data ethics policy

INTRODUCTION AND BACKGROUND

At COWI, we commit to utilizing and processing data in an ethically sound manner across all facets of our business.

COWI employs software, algorithms and artificial intelligence in analyses and assessments aimed at optimising our decision-making processes and cultivating valuable, better and more sustainable solutions for our customers.

The purpose of this policy is to formalize COWI’s data ethics principles and articulate our intentions regarding data usage and processing, making it clear to our customers, employees, and other stakeholders that we are dedicated to these efforts.

OUR DATA EThICS PRINCIPLES

COWI's data ethics principles derive from our corporate values centred around 'doing the right thing, always'.

At COWI, we always comply with statutory regulations regarding data and privacy protection. However, we also acknowledge that ongoing technological change and development, alongside increasing risks and benefits from the utilisation of data, require thoughtful and responsible decision-making where existing laws and regulations may not necessarily suffice.

Thus, we have identified four main principles which, together with COWI's corporate values, serve as COWI's data ethical compass:

TRUST

In any professional relationship, trust is important – for COWI it is essential.

We consider a trustful relationship with our customers, employees, and other stakeholders as one of the greatest successes of a company and we strive to build and maintain the trust of the people and companies whose data we process by adhering strictly to our commitments in this policy.

INTEGRITY

For COWI, integrity in data use and processing is about prioritizing the safety and care of individuals and customers impacted by our solutions and processes. 

Hence, we are dedicated to ensuring that our data usage and processing practices consistently uphold and protect the fundamental rights, freedom, and safety of individuals.

TRANSPARENCY

COWI commits to providing transparency regarding the principles of any processing activities of data to our employees, customers, and other stakeholders to maintain their confidence in COWI.

Additionally, COWI will cooperate with and openly disclose our data, including access to and checks of COWI applied algorithms, to authorities when mandated by legislation or any court or authority decision, ensuring that such cooperation is in line with our ethical standards and considers the legitimacy and integrity of the requesting body.

SECURITY

COWI adheres to the fundamental principles outlined in the international standard for information security ISO/ICE 27001. These principles constitute an integral part of COWI's business and internal audit controls and are continuously upheld to ensure compliance with both information security and data protection requirements.

Data in COWI's possession is always processed and stored securely, thereby minimising the risk of data breaches.

COWI has adopted and implemented a number of policies of relevance to support this data ethics policy in line with applicable legislation, including a personal data protection policy, a business integrity policy and an IT security policy.

INTERNAL GOVERNANCE

The Executive Board of COWI Holding A/S has approved this policy and, based on input received from COWI's Digital Transformation Team, assesses at least once a year its content and sufficiency.

The administration of this policy is anchored with COWI's Digital Transformation Team to facilitate and ensure implementation in COWI's business units of the data ethics efforts as set out herein. 

The Digital Transformation Team is headed by COWI's Chief Business Development Officer, and its mandate to administer this policy is specified in terms of reference issued by COWI's Executive Board.

This policy applies to all COWI Group companies.

This Data Ethics Policy was approved and adopted by the Executive Board of COWI Holding A/S on January 20, 2022. This policy was last updated on January 12, 2024.