The EU-U.S. Privacy Shield Framework was designed by the U.S. Department of Commerce and European Commission to provide companies on both sides of the Atlantic with a mechanism to comply with EU data protection requirements when transferring personal data from the European Union to the United States in support of transatlantic commerce. On July 12, 2016, the European Commission deemed the Privacy Shield Framework adequate to enable data transfers under EU law (see the adequacy determination).
The Privacy Shield program, which is administered by the International Trade Administration (ITA) within the U.S. Department of Commerce, enables U.S.-based organizations to join the Privacy Shield Framework and benefit from the adequacy determination. Upon voluntarily joining the Privacy Shield Framework, and publicly committing to comply with the Framework’s requirements, the commitment becomes enforceable under U.S. law. Consistent with its commitment to protecting personal privacy, i9advantage.com adheres to the Privacy Shield Principles.
For purposes of this Policy, the following definitions will apply:
“Agent” means any third party that uses personal information provided by i9advantage.com to perform tasks on behalf of and under the instruction of i9advantage.com.
“i9advantage.com” means the corporation, its successors, affiliates and subsidiaries.
“Personal Information” means any information or set of information that identifies or is used by or on behalf of i9advantage.com 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 Information” means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership, or information that concerns an individual’s health. In addition, i9advantage.com will treat, as sensitive personal information, any information received from a third party where that third party treats and identifies the information as sensitive.
This Policy applies to all personal information received by i9advantage.com in the United States from the EU, in any format including electronic, paper, or verbal.
Where i9advantage.com collects personal information directly from individuals in the EU, it will inform them about the purposes for which it collects and uses the information, the types of third parties to which i9advantage.com discloses that information, and the choices and means, if any, i9advantage.com 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 i9advantage.com, or as soon as practicable thereafter, and in any event before i9advantage.com uses the information for a purpose other than that for which it was originally collected.
i9advantage.com may be required, at times, to disclose personal information in response to lawful requests by government agencies and public authorities, including to meet national security or law enforcement requirements.
Where i9advantage.com receives personal information from its subsidiaries, affiliates or other entities in the EU, it will use such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.
i9advantage.com will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a 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 information, i9advantage.com will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a third party or to the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
DISCLOSURES AND TRANSFERS TO AGENTS
i9advantage.com may share an individual’s information with agents, contractors, or partners of i9advantage.com in connection with federal Form I-9 services that these individuals or entities perform for, or with, i9advantage.com. Onward transfer of personal information is not shared, but, rather, is entered into i9advantage.com’s electronic I-9 software system and made available exclusively to authorized users of the electronic I-9 environment. In the unlikely event of onward transfer of data to third parties, i9advantage.com assumes liability (a) to the extent we are required to respond by way of legal or ethical obligation; and (b) to the extent expressly permitted by an applicable law, rule, or regulation.
i9advantage.com ensures that the use and disclosure of personal data is limited to agents, contractors, partners, or clients authorized to enter or edit such Form I-9 data on behalf of an employee. I9advantage.com will obtain assurances from its agents and contractors that they will safeguard personal information received from us in a manner consistent with this Policy. Appropriate assurance of compliance may be given in a number of ways, which may include one or more of the following:
- A contract between i9advantage.com and the third party which includes provisions requiring the third party to provide at least the same level of protection as is required by the relevant Privacy Shield Principles.
- The third party may be subject to the EU Data Protection Directive itself.
- The third party may have filed its own Privacy Shield certification.
Where i9advantage.com has knowledge that an agent, contractor, or partner is using or disclosing personal information in a manner contrary to this Policy, we will take assertive and appropriate steps to prevent or stop the use or disclosure.
i9advantage.com will employ reasonable safeguards to protect personal information in its possession. To prevent unauthorized access, disclosure, and destruction of personal information and to maintain data accuracy and ensure the appropriate use and confidentiality of the personal information, either for i9advantage.com’s own purposes or on behalf of our customers, i9advantage.com has put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the personal information i9advantage.com processes.
i9advantage.com processes personal information only in ways compatible with the purpose for which it was collected or subsequently authorized by the individual. To the extent necessary for such purposes, i9advantage.com takes reasonable steps to ensure that personal information is accurate, complete, current, and otherwise reliable with regard to its intended use.
ACCESS AND CORRECTION
Upon request, individuals will be granted reasonable access to personal information that is maintained by i9advantage.com. If an individual becomes aware that the personal information is inaccurate, the individual may contact i9advantage.com using the contact information below. Upon receipt of such request, i9advantage.com will take reasonable steps to permit individuals to correct, amend, or delete information that is found to be inaccurate or incomplete.
i9advantage.com periodically verifies that this Policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented, and in conformity with the Privacy Shield Principles. All reported breaches or potential breaches will be investigated by the Privacy Officer and the investigative agents the Officer assigns, who will take such actions as they deem appropriate in the investigation, and if necessary, remediate the situation. Any employee that i9advantage.com determines is in violation of this Policy will be subject to disciplinary action up to and including termination of employment. i9advantage is also subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
In compliance with the Privacy Shield Principles, i9advantage.com commits to resolving complaints about our collection or use of your personal information. Individuals in the European Union (EU) with inquiries or complaints regarding our Private Shield policy should first contact our Privacy Officer at:
PrivacyPolicy@i9advantage.com (additional contact information found below).
i9davantage.com has further committed to refer unresolved Privacy Shield complaints to cooperate with EU data protection authorities (DPAs) with regard to human resources data transferred from the EU in the context of the employment relationship. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU DPAs for more information or to file a complaint. The services of EU DPAs are provided at no cost to you.
Any questions or concerns regarding the use or disclosure of personal information should be directed to the Privacy Officer at the address given below. i9advantage.com will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the Privacy Shield Principles contained in this Policy. For complaints that cannot be resolved between i9advantage.com and the complainant, i9advantage.com has agreed to participate in the dispute resolution procedures of the panel established by the European data protection authorities to resolve disputes pursuant to the Privacy Shield Principles.
In accordance with the Privacy Shield Framework Principles (“Principles”) and the Privacy Shield’s arbitration requirement found in Annex I, i9advantage.com agrees to allow the Privacy Shield Panel to determine, for residual claims, whether i9advantage.com has violated its obligations under the Principles as to that individual, and whether any such violation remains fully or partially unremedied. The Privacy Shield Panel is authorized to impose individual-specific, non-monetary equitable relief (such as access, correction, deletion, or return of the individual’s data in question) necessary to remedy the violation of the Principles only with respect to the individual. No damages, costs, fees, or other remedies are available.
Questions or comments regarding this Policy should be submitted to the i9advantage.com Privacy Officer by mail as follows:
Product and Compliance Manager
21220 Kelly Road
Eastpointe, Michigan 48021
LIMITATION ON APPLICATION
Adherence by i9advantage.com to the Privacy Shield Principles may be limited in liability (a) to the extent we are required to respond to a legal or ethical obligation; and (b) to the extent expressly permitted by an applicable law, rule, or regulation.
This Policy may be amended from time to time, consistent with the requirements of the Privacy Shield Principles. Notice of any such amendment will be posted on i9advantage.com’s web page - http://www.i9advantage.com/.