Privacy Shield Policy
Last updated Ė May 16, 2017
Survey Research Associates, Inc. ("SRA-Inc.") has adopted this Privacy Shield Policy ("Policy") to establish and maintain an adequate level of Personal Data privacy protection. This Policy applies to the processing of Personal Data that SRA-Inc. obtains from our client firms who have employees located in the European Union.
The Federal Trade Commission (FTC) has jurisdiction over SRA-Inc.'s compliance with the Privacy Shield.
All SRA-Inc. employees who handle Personal Data from Europe are required to comply with the Principles stated in this Policy.
Capitalized terms are defined in Section 14 of this Policy.
This Policy applies to the processing of Individual Customer Personal Data that SRA-Inc. receives in the United States concerning Individual Customers who reside in the European Union. SRA-Inc. provides management consulting services to client firms, to include 360 feedback surveys, upward review surveys and employee opinion surveys.
II. RESPONSIBILITIES AND MANAGEMENT
SRA-Inc. has designated the Corporate President to oversee its information security program, including its compliance with the EU Privacy Shield program. The Corporate President shall review and approve any material changes to this program as necessary. Any questions, concerns, or comments regarding this Policy also may be directed to Arthur.Wohlers@SRA-Online.com.
SRA-Inc. will maintain, monitor, test, and upgrade information security policies, practices, and systems to assist in protecting the Personal Data that it collects. SRA-Inc. personnel will receive training, as applicable, to effectively implement this Policy. Please refer to Section 7 for a discussion of the steps that SRA-Inc. has undertaken to protect Personal Data.
III. RENEWAL / VERIFICATION
SRA-Inc. will renew its EU Privacy Shield certification annually, unless it subsequently determines that it no longer needs such certification or if it employs a different adequacy mechanism.
Prior to the re-certification, SRA-Inc. will conduct an in-house verification to ensure that its attestations and assertions with regard to its treatment of Individual Customer Personal Data are accurate and that the company has appropriately implemented these practices. Specifically, as part of the verification process, SRA-Inc. will undertake the following:
C. Ensure that this Policy continues to comply with the Privacy Shield principles
D. Confirm that Individual Customers are made aware of the process for addressing complaints and any independent dispute resolution process (SRA-Inc. may do so through its publicly posted website, Individual Customer contract, or both)
E. Review its processes and procedures for training Employees about SRA-Inc.'s participation in the Privacy Shield program and the appropriate handling of Individual's Personal Data
SRA-Inc. will prepare an internal verification statement on an annual basis.
IV. COLLECTION AND USE OF PERSONAL DATA
SRA-Inc. provides various solutions to its Individual Customers who make use of its survey processes. SRA-Inc. makes use of Personal Data provided by client firms to provide customized survey solutions for those firms.† Information such as employee names and email addresses are used to communicate with a client firmís employees to send them email invitations to complete surveys, reminder messages, and in some cases survey results.
As a general matter, SRA-Inc. is provided the following types of Personal Data by its client firms: employee name, work email address, work mailing address, title, and employee ID.† For employee opinion surveys it may also include demographic information such as the personís department.† For 360 feedback and upward feedback it will typically include information on who the person has recently worked with.
We also may collect Personal Data from persons (potential client firms) who contact us through our website to request additional information on our services; in such a situation, we would collect contact information and any other information that the person chooses to submit through our website.
V. DISCLOSURES / ONWARD TRANSFERS OF PERSONAL DATA
SRA-Inc. does not disclose Personal Data to Third Parties. The only exception to this is when a client firm decides to make use of a new vendor for their upward review, 360 feedback, and/or employee survey processes. In such a case, SRA-Inc. will, at the client firmís request, either: (a) destroy all Personal Data provided to SRA-Inc. by that client firm, or (b) transfer the relevant Personal Data to the new vendor, but only if the new vendor agrees in writing to the same Privacy Shield non-disclosure conditions and accepts liability for any future violation of the same. However, should this change in the future, SRA will notify its customers and provide them with the option to op-out.
SRA-Inc. does not sub-contract any of its work to third parties, therefore no Personal Data is transferred onward. However, should this change in the future, SRA may potentially be liable for onward transfers to third parties.
