Privacy Shield Statement
As set forth in Ward Howell's Global Code of Conduct: "We respect the confidentiality and privacy of our clients, our people and others with whom we do business."
Ward Howell International and its affiliated US subsidiaries (“Ward Howell,” “we,” “us,” or “our”) complies with the requirements of the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce (the “Principles”). Ward Howell has certified that it adheres to the Principles with respect to personal information (as described below) that is transferred from the European Union and its Member States, the European Economic Area, the United Kingdom and/or Switzerland (“EU”) to the United States. If there is any conflict between the terms in this Privacy Shield Policy and the Principles, the Principles shall govern. Ward Howell is subject to investigatory and enforcement powers of the U.S. Federal Trade Commission.
This Privacy Shield Policy applies to personal information within the scope of Ward Howell’s Privacy Shield certification, which covers the following categories of information:
For the purposes of this Privacy Shield Policy, “personal information” means information that is about, or pertains to a specific individual and can be linked either directly or indirectly to that individual. In addition, certain personal information covered by Ward Howell’s Privacy Shield certification may be subject to more specific privacy policies of Ward Howell, which are also consistent with the requirements of the Principles, and in the case of any conflict between these policies and the Principles, the Principles will control.
Individual Notice and Choice
We collect and process personal information from certain individuals and for the purposes described in this Privacy Shield Policy. Personal information covered by this Privacy Shield Policy is collected and processed only as permitted by the Principles.
Notice to individuals regarding the personal information collected from them and how that information is used may be provided through this Privacy Shield Policy, other Ward Howell website notices, or other direct forms of communication with appropriate parties, such as contracts or agreements. Where necessary and appropriate, consent for personal information to be collected, used, and/or transferred may also be obtained through these same means of communication (including opt-in consent for sensitive personal information).
Disclosures & Accountability for Onward Transfers
Consistent with the Principles, Ward Howell may transfer personal information to third parties, including transfers from one country to another. We will only disclose an individual’s non-public personal information to third parties under one or more of the following conditions:
Individuals whose personal information is covered by this Privacy Shield Policy have the right to access the personal information that Ward-Howell maintains about them as specified in the Principles. Individuals may contact us to correct, amend or delete such personal information if it is inaccurate or has been processed in violation of the Principles (except when the burden or expense of providing access, correction, amendment, or deletion would be disproportionate to the risks to the individual’s privacy, or where the rights of persons other than the individual would be violated). Requests for access, correction, amendment or deletion should be sent to: firstname.lastname@example.org.
Security Ward Howell takes appropriate measures to protect personal information in its possession to ensure a level of security appropriate to the risk of loss, misuse, unauthorized access, disclosure, alteration, and destruction. These measures take into account the nature of the personal information and the risks involved in its processing, as well as best practices in the industry for security and data protection.
Data Integrity and Purpose Limitation
Ward Howell collects and processes personal information only to the extent that it is compatible with the purposes for which it was collected or subsequently authorized by the data subject. Ward Howell does not retain personal information after it no longer serves the purposes for which it was collected or subsequently authorized. Ward Howell takes reasonable steps to ensure that personal information is accurate, complete, current, and reliable for its intended use.
In compliance with the Principles, Ward Howell commits to resolve complaints about our collection or use of your personal information. Individuals with inquiries or complaints regarding our Privacy Shield Policy should first contact Ward Howell at: email@example.com. Ward Howell has a policy of responding to individuals within forty-five (45) days of an inquiry or complaint. If an individual has an unresolved complaint or concern that is not addressed satisfactorily, that individual may contact our U.S. based third party dispute resolution provider (free of charge), the International Centre for Dispute Resolution/American Arbitration Association ("ICDR/AAA"). Please contact or visit ICDR/AAA for more information or to file a complaint. If the dispute involved human resources personal information, or information collected in the context of an employment relationship, we will cooperate with the competent EU or Swiss data protection authorities and comply with the advice of such authorities.
You may have the option to select binding arbitration under the Privacy Shield Panel for the resolution of your complaint under certain circumstances. For further information, please see the Privacy Shield website. To learn more about the Privacy Shield Framework, and to view Ward Howell’s certification, please visit https://www.privacyshield.gov.
Ward Howell may update this Policy at any time by publishing an updated version here. We will not update this Privacy Shield Policy in contravention to the Principles so long as we remain certified to the Privacy Shield.