Effective Date: December 15, 2017
Last updated May 28, 2019
Personal Data Collection and Use
DCI may receive the following categories of EU & Swiss Personal Data in the US: Data provided by its customers or their partners for processing in connection with the software and services DCI provides, human resources and recruiting data in connection with its internal human resources activities, and marketing & sales data, including voluntarily provided contact information. To the extent that DCI customers input EU & Swiss Personal Data into DCI’s products and services, there is no way to distinguish such Personal Data from any other type of data. DCI will only process EU & Swiss Personal Data in ways that are compatible with the purpose that DCI collected it for, or for purposes the data subject later authorizes. Before DCI uses EU & Swiss Personal Data for a purpose that is materially different than the purpose we collected it for or a purpose later authorized by the data subject, DCI will provide you with the opportunity to opt out. By providing DCI with unsolicited sensitive personal data, you explicitly consent to such data being collected, processed and transferred by DCI.
Data Transfers to Third Parties
Third-Party Agents or Service Providers. DCI does not transfer data to Third-Party Agents but may transfer EU & Swiss Personal Data to its service providers who host and/or transmit the data on its behalf. Where required by the Privacy Shield, DCI enters into written agreements with those service providers requiring them to provide the same level of protection the Privacy Shield requires and limiting their use of EU & Swiss Personal Data to the specified services provided on DCI’s behalf. Under certain circumstances, DCI may remain liable for the acts of its service providers who perform services on its behalf for their handling of EU & Swiss Personal Data that DCI transfers to them.
Compelled Disclosure: Under certain circumstances, DCI may be required to disclose EU & Swiss Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
DCI maintains reasonable and appropriate security measures to protect EU & Swiss Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the Privacy Shield.
EU & Swiss data subjects may have the right to access the EU & Swiss Personal Data in DCI’s possession, and to limit use and disclosure of such EU & Swiss Personal Data. Concerns regarding EU & Swiss Personal Data not collected by DCI, but provided to DCI from its customers for processing should be addressed to the parties who provided the EU & Swiss Personal Data for processing. 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 EU & Swiss Personal Data, you can submit a written request to DCI via the contact information provided below. DCI may request specific information from you to confirm your identity. In some circumstances DCI may charge a reasonable fee for access to your information.
Questions or Complaints
In compliance with the Privacy Shield Principles, DCI commits to resolve complaints about our collection or use of your personal information. DCI will investigate and attempt to resolve any complaints or disputes regarding the collection or use of your EU & Swiss Personal Data within 45 days of receiving your complaint.
For any unresolved Privacy Shield complaints, DCI has agreed to cooperate with the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to data transferred from the EU and Switzerland in the context of the employment relationship. Privacy Shield also affords the opportunity, under certain conditions, for the individual to invoke binding arbitration.
EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact DCI by email to the Information Security & Compliance Manager, with “Privacy Shield” in the subject line:
Information Security & Compliance Manager
DCI Consulting is a risk management human resources consulting firm strategically located in Washington, D.C.
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