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Submission: On September 07 via manual from US — Scanned from DE
Submission: On September 07 via manual from US — Scanned from DE
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GREAT PLACE TO WORK® INSTITUTE, INC.
GLOBAL PRIVACY NOTICE
UPDATED FEBRUARY 1, 2022
Table of Contents
1. Information Collected
2. Websites
3. Purposes of Processing Your Personal Information and Potential Uses
4. Your Right to Access, Rectify, and Object to Your Personal Information
5. Safeguarding Your Personal Information
6. Links to Other Sites
7. International Data Transfers
8. GPTW EU-U.S. and Swiss-U.S. Privacy Shield Notice
9. Emprising™ Complies with All Global Data Security and Data Privacy Laws
10. Updates to Our Global Notice
11. How to Contact GPTW
Great Place To Work Institute Inc. (GPTW) and its licensed affiliates
(collectively, "GPTW Network") respect your privacy. This Global Privacy Notice
describes the types of personal information we collect, how we use the
information, with whom we share it, and the choices you can make about our use
of the information. We also describe the measures we take to protect the
security of the information and how you can contact us about our privacy
practices. Our privacy practices may vary among the countries in which we
operate to reflect local practices and legal requirements.
1. INFORMATION COLLECTED
GPTW collects information from you when you choose to share it with us through
or in connection with, but not limited to, our websites, events, conferences,
client engagements, survey and assessment tools, certification, and business
development activities. For example, when you share your personal information
with us to submit an inquiry through our websites, sign-up for our e-mail lists
or newsletters, register for an event or conference, apply for one of our Best
Companies to Work For and/or Best Workplaces lists, receive information about
our events, products and services, and/or contact you regarding a potential or
actual future, existing or current project or engagement. The information we
collect may include name, address, telephone number, mobile telephone number,
e-mail address, company name, job function, company industry, company size,
nature of your inquiry, the types of information you want to receive, event
information, dietary restrictions and meal preferences, and if you make a
purchase, credit/debit card number or other financial information.
2. WEBSITES
GPTW may use cookies, web beacons, pixel tags, log files, or other technologies
to collect certain information about visitors to and users of our websites to
monitor interactions with our emails, text messages and online advertisements.
For example, we may automatically collect certain information from you, such as
the type of web browser and operating system you use, the name of your Internet
Service Provider, Internet Protocol (“IP”) address, software version, coarse
geo-location information (for example, based on IP address or location of
cellular tower used for the connection), and/or the domain name from which you
accessed our websites. In addition, we may collect information about your
browsing behavior, such as the date and time you visit our sites, the areas or
pages of our sites that you visit, the amount of time you spend viewing or using
our websites, the number of times you return to our websites, other click-stream
or website usage data, and/or emails or ads that you open, forward or
click-through to our websites.
You can set your Internet browser or operating system settings to stop accepting
new cookies, to receive notice when you receive a new cookie, to disable
existing cookies, to omit images (which will disable pixel tags) or adjust your
tracking preferences. Note that the opt-out will apply only to the browser that
you are using when you elect to opt out of advertising cookies. Without cookies
or pixel tags though, you may not be able to take full advantage of our sites’
features. Check the “Tools” or “Help” tab on your browser to learn how to change
your cookie and other tracking preferences.
Our website may host various blogs, forums, wikis, and other social media
applications or services that allow you to share content with other users
(collectively “Social Media Applications”). Any personal information or other
information that you contribute to any Social Media Application can be read,
collected, and used by other users of that Social Media Application over whom we
have little or no control. Therefore, we are not responsible for any other
user’s use, misuse, or misappropriation of any personal information or other
information that you contribute to any Social Media Application.
GPTW may also use Google Analytics and other service providers to collect
information regarding visitor behavior and visitor demographics on our Services.
For more information about Google Analytics, please visit
www.google.com/policies/privacy/partners/. You can opt out of Google’s
collection and processing of data generated by your use of the Services by going
to http://tools.google.com/dlpage/gaoptout.
