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EU PRIVACY POLICY
General The Wackenhut Corporation Consulting and Investigation Services (“TWC C&I”) respects your concerns about maintaining the privacy of your personal data that is submitted to us by our clients in connection with the investigations, hotline services, and employment background and credential verification services that TWC C&I provides to such clients. These clients are the current and prospective employers of individuals who have submitted personal data in connection with their current or prospective employment. This Privacy Policy covers all the information practices of TWC C&I and describes the principles TWC C&I will follow with regard to information submitted by our clients via the TWC C&I web site and to other data that we collect from third parties and other sources in connection with the services we provide. All TWC C&I personnel, regardless of their location, will implement these principles. All data shall be collected, stored and used in compliance with applicable law, which may include the Fair Credit Reporting Act (“FCRA”), the European Union Data Protection Directive and other national laws. This Privacy Policy applies only to TWC C&I. This Privacy Policy does not apply to data collected by The Wackenhut Corporation, or by any of the business units of The Wackenhut Corporation, Inc. other than TWC C&I, nor does it apply to data collected on any other web site, including any web sites to which this site links. TWC C&I also respects the privacy of the personal data it processes on behalf of clients who may employ residents of the Member States of the European Union and in other countries, and to data they collect in those jurisdictions. This data is submitted or collected in connection with the employment background and credential verification services, ethics and compliance reporting services, or investigative or consulting services that TWC C&I provides to its clients. TWC C&I’s clients are the current and prospective employers of individuals who either submit data through the TWC C&I web site or who download forms from the TWC C&I web site for the purpose of submitting personally identifying information in connection with those services. TWC C&I Is Committed to Privacy and
Data Protection Around the World As a global company which does a considerable amount of business in the electronic marketplace, we believe that it is our responsibility to set industry-leading standards in our approach to the protection of personal data. We comply with federal, state and country-specific legal requirements applicable to the protection and dissemination of personal data. Aggregated Information Through this web site, TWC C&I collects and stores non-personal information in aggregate form. The data are collected and stored for internal statistical purposes. TWC C&I also collects and stores individual data to maintain and issue a unique session ID for individuals while they are at this site.
Personal Information o Use and Transfer of Information: Our clients may provide us with your personal information through our web site in connection with our preparing a report for such clients. Such personal information may include your history of employment and other credentials related to your prospective employment. If for pre-employment and credential verification services, TWC C&I will use such information only for the purposes of performing pre-employment screening and credential verification services, including to verify the accuracy of the personal information and to check on references. In addition to the data that is submitted to TWC C&I by our clients, TWC C&I may collect data from third parties, such as contact information, public records, biographical information, credit and other lawful checks. TWC C&I may prepare interview notes, comments from references and a record of our contact with individuals. We may provide all such information to our client (your current or prospective employer) in one or more reports. TWC C&I may also collect email correspondence from visitors to this site who send email to TWC C&I. If for ethics and compliance services, we will only collect that information that you knowingly enter by filling out the information form. In connection with these services, TWC C&I complies with the European Union Data Protection Directive and applicable national laws. In connection with these services, we may, in some instances, employ other companies and individuals, as our subcontractors, to perform functions on our behalf. All such contractors are contractually obligated to use and maintain the confidentiality of personal information in a manner consistent with this Privacy Policy. These companies may not share any such information with any third party, other than TWC C&I’s subcontractors or clients. Except as described in this Privacy Policy, we will not use or otherwise disclose any of the personal data that you provide or that we collect from third parties or other sources. o Confidentiality. We will never sell or provide personal data to a third party, except as provided in this Privacy Policy, without your express consent. Although we may hold or process your personal data that our client submits or that we collect from third parties or other sources. We may, however, disclose personal data in response to a court order or other legal obligation. In the highly unlikely event that a liquidator, administrator or receiver is appointed over TWC C&I or all or any part of our assets, we may transfer your information to a third-party purchaser of the business if that purchaser undertakes to only use your personal data as set out in this Privacy Policy. o Retention: Pursuant to the FCRA, we must maintain any reports that we generate for a minimum period of two years. Reports generated using data collected in or originating from a European Union Member State shall not be kept longer than necessary for the purpose of meeting our obligations to our client and the law. TWC C&I stores data electronically for a minimum of 5 years, or as otherwise required by our client. o Choice If you are a U.S. resident and you do not wish to have your personal data made available to our client (your current or prospective employer), please do not submit any such information to us through our client. By submitting information through you are agreeing to TWC