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GUIDEPOST SOLUTIONS LLC

EU-U.S. PRIVACY SHIELD POLICY

Effective: May 24, 2018
Approved: July 18, 2018

Guidepost Solutions LLC (“Guidepost Solutions” or “we”) offers global investigations, compliance, monitoring, and security and technology consulting solutions for clients in a wide range of industries.  Our address is 415 Madison Avenue, 11th Floor, New York, NY 10017.

We regard the privacy of individuals and the confidentiality of our clients’ business activities to be essential to our values as a company.

This EU-U.S. Privacy Shield Policy (the “Shield Policy”) describes how Guidepost Solutions collects and uses personal information we receive from within European Union (“EU”) member countries under the EU-U.S. Privacy Shield Framework Principles.  We will comply with the requirements of the Privacy Shield Framework Principles as explained in more detail below.

This Shield Policy covers Personal Data, including Sensitive Data, which we receive from within the EU in the course of conducting investigations of individuals on behalf of our clients.  The terms Personal Data and Sensitive Data mean information about an identified or identifiable individual as those terms are defined in the EU-U.S. Privacy Shield Framework Principles (www.privacyshield.gov).  To learn how Guidepost Solutions collects and uses personal data collected through its company website, www.guidepostsolutions.com, please see our website privacy policy (www.guidepostsolutions.com/privacy-policy).

Guidepost Solutions is subject to the regulatory and enforcement authority of the US Federal Trade Commission.

CHANGES TO THIS POLICY

Guidepost Solutions may update this Shield Policy at any time so long as the changes are consistent with the Privacy Shield Framework Principles and any other terms of our certification under it.  We will post the effective date of any changes as part of any updated Shield Policy.

THE PRIVACY SHIELD PRINCIPLES

Consistent with its commitment to protect personal privacy, Guidepost Solutions complies with the principles set forth in the EU-U.S. Privacy Shield Framework Principles as adopted by the U.S. Department of Commerce regarding the collection, use and retention of all Personal Data we receive from the EU within the scope of this Shield Policy. We have certified that we adhere to the Privacy Shield Framework Principles’ requirements of: notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, and recourse, enforcement and liability with respect to certain data, including all Personal Data transferred from within the EU as part of our investigations of individuals. To learn more about the Privacy Shield Framework Principles, and to view Guidepost Solutions’ certification, please visit www.privacyshield.gov.    If there is a conflict between the terms of this Shield Policy and the Privacy Shield Framework Principles, the terms of the Privacy Shield Framework Principles shall govern.

1. Notice

Guidepost Solutions collects and processes Personal Data in the course of conducting investigations and due diligence under contract with its clients (or their legal representatives).

Personal Data we process on behalf of our clients may include, for example, the following: name, date of birth, address, driver’s license, passport, visa or other national identifiers, title at work, or any similar information helpful to correctly identify a subject of investigation and provide the information requested by the client.  We may add personal information from other sources, for example, from an employer’s records, from social media or public databases, court records, or an educational institution.  Subject to applicable law, we may collect court records or certificates related to criminal history or bankruptcies, litigation history, credit history, information related to service in a directorship, or professional licenses and certificates.

We will post a link to this Shield Policy on our website, www.guidepostsolutions.com, and ask our clients to provide either a link to it or its url on any form from which the client provides notice or seeks consent for us to conduct our investigations on its behalf or to receive data transferred from the EU.

To the extent permitted by the Privacy Shield Principles and applicable law, Guidepost Solutions also reserves the right to process Personal Data provided by or collected on behalf of a client without notice or knowledge of individuals involved, including any supplementation of the information through publicly available sources, as we may deem necessary to fulfill our obligations to our clients.

2. Choice

Guidepost Solutions recognizes its duty under the Shield Framework Principles to give individuals the right of choice before use of Personal Data about them for a purpose materially different from the purposes for which the data was collected or for disclosure to a third party for any use unrelated to those purposes.   We will offer choice if either of those circumstances occurs except as otherwise permitted by the Privacy Shield Framework Principles or applicable law.

