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0 At NGA HR, we truly care about upholding our reputation for excellence and the privacy, security and integrity of the information we handle on behalf of our customers, in conjunction with our partners and with regard to our own employees. On this page you can find our important policies and more transparency on how NGA handles personally identifiable information. At NGA Human Resources ('NGA HR'), we truly care about upholding our reputation for excellence. A major part of that commitment includes a focus on protecting the privacy, security and integrity of the information we handle on behalf of our clients, in conjunction with our affiliates, partners and third-party suppliers. At NGA HR we are passionate not only about protecting our clients' personal and confidential data but also about that of our own employees as well.On this page, you can find our important policies and more transparency on how NGA HR collects, uses, retains and discloses your personally identifiable information (personal data).
1 NGA HR Online Privacy Policy NGA HR Privacy Notice
2 Safe Harbor Privacy Statement Safe Harbor Privacy Statement
3 Code of Conduct Code of Conduct
4 Anti-Corruption Policy Anti-Corruption Policy
5 Anti-Money Laundering Policy Anti-Money Laundering Policy
6 Modern Slavery and Human Trafficking Statement Modern Slavery and Human Trafficking Statement
7 Abridged Data Privacy Policy Abridged Data Privacy Policy
8 Equality, Diversity and Dignity Policy Equality, Diversity and Dignity Policy
9 Security and Compliance Standard for Outsourced Third Party Service Providers Security and Compliance Standard for Outsourced Third Party Service Providers
10
11 NGA HR Online Privacy PolicyNGA NGA HR Online Privacy PolicyProduct-specific sections in this Privacy Notice provide additional information that is or may be relevant to the particular NGA HR products.
12 group of companies (hereinafter referred to 'us' or 'we') is committed to protecting and respecting the individual's right to privacy. Our privacy policy reflects current global principles and standards on handling personal data. This policy (together with our terms of use and any other documents referred to on it) sets out the basis on which any personal data we collect from the user of NGA's worldwide websites (hereinafter referred to 'you'), or that you provide to us, will be processed by us. The NGA HR group of companies (hereinafter referred to 'us', 'we', 'our') is committed to protecting and respecting the individual's ('you', 'your') right to privacy. Our privacy notice reflects current global privacy principles and standards when processing your personal data.This
13 T Privacy Notice applies to personal data we obtain through our websites, our affiliates' websites (if any), products, services (e.g. Marketing) and/or web-based applications (collectively, the 'Services'). A separate privacy notice may apply when you use the services of a Partner or a Third Party, linked to the Services of NGA HR.
14 When you access or use our Services, you acknowledge that you have read and understand its content.
15 his privacy policy applies to all NGA websites and our affiliates' websites (if any), but does not apply to any of the other NGA business activities whether online or offline. In addition, this privacy policy does not apply to services offered by third party companies or individuals such as but not limited to sites linked NGA HR may update this Privacy Notice, or other privacy policies, at any time as we deem appropriate. Where changes are material, we will post them here and, if changes are likely to affect you personally, we will attempt to contact you directly. It is important that you check from time to time this Privacy Notice to ensure that you have reviewed the most current version of this Notice.
16 How We Collect Personal Data
17 from our services, advertiser's services or other companies referred to in our site. We may collect information either directly from you (e.g. through this website, events, webinars), information that is collected automatically (e.g. IP address, browser type and version) or
18 Personal data NGA may collect from you
19 NGA may collect and process p through other sources (such as our clients or third party providers).
20 ersonal data (information) that you provide us Why and How We Use Your Personal Data
21 in any of the following ways: Your personal data may be processed in any of the following ways:
22 Information that you provide by filling in forms on any of our sites as listed in the attached document ('our site'). This includes information provided at the time of registering to use our site, subscribing to our service, posting material, any inquiry through the "Contact Us" section of the Site, an online employment application or requesting further services. We may also ask you for information when you report a p Information that you provide by filling in forms on any of our sites; this includes information provided at the time of registering to use our site, subscribing to our Services, posting material, any inquiry through the "Contact Us" section of our site, an online employment application or requesting further Services;
23 Establish and manage NGA HR accounts;
24 Communicate changes to our Services;
25 roblem with our site. Provide customer support, trouble
26 If you contact us for any purpose whatsoever, we may keep a record of that correspondence.
27 NGA may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
28 Details of your visits to our site including, but not limited to, traffic data, country data based on the IP address, we -shooting, manage subscriptions and respond to requests, questions and comments;
29 Ensure that the content of our site is presented in the most effective manner for you and your computer;
30 Communicate about, and administer participation, in special events, surveys, contests, webinars, and other offers and promotions;
31 Analyze users' behaviour when using our Services to customize preferences, and develop new products, services and advertising;
32 blogs and other communication data, and the resources that you access. Enable posting on our blog and other communication
33 Persons who supply us with their phone numbers, mailing address, phone number, and email address online may receive telephone contact or an answer channels (such as Social Media);