3. PURPOSES OF PROCESSING YOUR PERSONAL INFORMATION AND POTENTIAL USES
GPTW processes your information for the following purposes or may use your
information in the following ways:
* Respond to your inquiries or requests via the contact information you
provide, including, but not limited to, e-mail messages;
* Sign you up for, and provide you with, our newsletters and informative e-mail
messages, as well as those of other licensed affiliates within the GPTW
Network;
* Register you for our events and conferences, as well as those of other
licensed affiliates within the GPTW Network;
* Promote our events and conferences, as well as those of other licensed
affiliates within the GPTW Network;
* Provide you with information regarding our events, conferences, products and
services, as well as those of other licensed affiliates within the GPTW
Network;
* Register and consider your company for one of our and/or Best Workplaces
lists;
* Communicate and/or coordinate with you regarding potential or actual future,
current or past projects and engagements;
* Facilitate the purchase of our books, products, services or other offerings,
as well as those of other licensed affiliates within the GPTW Network;
* Develop new products and services;
* Address problems and review the usage and operations of our websites or
business, and improve our content, products, and services;
* Manage our telecommunications networks, as well as those of other licensed
affiliates within the GPTW Network;
* Process and archive scientific and historical research and statistical
analysis assessing workplace culture, performance, and accreditation to
assist organizations in evaluating and improving their workplaces;
* Protect the security or integrity of our sites and our business, as well as
those of other licensed affiliates within the GPTW Network;
* Facilitate or consider the sale of GPTW or one of our licensed affiliates to
another company;
* Investigate or prevent an actual or suspected crime or injury to ourselves or
others; and
* Respond to a request from law enforcement authorities or other government
officials, or as otherwise required by law.
4. YOUR RIGHT TO ACCESS, RECTIFY, AND OBJECT TO YOUR PERSONAL INFORMATION
You have the right to obtain the following information from us:
* Confirmation as to whether or not your personal information is being
processed by GPTW and
If we are processing your personal information:
* Purposes of the processing;
* Categories of data concerned;
* Recipients or categories of recipients to whom the personal information is
disclosed, including the identity of any service providers we use to process
your personal information on our behalf;
* Details of any transfers of your personal information to non-European
countries; and
* Copy of the personal information being processed and of any available
information as to the source of the information, except where prohibited by
law.
You have the right to obtain this information from us at reasonable intervals
and without excessive delay, unless we are prohibited by law from sharing such
information or where it is necessary to protect the rights and freedoms of
others.
GPTW takes reasonable care to ensure that your personal information is accurate,
and where necessary, kept up to date. If it is determined that your personal
information is inaccurate or out of date, we take every reasonable step to
correct it.
You can object to the processing of your personal information if it is processed
unlawfully. Further, if you allow us to process your personal information as
described in this Global Privacy Notice, you can later withdraw your consent at
any time (in which case, we will no longer process your personal information,
anonymize it or delete it, as appropriate).
To exercise any of these rights, please contact us as provided below.
5. SAFEGUARDING YOUR PERSONAL INFORMATION
GPTW employs commercially reasonable technical, physical, administrative and
organizational safeguards designed to protect the confidentiality, security and
integrity of your personal information, including measures aimed at protecting
personal information against accidental or unlawful destruction or accidental
loss, alteration, unauthorized disclosure or access, and against all other
unlawful forms of processing.
In addition, we contractually require all service providers that process your
personal information on our behalf to implement and maintain commercially
reasonable technical, physical, administrative and organizational safeguards
designed to protect your personal information.
6. LINKS TO OTHER SITES
GPTW tries to make sure that any links on our websites send you to a helpful and
reliable place on the Internet, but we are not responsible for the content of
these other websites or their privacy practices. We may also have “plugins”
(such as the Facebook “Like” button) to third-party sites or offer login (such
as log in with Facebook) through a third-party account. Third-party plugins and
login features, including their loading, operation and use, are governed by the
privacy notice and terms of the third-party providing them.
GPTW also provides links to the websites of other affiliates within the GPTW
Network. These websites are governed by the privacy notice and terms of the GPTW
Network affiliate providing them.
7. INTERNATIONAL DATA TRANSFERS
We may transfer the personal information we collect about you to recipients in
countries other than the country in which the information was originally
collected, including the United States of America. Those countries may not have
the same data protection laws as the country in which you initially provided the
information. When we transfer your information to other countries, we will
protect that information as described in this Global Privacy Notice or as
otherwise disclosed to you at the time the data is collected (e.g. via program
specific privacy notice).
GPTW is a global business. To offer our services, we may need to transfer your
personal information among several countries, including the United States, where
we are headquartered. We comply with applicable legal requirements providing
adequate safeguards for the transfer of personal information to countries
outside of the European Economic Area ("EEA") or Switzerland.
