Overview/Policy Statement
The Hartford prohibits the unauthorized or secret recording of confidential, proprietary or personal information and personal images or voices belonging to The Hartford or its employees, customers or clients.
“Unauthorized” means any purpose not approved by management.
“Recording” means the use of any device to capture images or voices, regardless of whether in person, by telephone or by other means, such as videoconferencing, screen shots, click-to-chat or in writing.
Rationale
The Hartford recognizes the need to protect its confidential, proprietary information from unauthorized disclosure while also avoiding deceptive practices that do not promote honest, ethical standards of business conduct.
Applying the Policy
- Consent Required for Audio and Video Recording. While some states permit recording by one party to a conversation, this policy prohibits such recordings without the consent of all parties to the conversation, regardless of the location of each party. If a participant at a meeting or conference speaks into a recording device (such as a microphone or video camera) or a recording indicator is activated including the display of a TEAMS recording notification message, then The Hartford considers that the participant had notice of the recording and consented to it. In situations where it may not be obvious or apparent to participants that the meeting is being recorded (such as no recording light or message exists or participation is by telephone), then the facilitator should notify all participants when they join the meeting that it will be recorded.
- Audio and Video Recording Prohibited. Meetings regarding the following, whether through TEAMS or another device, must not be recorded:
- Lawsuits and other legal proceedings, threatened litigation, or legal advice
- Sensitive customer or employee personally identifiable information, including social security numbers, full date of birth, financial information and medical information
- Actual claims or policy underwriting, including coverage, valuation, settlement, pricing, and benefits eligibility
- Information classified as Hartford Highly Restricted Information, including privileged or proprietary information of The Hartford, its customers, agents vendors and partners
- Personnel matters, including organizational talent reviews, candidate interviews, performance calibration, compensation decisions, performance reviews, performance or behavioral warnings, internal investigatory interviews, formal or informal coaching, or manager and employee one-on-one or check-in meetings
- Mergers and Acquisitions
- Material Non-Public Information (MNPI)
- Recorded Lines. In certain business environments, a recorded line device may be used to monitor or record telephone calls. The purpose is to ensure employees interact with customers in a manner that supports business goals. Under these circumstances, the business must notify employees and callers in advance that this type of monitoring may occur, either by use of an audible beep at periodic intervals during the telephone call or advance audio or written notice.
- Surveillance Cameras. The use of web cameras, spy or surveillance cameras in any Hartford facility is prohibited without prior, written authorization from Corporate Security.
- Data and Call Centers. No Recordings will be made in data or call centers without the prior, written permission of senior management of such centers.
- Corporate Communications. This policy does not prohibit the Marketing & Communications Department from creating Recordings within Hartford facilities. Projects using outside vendors to record such images must be directly supervised by the Marketing & Communications Department or a Hartford Manager responsible for the area involved to ensure that no Recording of confidential information occurs.
- The Hartford abides by all applicable federal, state and local laws and regulations regarding employees' rights. Likewise, it expects employees not to engage in activities that violate The Hartford's policies or applicable laws and regulations when using electronic communication devices for audio/video-recording or picture-taking purposes; if employees have any questions about what is considered to be a violation of policy or applicable laws and regulations when using electronic communication devices, they should contact their manager or Human Resources.
Frequently Asked Questions
Do I have to sign a consent form if I ask a question at a Town Hall Meeting?
No. A consent form is not required so long as participants are not secretly recorded.
Do employees have to sign consent forms before taking group videos or photos at business events?
No. A consent form is not required so long as participants are not secretly recorded or photographed and the recording is not used for external marketing or advertising purposes.
No. A consent form is not required so long as participants are not secretly recorded or photographed and the recording is not used for external marketing or advertising purposes.
When must an employee sign a consent form?
All employees are asked to provide consent at their time of hire to allow for recordings of their image or voice for business-related purposes such as training, marketing, and advertising. Employees who work in call centers or whose lines are recorded or monitored are also asked to acknowledge, in writing, that this practice is taking place.
Does this policy prohibit me from writing down confidential information belonging to Hartford customers?
No, so long as you make the recording for legitimate business reasons and your manager understands that your method, such as handwritten notes, takes place in order for you to do your job. In addition, you should exercise care to maintain the confidentiality of that information and consider using only the most reliable methods to do so. Finally, you should follow the proper protocols detailed in The Hartford’s policies related to record retention and destruction.
No, so long as you make the recording for legitimate business reasons and your manager understands that your method, such as handwritten notes, takes place in order for you to do your job. In addition, you should exercise care to maintain the confidentiality of that information and consider using only the most reliable methods to do so. Finally, you should follow the proper protocols detailed in The Hartford’s policies related to record retention and destruction.
Can I take screen shots of customer information and share with co-workers?
Only if your co-worker has a business related reason for seeing this confidential information.
Only if your co-worker has a business related reason for seeing this confidential information.
Does this policy apply to my cell phone’s camera or video function?
Yes. It applies to all work and personal devices that can record images and voices.
Yes. It applies to all work and personal devices that can record images and voices.
Scope
This policy applies to all employees, contractors, and visitors of The Hartford and its locations in the United States.
Revised: 11/15/24