34 Comply with and enforce applicable legal requirements, agreements, and policies; and
35 Any other activity consistent with this Privacy Notice.
36 You have the right to OPT-OUT at any time by contacting us by the below listed details.
37 Specific examples of why and how we process your personal data:
38 SERVICE DELIVERY
39 in the form of an answer to an email or documentation sent to an address with information regarding new products and services or upcoming events. If you do not wish to receive such telephone calls or any other form of answer, please let us know by sending us an email. NGA HR processes the data we collect to provide you the Services we offer, which includes using the
40 NGA may collect and process personal data (information) that we collect from you in any of the following ways: data to improve and personalize your experience. We may also use that information to communicate with you, for service provisions or product updates. We usually process information not collected directly by us, but by way of our clients, which includes general HR and payroll information. When processing data for this purpose, we rely on contractual agreements with our customers who are the Data Controllers of your data.
41 IP ADDRESSES IP ADDRESSES
42 We may collect information about your computer that does not, by itself, identify you by name, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns. The purpose of the data is to improve effectiveness of the site, to help diagnose problems and to administer the site. We may collect information about your computer that does not, by itself, identify you by name, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns. The purpose of the data is to improve effectiveness of the site, to help diagnose problems and to administer the site.
43 COOKIES COOKIES AND INFORMATION GATHERING TOOLS
44 Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.
45 INFORMATION GATHERING TOOLS
46 NGA may also collect information during your visit to our website through automated tools, which include Web beacons (or named as web bugs), embedded web links and any other commonly used information gathering tools. You can read more on Cookies here . NGA HR may also collect information during your visit to our website through automated tools, which include Web beacons (or named as web bugs), embedded web links and any other commonly used information gathering tools.
47 A web bug is an object that is embedded in a web page or email and is usually invisible to the user but allows checking that a user has viewed the page or email. NorthgateArinso may use the Web beacons for the purpose of email tracking and page tagging for Web analytics . In addition we might use web bugs implemented through an embedded image include tracking pixel, pixel tag, 1×1 gif, and clear gif that may be implemented by using JavaScript .Where we store your personal data A web bug is an object that is embedded in a web page or email and is usually invisible to the user but allows checking that a user has viewed the page or email. NGA HR may use the Web beacons for the purpose of email tracking and page tagging for Web analytics . In addition we might use web bugs implemented through an embedded image include tracking pixel, pixel tag, 1×1 gif, and clear gif that may be implemented by using JavaScript .
48 The data that we collect from you may be processed, transferred to, and stored at any destination in the world located outside of the country where the data is collected. This means that data protection standards may be different from the place where the data is collected (such as a destination outside the European Economic Area ("EEA"), a destination outside the USA, or any other destination in the world). Data may be also stored in a cloud service and therefore located in an unknown place in the world. Data may also be processed by staff, operating outside any other countries where the data is collected, who work for us as an employee or contractor or for one of our third party suppliers (i.e. agents, service vendors, business partner and other). Such staff maybe engaged in, among other things, the fulfilment of your request and the provision of any kind of support services. By submitting your personal data to us, you agree to this transfer, storing or processing at any location in the world. NGA will take reasonable steps necessary to ensure that your data is treated securely and in accordance with this privacy policy.
49 Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
50 Uses made and purpose of the personal data
51 We use personal data collected and held about you through this website in the following ways:
52 To ensure that content of our site is presented in the most effective manner for you and for your computer.
53 To respond to your requests and thereafter to process your requests and deliver the requested materials and information. Any personal data requested by us will be the minimum to enable NGA to deal with the request. Where additional information is requested this will be marked and its provision is voluntary.
54 To provide you with information, products or services which we feel may be of an interest to you, where you have consented to be contacted for such purposes. Upon your acceptance, we may contact you via your email, telephone or address provided. The purpose of the data collected is to keep you up to date on the latest product announcements and services for marketing purposes or promotional activities and to respond to any of your requests. In addition, in case of a job application, the information will be kept in order to be able to respond back to you.
55 To notify you about changes to our service.
56 If you would not wish us to contact you (via phone, email, SMS or any other way), nor use your data in the way described in this privacy policy, nor you would want us to pass your details on to third parties, please do not hesitate to contact us at the following email address: marketing@ngahr.com .
57 Sensitive information is not sought through this website except where legally required or for legitimate purpose. However, if you decide to provide such sensitive information, the information will be accepted as explicit consent to use that information in connection with the purpose for which it has been provided.
58 Sharing of your personal data
59 As a global business operating company, we may disclose your personal data to any member of NGA group of companies, which means our subsidiaries, our ultimate holding company and its subsidiaries located at any place in the world.
60 We may disclose your personal data to third parties in the following cases:
61 In the event that we sell, buy, merger, consolidate, transfer, change in control any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
62 In the event of reorganisation or liquidation of our company whereby in some countries such a transaction may involve, in accordance with applicable laws, the disclosure of personal data to prospective or actual purchasers, or the receipt of it from sellers.
63 If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or any other governmental request.
64 If we may be required to provide personal data in response to a court order, subpoena, warrant, government investigation, any procedure issued by authority, or as otherwise required by law. We also may choose to establish or exercise our legal rights or defend against legal claims.
