Our Commitment to Your Privacy

EFFECTIVE DATE:  April 20, 2011 

Your privacy is of the utmost importance to us. We want to make your experience satisfying and safe.

Because we gather certain types of personal information about our customers and their employees, we feel you should fully understand our policy surrounding the capture and use of this information and more importantly, how we plan to protect the security and privacy of any personal information that our customers provide to us.

This personal information includes customers’ employee names, addresses, social security numbers and payroll data as well as any information that can be linked to an individual employee of SGWI’s customers. Not only does SGWI strive to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business, but it also has a tradition of upholding the highest ethical standards in its business practices.

Certification of Compliance
SafeGuard World International complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland.

SafeGuard World International has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view SafeGuard World International’s certification, please visit http://www.export.gov/safeharbor/

More importantly, how we plan to protect the security and privacy of any personal information that customers provide to us. This personal information includes customer’s employee’s names, addresses, social security numbers and payroll data as well as any information that can be linked to an individual employee of SGWI’s customers. Not only does SGWI strive to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business, but it also has a tradition of upholding the highest ethical standards in its business practices.

Safe Harbor
The United States Department of Commerce and the European Commission and the Swiss Federal Data Protection and Information Commissioner have agreed on a set of data protection principles and frequently asked questions (the “Safe Harbor Principles”) to enable U.S. companies to satisfy the EU law and Swiss Federal requirement that personal information transferred from the EU to the United States be adequately protected. Consistent with its pledge to protect personal privacy, SGWI adheres to the Safe Harbor Principles.

Scope
This Safe Harbor Privacy Policy (the “Policy”) sets forth the privacy principles that SGWI follows with respect to transfers of personal information from the European Union (EU) to the United States and from Switzerland to the United States according to both the US.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework, in any format including electronic, paper or verbal.

Definitions
The following definitions shall apply throughout this Policy:

“Agent” means any third party that uses personal information provided to SGWI to perform tasks on behalf of and under the instructions of SGWI.

“SGWI” means Safeguardworld International LLC, its successors, subsidiaries, divisions and groups in the United States.

“Personal information” means any information or set of information that identifies or could be used by or on behalf of SGWI to identify an individual. Personal information does not include information that is encoded, anonymized, aggregated 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, or trade union membership, or that concerns health or sex life. In addition, SGWI will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.

“Payroll Data” means salary and other wage information, deduction information, voluntary and otherwise, tax withholdings and other related information found on payroll checks, paystubs, direct deposit receipts or W-2s.

Privacy Principles
The privacy principles in this Policy are based on the Safe Harbor Principles.

Notice
When SGWI collects personal information directly from individuals in the EU and Switzerland, or their respective employers, it will inform them about the purposes for which it collects and uses their personal information, the types of non-agent third parties, if any, to which SGWI discloses that information and the choices and means, if any, that SGWI offers individuals for limiting the use and disclosure of their personal information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to SGWI, or as soon as practicable thereafter, and in any event before SGWI uses the information for a purpose other than that for which it was originally collected.

If SGWI receives personal information from its subsidiaries, affiliates or other entities in the EU and Switzerland , it will use such information in accordance with the notices such entities provided and the choices made by the individuals to whom such personal information relates.

Choice
SGWI will offer individuals the opportunity to choose (opt-out) whether their 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.

For sensitive personal information, SGWI will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. SGWI will provide individuals with reasonable methods to exercise their choices.

Data Integrity
SGWI will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. SGWI will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.

Transfer to Agents
SGWI will obtain assurances from its agents that they will safeguard personal information consistently with this Policy. If SGWI has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, SGWI will take reasonable steps to prevent or stop the use or disclosure.

Access and Correction
Upon request, SGWI will grant individuals reasonable access to personal information that it holds about them, and SGWI will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete. Updates and access is often from individuals’ employers’ upstream human resources management system/ recordkeeping system from which SGWI receives all personal information from.

Security
SGWI will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

Enforcement
SGWI will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that SGWI 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 SGWI Privacy Officer at the address given below. SGWI will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this Policy. For complaints that cannot be resolved between SGWI and the complainant, SGWI has agreed to participate in the dispute resolution procedures of the panel established by the European data protection authorities as well as the Swiss Federal Data Protection and Information Commissioner to resolve disputes pursuant to the Safe Harbor Principles.

Changes to the Safe Harbor Privacy Policy
This Policy may be amended from time to time, consistent with the requirements of the Safe Harbor Principles. SGWI will provide appropriate public notice about such amendments. The most recent version of this Policy will be available at www.www.safeguardworld.com.

Learn More
To learn more about the Safe Harbor program or to view SafeGuard World International’s certification, please visit http://www.export.gov/safeharbor/.

Contact Us
SafeGuard World International Ltd.
24-25 Edwin Foden Business Centre, Moss Lane
Sandbach, Cheshire, CW11 3AE
United Kingdom

Call: +44 (0) 8432 90 90 70
Fax: +44 (0) 8432 90 90 74
Email: johngiles@52.213.147.90

EFFECTIVE DATE:  April 20, 2011