SRA-Inc. will disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
VI. SENSITIVE DATA
SRA-Inc. does not collect Sensitive Data from its Individual Customers.
VII. DATA INTEGRITY AND SECURITY
SRA-Inc. uses reasonable efforts to maintain the accuracy and integrity of Personal Data and to update it as appropriate. SRA-Inc. has implemented physical and technical safeguards to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alternation, or destruction. For example, electronically stored Personal Data is stored on a secure network with firewall protection, and access to SRA-Inc.'s electronic information systems requires user authentication via password or similar means. SRA-Inc. also employs access restrictions, limiting the scope of employees who have access to Individual Customer Personal Data.
Further, SRA-Inc. uses secure encryption technology to protect certain categories of personal data. Despite these precautions, no data security safeguards guarantee 100% security all of the time.
IX. ACCESSING PERSONAL DATA
SRA-Inc. personnel may access and use Personal Data only if they are authorized to do so and only for the purpose for which they are authorized.
X. RIGHT TO ACCESS, CHANGE OR DELETE PERSONAL DATA
B. Requests for Personal Data. SRA-Inc. will track each of the following and will provide notice to the appropriate parties under law and contract when either of the following circumstances arise: (a) legally binding request for disclosure of the Personal Data by a law enforcement authority unless prohibited by law or regulation; or (b) requests received from the Data Subject. If SRA-Inc. receives a request for access to his/her Personal Data from an Individual Customer, then, unless otherwise required under law or by contract with such Individual Customer, SRA-Inc. will refer such Data Subject to the Individual Customer (client firm).
C. Satisfying Requests for Access, Modifications, and Corrections. SRA-Inc. will endeavor to respond in a timely manner to all reasonable written requests to view, modify, or inactivate Personal Data.
XI. CHANGES TO THIS POLICY
This Policy may be amended from time to time, consistent with the Privacy Shield Principles and applicable data protection and privacy laws and principles. We will make employees aware of changes to this policy either by posting to our intranet, through email, or other means. We will notify Customers if we make changes that materially affect the way we handle Personal Data previously collected, and we will allow them to choose whether their Personal Data may be used in any materially different manner.
XII. QUESTIONS OR COMPLAINTS
EU Individual customers may contact SRA-Inc. with questions or complaints concerning this Policy at the following address:
XIII. ENFORCEMENT AND DISPUTE RESOLUTION
In compliance with the US-EU Privacy Shield Principles, SRA-Inc. commits to resolve complaints about your privacy and our collection or use of your personal information. EU individuals with questions or concerns about the use of their Personal Data should contact us at Arthur.Wohlers@SRA-Online.com
SRA-Inc. commits to cooperate with EU data protection authorities (DPAs) and comply with the advice given by such authorities with regard to human resources data transferred from the EU in the context of the employment relationship.
XIV. DEFINED TERMS
"Individual Customer" means an Individual customer or clients of SRA-Inc. from EU. The term also shall include any individual agent, representative, of an individual customer of SRA-Inc. and all employees of SRA-Inc. where SRA-Inc. has obtained his or her Personal Data from such Individual Customer as part of its business relationship with SRA-Inc.
"Data Subject" means an identified or identifiable natural living person. An identifiable person is one who can be identified, directly or indirectly, by reference to a name, or to one or more factors unique to his or her personal physical, psychological, mental, economic, cultural or social characteristics.
"Employee" means an employee (whether temporary, permanent, part-time, or contract), former employee, independent contractor, or job applicant of SRA-Inc. or any of its affiliates or subsidiaries, who is also a resident of a country within the European Economic Area.
"Europe" or "European" refers to a country in the European Union.
"Personal Data" as defined under the European Union Directive 95/46/EC means data that personally identifies or may be used to personally identify a person, including an individual's name in combination with country of birth, marital status, emergency contact, salary information, terms of employment, job qualifications (such as educational degrees earned), address, phone number, e-mail address, user ID, password, and identification numbers. Personal Data does not include data that is de-identified, anonymous, or publicly available. "Sensitive Data" means Personal Data that discloses a Data Subject's medical or health condition, race or ethnicity, political, religious or philosophical affiliations or opinions, sexual orientation, or trade union membership.
"Third Party" means any individual or entity that is neither SRA-Inc. nor an SRA-Inc. employee, agent, contractor, or representative.