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PRIVACY AT ADP


ADP'S PRIVACY COMMITMENT

ADP is committed to privacy and the protection of all personal data related to
ADP associates, contingent workers and job applicants, client employees and
workers, business contacts such as clients, prospects, website users or vendors.
ADP has adopted a set of privacy principles that serve as the foundation for our
global privacy program which are included in our Global Privacy Policy and our
Binding Corporate Rules (BCRs).

We are proud to have also achieved certification to ISO 27701, an international
standard for privacy information management. This represents another significant
milestone in our privacy commitment, by providing third party validation of our
implementation of privacy controls.

ADP’s Global Chief Privacy Officer is charged with leading and overseeing ADP’s
Global Privacy Programs, along with the members of the global privacy team. The
global privacy team may be contacted at privacy@adp.com.

ADP is also committed to upholding strong ethics as part of our core business
approach. ADP has adopted rigorous principles and processes to govern its use of
newer technologies, including real-time, operational monitoring of automated
decisions. We reflect this every day in our actions and commitments, including
placing a great focus on Privacy.

Our Global Privacy Policy


ARTIFICIAL INTELLIGENCE,
DATA & ETHICS

Automation fueled by artificial intelligence (AI) is helping transform
organizations, the way we work, and even the nature of the work itself. At ADP,
we’ve adopted a set of principles and processes to govern our use of newer
technologies like AI and machine learning.

Read more about Ethics in Artificial Intelligence


ISO 27701: 2019 IS AN INTERNATIONAL STANDARD FOR PRIVACY INFORMATION MANAGEMENT

Our ISO 27701 certification is an extension of our ISO 27001 security
certification and covers the same scope for our infrastructure in the U.S. and
EMEA.
For more information on our ISO 27001 certification, please see our Data
Security site.

ISO/IEC 27701: 2019 - SRI Certificate for US #4996-01/02/06
ISO/IEC 27701: 2019 - SRI Certificate for EMEA #4996-00-EUR-ISMS


TRANSPARENCY AND NOTICE

Whether you are a prospective or an existing client of ADP, a vendor or any
other business contact, a job applicant, a client employee or worker, a website
user, an ADP associate or a contingent worker, you will receive information as
to how ADP handles your personal data in the relevant ADP Privacy Statement that
is made available to you.

Privacy Statement for Business Contacts

Privacy Statement for Client Employees and Workers

Privacy Statement for Job Applicants


CHOICE AND CONSENT

When collecting your personal data, ADP is committed to respecting your choices
regarding the processing of such data. We will process your data for the
business purpose such data was collected. Under very limited circumstances as
described in our Binding Corporate Rules, ADP may process your data for a
legitimate secondary purpose that is closely related to the original purpose for
which such data was collected. If you are a Client employee or worker, ADP will
process your data in accordance with the instructions that we receive from our
Clients.


DATA MINIMIZATION AND ACCESS CONTROL

We collect and use only the minimum personal data necessary to achieve the
business purpose for which it was collected. When ADP processes your data,
access is granted based on specific roles and job functions.


DOCUMENTED DATA PROCESSING ACTIVITIES

We perform data flow mapping and regular privacy risk assessments (Privacy
Impact Assessments) on our data processing activities. We monitor and regularly
assess our company’s technology tools against industry standards. This enables
us to comply with privacy-related regulatory requirements, and keep an inventory
of our processing activities.


PRIVACY BY DESIGN

ADP has developed Privacy by Design Policies, Standards and Guidelines to assist
our Associates and Contingent Workers in using Privacy Enhancing Technologies
(PETs), for privacy protection purpose, and in implementing the Seven
Foundational Principles of Privacy by Design as adopted by the International
Assembly of Privacy Commissioners and Data Protection Authorities in 2010.

Our Privacy by Design (PbD) Policies, Standards and Guidelines set forth
requirements for the development and implementation of ADP Products and Services
throughout our entire product and services development life-cycles.

