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Syrus Global Privacy Policy
Syrus Global’s mission is to help client organizations integrate ethics and professional responsibility into their cultures. Our solutions include the Listen Up™ ethics reporting and helpline service (including a case tracking and management system), Ethics in Action ethics training, anonymous exit interviews, and a variety of related advisory services.
Syrus Global takes privacy and confidentiality seriously, as necessitated by our profession and by our own high ethical standards. It is imperative that our policies and procedures require the utmost care in handling sensitive and confidential information. Syrus Global personnel and partners agree to and sign a confidentiality statement annually, committing that they will use the information received by them, or to which they have access, only to carry out Syrus Global's responsibilities to our clients.
Submitters of ethics reports or helpline questions may remain anonymous. Syrus Global employs a number of measures to protect privacy. For example, our Listeners do not have caller ID on their phones; our submission web sites employ Secure Socket Layer encryption; we do not collect or retain computer IP addresses; and our submission sites do not cache pages on the user’s machine once a browser session has been closed.
Syrus Global employs practices to protect private and sensitive information throughout all facets of our operations. These practices are designed to earn the trust of our clients’ employees and partners, and everyone with whom we do business.
Syrus Global European Union Privacy Policy
Syrus Global takes its obligations with respect to individual privacy seriously. We adhere to strict practices to handle any personal information received by Syrus Global in accordance with the Safe Harbor Principles for the countries where we do business.
SCOPE
This European Union Privacy Policy applies to information transferred between the United States of America and the European Union member states.
The European Union (“EU”) Data Protection Directive 95/46 EC, as amended, is referred to herein as the “Directive” and the U. S. Department of Commerce’s Safe Harbor Documents (http://export.gov/safeharbor), as amended, are referred to herein as the “Safe Harbor Documents”.
Listen Up Group, LLC (d/b/a Syrus Global) (“Syrus”) adheres to the safe harbor privacy principles and relevant frequently asked questions of the Safe Harbor Program administered by the United States Department of Commerce, http://export.gov/safeharbor (collectively, the “Safe Harbor Principles”), subject to certain limitations. Syrus’ adherence to the Safe Harbor Principles may be limited (a) to the extent necessary to meet national security, public interest, or law enforcement requirements, (b) by statute, government regulation or case law that create conflicting obligations or explicit authorizations, provided that, in exercising such authorization Syrus can demonstrate that its non-compliance with the Safe Harbor Principles is limited to the extent necessary to meet the overriding legitimate interests furthered by such authorization or (c) if the effect of the Directive or EU Member State law is to allow exceptions or derogations, provided that such exceptions or derogations are applied in comparable contexts.
DEFINITIONS
For purposes of this Privacy Policy, the following definitions apply:
“Personal Information” means any personal information or data that identifies or could be used to identify an individual, excluding personal information or data that is (a) anonymized, (b) derived from public records and not combined with non-public personal information or (c) already publicly available to the public at large and not combined with non-public personal information.
“Sensitive Personal Information” means personal information or data that pertains to racial or ethnic origins, political opinions, philosophical or religious beliefs, trade union membership, or health or sex life.
THE SAFE HARBOR PRIVACY PRINCIPLES:
Notice
Syrus is contracted by its client companies (the “Companies”) to receive, process and store, on behalf of the Companies, information (which may or may not contain Personal Information) from a submitter (the “Submitter”) regarding tips or suggestions which may or may not mention another individual (the “Subject” or “Subjects”) and his or her conduct in relation to general employment practices, legal matters, or the Companies’ policies and procedures including, but not limited to, the Companies’ codes of conduct, ethics programs or other legal or ethical matters (the “Reports”). Submitters are typically employed by the Companies, and Submitters may also be employed by Companies’ vendors, customers or agents. Companies, Submitters and Subjects could be in any location, including the EU. Syrus allows Reports to be accessed by Companies but has no responsibility for the content or the handling of the information in the Reports. Syrus provides this comprehensive service to Companies through its Listen Up (“Listen Up”) service.
