EU Privacy Policy
Introduction
Protecting consumer privacy is important to Press Ganey Associates, Inc. Press Ganey (“PG”) and its affiliated subsidiaries. Accordingly, PG complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. PG has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view PG’s certification, please visit http://www.export.gov/safeharbor/ If there is any conflict between the policies in this privacy policy and the Principles, the Principles shall govern. This privacy policy outlines our general policy and practices for implementing the Principles, including the types of information we gather, how we use it and the notice and choice affected individuals have regarding our use of and their ability to correct that information. This privacy policy applies to all personal information received by PG whether in electronic, paper or verbal format.
Definitions
“Personal Information” or “Information” means information that (1) is transferred from the EU to the United States; (2) is recorded in any form; (3) is about, or pertains to a specific individual; and (4) can be linked to that individual.
“Sensitive Personal Information” means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership or that concerns an individual’s health.
Principles
Notice
PG shall inform an individual of the purpose for which it collects and uses the Personal Information and the types of non-agent third parties, if any, to which PG discloses or may disclose that Information. PG shall provide the individual with the choice and means for limiting the use and disclosure of their Personal Information. Notice will be provided in clear and conspicuous language as soon as practicable before PG uses or discloses the Information for a purpose other than for which it was originally collected.
Choice
PG will offer individuals the opportunity to choose (opt out) whether their Personal Information is (1) to be disclosed to a third party or (2) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. For Sensitive Personal Information, PG will give individuals the opportunity to affirmatively or explicitly (opt out) consent to the disclosure of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. PG shall treat Sensitive Personal Information received from an individual the same as the individual would treat and identify it as Sensitive Personal Information.
Onward Transfers
Prior to disclosing Personal Information to a third party, PG shall notify the individual of such disclosure and allow the individual the choice (opt out) of such disclosure. PG shall ensure that any third party for which Personal Information may be disclosed subscribes to the Principles or are subject to law providing the same level of privacy protection as is required by the Principles and agree in writing to provide an adequate level of privacy protection.
Data Security
PG shall take reasonable steps to protect the Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. PG has put in place appropriate physical, electronic and managerial procedures to safeguard and secure the Information from loss, misuse, unauthorized access or disclosure, alteration or destruction. PG cannot guarantee the security of Information on or transmitted via the Internet.
Data Integrity
PG shall only process Personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, PG shall take reasonable steps to ensure that Personal Information is accurate, complete, current and reliable for its intended use.
Access
PG shall allow an individual access to their Personal Information and allow the individual to correct, amend or delete inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated.
Enforcement
PG uses a self-assessment approach to assure compliance with this privacy policy and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the Principles. We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Information in accordance with the Principles.
If a complaint or dispute cannot be resolved through our internal process, we agree to cooperate and comply with the EU and Swiss data protection authorities.
Amendments
This privacy policy may be amended from time to time consistent with the requirements of the Safe Harbor. We will post any revised policy on this website.
Information Subject to Other Policies
PG is committed to following the Principles for all Personal Information within the scope of the Safe Harbor Agreement. However, certain information is subject to policies of PG that may differ in some respects from the general policies set forth in this privacy policy.
Contact Information
Questions, comments or complaints regarding PG's Safe Harbor Policy or data collection and processing practices can be mailed or emailed to:
privacy@pressganey.com.
Notice of Privacy Practices >
Press Ganey Associates, Inc.
Attn: Legal Department
404 Columbia Place
South Bend, IN 46601