Updated 27 January 2020
Personal Privacy Data Handling Information
At GP Strategies our Data Privacy and Records Management Policy is a commitment to protecting the privacy data of employees, clients, business partners and web and social media site visitors. The Policy guides our privacy data handling practices as described here in this Frequently Asked Questions (FAQ) format. GP Strategies (GP) makes every reasonable effort to protect the privacy of data collected when individuals visit our sites.
GP Strategies policy and practice is also guided by the General Data Protection Regulation (GDPR) of the European Union (EU), other country or U.S. state laws like the California Consumer Privacy Act (CCPA), the U.S. Securities Exchange Commission regulation and guidance and the EU-U.S. and Swiss-U.S. Privacy Shield protocols.
For example, the GDPR and Privacy Shield are our worldwide administrative thresholds but we do adhere to more strict laws when applicable. GP Strategies does not buy or sell consumer privacy data as defined in the CCPA and therefore while abiding by the law, we are not subject to all provisions of the CCPA. For example, for CCPA compliance case we are not required to have a separate landing page describing how GP buys and sells consumer privacy data. Therefore, there are limited needs for opt-out, opt-in and other CCPA specific disclosures.
If you are under 18 years of age we request you obtain parental consent before posting a comment on our blogs and sites. Our websites do not publish content for or collect data that is directed at children.
Contacting GP Strategies and more Information about Data Privacy Practices
As a GP Strategies web site visitor, what information does GP collect?
When you visit the GP Strategies web site, we collect and store information about your visit. We may also engage other companies to do this on our behalf. Examples of the kind of information we, or third parties we engage, track include which pages you view on our site, the site you visited just before coming to ours, keywords you used in your search, your company name and the name of your Internet Service Provider. We use this information to develop ideas for improving our site, our products and services and for improving marketing of our products and services. We do not make any attempts to link this information with you as an individual.
There are also various forms on our web site that ask for personal information about you, such as your name, phone number, and e-mail address. If you tell us any personal information, we use it only to contact you in response to your request or to provide you with information that we think you may be interested in receiving. If you inform us that you do not want to receive any information that you have not specifically requested, we will honor your request. We will not sell or otherwise disclose your information to any other company.
GP Strategies employs professional security personnel and takes technical and organizational measures designed to prevent unauthorized access, use, alteration, or disclosure of privacy data collected via GP sites. We try to be both selective and proactive in checking the security background for certain external social media sites and other sites that we come in contact with but do not control. GP has been in business for over 50 years and has more than 30 years of experience in operating highly secured data repositories with security controls that are continuously updated to meet industry standards and address protective measures for emerging threats. Security practices are described in detail in our internal information technology (IT) policies and procedures. Also see our information security practices IT Fact Sheet below for more information.
As a GP Strategies site visitor does the “GDPR”, “CCPA” , Privacy Shield and other similar data privacy and records management requirements apply to my data?
Companies within the EU and California, or who are externally located controllers and processors of the personal privacy data of EU and California residents in the context of collecting privacy data while soliciting and providing goods or services, must comply with the GDPR and CCPA. As a GP site visitor we do collect your business contact information. However, we may also collect or process privacy data for the purpose of providing additional services. We are very aware that combining multiple privacy data elements, even if not considered personal data when taken alone, may result in the sum of the elements being considered personal privacy data when combined into a listing, and we protect it as required.
GP may move your data within or to locations outside of the European Economic Area (EAA) or California. These data transfers are legal under the GDPR, CCPA and Privacy Shield as long as we adhere to the requirements for legal processing. We encrypt all data in transit and in storage.
GP has evaluated our obligations under the GDPR, Privacy Shield and other laws like the CCPA, in part, based on: (1) the type of visitor data that we collect via our sites, and (2) the legal basis on which you rely for the protection of your data. We will exercise data privacy stewardship on all of our sites.
How will my personal information be used and shared by GP Strategies for internal management of the sites?
The personal information we collect in our various sites, if needed, allows us to:
- Respond to your inquiries;
- Provide the information, products and services you have ordered;
- Verify your identity and details of your payment method or credit card amount;
- Administer our sites and provide user services;
- Meet legal, regulatory and compliance requirements;
- Monitor and analyze the use of any account to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents, public safety threats to you or crime;
- Gather management information to form statistical and trend analysis;
- Communicate with you;
- Investigate any complaints about our sites;
- Personalize your experience of the sites;
- Contact you about our products and services which we think might be of interest to you (where we have the appropriate permissions to do so);
- When warranted, we share your personal information with our GP affiliate companies and brands for the above purposes, they adhere uniformly to these data handling practices;
- Employ the services of third party service providers to help us in certain areas, such as site hosting, maintenance and call center operation. In some cases the third party may receive your information. However, at all times we use third parties, we will contractually control and be responsible for the use of your information and place contractual requirements on privacy data sent to our sub-processors.