8. GPTW EU-U.S. AND SWISS-U.S. PRIVACY SHIELD PRIVACY NOTICE
GPTW complies with 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
regarding the collection, use, and retention of personal information that is
transferred from the European Union and Switzerland to the United States. GPTW
also expressly confirms that this commitment extends to personal data and/or
Human Resources data from the UK in reliance on the Privacy Shield. GPTW has
certified that it adheres to the Privacy Shield Principles. If there is any
conflict between the terms in this privacy policy and the Privacy Shield
Principles, the Privacy Shield Principles shall govern. To learn more about the
Privacy Shield program, and to view our certification, please visit
https://www.privacyshield.gov.
In compliance with the Privacy Shield Principles, GPTW commits to resolve
complaints about our collection or use of your personal information. EU and
Swiss individuals with inquires or complaint regarding our Privacy Shield policy
should first contact GPTW at: privacy@greatplacetowork.com; or write to us at:
Chief Data Protection Officer
Great Place To Work® Institute, Inc.
1999 Harrison Street, Suite 2070, Oakland, CA 94612
GPTW has further committed to cooperate with the panel established by the EU
Data Protection Authorities (DPAs) and the Swiss Federal Data Protection and
Information Commissioner (FDPIC) with regard to unresolved Privacy Shield
complaints concerning human resources data and non-human resources data
transferred from the EU and Switzerland.
GPTW receives and processes personal information from or relating to GPTW
Affiliates and other legally separate entities in the context of the provision
of products, services and support to these entities. Personal information
received by GPTW will be treated in accordance with their instructions or
pursuant to GPTW contractual arrangements with them consistent with the Privacy
Shield requirements. GPTW acts as a data processor with respect to this
information.
Individuals have rights under the Privacy Shield to access their personal
information and to limit use and disclosure of their personal information.
Please contact us if you wish to exercise these rights and we will refer any
requests to relevant data controllers and support them as needed in responding
to your request.
As a data processor, GPTW will disclose personal information only as authorized
by the relevant data controller. We may use a limited number of third-party
service providers to assist us in providing our services or in meeting internal
business operation needs. These third parties will access information only to
perform tasks on our behalf.
GPTW is accountable for the onward transfer of data to third party service
providers or agents who assist us in providing services. GPTW maintains
contracts with these third parties in compliance with our Privacy Shield
obligations and other obligations and accepts liability if those parties fail to
meet these obligations and we are responsible for the event giving rise to the
damages.
Personal Information may also be disclosed as part of a corporate transaction
such as a sale, divestiture, reorganization, merger or acquisition.
Disclosures of personal information may also be required to law enforcement,
regulatory, or other government agencies, professional bodies or to other third
parties, in each case to comply with legal or regulatory obligations or requests
and professional standards. GPTW will notify the applicable data controller of
any such request unless prohibited by law.
GPTW is subject to the investigatory and enforcement powers of the Federal Trade
Commission (FTC). Should you believe that your rights have been infringed, you
have the possibility, under limited circumstances, a binding arbitration option
may be available before a Privacy Shield Panel.
GPTW Privacy Shield Update
On July 16, 2020 the Court of Justice of the EU issued a Decision invalidating
the use of the Privacy Shield as a means to transfer personal data from the EU
to the US. The Decision did not invalidate the Privacy Shield itself and GPTW
continues to comply with its requirements. The Decision affirmed the use of the
2010 Standard Contractual Clauses (SCC) as a means of transferring personal data
from the EU to the US if the Company performs a two part “assessment” of GPTW.
First, GPTW must inform Company if it is unable to comply with the SCC, which
GPTW so warrants. Second, GPTW has put in place what is referred to in the
Court decision as “supplementary measures.” GPTW has incorporated all of the
SCC into the GPTW Products and Services Agreement which governs the terms of the
engagement with GPTW clients and which has the following link on the bottom of
the GPTW homepage: https://www.greatplacetowork.com/products-services-agreement
and will sign the SCC separately, if desired. One of the supplementary measures
implemented by GPTW is a Transparency Report. Initially pursuant to an agreement
with the U.S. Department of Justice and later Section 604 of the 2015 USA
Freedom Act, a number of tech companies have published statistics in
“Transparency Reports” about the production orders received from national
security and law enforcement authorities. Providers are allowed to disclose
aggregated statistics about the number of requests received pursuant to various
criminal and national security authorities, but given the non-disclosure orders
that generally accompany FISA and National Security Letters, disclosures are
limited to a preset number of data points and the use of general ranges of
numbers (“bands”). Since its incorporation as a business and through the date of
this Policy, GPTW has never received or been notified of a National Security
Letter, an order under the Foreign Intelligence Surveillance Act, or any other
classified request for user information pursuant to the national security laws
of the United States or any other country.” Such a declaration further bolsters
the proposition that reliance on SCC can ensure adequate protection for EU
citizen data, despite the existence of EO 12333, PPD 28 and FISA Section 702.
