SAFE HARBOR PRIVACY STATEMENT
Last Updated: September 29, 2015
To learn more about the Safe Harbor program, and to view Career Management International, Inc.’s certification, please visit http://www.export.gov/safeharbor/.
SAFE HARBOR BACKGROUND
The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions to enable U.S. companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the EEA to the United States (the “U.S.-EU Safe Harbor”). The EEA also has recognized the U.S.-EU Safe Harbor as providing adequate data protection (OJ L 45, 15.2.2001, p.47). The United States Department of Commerce and the Federal Data Protection and Information Commissioner (FDPIC) of Switzerland have agreed on a similar set of principles and frequently asked questions to enable U.S. companies to satisfy the requirement under Swiss law that adequate protection be given to personal information transferred from Switzerland to the United States (the “U.S.-Swiss Safe Harbor”). Consistent with its commitment to protect personal privacy, CMI adheres to the principles set forth in the U.S.-EU Safe Harbor and the U.S.-Swiss Safe Harbor (jointly referred to herein as the “Safe Harbor Principles”).
For purposes of this Policy, the following definitions shall apply:
“Agent” means any third party that collects or uses personal information under the instructions of, and solely for, CMI or to which CMI discloses personal information for use on CMI’s behalf.
“CMI” means Career Management International, Inc. in the United States.
“Personal information” means any information or set of information that identifies or could be used by or on behalf of CMI to identify an individual. Personal information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal information.
“Sensitive personal information” means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, views or activities, health status, information about financial benefits, or information on criminal or administrative proceedings and sanctions other than in the context of pending proceedings. In addition, CMI will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.
The privacy principles in this Policy have been developed based on the Safe Harbor Principles.
NOTICE: Where CMI collects personal information directly from individuals in the EEA and Switzerland, it will inform them about the purposes for which it collects and uses personal information about them, the types of non–agent third parties, if any, to which CMI discloses that information, the choices and means, if any, CMI offers individuals for limiting the use and disclosure of personal information about them, and how to contact CMI. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to CMI, or as soon as practicable thereafter, and in any event before CMI uses or discloses the information for a purpose other than that for which it was originally collected.
Where CMI receives personal information from its affiliates or other entities in the EEA, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.
CHOICE: CMI will offer individuals the opportunity to affirmatively and explicitly (opt-in) whether their personal information or sensitive personal information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
CMI will provide individuals with reasonable mechanisms to exercise their choices.
DATA INTEGRITY: CMI will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. CMI will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.
TRANSFERS TO BUSINESS PARTNERS/AGENTS: CMI will obtain assurances from its business partners/agents that they will safeguard personal information consistently with this Policy. Examples of appropriate assurances that may be provided by business partners/agents include: a contract obligating the business partner/agent to provide at least the same level of protection as is required by the relevant Safe Harbor Principles, being subject to EU Directive 95/46/EC (the EU Data Protection Directive), being subject to Swiss Federal Act on Data Protection, Safe Harbor certification by the business partner/agent, or being subject to another European Commission or Swiss FDPIC adequacy finding (e.g., companies located in Canada). Where CMI has knowledge that a business partner/agent is using or disclosing personal information in a manner contrary to this Policy, CMI will take reasonable steps to prevent or stop the use or disclosure.
ACCESS AND CORRECTION: Upon request to the address below, CMI will grant individuals reasonable access to personal information that it holds about them. In addition, CMI will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.
SECURITY: CMI will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.
ENFORCEMENT: CMI will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that CMI determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.
DISPUTE RESOLUTION: Any questions or concerns regarding the use or disclosure of personal information should be directed to the CMI Privacy Office at the address given below. CMI will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information by reference to the principles contained in this Policy.
For complaints that cannot be resolved between CMI and the complainant, CMI has agreed to JAMS Safe Harbor Alternate Dispute Resolution Program as the independent dispute resolution mechanism. Individuals who submit a question or concern to CMI and who do not receive acknowledgment from CMI of the inquiry or who think their question or concern has not been satisfactorily addressed should then contact the JAMS Safe Harbor Alternate Dispute Resolution Program on the Internet at http://www.jamsadr.com/file-safe-harbor-claim/. JAMS will act as a liaison to CMI to resolve these disputes.
LIMITATION ON APPLICATION OF PRINCIPLES
Adherence by CMI to these Safe Harbor Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; (b) to the extent necessary to meet national security, public interest or law enforcement obligations; and (c) to the extent expressly permitted by an applicable law, rule or regulation.
Questions or comments regarding this Policy should be submitted to the CMI Privacy Office by mail to:
CMI Privacy Office
Career Management International, Inc.
5373 West Alabama, Suite 420 Houston, Texas, 77056 U.S.A.
Or by sending an e-mail to firstname.lastname@example.org
EFFECTIVE DATE: September 29, 2015
You may also be interested in:
CMI’s Code of Business Conduct
CMI’s Acceptable Use Policy, Shared Data and Information Technologies