Should Syrus receive Personal Information about individuals, it will inform them of the purposes for which it collects and uses such Personal Information, how to contact Syrus with inquiries or complaints, any non-agent third parties to which Syrus discloses the Personal Information, and the choices and means that Syrus offers individuals to limit the use and disclosure of such Personal Information, if any.
Choice
It is the Companies’ duty to communicate that use of the Listen Up service is completely voluntary. Should Syrus receive Personal Information about individuals, Syrus will offer individuals the opportunity to choose (opt-out) whether their Personal Information will be disclosed to a non-agent third party or used for a purpose incompatible with the purpose for which it was originally collected or subsequently authorized by the individual.
For Sensitive Personal Information, affirmative or explicit choice (opt-in) consent must be given by each individual to the disclosure of Sensitive Personal Information to a non-agent third party or used for a purpose other than its original purpose or the purpose subsequently authorized by the individual.
Onward Transfers to Third Party Agents
Syrus may transfer information to a third party acting as an agent for Syrus if Syrus ascertains that the third party (1) subscribes to the Safe Harbor Principles or (2) is subject to the Directive or another adequacy finding or (3) enters into a written agreement with the third party requiring that the third party provide at least the same level of privacy protection as required by the relevant Safe Harbor Principles.
Security
Syrus takes reasonable precautions to protect Personal Information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Syrus’ web submission sites employ 128-bit secure sockets layer encryption. Listen Up sites do not cache pages on the user's machine once a browser session has been closed. Using an employer’s computer creates the possibility that the employer could learn of an employee’s Internet navigation.
Syrus does not elicit any Personal Information or data that identifies or could be used to identify either a Submitter or a Subject, and if a Submitter offers such information or data, Syrus reasonably attempts to anonymize or remove such information and data in any report that Syrus provides to its Companies.
Data Integrity
Syrus takes reasonable steps to ensure that Personal Information is relevant for the purposes for which it is to be used, accurate, complete and current. Syrus will not process Personal Information in a way that is incompatible with the purposes from which it was collected or subsequently authorized by an individual.
Access
Upon written request to Syrus, individuals may have reasonable access to Personal Information about them (only to the extent that Syrus stores the Personal Information) and Syrus will take reasonable steps to permit individuals to correct, amend or delete such Personal Information that the individual proves is inaccurate or incomplete, subject to certain exceptions. The obligation of Syrus to provide access to Personal Information that it stores about an individual is not absolute and Syrus may deny access in accordance with the Safe Harbor Principles including, but not limited to, where the rights of persons other than the individual would be violated.
Enforcement
a. Verification
Syrus conducts an annual self-assessment in order to verify that its published Privacy Policy regarding Personal Information received from the EU is accurate, comprehensive, prominently displayed, completely implemented, accessible and conforms to the Safe Harbor Principles. Syrus has appropriate procedures in place for training its employees on the implementation of its Privacy Policy, disciplining its employees for their failure to follow its Privacy Policy and internal procedures for periodically conducting an objective review of compliance with the above. Syrus will annually certify with the U.S. Department of Commerce that it will comply with the Safe Harbor Principles.
b. Dispute Resolution and Remedies
Any complaints regarding Syrus’ use or disclosure of Personal Information should be directed to Syrus as indicated under the ”Contact Information” section of this Privacy Policy. Syrus will investigate and attempt to resolve such complaints in accordance with this Privacy Policy. If the complaint is not resolved through this process, complaints may subsequently be pursued through independent recourse mechanisms and Syrus is committed to cooperate with the U.S. Federal Trade Commission, the European Data Protection Authorities or their authorized representatives which may investigate complaints and impose sanctions for noncompliance with the Safe Harbor Principles.
Contact Information
Listen Up Group, LLC (d/b/a Syrus Global)
200 W. Adams Street
Suite 1825
Chicago, Illinois 60606
312-635-1500
EUprivacy@syrusglobal.com
Syrus reserves the right to revise or amend this Privacy Policy at any time and will provide appropriate notice of any changes to this Privacy Policy.
"It is not every question that deserves an answer."
Publilius Syrus
100 B.C.
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