9. EMPRISING™ AND ALL GLOBAL DATA SECURITY AND DATA PRIVACY LAWS
The GPTW Emprising™ survey and analytics software platform operates by uploading
to Emprising an Employee Data File (EDF) containing an email address list for
the Company’s Employees taking the survey and, optionally, other information
such as pre-coded demographics etc. of the Company’s Employees. The EDF can be
uploaded to Emprising either GPTW or directly by the Company. The EDF is stored
encrypted in a separately partitioned area from the Company Employee Data which
contains the Survey Responses from the Company’s Employees. When the Company
Survey starts running, the email list from the EDF is used to generate a
Personalized Invite to each Company Employee which is a log-in identifier unique
to each Company Employee. When the Company Survey closes, the link is broken
between the EDF and the Company Employee Data containing the Survey Responses of
the Company Employees which disassociates and physically separates the EDF from
the Company Employee Data. After the survey closes, the Company Employee Data
does not contain the Company name, nor the name or email address of the Company
Employee, nor any Personal Information that can be used to identify the Company
Employee. As a result, the Company Employee Data is immediately de-identified
and made anonymous when the survey closes. Within five business days after
closing the Company Survey, the functionality of the survey is confirmed by GPTW
and the EDF is deleted.
The types and categories of Company Personal Data to be processed are found in
the demographic section and Trust Index questions of the survey. If the Company
chooses to include demographic data in the survey responses, that demographic
data is made part of the EDF which then populates the Survey Responses when the
Company Employee uses their unique log-in identifier to take their survey. After
the Company Survey closes, any demographic data remains a part of both the EDF
and the Company Employee Data. To protect the confidentiality of the Company
Employee Data, GPTW uses a suppression algorithm. GPTW will not report on
Assessment results in which fewer than five (5) people in a Company demographic
group have responded.
The personalized Invite explains that the results of the Survey will be used to
determine if the Company can be Great Place to Work-Certified, qualify to be on
one of the GPTW Best Companies To Work For and/or Best Workplaces lists and to
potentially publish a profile of your workplace on the GPTW website or the
website of one of the GPTW licensees or affiliates. The Company Employee is
assured that their participation is completely confidential and voluntary. The
Survey responses come directly to GPTW. Besides responding to statements and
demographics, and/or there may be open-ended questions soliciting an essay style
responses. The Company has the option to add additional open-ended questions.
The Company Employee is advised that should they choose to use their name or the
names of others in the essay style responses to the open-ended questions, they
will appear verbatim and the Company may read them.
Comments supplied may also be quoted in GPTW articles or reviews, but they will
never be associated with your name or other personally identifying information.
The nature and purpose as well as the subject matter and duration of the
Processing of the Company Personal Data is to collect Company employee survey
data for processing and archiving scientific and historical research purposes
and statistical purposes assessing workplace culture, performance, and
accreditation to assist organizations in evaluating and improving their
workplaces. This exact language is found in Article 89 of the GDPR.
The GPTW analytical survey platform named Emprising is hosted by the cloud
provider Microsoft Azure. GPTW contracts with Azure to maintain the highest
level of Data Security and Data Privacy global compliance at all times. This
legal protection is passed along to all GPTW clients though the warranties in
the Products and Services Agreement for the entire term of our engagement as
detailed below. The Azure audit reports and other resource documentation as
well as the Azure Compliance Manager Tool used by GPTW to comply with the GDPR
and other privacy laws are found at the following
URLs: https://servicetrust.microsoft.com/ and other compliance offerings:
https://www.microsoft.com/en-us/trustcenter/compliance/complianceofferings. A
general article about Azure compliance is here:
https://www.communicationsquare.com/news/everything-about-gdpr-compliance-in-microsoft-cloud/ and
a blog
here: https://azure.microsoft.com/en-us/blog/protecting-privacy-in-microsoft-azure-gdpr-azure-policy-updates/ There
are some country specific compliance resources as well. For example, compliance
in Germany is addressed at the following
URL: https://servicetrust.microsoft.com/ViewPage/GermanComplianceResourcesV3.
