Effective Date: November 6, 2018.
This policy applies to CRA, Inc. and its affiliated companies (collectively “CRA”).
CRA understands that your privacy is important to you and is committed to safeguarding the confidentiality and privacy of personal information entrusted to it.
Scope of this policy
This policy applies to personal information which is collected and/or used by CRA in its capacity as a controller as that term is defined in the EU data protection laws. The contexts in which this might occur are explored under “When do we collect personal information” below.
When we provide Services to clients, we sometimes handle personal information as a processor (for example, the hosting of client data). This means that we process the information solely on the instructions of our clients, who retain control of the information. Therefore, if our use of your personal information is not covered by this policy, you may need to contact the client (and controller) on whose behalf the processing of your information is carried out.
CRA collects personal information from and on behalf of its clients (e.g. about their employees and customers) to provide business advisory services to those clients. It also processes client personal information to manage its relationship with those clients. Further, CRA also collects some personal information from visitors to this website, recruitment applicants, and attendees at CRA events.
CRA uses personal information to deliver its Services to clients. For its own purposes, it also uses personal information to analyze and improve how it delivers those services, to contact representatives of its clients or prospective clients and to market to them, and to administer recruitment and events.
If CRA uses your personal information, you may have certain important rights which you can exercise. The rights you will be able to exercise will depend on how and why CRA uses your information.
The primary point of contact at CRA for questions regarding your personal information is firstname.lastname@example.org.
Who is your controller?
The CRA entity responsible for your personal information will be the entity that originally collected information from or about you. If you have a direct interaction with CRA (for example, you attend an CRA hosted event), the identity of your controller may be disclosed to you in connection with that interaction. If we process your personal information in the course of providing our Services to clients, your controller will be the CRA entity providing the Services (assuming those Services are provided as a controller, see above for an explanation). Please note that the contact details for all CRA entities in respect of data protection or privacy issues are the same and are as set out below.
When do we collect personal information?
We collect information about you if:
- You use this (or any other CRA) website;
- You enquire about, or engage CRA to provide, its Services (either in a personal capacity, or as a representative for your employer or client);
- The use of your personal information is reasonably necessary to provide our Services (in these circumstances, your personal information may be disclosed to us by our client who may, for example, be your employer or service provider, or we may obtain your personal information from a range of public or subscription sources, directly from you, or from your associates or persons known to you);
- You apply for a position with CRA;
- You attend an CRA hosted or sponsored event or webinar;
- You contact us with any other enquiry, complaint or notice.
What types of personal information are collected and what do we use it for?
The following is a summary of the types of personal information we collect, and the purposes for which that information is used.
Website users CRA collects your name, address, e-mail address, telephone number and any other personally-identifiable information about you in connection using the “Contact Us” email on its website, and with career-related inquiries that you submit through its website.
CRA’s former, current and prospective clients If you submit an enquiry to CRA about our Services (either over the website, or by emailing, telephoning or meeting with one of our colleagues), then we will process information such as your name, job title and contact information in order to respond to your enquiry.
If you attend an CRA event or webinar, or if you associate with an CRA colleague at, for example, an industry event, then CRA may collect basic personal information, such as contact details, which you voluntarily provide (for example, by filling in a form or handing over a business card) in order to facilitate your participation in the event, and for the management of our relationship with you as an actual or prospective client.
If you or the organization you are associated with becomes an CRA client, then we may process your personal information in order to:
- Carry out “Know Your Client” checks and screening prior to starting a new engagement (as well as basic contact information, this may mean processing compliance related information such as proof of your identity, information about your professional background, history of directorships and, in some circumstance, details of any criminal convictions or adverse media coverage);
- Carry out background checks for the purposes of complying with anti-money laundering and terrorist financing laws;
- Carry out client communication, service, billing and administration;
- Deal with client complaints; and
- Administer claims.
Taking account of applicable marketing laws, we also process personal information about our clients (former, current and prospective) in order to:
- Send our clients newsletters, know-how, promotional material and other marketing communications;
- Invite our clients to events (and arrange and administer those events).
Performing services for our clients As discussed above, many of our Services involve the processing of personal information. In the majority of cases, personal information is provided to us in strict confidence, subject to restrictive undertakings on its use / disclosure. CRA has a team of experts who are experienced in designing and implementing communication strategies, leadership counsel and coaching, organizational research, and other advisory services for clients. In order to provide clients with tailored counsel, CRA may be given, and may pro-actively collect through its own research, personal information about key individuals or parties involved in an issue or incident about which our client has requested communications advice. Our legal basis is a legitimate interest in providing consultation to clients, including in relation to the handling of situations relating to or involving particular individuals.
