HAINAN AIRLINES DATA PROTECTION POLICY / CODE OF CONDUCT
1.1 This Policy gives important information about:
1.1.1 the data protection principles with which Hainan Airlines Holding Company Limited (hereinafter the "Company", "we", "us" or "our") must comply;
1.1.2 what is meant by personal information (or data) and sensitive personal information (or data);
1.1.3 how we gather and use personal information and sensitive personal information in accordance with the data protection principles under the General Data Protection Regulation (EU) 2016/679 ("GDPR") and the requirements of other relevant laws and regulations of other countries and regions; and
1.1.4 data subjects' rights and obligations in relation to data protection.
1.2 This Policy applies to all personal information collected by or on behalf of the Company, and may include personal information about its customers, potential customers, website visitors and job applicants. This Policy may be provided to you using a number of methods, including through the use of any of our websites, through the use of any of our mobile applications, through the use of telephone, or in-person at any of our retail locations.
1.3 We will review and update this Policy as we deem necessary or in accordance with our data protection obligations.
1.4 The Company may obtain, keep and use personal information (also referred to as personal data) about its customers, potential customers, website visitors and job applicants for a number of specific lawful purposes.
1.5 This Policy sets out how we comply with our data protection obligations and seek to protect personal information. Its purpose is also to ensure that our staff understand and comply with the rules governing the collection, use and deletion of personal information to which they may have access in the course of their work.
1.6 We are committed to complying with our data protection obligations, and to being concise, clear and transparent about how we obtain and use personal information, and how (and when) we delete that information once it is no longer required.
1.7 The Company’s Data Protection Officer has overall responsibility for addressing all issues relating to the protection of your personal information, and is responsible for assisting us in monitoring internal compliance, informing and advising on our data protection obligations and acting as a contact point for you and any supervisory authority. If you have any questions or comments about the content of this Policy or if you need further information, you can contact the following persons:
1.7.1 The Company's Data Protection Officer: [firstname.lastname@example.org]; or
1.7.2 The Company's EU representative: [email@example.com].
"criminal records information" means personal information relating to criminal convictions and offences, allegations, proceedings, and related security measures;
"data breach" means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal information;
"data subject" means the individual to whom the personal information relates;
"personal information" or "personal data" means information relating to an individual who can be identified (directly or indirectly) from that information;
"processing" means obtaining, recording, organising, storing, amending, retrieving, disclosing and/or destroying information, or using or doing anything with it;
"pseudonymised" means the process by which personal information is processed in such a way that it cannot be used to identify an individual without the use of additional information, which is kept separately and subject to technical and organisational measures to ensure that the personal information cannot be attributed to an identifiable individual;
"sensitive personal information" (sometimes known as "special categories of personal data" or "sensitive personal data") means personal information about an individual’s race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership (or non-membership), genetics information, biometric information (where used to identify an individual) and information concerning an individual’s health, sex life or sexual orientation.
"Websites" means any website(s) owned or operated by the Company.
3. DATA PROTECTION PRINCIPLES
3.1 The Company will comply with the following data protection principles when processing personal information:
3.1.1 we will process personal information lawfully, fairly and in a transparent manner;
3.1.2 we will collect personal information for specified, explicit and legitimate purposes only, and will not process it in a way that is incompatible with those legitimate purposes;
3.1.3 we will only process the personal information that is adequate, relevant and necessary for the relevant purposes;
3.1.4 we will keep accurate and up to date personal information, and take reasonable steps to ensure that inaccurate personal information are deleted or corrected without delay;
3.1.5 we will keep personal information in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the information is processed; and
3.1.6 we will take appropriate technical and organisational measures to ensure that personal information are kept secure and protected against unauthorised or unlawful processing, and against accidental loss, destruction or damage.
4. PRIVACY NOTICE
4.1 The Company may supplement this Policy by issuing privacy notices, informing you about the personal information that we collect and hold relating to you, how you can expect your personal information to be used and for what purposes.
4.2 We will take appropriate measures to provide information in privacy notices in a concise, transparent, intelligible and easily accessible form, using clear and plain language.