GPTW provides the highest standard of legal protection by warranting to our
clients that during the entire term of the engagement, GPTW has not received
notice of non-compliance with the following industry standards: CPA-audited
financial statements by the firm Abbott, Stringham & Lynch, the International
Organization for Standardization (ISO) for data security ISO 27001:2013,
business continuity management ISO 22301:2019, and quality management ISO
9001:2015 as well as the National Institute of Standards and Technology (NIST
2015) cybersecurity framework. If applicable, GPTW also complies with the
Payment Card Industry Data Security Standard (PCI DSS) through a third-party
provider. GPTW also provides these warranties and representations for the
GPTW Network even though it does not support Emprising. The Emprising survey
questions and responses never touch the GPTW Network. Any communication between
Emprising hosted on Azure and the GPTW Network is strictly limited to an
end-to-end secure VPN connection using IPSec protocol. Accordingly, GPTW
considers the third-party financial and security audits of the GPTW Network to
be for “restricted use” and confidential and does not release them to any
company.
GPTW maintains a Chief Data Protection Officer (CDPO) and a Certified Lead
Auditor (Auditor) for ISO 27001:2013 to ensure compliance with these industry
standards. The CDPO and Auditor report directly to the CEO and President of
GPTW.
GPTW will use commercially reasonable efforts consistent with industry standards
to collect, transmit, store, protect and maintain the Data and Company Data
obtained through the Services in accordance with the details provided in the
GPTW Global Privacy Policy found at the following
URL:https://www.greatplacetowork.com/privacy-policy. GPTW represents and
warrants that during the Term it complies with the European Union (EU) 2016
General Data Protection Regulation (GDPR), the California Consumer Protection
Act of 2018 AB 375 (CCPA), the Asia-Pacific Economic Cooperation (APEC) Cross
Border Privacy Rules, and the Data Protection Laws of all other country, state,
or regulating bodies. GPTW is also certified under the US/EU and US/CH Privacy
Shield. If needed, appended to this Agreement is an executed Standard
Contractual Clauses (new SCC) recited in the June 4, 2021 final Implementing
Decision released by the European Commission.. GPTW collects Data for processing
and archiving scientific and historical research purposes and statistical
purposes assessing workplace culture, performance, and accreditation to assist
organizations in evaluating and improving their workplaces. This exact language
is found in Article 89 of the GDPR. The types and categories of Company
Personal Data to be processed is found in the demographic section and Trust
Index questions of the survey. GPTW DOES NOT SELL PERSONAL DATA to any third
party.
As advised in the GDPR, GPTW maintains a full-time Chief Data Protection Officer
(CDPO) and staff to ensure compliance with all Data Protection Laws. The CDPO
reports directly to the CEO and President of GPTW. GPTW also employs full-time
a Certified Information Privacy Practitioner (CIPP) and a Certified Information
Privacy Manager (CIPM) who are certified by the International Association of
Privacy Professionals at www.iapp.org whose credentials are accredited by the
American National Standards Institute (ANSI) under the International
Organization for Standardization (ISO) standard 17024:2012.
10. UPDATES TO OUR GLOBAL POLICY NOTICE
Check this Global Privacy Policy from time to time, as we may change or update
portions of this statement at any time and without prior notice to you. If we
change or update this statement in a material way, we will process personal
information received under this Global Privacy Policy according to the terms of
this Global Privacy Policy, unless you consent otherwise.
11. HOW TO CONTACT GPTW
If you have any questions or comments about this Global Privacy Notice, GPTW's
privacy practices or if you would like us to update information or preferences
you provided to us, please e-mail us at: privacy@greatplacetowork.com; or write
to us at:
Timothy H. Gens | Vice President, Director Legal Affairs
Chief Data Protection Officer, Certified Information Privacy Practitioner
1999 Harrison Street, Suite 2070 Oakland, CA 94612
P: 415.844.2649 E: Tim.Gens@greatplacetowork.com
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