C&I’s disclosure of information that is submitted about you to our client and to our sharing that information with TWC C&I for the purpose of data processing, as described above, and to our subcontractors. If you are an EU resident or reside in other countries where TWC C&I has registered with data protection authorities, and to data they collect in those jurisdictions, you may choose not to submit personal information to TWC C&I through its web site, phone lines or through forms downloaded from its web site for that purpose. If for background and credential verification services, you have been provided a consent form either by TWC C&I or by TWC C&I’s client. By filling out and submitting the consent form you expressly agree to provide personally-identifying information, and you consent to our use of that information in accordance with TWC C&I’s privacy policy. For ethics and compliance reporting, there is no consent form, but by voluntarily telephoning or filling out and submitting any forms, and if you volunteer any personally-identifying information, you consent to our use of that information in accordance with TWC C&I’s privacy policy. o Accuracy: Although we make every effort to ensure that the data we collect and store about you is as accurate as possible, TWC C&I does not vouch for, and is not responsible for, the accuracy of data about you that may be supplied by our clients or any other third-party sources of information. As provided in this Privacy Policy, you may have access (as described below) to personal data about you, including for the purpose of correcting any inaccuracies, pursuant to the FCRA and/or the European Union Data Protection Directive. o Access: If you are submitting an ethics and compliance report, we may also collect other information such as details about the specific workplace issue that you are reporting. All information submitted as part of an ethics and compliance report will only be shared with TWC C&I Communication Specialists and the company being reported. This will be done in a manner that protects your anonymity, should you choose to remain anonymous. You have the right to access that information only when you provide the secure file ID that is provided to you when you end a call. All subjects of consumer reports have the right of access to any reports TWC C&I produces and maintains on them. You may contact TWC C&I, as set out at the end of this Privacy Policy, at any time to determine whether we hold any personal information about you and to obtain access to that information. We will only afford you access to your data upon proof of identity, including proper verification and confirmation that you are the individual who is entitled to request access. If, for good reason, we are unable to provide you with access to your data or to correct data, we will let you know. Otherwise, we will mail to you if you are a U.S. resident a copy of the report about you within 7 days, as it has been provided to your current or prospective employer, at no charge (as mandated by the Fair Credit Reporting Act.). TWC C&I stores all personal information in electronic form. If you are an EU resident or a resident of any other country where TWC C&I conducts business and is registered with data protection authorities, you may contact us to determine whether we hold personal data about you, at any time for purposes of reviewing your personal information, for a nominal fee, which TWC C&I uses to cover administrative costs, of not greater than the equivalent of $15 USD. If you wish to have access to that information or to correct information that you have already received from us, please communicate with the The Wackenhut Corporation contact listed below. If for good reason, we are unable to provide you with access to your data or to correct your data, we will let you know. If you request access to your data, we will mail you within 48 days a copy of the report about you, as it has been provided to your current or prospective employer. o Security: TWC C&I will take all appropriate measures to assure the security of personal data. TWC C&I’s pre-employment and credential services web site and any data transmitted to or from it are protected by a secure socket layer (SSL) key that encrypts the data. All data is stored on our servers in a secure, encrypted manner. Access to those servers is strictly limited to network administrators and other authorized personnel of TWC C&I, who have been trained to protect against loss, misuse, unauthorized access, disclosure, alteration or destruction of personal data under TWC C&I’s control. We take pride in our technology and our security policies. o Other Inquiries or Questions: If you have a concern or complaint about our handling of your personally identifiable information, or if you believe our response to an inquiry has not been satisfactory, please contact our privacy officer at the address below. Our privacy officer will investigate and try to resolve in a timely manner any concern or complaint about our use or disclosure of your personally identifiable information in accordance with the principles contained in this Policy. For any concern or complaint that cannot be resolved in this way, we have agreed to cooperate with the American Arbitration Association to resolve any disputes relating this Policy. The American Arbitration Association can be contacted at www.adr.org or 1-800-778-7879. For concerns about our handling of human resources data, you also have the right to contact European Union Data Protection authorities. A listing of the Data Protection Commissioners is appended at the end of this notice. o Policy Changes: TWC C&I reserves the right to amend this Privacy Policy at any time without notice. If we decide to change this Privacy Policy, we will post those changes here so that you will always know how we will use the information that is collected about you. Regardless of any amendments to this Privacy Policy, we will never use your information in a material new way (a way not stated in the current privacy policy) without first providing you a direct and meaningful opportunity to opt-out or otherwise prevent that new use. Should you have any questions regarding this Privacy Policy, please contact:
The Wackenhut Corporation (Effective 10/2004)
NATIONAL OFFICES OF THE DATA PROTECTION COMMISSIONERS
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