4.3 When personal information is collected
4.3.1 We collect personal information where it is necessary for us to conduct our everyday activities or functions.
4.3.2 Here are some examples of situations where we collect personal information:
(a) when you register for an account on our Websites, apps or kiosks;
(b) when you complete purchase orders, requests or applications for our products, services and/or facilities (by telephone, in person, by post, on forms, through our Websites or by any other means);
(c) when you communicate with us directly in relation to our products, services and/or facilities (by telephone, in person, by post, on forms, through our Websites or by any other means);
(d) when you use services and/or facilities that are made available on our Websites or at our physical locations;
(e) when you conduct certain types of transactions such as booking tickets, redeeming points for tickets, purchasing points, or refunds;
(f) when you enter, and when you interact with us during, any of our promotions, competitions, contests, lucky draws or special events;
(g) when you subscribe to any of our membership programmes;
(h) when you participate in our surveys and other types of research; or
(i) when you apply for employment with us.
4.3.3 We do not collect personal information from persons under the age of 16 without prior permission from a parent or a guardian. If you believe that we have accidentally collected personal information from a person under the age of 16 without the prior permission of a parent or guardian, please contact our Data Protection Officer at once under paragraph 1.7 of this Policy in order to have the relevant personal information erased. If you are under the age of 16, please do not proceed to provide us with any of your personal information through any means whatsoever unless you have first procured permission from your parent or your guardian.
4.4 What personal information is collected
4.4.1 The provision of your personal information is voluntary unless otherwise indicated as mandatory. If you do not provide any personal information to us which is mandatory, we may not be able to provide the products and/or services that you require of us.
4.4.2 The types of personal information which we may collect include the following:
(a) contact information such as names, addresses, telephone numbers, email addresses, delivery addresses and usernames;
(b) billing information such as billing address, bank card information and credit card information;
(c) unique information such as nationality and identity document information (including but not limited to identity card numbers, passport numbers, photographs and date of birth), occupational duties, health status and meal preferences;
(d) contact and marketing preferences;
(e) details of any membership that you have with us;
(f) details of your visits to our Websites, such as traffic data, location data, and the resources that you access on our Websites;
(g) details of your online identifiers, such as internet protocol addresses, cookie identifiers or other identifiers such as radio frequency identification tags;
(h) your transaction history with us; and
(i) if you are a candidate for employment, any personal information that you provide to us during the recruitment process including personal details from your resume and any application form that you submit to us. Such personal information may include your employment history and working eligibility rights.
4.4.3 You may, in certain circumstances, provide us with personal information relating to third parties (for example, your designated Fortune Wings Club beneficiaries, next-of-kin, traveling companion or, if you are a candidate for employment, any person whom you have nominated as your referee). When this happens, you are deemed to have represented and confirmed to us that you have obtained the consent of such third party to provide his/her personal information to us for processing in the manner set out in this Policy.
4.5 Purposes for collection, use and processing of personal information
4.5.1 The personal information which we collect from you may be collected, used, disclosed and/or processed for various purposes, depending on the circumstances at hand and your consent, including for example:
(a) to assess, process and provide our products, services and/or facilities requested by you; including but not limited to:
selling flight tickets, flight ticket and hotel packages, in-flight merchandise, etc.