In all cases where legitimate interests is relied upon as a lawful basis for processing Personal Data, CRA takes steps to ensure that its legitimate interests are not outweighed by any prejudice to the rights and freedoms of the underlying data subjects. This is achieved in a number of ways, including through the application of principles of data minimization and security, and by taking steps to ensure that personal information is only collected or otherwise obtained where it is relevant to the provision of Services to a client, and where access to personal information for CRA is reasonably necessary for the provision of those Services.
Other uses If you apply for a position with CRA, we will need to collect personal information in order to consider your application, and during any interview and assessment phase.
Finally, if you contact us for any other reason, we will collect basic contact details, as well as any other personal information relevant to the reason for your enquiry, in order to resolve that enquiry.
What is our legal basis for collecting personal information? All processing (i.e. use) of your personal information is justified by a “lawful basis” for processing. In the majority of cases, processing will be justified on the basis that:
- The processing is necessary for the performance of a contract to which you are a party, or to take steps (at your request) to enter into a contract (e.g. where you request certain Services as an individual client, or where we help advise your employer or service provider on fulfilling an obligation to you under a contract);
- The processing is necessary for us to comply with a relevant legal obligation (e.g. where we are required to collect certain information about our clients for tax or accounting purposes, or where we are required to make disclosures to courts or regulators); or
- The processing is necessary for the performance of a task carried out in the public interest (e.g. background checks for anti-money laundering and terrorist financing purposes); or
- The processing is in our legitimate interests, subject to due consideration for your interests and fundamental rights (this is the basis we rely upon for the majority of the processing of personal information in connection with the provision of our Services, and also for the purposes of most client on-boarding, administration and relationship management activities).
In limited circumstances, we will use your consent as the basis for processing your personal information, for example, where we are required by applicable law to obtain your prior consent in order to send you marketing communications.
Before collecting and/or using any special categories of data (as that term is defined in the GDPR), or criminal record data, we will establish a lawful exemption which will allow us to use that information. This exemption will typically be:
- Your explicit consent;
- The establishment, exercise or defense by us or third parties of legal claims; or
- Other uses allowed by applicable law including context specific exemptions provided for under local laws of EU Member States and other countries implementing the GDPR, such as in relation to the processing of special category data for the purposes of preventing or detecting fraud in relation to instructions from potential clients.
CRA may also disclose your personal information for the purposes of:
- Responding to requests from law enforcement agencies, regulators or courts, or to subpoenas, search warrants, or other legal requests;
- The prevention and/or detection of crime;
- Establishing legal rights or to investigate or pursue legal claims;
- A merger, acquisition or corporate restructuring to which CRA is subject;
- Preventing risk of harm to an individual.
International hosting and transfer of information CRA is a global organization and may transfer certain personal information collected on its websites across geographical borders to CRA offices, personnel, or third parties located throughout the world. CRA may also store such information in a jurisdiction other than where you are based including outside of the European Economic Area (“EEA”).
CRA will take appropriate steps ensure that transfers of personal information are in accordance with applicable law and carefully managed to protect your privacy rights and interests and transfers are limited to countries which are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangement are in place to protect your privacy rights. To this end:
- Transfers of personal information to CRA’s US offices are protected by CRA’s certification under the EU-US and Swiss-US Privacy Shield schemes. Transfers to US based service providers may also be protected through reliance on Privacy Shield.
- Where we transfer your personal information outside CRA to third parties who help provide us with any of the activities described in this policy, we obtain contractual commitments (such as the Standard Contractual Clauses) from them in order to protect your personal information.
- Where we receive requests for information from law enforcement, courts or regulators (who may be based overseas), we carefully validate these requests before any personal information are disclosed.
You have a right to contact us for more information about the safeguards we have put in place (including a copy of relevant contractual commitments) to ensure the adequate protection of your personal information when this is transferred as mentioned above.
Information security CRA has reasonable technical safeguards, security policies and procedures in place to protect personal information from unauthorized loss, misuse, alteration, or destruction. Measures we take include placing confidentiality requirements on our staff members and service providers, limiting access to your personal information on a “need to know” basis, and providing training to appropriate CRA personnel.
Despite CRA’s best efforts, however, security cannot be absolutely guaranteed against all threats.
