Prehire, Inc. EU – U.S. Privacy Shield Policy
Prehire, Inc. respects individual privacy and values the confidence of its customers, employees, consumers, business partners and others. Not only does Prehire strive to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business, it also has a tradition of upholding the highest ethical standards in its business practices. This EU-U.S. Privacy Shield Policy (the “Policy”) sets forth the privacy principles that Prehire, Inc. follows with respect to transfers of personal information from the EU (EU) to the United States.
Compliance with EU-U.S. Privacy Shield Principles
The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions (the “EU-U.S. Privacy Shield Framework”) to enable U.S. companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the EU to the United States.
Prehire, Inc. recognizes that the European Community has established a data protection regime which applies to the European Economic Area (“EEA”) and restricts companies in the EEA in transferring personal data about individuals in the EEA to the United States, unless there is “adequate protection” for such personal data when it is received in the United States. To create such “adequate protection,” Prehire Corp adheres to the EU-U.S. Privacy Shield Framework published by US Department of Commerce (“EU-U.S. Privacy Shield Principles”) with respect to personal data about individuals in the EEA that we receive from our customers and other business partners. Prehire’s EU-U.S. Privacy Shield Certification also extends to data that we receive directly through Prehire’s publicly accessible websites via secure form submission (any of our websites such as www.interviewed.com). More information on the EU-U.S. Privacy Shield and Prehire’s scope of participation in the EU-U.S. Privacy Shield Framework is available at www.privacyshield.gov/welcome.
Adherence to EU-US Privacy Shield Principles
Client Personal Data processed or stored by Prehire, Inc. may be subject to contractual agreements with our clients that require more stringent privacy and security safeguards than the requirements in the EU-U.S. Privacy Shield. At a minimum, however, Prehire, Inc. handles Client Personal Data in accordance with our EU-U.S. Privacy Shield Policy, which is based upon the seven principles identified in the EU-U.S. Privacy Shield Framework.
This Notice addresses data subjects residing in the EU (“EU Persons”) whose data we may receive from one of our customers, suppliers or other business partners in the EU e.g., referral partners, integration partners, etc. When Prehire, Inc. receives Client Personal Data for processing pursuant to instructions of clients or their partners, we are acting as an agent for our client and do not provide notice to individuals regarding the collection and use of their personal data. Our clients remain responsible for providing notice, if and to the extent they believe such notice is necessary under applicable EU law.
Business Purposes for the Collection and Use of Personal Data
Prehire, Inc. sells and maintains web-based job application coordination and job assessment software primarily for small, midsize and enterprise businesses. We receive job applicant data from individuals in the EU such as contact information, resumes, and other job-relevant data including without limitation, names, addresses, phone numbers, email addresses, etc. of EU Persons (“EU Data”). In connection with these services our customers use our hosted technology platform to store and process EU Data at their own discretion.
Prehire, Inc. collects and uses EU Data for purposes of providing products and services to our customers, communicating with corporate business partners about business matters, processing EU Data on behalf of corporate customers, providing information on our/their services, and conducting related tasks for legitimate business purposes.
Accountability of Onward Transfer
Prehire, Inc.’s accountability for personal data that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Everyone Counts remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless Everyone Counts proves that it is not responsible for the event giving rise to the damage. Prehire, Inc. will not transfer any personal information to a third-party without first ensuring, via written contract, that the third-party handles the data under the same level of protection as set forth in this policy. Prehire, Inc. does not transfer Client Personal Data to unrelated third parties, unless lawfully directed by a client, or in certain limited or exceptional circumstances in accordance with the EU-U.S. Privacy Shield Framework. For example, such circumstances would include disclosures of Client Personal Data required by law or legal process, or disclosures made in the vital interest of an identifiable person such as those involving life, health or safety.
Please be aware that Prehire, Inc. may be required to disclose an individual’s Personal Data in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
In the event that Prehire, Inc. is requested to transfer Client Personal Data to an unrelated third party, Prehire, Inc. will ensure that such party will enter into a written agreement with the third party requiring them to provide protections consistent with the EU-U.S. Privacy Shield Framework and Prehire, Inc.’s EU-U.S. Privacy Shield Policy. Should Prehire, Inc. learn that an unrelated third party to which Personal Data has been transferred by Prehire, Inc. is using or disclosing Personal Data in a manner contrary to this Policy, Prehire, Inc. will take reasonable steps to prevent or stop the use or disclosure.
Contact information and Client Personal Data is accessible only by those Prehire, Inc. employees and consultants who have a reasonable need to access such information in order for us to fulfill contractual, legal and professional obligations. All of our employees and consultants have entered into strict confidentiality agreements, and/or have been subjected to thorough criminal background checks requiring that they maintain the confidentiality of Client Personal Data.
Prehire, Inc. assures compliance with this EU-U.S. Privacy Shield Policy and the EU-U.S. Privacy Shield Framework by utilizing the self-assessment approach as specified by the U.S. Department of Commerce. The assessment is conducted on an annual basis to ensure that all of Prehire, Inc.’s relevant privacy practices are being followed in conformance with this EU-U.S. Privacy Shield Policy and the EU-U.S. Privacy Shield Framework. Any employee that Prehire, Inc. determines is in violation of these policies will be subject to discipline, up to and including termination of employment and/or criminal prosecution.
Prehire, Inc. is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
For complaints that cannot be resolved by Prehire, Inc. and the complainant, Prehire, Inc. agrees to cooperate with BBB EU Privacy Shield – an independent dispute resolution mechanism, pursuant to the EU-U.S. Privacy Shield Framework.
With respect to emails, EU Persons may opt-out of receiving further email communications from Prehire or Prehire clients by following opt-out instructions that are contained in the bottom of the email communication you received.
EU-U.S. Privacy Shield Policy Updates
This EU-U.S. Privacy Shield Policy may occasionally be updated. When material updates are made, the date of the last revision will be reflected at the end of the page. This page may be bookmarked to facilitate periodic review of this EU-U.S. Privacy Shield Policy and to note recent updates. Neither this EU-U.S. Privacy Shield Policy nor updates to it will affect or modify any contracts we have with our clients.
Access, Review & Update
If you are an EU Person about whom we hold EEA Data on a clients behalf, you may request access to, and the opportunity to update, correct or delete, such EEA Data. To submit such requests or raise any other questions, please contact the business that provided your EEA Data. You can also submit a written request to our EU-U.S. Privacy Shield Contact at email@example.com. We reserve the right to take appropriate steps to authenticate an applicant’s identity, to charge an adequate fee before providing access and to deny requests, except as required by the EU-U.S. Privacy Shield Framework.
We will provide an individual opt-out choice before we share their data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To limit the use and disclosure of your personal information, you may submit a written request to firstname.lastname@example.org
EU-U.S. Privacy Shield Contact
If you have questions, please contact Prehire’s Security Officer, e-mail: email@example.com. Or you may call us at: 1-888-789-8889. We will promptly investigate and attempt to resolve complaints and disputes in a manner that complies with the principles described in this Policy.
Prehire, Inc. has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.
Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.