sending you product or service booking confirmations
providing you with flight-related services, such as check-in, meals, seat selection, luggage services, transit accommodation, irregular flight guarantees and special passenger services
providing notifications and instructions related to products or services during your journey, such as instructions about boarding gates and baggage collection
(b) to provide you with any assistance that you have requested; including but not limited to:
related enquiries or information confirmation operations that you have authorized us to carry out
responding to your enquiries
assisting you with transaction operations
providing you with technical assistance
(c) to maintain and improve our customer relationship with you; including but not limited to:
inviting you to join the Fortune Wings Club
inviting you to participate in various satisfaction surveys
(d) to establish your identity; including but not limited to:
requesting that you present the relevant documents during check-in, boarding, baggage inspection and other procedures
informing you about login activity on your online account
(e) to administer and process any payments (including refunds) related to products, services and/or facilities or other commercial transactions requested by you; including but not limited to:
making order payments
handling your refund requests
fulfilling our compensation obligations
(f) to respond to your enquiries or complaints and resolve any issues and disputes which may arise in connection with any dealings between us;
(g) to provide you with information and updates on products, services, facilities, loyalty programmes, promotions, launches, campaigns, contests and/or events offered or organised by us and our affiliated partners from time to time, in accordance with your consent; including but not limited to
sending you event invitations
delivering or distributing prizes to you
for direct marketing purposes via SMS, phone, email, fax, mail, instant messaging, social media and/or any other appropriate communication channels, in accordance with your consent;
(i) to administer our loyalty or rewards programmes, including the use of airport lounges and the administration of the Fortune Wings Club;
(j) to engage in codesharing or similar business arrangements with other airlines;
(k) to cater to your dietary requirements when using our products, services and/or facilities;
(l) for internal administrative purposes and record-keeping;
(m) to send you seasonal greetings messages from time to time;
(n) to send you service or account change notifications and information when necessary;
(o) to monitor, review and improve our products, services, facilities, promotions and/or events; including but not limited to:
cookies used by our websites and apps
traffic analysis and performance monitoring tools used by our websites and apps
(p) to conduct market research or surveys, internal marketing analysis, customer profiling activities, analysis of customer patterns and choices, planning and statistical and trend analysis in relation to our products, services and/or facilities;
(q) to process, combine and/or analyse your personal information for the above purposes;
(r) for detecting, investigating and preventing fraudulent, prohibited or illegal activities;
(s) for our audit, risk management and security purposes;
(t) for enabling us to perform our obligations and enforce our rights under any agreements or documents that we are a party to;
(u) to transfer or assign our rights, interests and obligations under any agreements entered into with us;
(v) for meeting any applicable legal or regulatory requirements and making disclosure under the requirements of any applicable law, legislation, regulation, direction, court order, by-law, guideline, circular or code applicable to us from time to time ("Applicable Law");
(w) to enforce or defend our rights and your rights under, and to comply with, our obligations under any Applicable Law.
4.5.2 We will notify you in advance of any other purpose(s) for which we intend to use your data and obtain your consent where necessary, unless we are permitted by the GDPR or any other Applicable Law to process your personal information without your consent.
4.5.3 Please note that you have the right to object to the processing of your personal data for direct marketing purposes and the right to opt-out of any direct marketing from us and to unsubscribe from any SMS, phone, email, fax, mail, instant messaging, social media and/or other communication channels we use to engage in direct marketing with you. We will endeavour to provide instructions in all such communications on how to opt-out, but you may also contact our Data Protection Officer under paragraph 1.7 of this Policy if you wish to exercise your right to opt-out and are not clear how to exercise such right accordingly.
4.6 Transfer of personal information
4.6.1 In order to smoothly conduct our business operations and/or to fulfil our obligations to you, we may disclose the personal information that we have collected from you to third parties, for one or more of the purposes set out at paragraph 4.5 of this Policy. Examples of third parties to whom we may disclose your personal information include:
(a) other companies in our group, such as our sister airlines, for the purposes of paragraphs 4.5.1(a), 4.5.1(b), 4.5.1(i), 4.5.1(j) and 4.5.1(k).
(b) third party service providers, agents, affiliates or related companies who provide operational services in connection with our business such as data entry, telecommunications, information technology, logistics, storage and warehousing, catering, delivery, assembly, installation, printing and postal services, credit checks, credit facilities or services relating to marketing and promotional activity; including but not limited to:
providers of related supplementary services, such as hotels, insurance companies, logistics companies, food supply companies and sales product suppliers
information technology providers, such as TravelSky, Amadeus and Google
(c) our professional advisors, consultants and/or auditors; and
(d) relevant government regulators or authorities (in accordance with any Applicable Law). Including but not limited to:
public security agencies (such as the National Civil Aviation Public Security Big Data Operation & Training Center) to which we submit personal information for screening in the interests of public safety and anti-terrorism
4.6.2 The third parties with whom we conduct business are only authorised to use your personal information to perform the service for which they were hired. As part of our agreement with them, they may be required to adhere to the GDPR and/or any policies that we provide, and to take reasonable measures to ensure your personal information is secure.
4.7 Transfer of personal information of EEA data subjects out of the EEA
4.7.1 Due to the global nature of the services that we provide, it is sometimes necessary for us to share the personal information of data subjects in the EEA with parties outside the EEA, for example:
(a) with our offices outside the EEA;
(b) with our service providers located outside the EEA;
(c) if the data subject is based outside the EEA; or
(d) where there is an international dimension to the services we are providing to the data subject.