- If you provide a credit or debit card, we may also use third parties to check the validity of the sort code, account number and card number you submit in order to prevent fraud as well as to process any transaction you attempt via the website.
- If false or inaccurate information is provided and fraud is identified, we will follow legal processes if details will be passed to fraud prevention agencies. Law enforcement agencies may access and use this information. We and other organizations may also access and use this information to prevent fraud and money laundering, for example when:
- Managing credit and credit related accounts or facilities
- Recovering debt
- Checking details on proposals and claims for all types of insurance
- Checking details of job applicants and employees when required.
Where does GP Strategies store my privacy information?
GP Strategies stores privacy data in data centers in the United Kingdom and the United States. These are certified centers which have one or more of the following: SOC 1 Type 2, SOC 2 Type 2, Lloyd’s Register (LRQA) and ISO (International Standards Organization) 27001. (SOC = Service Organization Controls reports (1-3) of the AICPA (American Institute of Certified Public Accountants). ISO 27001 is one of the most recognized worldwide information technology security standards. SSAE 16 and ISAE 3402 – 22451 and PCI – Data 2334 Security Standard (SSAE = Statement on Standards for Attestation Engagements (#16 & 18), PCI = Payment Card Industry-Data Security Standard ((PCI-DSS)).
What constitutes personal privacy data?
Personal privacy data is information related to a natural person (called a ‘data subject’ by the GDPR, a “consumer” in the CCPA and as otherwise differentiated by other laws) that can be used to directly or indirectly identify the person when not encrypted and used individually or in combinations to create a profile.
Personal privacy data is a very broad range of personal information and can be any information item that might be used to create a profile, to include basic business contact information of name, business address, and business phone and business title or business job. Further personal privacy information would also be: an identifiable photo; identifiable voice recordings; fingerprints; biometric data; psychological profile, a personal email address, home phone number, home address; numbered identifiers – bank account, credit information and credit card, passport, country identification, driver’s license, pension and social security numbers; family member information; medical information; political opinions; sex, sexual preferences; computer IP address; data on children; travel profiles; trade union membership; criminal records. Some countries differentiate some of these listed items as Sensitive Personal Identification Information (SPII).
What is the difference between a data processor and a data controller?
- A controller is the entity that determines the purposes, conditions and means of the processing of personal data. A controller can be a processor. A web site owner is a controller.
- A data processor is an entity which processes personal data, with instructions and IT security framework, on behalf of the controller.
- GP Strategies is a controller and/ or a processor at varying times in our conduct of business.
Is GP Strategies a data processor or data controller in regard to my personal data?
GP Strategies acts as a data controller and in some cases is also a processor (or sub-processor) for personal data provided to GP through our customers, by individuals and other third parties such as business partners.
If a data subject (consumer) provides their personal data directly to GP Strategies (such as a site visitor, a forum or conference attendee, a site browser, etc.) GP acts as the data controller for that personal data. Note, if GP also processes that personal data in some fashion, GP also qualifies as a data processor in regard to that personal data.
Is GP Strategies organized to manage the data processor obligations imposed by the GDPR, Privacy Shield and other similar laws and regulations?
GP Strategies established a Data Protection and Records Management (DPRM) Committee and appointed Data Protection Officers (DPOs) to manage the DPRM Program and comply with the GDPR, Privacy Shield and other laws. The Committee is tasked with instituting, conducting and monitoring GP’s internal data privacy compliance initiatives.
For GP Strategies, keeping site visitor and all data secure is a high priority. Along with ensuring data security, it is important that a site visitor’s confidence is always maintained and a high level of security around processes and protection is strongly administered.
At GP Strategies, we strongly value and base our business on the trust that our site visitors, employees and customers have placed upon us. We will continue to earn and reinforce that trusted relationship by cooperating with requests related to our GDPR, CCPA, Privacy Shield and other country data privacy obligations.
GP Strategies is committed to taking advanced measures to support and continuously enhance the security of our systems, to ensure that we collect and process personal data in a manner compliant with GDPR, Privacy Shield or any similar legislation.
GP Strategies management strongly believes that information technology security/ compliance is a key business service. Information security objectives and strategy must be continually aligned with GP’s business strategy and objectives.
When does GP Strategies delete client data?
GP Strategies deletes client data, including backups based on our records management schedule. In some cases that can be shortly after you leave one of our sites. Web and social media privacy information is deleted after you finish browsing or have opted out of receiving our communications or you have been unresponsive to our inquiry messages for a period of time. If you acknowledge our site use rules to continue browsing or you agree when specifically requested to opt-in your information is transferred to our secure customer relations management data base.
