metadata;
  • Video monitoring in workplace areas (excluding restrooms, locker rooms, or other legally protected areas);
  • Location, device, and driving-related data generated through the use of company-owned or leased vehicles and related systems, including route information, vehicle location, and driver performance such as speed, braking, acceleration, idle time, safety events, and similar operational metrics; and
  • Building and facility access information, including entry, exit, and movement within the Company facilities or secured areas through keycard, badge, or similar access control systems, as such monitoring supports security, safety, access control, workplace management, and compliance with legal and regulatory obligations.
• The Hartford’s Systems are provided for business use and may contain proprietary and confidential information belonging to The Hartford, its customers, or suppliers. Employees must comply with all applicable policies, including the Electronic Communications Policy.
• Limited personal use of The Hartford's Systems is permitted only as described in the Electronic Communications Policy. Any such use may be monitored and reviewed in accordance with this Policy and applicable law. 
• To the extent permitted by law, continued use of The Hartford’s Systems constitutes ongoing consent to the monitoring described in this Policy.
• Surveillance equipment (e.g., webcams, hidden cameras) may not be used in any Hartford facility without prior written authorization from the Head of Corporate Security.
• Personal devices classified as dual-use devices are subject to the Mobile Device Policy and may be monitored when used to access Company systems.

Monitoring Specific to Customer-Facing Employees

• Customer-facing employees whose roles involve frequent interaction with insureds, claimants, potential customers and/or other third-parties may have their work-related computer and phone activities monitored and recorded by the Company, including through the use of third-party monitoring technology. The purpose of this monitoring and recording is to support operational efficiency, quality assurance, compliance and other legitimate business needs.
  • What May Be Monitored and/or Recorded: The monitoring tools may capture and/or record information related to the use of The Hartford’s Systems, including but not limited to:
    • Telephone interactions (e.g., call activity, call recordings);
    • Computer activity (e.g., screen activity, keystrokes, application usage);
    • Role specific productivity, service, or compliance-related metrics ; and
    • Real-time and/or recorded viewability of certain on-screen work functions when required for training, coaching, quality assurance or compliance reviews. 
  • Monitoring of customer-facing employees is conducted only for legitimate business purposes by authorized personnel with a legitimate business need.
  • The Company’s third-party technology vendors may have access to such recordings for business purposes.

Scope