COPC Handbook December 2023 Q4

10.3

10.5

Cell Phones, Smartphones, Texting While Driving and Communications in General

Access to Data Systems and Passwords Computer system passphrases are confidential and may never be shared with anyone. Employees are not permitted to bypass or attempt to override the established security systems in place. Employees are not to use accounts or passphrases issued to another employee. Should an employee need

will only be required to change it if the account becomes unsecured or compromised in some way. Employees must only use their passphrase for COPC Windows accounts and for no other accounts or services. Employees will never be asked for their passphrase; any attempt to retrieve a passphrase must be reported to the employee’s manager immediately. If an attempt at retrieving a passphrase is made, gather all possible information when reporting. Employees are required to log out or secure (lock) their workstation when away for any length of time. If access is required to a locked workstation, IT will be required to log the employee out and anything left open will be closed with the possibility of data loss.

● Cell phones should be turned off or set to “silent” or “airplane mode” during meetings or in locations where incoming calls may cause disruption. ● Some positions may require the use of a Company-subsidized cell phone or device. Do not use it while operating equipment, while around equipment or while driving a vehicle. This includes, but is not limited to, texting, talking or internet usage. ● When driving, employees must adhere to all Ohio (and/or any other state laws, as applicable) Department of Transportation federal, state, or local laws/rules regarding cell phone use. Employees who incur fines as a result of violating these laws/rules, will be solely responsible for such fines. ● When driving on Company time, employees may only use their cell phone if they are using a hands-free device or if they have pulled over to a safe area to complete the call.

COPC encourages employees to exercise sound business judgment when using cell phones, mobile devices, and/or smartphones in the workplace. Personal cell phone usage should not interfere with productivity or impact job performance, including making or receiving personal calls or sending or receiving text messages during work hours. Employees are reminded that using any device including those considered to be a “smartphone” for covert recording, scanning, or photocopying is in violation of COPC’s Confidentiality Agreement and may lead to disciplinary action, up to and including termination of employment. This policy is not intended to restrict in any way, employees’ rights under the National Labor Relations Act. It is necessary that employees use common sense and good safety guidelines when using communications devices. The following are some examples that must be strictly followed: Under no circumstances is an employee authorized to text while driving a personal vehicle while on Company time. Texting while driving is illegal in the state of Ohio (as well as in many other states). Employees are required to adhere to all Ohio (and/or any other state laws, as applicable) Department of Transportation federal, state, or local laws/rules regarding cell phone use as it relates to texting and driving.

to gain access into another user’s account, the manager should request approval from the CHRO of COPC. The passphrase will be reset for that account as appropriate, to maintain secure access. COPC uses passphrases as a security mechanism for all user accounts. Passphrases are, at minimum, twenty-six (26) characters in length and require some kind of special character (e.g. !,?,#). This passphrase will never expire, and users Email Employees must understand that any messages they send outside of the Company (i.e., over the internet) are not secure unless they are encrypted. Any email with PHI or PII must be encrypted when Data Confidentiality Employees should not disclose any of the data or information residing on the Company’s systems to anyone unless they are certain the person has the right and a need to receive it. The Company’s data and information should only be disclosed to non- Company personnel if the employee has received written permission from Company management. Proper Use of Data Systems Employees are prohibited from using the Company’s equipment or systems for any illegal purpose. Employees are also prohibited from attempting to interfere with or disrupt any network users, services, or equipment. Examples of such prohibited conduct includes forging, deleting, examining, copying, or modifying files and/ or data belonging to other users without their prior consent. Attempts to send unsolicited, nonbusiness-related junk mail, “for profit” messages, or chain letters is prohibited. Employees should not expect any privacy in creating, sending, or receiving communications in the workplace, regardless of whether they have been assigned

10.6

sent. Employees are not to initiate or forward chain emails. (Chain emails are sent to a number of people asking each recipient to send copies of the message to other people as well.)

10.7

In addition, employees may not remove any data or information from the Company’s systems in the form of tapes, discs, printed reports, USB drives, or any other media from the Company’s premises nor store any Company data in private, non- Company-owned cloud storage services, unless it is part of their normal job duties.

10.4

Monitoring Employee Data and Electronic Messages

In today’s legal environment, the courts require employers to monitor and oversee all its data control systems for inappropriate, illegal, and harassing activity. To meet these obligations, the Company will be reviewing employee email messages, voice mail messages, and internet trails on a regular basis, including employee mailboxes and recycle bins. Therefore, any messages created, received, stored, or sent on the Company’s equipment belongs to COPC and may be reviewed and distributed as it desires. Employees must understand that everything they write on a Company computer such as memos, letters, emails, and everything they receive on a Company computer, are never entirely deleted. The same is also true of many voicemail systems. Employees should take great care in what they write or say into any of the Company’s electronic communications systems. Furthermore, each

website employees visit on the Internet is permanently recorded on hard drives and possibly on the Company’s main server. Lastly, any mobile device or smart phone which interacts with COPC’s email system is subject to monitoring by the Company’s Mobile Device Management (MDM) system. Such systems have the capability of remotely updating devices to the latest approved OS, to remotely lock/disable/wipe the device, or to track its location. The MDM system does not, however, read the user’s email, catalog any apps downloaded by the user, or access the devices stored images. By connecting a mobile device to COPC’s email system, a user agrees to this monitoring. As a result, employees should never use the Company’s equipment improperly, since any data written, received, sent, or recorded using this technology leaves a permanent record of such information.

10.8

or use a password or security code. Further, employees should not expect any privacy in any of their communications, even those communications that have been deleted from the system, such as emails, since such messages may often be retrieved after being erased. COPC employees are not to use Company equipment in a manner that would violate any federal, state, or local laws, for personal gain, to send chain letters, to solicit money for religious or political organizations, for any use that might cause embarrassment to the Company or for any purpose unrelated to Company operations.

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Questions and concerns can be directed to your immediate supervisor, Human Resources (614) 304-2080 or the Compliance Hotline (866) 539-5813

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