Overview

As set forth in the Integrity Institute’s Code of Conduct: "We respect the confidentiality and privacy of our clients, our staff, our members, and others with whom we do business."

The Tech Integrity Institute (“the Integrity Institute,” “Integrity Institute,” “we,” “us,” or “our”) complies with the requirements of the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce (the “Principles”). The Integrity Institute has certified that it adheres to the Principles with respect to personal information (as described below) that is transferred from the European Union and its Member States, the European Economic Area, the United Kingdom and/or Switzerland (“EU”) to the United States. If there is any conflict between the terms in this Privacy Shield Policy and the Principles, the Principles shall govern. The Integrity Institute is subject to investigatory and enforcement powers of the U.S. Federal Trade Commission.

This Privacy Shield Policy applies to personal information within the scope of the Integrity Institute’s Privacy Shield certification, which covers the following categories of information:

• Personal information regarding current, former and prospective partners, staff and employees for the purposes of operating and managing the Integrity Institute, performing human resource administration and maintaining contact with individuals.

• Personal information regarding current, former and prospective clients and partners and their personnel or others for the purposes of delivering Integrity Institute services, maintaining ongoing relationships and performing business development activities.

• Personal information regarding our third parties (e.g., vendors, service providers, etc.) and their personnel for the purposes of managing and administering the Integrity Institute’s business relationships with such third parties.

• Additionally, the Integrity Institute may, from time to time, collect personal information from the general public in order to answer inquiries or provide information requested.

• For the purposes of this Privacy Shield Policy, “personal information” means information that is about, or pertains to a specific individual and can be linked either directly or indirectly to that individual. In addition, certain personal information covered by the Integrity Institute’s Privacy Shield certification may be subject to more specific privacy policies of the Integrity Institute, which are also consistent with the requirements of the Principles, and in the case of any conflict between these policies and the Principles, the Principles will control.

For example:

• Personal information obtained from or relating to clients, partners, or former clients or partners is further subject to the terms of any specific privacy notice provided to the client, any contractual arrangements with the client and applicable laws and professional standards.
  

Individual Notice and Choice

We collect and process personal information from certain individuals and for the purposes described in this Privacy Shield Policy. Personal information covered by this Privacy Shield Policy is collected and processed only as permitted by the Principles. 

Notice to individuals regarding the personal information collected from them and how that information is used may be provided through this Privacy Shield Policy, other Integrity Institute website notices, or other direct forms of communication with appropriate parties, such as contracts or agreements. Where necessary and appropriate, consent for personal information to be collected, used, and/or transferred may also be obtained through these same means of communication (including opt-in consent for sensitive personal information).

Disclosures & Accountability for Onward Transfers

Consistent with the Principles, the Integrity Institute may transfer personal information to third parties, including transfers from one country to another. We will only disclose an individual’s non-public personal information to third parties under one or more of the following conditions:

• The disclosure is to a third party providing services to the Integrity Institute, or to the individual, in connection with the operation of our business, and as consistent with the purpose for which the personal information was collected. We maintain written contracts with these third parties and require that these third parties provide at least the same level of privacy protection and security as required by the Privacy Shield Principles. To the extent provided by the Principles, the Integrity Institute remains responsible and liable under the Privacy Shield Principles if a third-party that it engages to process personal information on its behalf does so in a manner inconsistent with the Privacy Shield Principles, unless the Integrity Institute proves that it is not responsible for the matter giving rise to the damage;

• With the individual’s permission to make the disclosure;

• Where required to the extent necessary to meet a legal obligation to which the Integrity Institute is subject, including a lawful request by public authorities and national security or law enforcement obligations and applicable law, rule, order, or regulation.

• Where reasonably necessary for compliance or regulatory purposes, or for the establishment of legal claims.

Access

Individuals whose personal information is covered by this Privacy Shield Policy have the right to access the personal information that the Integrity Institute maintains about them as specified in the Principles. Individuals may contact us to correct, amend or delete such personal information if it is inaccurate or has been processed in violation of the Principles (except when the burden or expense of providing access, correction, amendment, or deletion would be disproportionate to the risks to the individual’s privacy, or where the rights of persons other than the individual would be violated). Requests for access, correction, amendment or deletion should be sent to the Integrity Institute staff: hello@integrityinstitute.org.

Security

The Integrity Institute takes appropriate measures to protect personal information in its possession to ensure a level of security appropriate to the risk of loss, misuse, unauthorized access, disclosure, alteration, and destruction. These measures take into account the nature of the personal information and the risks involved in its processing, as well as best practices in the industry for security and data protection.

Data Integrity and Purpose Limitation

The Integrity Institute collects and processes personal information only to the extent that it is compatible with the purposes for which it was collected or subsequently authorized by the data subject. The Integrity Institute does not retain personal information after it no longer serves the purposes for which it was collected or subsequently authorized. We take reasonable steps to ensure that personal information is accurate, complete, current, and reliable for its intended use.

Enforcement

In compliance with the Principles, the Integrity Institute commits to resolve complaints about our collection or use of your personal information. Individuals with inquiries or complaints regarding our Privacy Shield Policy should first contact Integrity Institute staff at hello@integrityinstitute.org. We have a policy of responding to individuals within forty-five (45) days of an inquiry or complaint. If the dispute involved human resources personal information, or information collected in the context of an employment relationship, we will cooperate with the competent EU or Swiss data protection authorities and comply with the advice of such authorities. 

You may have the option to select binding arbitration under the Privacy Shield Panel for the resolution of your complaint under certain circumstances. For further information, please see the Privacy Shield website.

Modifications

The Integrity Institute may update this Policy at any time by publishing an updated version here. We will not update this Privacy Shield Policy in contravention to the Principles so long as we remain certified to the Privacy Shield.