Retention of your personal information CRA retains your personal information for the period of time required for the purposes for which it was collected, any compatible purposes which we subsequently establish, or any new purposes to which you subsequently consent, or to comply with legal, regulatory and CRA policy requirements. This period of time will usually be the period of your, or the relevant client’s, relationship or contract with CRA plus a period reflecting the length of time for which legal claims may be made following the termination of such relationship or contract. Some information (such as certain information required to demonstrate regulatory compliance) may need to be kept for longer. Personal information will be kept for a shorter or longer period of time if so required by law or an CRA policy, if the information becomes subject to a legal hold (for example, following a communication from our regulator) or if we have identified through a data protection impact assessment that a different retention period is appropriate.
Your EEA rights If your personal information is processed by an CRA entity in the EEA then, subject to certain exemptions, and dependent on how and why we use it, you have certain rights in relation to your personal information. We may ask you for additional information to confirm your identity before disclosing any personal information to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
You can exercise your rights by contacting us. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfil your request.
We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
Right to access You have the right to access personal information which CRA holds about you, together with certain information about how and why your personal information is processed.
Right to rectification You have a right to request us to correct your personal information where it is inaccurate or out of date.
Right to be forgotten (right to erasure) You have the right under certain circumstances to have your personal information erased. Your information can only be erased if it is no longer necessary for the purpose for which it was collected, and we have no other legal ground for processing the information.
Right to restrict processing You have the right to restrict the processing of your personal information, but only where:
- Its accuracy is contested, to allow us to verify its accuracy; or
- The processing is unlawful, but you do not want it erased; or
- It is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or
- You have exercised the right to object, and verification of overriding grounds is pending.
Right to data portability You have the right to data portability, which requires us to provide personal information to you or another controller in a commonly used, machine readable format, but only where the processing of that information is based on (i) consent; or (ii) the performance of a contract to which you are a party. Please note that CRA rarely relies upon consent as a legal basis, and the performance of a contract basis will only be relevant to the extent that you, as an individual, are party to a contract with CRA or a client, and our use of your personal information is necessary for the performance of that contract.
Right to object to processing You have the right to object to the processing of your personal information at any time, but only where that processing is based on our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
If you reside in the European Economic Area (EEA) and would like to exercise your right to access, review, correct or discuss how your personal information is processed by CRA please contact us at email@example.com.
If you reside outside of the EEA you can also make a request to update or remove information about you by contacting firstname.lastname@example.org. CRA will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards.
In addition, under applicable local law you may have the legal right to lodge a complaint with the relevant supervisory authority or local data protection authority.
Your California rights If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your PII by CRA to a third party for the third party’s direct marketing purposes. CRA, does not share, sell, rent or trade your PII with any third parties for promotional purposes. To make such a request, please contact CRA using the contact information provided below.
Marketing CRA may send you information related to its services, products and events that we believe are of interest to you. This information may be sent by post or via email. If at any point you no longer prefer to receive marketing communications from CRA you can (i) unsubscribe from CRA communications sent by email using a link provided in marketing emails sent from CRA; or (ii) contact us to exercise your right to prevent all forms of marketing (both post and email).
Children CRA’s websites are not intentionally designed for or directed at children under the age of 13. It is CRA’s policy never to knowingly collect or maintain information about anyone under the age of 13, except as part of an engagement to provide professional services.
Contact us If you have questions or concerns regarding this policy or CRA’s personal data processing policies, please contact CRA at: email@example.com.
If you reside in the EEA and have questions or concerns regarding this policy or processing of your personal information, please contact CRA at: firstname.lastname@example.org.
Effective Date: July 31, 2018.
This policy applies to CRA, Inc. and its affiliated companies (collectively “CRA”).
What are cookies and other tracking technologies? A cookie is a small text file containing small amounts of information that a website puts on a user’s computer (or mobile device) when you visit a website and is used by the website to send information to your browser and for the browser to return information to the website.
What types of cookies may be used? First party cookies: First party cookies are set by the CRA website you are visiting and they can only be read by CRA.
Session cookies: Session cookies are used by the server to store information about user page activities so users can easily pick up where they left off on the server’s pages. These are temporary cookie files, which are erased when you close your browser, and when you restart your browser and go back to the site that created the cookie, the website will not recognize you. You will have to log back in (if login is required) or select your preferences/themes again if the website uses these features. A new session cookie will be generated, which will store your browsing information and will be active until you leave the site and close your browser.