To meet business operations, contractual and statutory requirements we are legally and /or contractually required to keep some data for more extended periods of time consistent with the lawful processing provisions of the GDPR. Data is held in various categories in our records management deletion schedules. These data retention categories range from nearly immediate up to seven (7) years unless there is a longer legal requirement. For more information about data retention times please contact us.
Does GP Strategies provide clients with the option to delete client data?
GP Strategies supports the deletion of client data. However, we prefer such requests to be in writing and made in cooperation with the GP Data Protection and Records Management Committee staff. This will ensure clarity of the request in the event it is not a temporary storage item like non-persistent web and social media cookies.
What are GP Strategies site cookie practices?
The types of cookies GP Strategies and others may place on your device are described below.
- GP will read or set only the types of cookies that are strictly necessary for quality browsing or specifically allowed by your browser preference settings.
- GP only places cookies that set your preferred language, deliver specific content based on visit history, and give access to various sections of the sites.
- Cookies set by our sites will remain on your device but GP will not access or use those non-strictly-necessary cookies. You may remove them using functionality provided by your browser. Please note that cookies are specific to the browser or device you use, as well as to the domain, and you will therefore have to configure your preferences again if you change your browser or device, or visit a different domain.
- Any specific questions regarding these cookie settings may be sent to firstname.lastname@example.org
How do you use Web Beacons?
Some of our web pages may contain electronic images known as web beacons (sometimes known as clear gifs) that allow us to count users who have visited these pages. Web beacons collect only limited information which includes a cookie number, time and date of a page view, and a description of the page on which the web beacon resides. We may also carry web beacons placed by third party advertisers. These beacons do not carry any personally identifiable information and are only used to track the effectiveness of a particular campaign.
How do you use Social Media Widgets?
How do you use Blog Information?
Should you choose to add a comment to any posts that we have published on our sites for example in a blog, the name and email address you enter with your comment will be saved to the site’s database, along with your computer’s IP address and the time and date that you submitted the comment. This information is only used to identify you as a contributor to the comment section of the respective blog post and is not passed on to any of the third party data processors. Only your name will be shown on a site that is public-facing. Your posted comment(s) and its associated personal data will remain on this site until we see fit to either 1) remove the comment, or 2) remove the blog post. Should you wish to have the comment and its associated personal data deleted, please email us listed with your contact information using the email address that you commented with.
NOTE: You should avoid entering personally identifiable information to the actual comment field of any blog post comments that you submit on this site.
How do you use Contact Forms and Email Links?
Should you choose to contact us using a contact form on our sites or an email link, the data you supply will be stored in our customer relationship management database or may be passed on to be processed by a third party data processor(s) or may be sent an internal affiliated subsidiary/ organization for response. We do retain information from data requests in our customer relationship management system. Collated and transferred data is encrypted before being sent across the internet. We do not sell personal information.
How do you use information we provide to you?
As a compliance philosophy GP Strategies makes every effort to apply a data minimization approach in our privacy data gathering and storage activities. We do collect and hold some personal information you give us. These are the general types of information we may collect from you:
Registration and Profile Information
We try to gather only the most necessary information for the involved inquiry or purpose. When you enter or register to use our site, our services, to receive information, to participate in our events, and create or update your forum profiles, we may collect various kinds of information about you. For example, we may collect: your name; postal address; phone number; fax numbers and email address; your log-in ID and password; your title; company; and other event specific profile information you provide; demographic information; and information linked with your profile such as comments you may post. We need this information to be able to respond to you, secure the site and provide services as applicable.
Information We Automatically Collect
- When you visit our site or use GP Strategies site services, as do many companies, some information is collected and recorded automatically such as your computer’s operating system, Internet Protocol (IP) address, access times, browser type and language, and the website you visited before our corporate sites, so we are aware of transfers and linking for security due diligence (blocking and enhancing) of our site and to protect you the user. This is logged automatically and stored in log files. We also collect information about your usage and activity on our corporate sites. We may tie your IP address to information we automatically collect on our corporate sites. We may also tie information we automatically collect with personal information, such as your login ID and information you give us for a registration. We use our own products, and products of third parties acting on our behalf, to analyze, optimize, securely protect and improve our site.
- GP will also collect information on your usage to ensure the security of the data we collect on behalf of our clients. You cannot opt-out of this collection and processing as it is necessary to ensure the security of the service we provide for our sites and for our clients.
- GP Strategies may also use device-recognition technologies combined with other identifiers to create cross-browsers and cross-devices identities to provide you with better services and security.
In GP Strategies’ Commitment to data protection what steps have been taken to protect my data?