3. Accountability for Onward Transfer

Guidepost Solutions may transfer Personal Data we collect and process to companies and individuals acting as agents for the limited purposes of helping us provide services to our clients.  These third-parties may include, for example, vendors that store or process data on our behalf or individual investigators who collect additional Personal Data as described above.   Investigators may disclose limited Personal Data to seek publicly available records, for example, to a court or to an educational institution or, in limited circumstances, to individuals with publicly available knowledge about the individual under investigation.

We obtain contractual assurances that our agents will safeguard Personal Data consistent with this Shield Policy. Examples of appropriate assurances that may be sought from agents include contractual obligations to limit use of the data to defined purposes, to abide by applicable law, to provide reasonable security and to notify us of any breach and to pass the same or similar protections on in any onward transfers.  If we find actual knowledge that an agent is using or disclosing Personal Data in a manner contrary to this Shield Policy, we will take reasonable steps to prevent or stop the use or disclosure. As described in the Privacy Shield Framework Principles, Guidepost Solutions may remain liable for onward transfer of Personal Data covered by the Shield Policy in certain circumstances.

Guidepost Solutions may also disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, to comply with a subpoena for a civil or criminal proceeding or similar legal process, or when we believe in good faith that disclosure is necessary to protect our rights, protect safety, investigate fraud, or respond to a government request.

The Privacy Shield requires: “In the context of an onward transfer, a Privacy Shield organization has responsibility for the processing of personal information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. The Privacy Shield organization shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless the organization proves that it is not responsible for the event giving rise to the damage.”

4. Security

Guidepost Solutions will take reasonable and appropriate measures to protect Personal Data in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into due account the risks involved and the nature of the Personal Data.  No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot warrant or guarantee its absolute security.

5. Data Integrity, Purpose Limitation and Use

Guidepost Solutions collects and uses Personal Data for the purposes requested by our clients.  Guidepost Solutions will retain a copy of Personal Data compiled on behalf of our clients for as long as we need the data to provide services to those clients. We may also retain and use any Personal Data covered by this Shield Policy as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

6. Access and Correction

Guidepost Solutions recognizes the rights of a person to access Personal Data and to amend that data or request deletion as that right is defined in the Privacy Shield Principles.  Requests for access may be made to Privacy Contact at the address at the end of this Shield Policy.  If, for example, you are aware that your employer has requested us to conduct an investigation of your background or if you have consented to such an investigation by an individual or company, we suggest that you first direct any requests for access to Personal Data directly to the employer or that individual or company.   That company, our client, retains ownership of any Personal Data we have collected on its behalf.  We hold the data subject to legal requirements of confidentiality.

7. Recourse, Enforcement and Liability

In compliance with the Privacy Shield Framework Principles, Guidepost Solutions commits to resolve complaints about your privacy and our collection or use of your personal information. EU individuals with inquiries or complaints regarding this privacy policy should first contact Guidepost Solutions at:  privacyshield@guidepostsolutions.com

or to:

Guidepost Solutions LLC

Attn:  Chief Privacy Officer Kenneth C. Citarella

415 Madison Avenue, 11th Floor

New York, NY 10017

We will endeavor to respond to any such questions or concerns within forty-five (45) days of receipt, as the Privacy Shield Framework Principles require.

Guidepost Solutions has further committed to refer unresolved privacy complaints under the Privacy Shield Framework Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.   The dispute resolution services will be provided at no cost to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at www.privacyshield.gov/article?id=ANNEX-1-introduction.

PRIVACY CONTACT

If you have any requests, concerns or questions under this Privacy Shield Policy, please submit them to privacyshield@guidepostsolutions.com

or to:

Guidepost Solutions LLC
Attn:  Chief Privacy Officer Kenneth C. Citarella
415 Madison Avenue, 11th Floor
New York, NY 10017

 

 

 

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