Persistent cookies: Persistent cookies are employed to store user preferences. These files stay in one of your browser’s subfolders until you delete them manually or your browser deletes them based on the duration period contained within the persistent cookie’s file. For Information on session and persistent cookies, see here.
Third party cookies: Third party cookies are set by a different organization to the owner of the website you are visiting. For example, the website might use a third party analytics company that will set its own cookies to perform this service (for example, as described below, this website uses Google Analytics).
CRA websites also uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to help analyze how users use the site, for example which pages are most frequently visited. The information generated by a Google Analytics cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
What if I don’t want cookies to be used? By using CRA’s website you agree that CRA can place cookies on your device as explained above. If you want to remove existing cookies from your device, you can do this using your browser options. If you want to block future cookies from being placed on your device, you can change your browser settings to do this. Please note that if you use your browser settings to block the use of all cookies it may impact certain functionality on the CRA websites or degrade your browsing experience.
Contact us If you have questions or concerns regarding this policy or CRA’s personal data processing policies, please contact CRA at: email@example.com.
EU-US AND SWISS-US PRIVACY SHIELD POLICY
EU-US and Swiss-US Privacy Shield CRA complies with the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks (collectively the “Privacy Shield”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the member countries of the European Union (EU), the European Economic Area (EEA), and Switzerland to the United States (“Personal Information”). CRA has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view CRA’s certifications, please visit www.privacyshield.gov.
CRA’s participation in the Privacy Shield applies to personal data received from the EU/EEA and Switzerland. CRA will comply with the Privacy Shield Principles in respect of such personal data. Some types of Personal Information may be subject to additional privacy-related requirements and policies, which are consistent with the Privacy Shield Principles. For example:
- Personal Information regarding and/or received from clients is also subject to any specific agreement with, or notice to, the client, as well as additional applicable laws and professional standards.
- Personal Information regarding CRA personnel is subject to internal human resource policies.
Types of personal information collected and purpose for collection Personal Information from Client Engagements: CRA provides professional consulting services to its clients. CRA’s clients may send Personal Information to it for processing on their behalf as part of the consulting services they have purchased. For example, CRA may receive Personal Information such as name, email address, employment information, or financial data. CRA uses any such Personal Information to perform services for its clients and to administer and manage its relationships with its clients.
In the event that a client engagement involves a transfer of Personal Information from the EU to the United States, the relevant clients are responsible for providing appropriate notice, where required, to the individuals whose Personal Information may be transferred to CRA, including providing individuals with certain choices with respect to the use or disclosure of their Personal Information, and obtaining any requisite consent. CRA handles such Personal Information in accordance with its clients’ instructions.
Personal Information Regarding CRA Employees: CRA may transfer Personal Information regarding CRA personnel. This Personal Information may include, without limitation, business contact information, employee ID, job role and reporting line, demographic information, work history, compensation and performance ratings. CRA uses such information to administer and manage its business.
Information security and data integrity CRA has reasonable security policies and procedures in place to protect Personal Information from unauthorized loss, misuse, alteration, or destruction.
Despite CRA’s best efforts, however, security cannot be absolutely guaranteed against all threats. To the best of CRA’s ability, access to your Personal Information is limited to those who have a need to know.
Access If CRA holds your Personal Information, under most circumstances you have the right to reasonable access to that data to correct any inaccuracies. You can also make a request to update or remove information about you by contacting firstname.lastname@example.org, and CRA will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards.
Recourse, enforcement and liability CRA commits to resolve complaints about your privacy and its collection or use of your Personal Information in compliance with the EU-US and Swiss-US Privacy Shield Principles. Please contact CRA at: email@example.com should you have a Privacy Shield-related (or general privacy-related) complaint.
If you are a resident of the EU/EEA, and you have a complaint related to this Policy that cannot be resolved with CRA directly, you may report your claim to the EU/EEA Data Protection Authorities located in your jurisdiction. If you are a resident of Switzerland, and you have a complaint related to this Policy that cannot be resolved with CRA directly, you alternatively may report your claim to the Swiss Data Protection Authority (Federal Data Protection and Information Commissioner). As further explained in the Privacy Shield Principles, a binding arbitration option will also be made available to you in order to address residual complaints not resolved by any other means.
CRA is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).
Changes to this policy CRA reserves the right to make changes to this EU – US and Swiss – US Privacy Shield Policy from time to time. CRA will notify you by posting amendments on this website.
Questions and comments If you have questions or concerns regarding this policy or CRA’s Personal Information processing policies, please contact CRA at: firstname.lastname@example.org.