GP Strategies initiated a data privacy data management compliance review and update effort beginning in October 2017 to ensure alignment with the May 2018 requirements of the European Union (EU) General Data Protection Regulation (GDPR) and other similar privacy data regulatory obligations coming into force around the world like Privacy Shield and the California Consumer Privacy Act (CCPA). GP was certified into the Privacy Shield regime by the U.S. Department of Commerce in 2017. These efforts are Companywide, ongoing and driven by a chartered Committee sponsored by senior corporate leaders. We meet regulatory requirements, to include these examples:
- We have not identified any information technology shortfalls in data privacy transmission and storage encryption.
- The standing Data Privacy and Records Management Committee meets regularly and has web based information sites available to employees and for Program administration where it keeps its meeting records and products.
- Privacy data owners’ storage information submissions are being continuously catalogued and updated.
- Standard contract language amendments for subcontractors/processors are in use.
- Frequently asked data privacy questions (FAQ) documents to enhance transparency and privacy data handling awareness are available to employees on our internal portal.
- In December 2017 GP obtained EU-U.S. Privacy Shield certification for the international transfer of EU privacy data. To learn more about the Privacy Shield Framework, and to view our certification, visit the U.S. Department of Commerce Privacy Shield web site.
- In December 2017 GP attained UK Government Cyber Essentials certification.
- We conduct employee data privacy awareness training annually.
- If you need additional elaboration on Committee actions please contact us.
In addition to efforts by the Committee, GP Strategies employs security professionals and takes technical and organizational measures designed to prevent unauthorized access, use, alteration, or disclosure of privacy data collected via GP sites. Further, GP has more than 30 years of experience in operating highly-secured solutions with security controls that are continuously updated to meet industry standards and address emerging threats. This is described in detail in our information technology (IT) policies and procedures. Also see our IT fact sheet on information security practices.
EU-U.S. and Swiss-U.S. Privacy Shield Framework
GP Strategies is committed to cooperate with 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 human resources data transferred from the EU and Switzerland in the context of employment relationship and/or a business services relationship. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.
GP Strategies has further committed to cooperate with the panel established by the EU DPAs and the FDPIC with regard to unresolved Privacy Shield complaints. Such complaints involving GP human resources, web and social media and client related privacy data transferred to the U.S. will be reviewed in the context of the employment relationship and/or a business services relationship.
In the conduct of our business to meet the international Privacy Shield requirements:
- We encrypt our data in transit and in storage.
- In our delivery of training activities and consulting services we are sometimes contractually required to conduct business operations processing wherein we collect client employee, vendor and client customer privacy data on behalf of our clients and for our internal services processes. We also may collect limited categories of privacy data from individuals that visit our web and social media sites. This information is stored in secure sites.
- We use or intermittently use contracted assistance to process GP payroll, human resources and related employee services and in doing so we necessarily disclose personal information to these third parties to accomplish these processing operations.
- We acknowledge that individuals have the right to inquire about and access their data.
- GP Strategies is required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
- We make efforts to limit the collection, use and disclosure of personal data to help protect personal privacy.
- We will discuss with you your specific request to limit use of your data if you choose to restrict the use of privacy data. We most likely cannot make exceptions for required legal, regulatory, contractual and personal public safety contact information erasure requests. Personal contact information may be used to contact you or family members in the event of an emergency to warn you and others of a dangerous safety situation. Such discussions will include the alternate processes and consequences of the alternative processing methods available to accomplish the same necessary services affected by your request, up to and including deleting data if that is an option. Your services may be slowed by your requested processing restrictions.
- GP Strategies is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
- An individual has the possibility, under certain conditions, for the individual to invoke binding arbitration when seeking more restrictive data privacy remedies from GP Strategies.
- GP Strategies understands that it may not be absolved of liability in cases of onward transfers of privacy data to third parties.
California Consumer Privacy Act (CCPA)
What is considered “personal information” under the CCPA?
“Personal information” is defined in the California law. CCPA categories are expanded beyond those in the EU General Data Protection Regulation (GDPR). In the law, personal information is any “information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with any particular consumer.” “Consumer” is a defined term in the CCPA similar to “data subject” as used in the GDPR, however it is not an exact matching definition.
As a California citizen does GP Strategies sell my data?
By Company Policy GP-C-18, GP Strategies does Not Sell or Buy Personal Information and has no intent to start. This “sale of consumer privacy data” element of the CCPA (and its regulations) is a major section that has limited impact on GP Strategies due to our Policy position. Therefore, for example, GP strategies is not required to have a separate landing page for California consumers that addresses the sales of their personal data.
Does GP Strategies honor the “rights” of consumers in the CCPA?
GP Strategies Global Privacy Office, GP Strategies Corporation
70 Corporate Center, Suite 200, 11000 Broken Land Pkwy,
Colombia, MD 21044 USA