4.7.2 These transfers are subject to special rules under European data protection law.
4.7.3 The Company may transfer personal information outside the EEA to:
(a) a country, territory or organisation that is designated as having an adequate level of protection; or
(b) an organisation receiving the information that has provided adequate safeguards by way of binding corporate rules, standard data protection clauses or compliance with an approved code of conduct.
4.7.4 In the absence of a European Commission adequacy decision, or of appropriate safeguards, we may need to transfer personal information of an EEA data subject to non-EEA countries where this is necessary for the performance of a contract or the implementation of pre-contractual measures.
4.7.5 There may also be circumstances where we ask for the explicit consent of an EEA data subject to the transfer of personal information to a non-EEA country for purposes other than the performance of a contract or the implementation of pre-contractual measures. In such circumstances, we will inform the data subject of the increased risks of such transfer due to the absence of safeguards and the fact that these non-EEA countries (for example, the People's Republic of China) do not have the same data protection laws as the EEA.
4.7.6 We will, however, ensure that all transfers of personal information of EEA data subjects out of the EEA comply with the GDPR. Our practice is, wherever possible and applicable, to use standard data protection contract clauses that have been approved by the European Commission. Those clauses are available on the following website of the European Commission:
4.7.7 If you would like further information please contact the Data Protection Officer as shown at paragraph 1.7 of this Policy.
5. BASIS FOR PROCESSING PERSONAL INFORMATION
5.1 In relation to any processing activity we will, before the processing starts for the first time, and then regularly while it continues:
5.1.1 review the purposes of the particular processing activity, and select the most appropriate lawful basis (or bases) for that processing, i.e.:
(a) that the data subject has consented to the processing;
(b) that the processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
(c) that the processing is necessary for compliance with a legal obligation to which the Company is subject;
(d) that the processing is necessary for the protection of the vital interests of the data subject or another natural person; or
(e) that the processing is necessary for the purposes of legitimate interests of the Company or a third party, except where those interests are overridden by the interests of fundamental rights and freedoms of the data subject – see paragraph 5.2 of this Policy.
5.1.2 except where the processing is based on consent, satisfy ourselves that the processing is necessary for the purpose of the relevant lawful basis (i.e. that there is no other reasonable way to achieve that purpose);
5.1.3 document our decision as to which lawful basis applies, to help demonstrate our compliance with the data protection principles;
5.1.4 include information about both the purposes of the processing and the lawful basis for it in our relevant privacy notice(s);
5.1.5 where sensitive personal information is processed, also identify a lawful special condition for processing that information (see paragraph 6.2.2 of this Policy), and document it; and
5.1.6 where criminal offence information is processed, also identify a lawful condition for processing that information, and document it.
5.2 When determining whether the Company’s legitimate interests are the most appropriate basis for lawful processing, we will:
5.2.1 conduct a legitimate interests assessment ("LIA") and keep a record of it, to ensure that we can justify our decision;
5.2.2 if the LIA identifies a significant privacy impact, consider whether we also need to conduct a data protection impact assessment ("DPIA");
5.2.3 keep the LIA under review, and repeat it if circumstances change; and
5.2.4 include information about our legitimate interests in our relevant privacy notice(s).
6. SENSITIVE PERSONAL INFORMATION
6.1 Sensitive personal information is sometimes referred to as ‘special categories of personal data’ or ‘sensitive personal data’ (e.g. information about your health status).
6.2 The Company may from time to time need to process sensitive personal information. We will only process sensitive personal information if:
6.2.1 we have a lawful basis for doing so as set out in paragraph 5.1.1 above, for example, it is necessary to comply with the Company’s legal obligations or for the purposes of the Company’s legitimate interests; and
6.2.2 one of the special conditions for processing sensitive personal information applies, for example:
(a) the data subject has given explicit consent; including but not limited to:
when you request special passenger services from us, such as for passengers with wheelchairs or passengers requiring a stretcher
when you request refunds from us
(b) the processing is necessary for the purposes of exercising the employment law rights or obligations of the Company or the data subject;
(c) the processing is necessary to protect the data subject’s vital interests, and the data subject is physically incapable of giving consent;
(d) processing relates to personal data which are manifestly made public by the data subject;
(e) the processing is necessary for the establishment, exercise or defence of legal claims; or
(f) the processing is necessary for reasons of substantial public interest.
