Data Ethics Policy/Statement

Introduction  

Millions of patients and healthcare professionals worldwide depend on the efficiency, safety, and performance of Ambu medical devices. We use computer programs, artificial intelligence and algorithms in analysis and evaluations to ensure increased welfare through continuous development of medical devices and improved treatment of patients.

Ambu acknowledge the concerns and ethical dilemmas in relation to the technological development, the large-scale data use, and the increased utilization of machine learning and artificial intelligence. We are therefore committed to balancing the potential benefits against the risks. Our commitment is based on the following principles:

• Compliance with applicable data and privacy laws and regulations
• Basic respect for employees’, customers’ and business partners’ data and personal data and focus on data security.
• Accountability in relation to the balance between benefits and risks associated with the use of data
• Openness and transparency in the collection, use of and storage of personal data and non-identifiable data.
• All employees who have access to personal data, trade secrets or other confidential information is bound by a confidentiality undertaking.
• Machine learning, AI and the like must be used to increase welfare.

Risk assessment 

Due to the nature of Ambu’s operations, the biggest data ethical challenges are in product development, including AI products, and in management of employee personnel data.

Policy

As stated in the Ambu Code of Conduct, Ambu maintain the highest ethical standards and comply with all applicable data and privacy laws and regulations.

Ambu expects employees to avoid and mitigate all negative data and privacy risks and to inform, through our management system or grievance mechanisms, any breach of this expectation or doubts that our expectations are being met.

Ambu expects its business partners to understand and address our expectations related to data ethics and to inform employees of Ambu or through Ambu’s grievance mechanism if expectations are not being met.

Ambu’s work with Data Ethics are made operational for each business area through internal policies and standard operating procedures.

Data Security

IT systems are developed with security as a main driver and ethics about how data is used in the system and shared with externals are part of the decision process. Ambu collaboration with authorities, both in relation to increase security and in relation to potential data leaks, and we act responsible through our procurement process to ensure that we only work with trusted third parties.

Design and transparency

Data Ethics are part of our design process for development of new products. Ambu ensures transparency about the purpose of new products and how data is used. We do not only pseudonymize data but anonymize data to the largest extent possible. 

Diversity

We ensure diversity in our employment to ensure insight into social, demographic, and financial differences that will support our data ethics principles and will avoid bias.  

Governance

The Board of Directors is overall responsible for this policy, including the adoption and renewal of the policy. The day-to-day operational responsibility is led by Corporate Business Ethics & Compliance, together with key stakeholders from Innovation, Corporate Legal and Corporate IT

Training

Employees who access the personal data of employees, customers or partners have signed a declaration of confidentiality and confidentiality clause and have completed an e-learning training on how to handle personal data.

Results

Ambu will monitor the implementation of the policy and will communicate about initiatives and results in the yearly Sustainability Report.

Version: 1
Approval date: 09/11/2021
Approver: Corporate Business Ethics and Compliance