Privacy Shield Policy
ATG recognizes that the EEA has established strict protections regarding the handling of EEA Personal Data, including requirements to provide adequate protection for EEA Personal Data transferred outside of the EEA. To provide adequate protection for certain EEA Personal Data about job applicants and employees received in the US, ATG has elected to self-certify to the EU-US Privacy Shield Framework administered by the US Department of Commerce (”Privacy Shield”). ATG adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access and Recourse, Enforcement and Liability.
Personal Data Collection and Use
For purposes of enforcing compliance with the Privacy Shield, ATG is subject to the investigatory and enforcement authority of the US Federal Trade Commission. For more information about the Privacy Shield, see the US Department of Commerce’s Privacy Shield website located at: https://www.privacyshield.gov
. To review ATG’s representation on the Privacy Shield list, see the US Department of Commerce’s Privacy Shield self-certification list located at: https://www.privacyshield.gov/list
describes the categories of EEA Personal Data that we may receive in the US as well as the purposes for which we use that EEA Personal Data. We may receive the following categories of EEA Personal Data in the US: name, identification number, location data, online identifier and/or one or more factors specific to the physical, economic or social identity of a person. We process EEA Personal Data for the following purposes: job applicants, employment and employees. ATG will only process EEA Personal Data in ways that are compatible with the purpose for which ATG collected it, or for purposes the individual later authorizes. Before we use your EEA Personal Data for a purpose that is materially different than the purpose for which we collected it or than you later authorized, we will provide you with the opportunity to opt out. ATG maintains reasonable procedures to help ensure that EEA Personal Data is reliable for its intended use, accurate, complete and current.
We may collect the following categories of sensitive EEA Personal Data: trade-union membership. We process sensitive EEA Personal Data for the following purposes: employment. When we collect sensitive EEA Personal Data, we will obtain your opt-in consent where the Privacy Shield requires, including if we disclose your sensitive EEA Personal Data to third parties, or before we use your sensitive EEA Personal Data for a different purpose than for which we collected it or than you later authorized.
Data Transfers to Third Parties
Disclosures for National Security or Law Enforcement. Under certain circumstances, we may be required to disclose your EEA Personal Data in response to valid requests by public authorities, including to meet national security or law enforcement requirements.
ATG maintains reasonable and appropriate security measures to protect EEA Personal Data from loss, misuse, unauthorized access, disclosure, alteration or destruction in accordance with the Privacy Shield.
You may have the right to access the EEA Personal Data that we hold about you and to request that we correct, amend or delete it if it is inaccurate or processed in violation of the Privacy Shield. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment or deletion of your EEA Personal Data, you can submit a written request via the contact information provided below. We may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee for access to your information.
Questions or Complaints
You can direct any questions or complaints about the use or disclosure of your EEA Personal Data to us at DataPrivacy@apextoolgroup.com. You may also report any concerns to your manager, human resources, the Legal Department or ATG’s ethics hotline (information on how to access our ethics hotline is available on BaseCamp under the “Apex Compliance Toolkit” link). We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your EEA Personal Data within 45 days of receiving your complaint. For any unresolved complaints, we have agreed to cooperate with the EU data protection authorities. If you are unsatisfied with the resolution of your complaint, you may contact the EU data protection authorities at: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm
for further information and assistance.
You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have taken the following steps: (1) raised your complaint directly with ATG and provided us the opportunity to resolve the issue; (2) made use of the independent dispute resolution mechanism identified above; and (3) raised the issue through the relevant data protection authority and allowed the US Department of Commerce an opportunity to resolve the complaint at no cost to you. For more information on binding arbitration, see US Department of Commerce’s Privacy Shield Framework: Annex I (Binding Arbitration)
If you have any questions about this Policy or would like to request access to your EEA Personal Data, please contact us as follows: DataPrivacy@apextoolgroup.com.
Changes to this Policy
We reserve the right to amend this Policy from time to time consistent with the Privacy Shield’s requirements.
Effective Date: May 24, 2018
Last modified: May 24, 2018