6.3 Before processing any sensitive personal information, our staff shall notify the Data Protection Officer of the proposed processing, in order that the Data Protection Officer may assess whether the processing complies with the criteria noted above.
6.4 Sensitive personal information will not be processed until:
6.4.1 the assessment referred to in paragraph 6.3 has taken place; and
6.4.2 the individual has been properly informed (by way of a privacy notice or otherwise) of the nature of the processing, the purposes for which it is being carried out and the legal basis for it.
6.5 During the recruitment process: the HR department, with guidance from the Data Protection Officer as necessary, will ensure that (except where the law permits otherwise):
6.5.1 during the short-listing, interview and decision-making stages, no questions are asked relating to sensitive personal information, such as race or ethnic origin, trade union membership or health;
6.5.2 if sensitive personal information is received, for example, the applicant provides it without being asked for it within his or her resume or during the interview, no record is kept of it and any reference to it is immediately deleted or redacted;
6.5.3 any completed equal opportunities monitoring form is kept separate from the individual’s application form, and not be seen by the person shortlisting, interviewing or making the recruitment decision;
6.5.4 ‘right to work’ checks are carried out before an offer of employment is made unconditional, and not during the earlier short-listing, interview or decision-making stages;
6.5.5 we will only ask health questions once an offer of employment has been made.
7.CRIMINAL RECORDS INFORMATION
7.1 7.1 We do not process criminal records information unless required to do so by relevant government authorities (for example, for immigration and security purposes) and under the control of the relevant official authority or authorities.
8.DATA PROTECTION IMPACT ASSESSMENTS (DPIA)
8.1 Where processing is likely to result in a high risk to an individual’s data protection rights, we will, before commencing the processing, carry out a DPIA to assess:
8.1.1 whether the processing is necessary and proportionate in relation to its purpose;
8.1.2 the risks to individuals;
8.1.3 what measures can be put in place to address those risks and protect personal information.
9.DOCUMENTATION AND RECORDS
9.1 We will keep written records of processing activities which are high risk (for example, which may result in a risk to individuals’ rights and freedoms or involve sensitive personal information or criminal records information), including:
9.1.1 the name and details of the employer’s organisation (and where applicable, of other controllers, the employer's representative and Data Protection Officer);
9.1.2 the purposes of the processing;
9.1.3 a description of the categories of individuals and categories of personal data;
9.1.4 categories of recipients of personal data;
9.1.5 details of cross-border transfers, including documentation of the transfer mechanism safeguards in place;
9.1.6 where possible, retention schedules; and
9.1.7 where possible, a description of technical and organisational security measures.
9.2 As part of our record of processing activities we document, or link to documentation, on:
9.2.1 information required for privacy notices;
9.2.2 records of consent;
9.2.3 controller-processor contracts;
9.2.4 the location of personal information;
9.2.5 DPIAs; and
9.2.6 records of data breaches.
9.3 If we process sensitive personal information or criminal records information, we will keep written records of:
9.3.1 the relevant purpose(s) for which the processing takes place, including (where required) why it is necessary for that purpose;
9.3.2 the lawful basis for our processing; and
9.3.3 whether we retain and erase the personal information in accordance with our policy documents (including this Policy) and, if not, the reasons for not following our policy.
9.4 We will conduct regular reviews of the personal information we process and update our documentation accordingly. This may include:
9.4.1 carrying out information audits to find out what personal information the Company holds;
9.4.2 distributing questionnaires and talking to staff across the Company to get a more complete picture of our processing activities; and
9.4.3 reviewing our policies, procedures, contracts and agreements to address areas such as retention, security and data sharing.