These requirements enable ADP to make our privacy guidance available upfront
during the ideation phases of our products and services. Both Privacy and
Security protections are enabled with our Privacy by Design strategy,
classifying data at its point of collection through properly destroying that
data at the end of its life-cycle. We are transparent with our users and
regularly review and update our Privacy Policies. Our products and services
enable users to exercise their privacy rights. We have embedded the foundational
concepts of Privacy by Design into our products and services, including but not
limited to data minimization, purpose specification, collection limitation and
use, retention and access control.


ACCESS AND ACCURACY

Where reasonable or required by law, ADP will provide information that you may
request regarding the data that ADP collected from you in accordance with our
Binding Corporate Rules. When processing personal data on behalf of its Clients,
ADP will provide assistance in addressing individuals’ rights requests, in
accordance with applicable law and contractual agreement with our Clients. ADP
is committed to provide you with a reasonable opportunity to examine your own
personal data and to update it if it is incorrect.


RETENTION, DELETION AND DESTRUCTION OF INFORMATION

ADP has implemented a Global Records Information Management (RIM) Policy,
covering the appropriate retention, maintenance, and deletion and/or destruction
of individuals’ personal data, Client information and company records.

Learn about Records Information Management


SECURITY

ADP’s Global Security Organization maintains administrative, technical and
physical controls to protect personal data entrusted to ADP. ADP’s incident
response process is designed to ensure that any incidents involving your
personal data are addressed, tracked and reported in a timely and effective
manner and in accordance with ADP security policies, procedures, and legal
requirements. When necessary, procedures for the notification of Clients,
individuals and all other parties who may be impacted by the incident are
initiated, and appropriate remedial actions are taken.

Learn more about our Global Security Organization


SUPERVISION OF THIRD PARTY PROVIDERS

ADP’s vendors must meet our data security and privacy standards. Our vendor
assurance process enables ADP to assess its vendors prior to entering into a
contract with them. Our vendors are contractually required to comply with ADP’s
privacy principles. We do not transfer personal data to third-party providers
other than to perform ADP services.


CROSS-BORDER TRANSFERS OF DATA

ADP will comply with applicable laws in case of transfer of personal data across
country borders. Where applicable, ADP shall also comply with its Binding
Corporate Rules for Client Data Processing Services (the Processor Code) which
provides the primary legal basis for transfers of personal data of our Clients’
employees from European locations to members of the ADP group located outside of
the European Economic Area (EEA).

ADP's Approach to International Data Transfers

Learn more


OVERSIGHT AND GOVERNANCE

As part of ADP’s enterprise risk assessment and risk management activities, our
Audit Committee of the Board of Directors oversees and reviews risk related to
privacy.

ADP’s Global Chief Privacy Officer is charged with leading and overseeing ADP’s
Global Privacy Programs, along with the members of the global privacy team. The
team works in cooperation with the representatives of our ADP business units and
functions, the ADP Privacy Stewards, the members of the ADP Legal department and
Compliance Professionals. Taking into account the sensitivity of the personal
data, ADP Associates and contingent workers who access personal data are trained
on the appropriate use and handling of personal data as it pertains to their job
responsibilities.

See ADP’s Privacy Governance

Learn more about Privacy at ADP

MEET OUR CLIENTS

We appreciate how ADP’s Next Gen HCM platform handles secure information. Our
clients require that we adhere to website content accessibility guidelines, and
we must be HIPAA compliant. Working in this platform provides all of that right
out of the box. We don’t have access to any personal data for the employees.
Everything lives on ADP’s platform and we’re able to provide functionality based
on attributes of that data, without actually seeing the data.



Alex Sherman General Manager, LifeMart (a division of Care.com)


READ HOW ADP IS HELPING YOU COMPLY WITH DATA PROTECTION AND PRIVACY LAWS

Complying with privacy laws across the globe

Download brochure

How ADP helps companies comply with GDPR

Download brochure
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