10.RIGHTS IN RELATION TO PERSONAL INFORMATION
10.1 All data subjects have the following rights in relation to their personal information:
10.1.1 to be informed about how, why and on what basis that information is processed – see paragraph 4 of this Policy regarding the Company’s privacy notices;
10.1.2 to obtain confirmation that your information is being processed and to obtain access to it and certain other information, by making a subject access request – see paragraph 10.3 below;
10.1.3 to have data corrected if it is inaccurate or incomplete;
10.1.4 to have data erased if it is no longer necessary for the purpose for which it was originally collected/processed, or if there are no overriding legitimate grounds for the processing (this is sometimes known as ‘the right to be forgotten’);
10.1.5 to restrict the processing of personal information where the accuracy of the information is contested, or the processing is unlawful (but the data subject does not want the data to be erased); and
10.1.6 to restrict the processing of personal information temporarily where you do not think it is accurate, or where you have objected to the processing.
10.2 If you wish to exercise any of the rights in paragraph 10.1 above, please contact the Data Protection Officer as shown at paragraph 1.7 of this Policy.
10.3 Subject access requests
10.3.1 The Company will seek to comply with subject access requests and to provide the appropriate data within one month of a request being made. Where this isn't possible, the data subject will be kept informed. The Company may take professional advice about how to comply with any request, to ensure that appropriate information is provided. Usually there will be no charge for providing the information.
10.3.2 In the unlikely event of manifestly unfounded or repetitive requests, the Company may decide not to provide information. However professional advice will be taken in those circumstances.
11.1 The Company will use appropriate technical and organisational measures to keep personal information secure, and in particular to protect against unauthorised or unlawful processing and against accidental loss, destruction or damage. These may include:
11.1.1 making sure that, where possible, personal information is pseudonymised or encrypted;
11.1.2 ensuring the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
11.1.3 ensuring that, in the event of a physical or technical incident, availability and access to personal information can be restored in a timely manner; and
11.1.4 a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing.
11.2 Where the Company uses external organisations to process personal information on its behalf, additional security arrangements will need to be implemented in contracts with those organisations to safeguard the security of personal information. In particular, contracts with external organisations will provide that:
11.2.1 the organisation may act only on the written instructions of the Company;
11.2.2 those processing the data are subject to a duty of confidence;
11.2.3 appropriate measures are taken to ensure the security of processing;
11.2.4 sub-contractors are only engaged with the prior consent of the Company and under a written contract;
11.2.5 the organisation will assist the Company in providing subject access and allowing individuals to exercise their rights in relation to data protection;
11.2.6 the organisation will assist the Company in meeting its obligations in relation to the security of processing, the notification of data breaches and data protection impact assessments;
11.2.7 the organisation will delete or return all personal information to the Company as requested at the end of the contract; and
11.2.8 the organisation will submit to audits and inspections, provide the Company with whatever information it needs to ensure that they are both meeting their data protection obligations, and tell the Company immediately if it is asked to do something infringing data protection law.
12.RETENTION OF PERSONAL INFORMATION
12.1 Personal information (and sensitive personal information) should not be retained for any longer than necessary. The length of time over which data should be retained will depend upon the circumstances, including the reasons why the personal information was obtained. In general, personal information will be retained as long as is necessary, or for 7 years after it is no longer in use, whichever is earlier.
12.2 Personal information (and sensitive personal information) that is no longer required will be deleted permanently from our information systems and any hard copies will be destroyed securely.
13.1 A data breach may take many different forms, for example:
13.1.1 loss or theft of data or equipment on which personal information is stored;
13.1.2 unauthorised access to or use of personal information either by a member of staff or third party;
13.1.3 loss of data resulting from an equipment or systems (including hardware and software) failure;
13.1.4 human error, such as accidental deletion or alteration of data;
13.1.5 unforeseen circumstances, such as a fire or flood;
13.1.6 deliberate attacks on IT systems, such as hacking, viruses or phishing scams; and
13.1.7 ‘blagging’ offences, where information is obtained by deceiving the organisation which holds it.
13.2 In the event of a data breach, the Company will act in accordance with its Data Breach Disclosure Plan without undue delay.
14.1 At any time, if you
14.1.1 have any complaints, grievances
or comments regarding how we are handling your personal information or about our
compliance with the GDPR or any other applicable data protection law; or
14.1.2 wish to revoke any consent you have previously given to us to use your personal information;
we welcome you to contact our Data Protection Officer and/or our EU Representative using the contact details provided under paragraph 1.7 of this Policy. We will strive to deal with any complaints, grievances or comments that you may have speedily and fairly.