65 If we believe that there is a threat to the information stored in this website, or in order to protect or defend our rights or the well-being of our users. In general, we may release certain personal data in cases where we believe that the release of the information is reasonably necessary to protect the rights, property, and safety of others and ourselves.
66 We may contract with any third party supplier to provide any services for operating this website, for any requests or for the purpose of supporting our business activities. Any third party providing services to us may be allowed, on our behalf, to access your personal data provided by you for their proper use in connection with the specific services provided.
67 In cases where you provide us with your consent to do so. In those cases we will ask you for an explicit written consent confirmation.
68 Your rights on how the personal data is used
69 You have the right to ask us not to process your personal data in general or for any specific purpose. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing at any time by contacting us at marketing@ngahr.com . Your opt-out right will only apply for the specific purpose you have asked us for and therefore we may choose to correspond with you regarding your existing requests or other matters with us or to any correspondence that has already been initiated.
70 Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and any other third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites. NGA does not have any responsibility or liability for any tracking, data collection or other activities of third parties.
71 Access to information
72 If you wish to access or inspect the information we hold about you please contact us by email addressed to marketing@ngahr.com or you may choose to enter our site and view the information we hold about you. NGA does not assume any responsibility or any liability for confirming the accuracy and the completeness of the information we hold about you. If the information is not accurate or wrong please either send us an email or edit the information yourself in order to be able to update the information. When updating your information, we may ask you some questions in order to verify your identity before we can act on your request.
73 Information access and correction will do so free of charge, except where it would require a disproportionate effort we will inform you in advance of the fee to be paid.
74 Security of the personal data
75 In accordance with NGA policies, the group is committed to protect any personal data divulged to us. NGA implemented industry standard security measures, technologies and procedures in order to protect your personal data from loss, misuse, alteration or destruction. Our management team, employees and partners are required to keep personal data confidential.
76 Unfortunately, the transmission of information via the internet (by way of an email or other) is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use internal procedures and security features trying to prevent unauthorised access.
77 Changes to our privacy policy
78 Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Changes and additions are entering into effect when they are posted.
79 Data Retention information
80 NGA is retaining information for legitimate business or for legal purposes and will not hold information for a period longer than is reasonably necessary to fulfil the purposes for which it was collected and in the alternative information will be saved for the maximum period of 10 years.
81 Contact
82 Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to marketing@ngahr.com . In addition, please do not hesitate to contact us if you suspect any privacy or security breaches.
83
84 Safe Harbor Privacy Statement
85 NorthgateArinso, Inc. (NGAHR's U.S. company) 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. NorthgateArinso, Inc. 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 NorthgateArinso's certification, please visit http://www.export.gov/
86 safeharbor/
87 To read the entire Safe Harbor Privacy Statement, click here: http://www.ngahr.com/sites/default/files/nga_safe_harbor_privacy_policy_oct_2015.pdf
88 ​To read NGA's statement on the ECJ ruling of October 6, 2015 on the Safe Harbor Framework please follow this link: http://www.ngahr.com/blog/faqs-regarding-invalidity-eu-us-safe-harbor-agreement
89
90 Code Of Conduct
91 The Northgate Code of Conduct document articulates ethical and behavioral guidance for all Northgate Information Solutions (NIS) companies (including NGA Human Resources).
92 At Northgate Information Solutions (Northgate), we understand the great privilege and yet even greater responsibility we have in managing some of our clients' most sensitive assets – including their financial, HR and Payroll Data. Therefore, we make every effort to ensure that everyone at Northgate not only understands this responsibility but also embraces it with the highest standards of care and professionalism.
93 To read Northgate's entire Code of Conduct, click here: http://northgate-is.com/files/nis-code-conduct2014.pdf
94
95 Anti- Corruption Policy
96 This document defines Northgate Information Solutions' policy on the avoidance of bribery and corruption. It is applicable globally to all companies in the Northgate group, their employees, and business partners (collectively, Northgate). It will be regularly reviewed to ensure that it reflects any changes in applicable laws and developments in acceptable standards for the conduct of business. We are committed to maintaining the highest ethical standards and vigorously enforcing the integrity of our business practices wherever we operate throughout the world. Northgate will not engage in bribery or corruption of any kind. Adherence to the guidelines set out in this policy will help ensure that we comply with anti-bribery and anti-corruption laws and governmental guidance.
97 To read Northgate's entire Anti-Corruption Policy, click here: http://northgate-is.com/files/anti-corruption_policy.pdf
98
99 Anti-Money Laundering Policy
100 This document articulates operational and performance guidance for Northgate Information Solutions companies, employees and business partners.
101 To read Northgate's entire Anti-Money Laundering Policy, click here: http://northgate-is.com/files/anti-money-laundering-policy.pdf
102
103 Modern Slavery and Human Trafficking Statement
104 At Northgate we take seriously our responsibility to help prevent the crime of modern slavery and human trafficking across our own business as well as that of our partners and suppliers. As part of our commitment, we ensure that our workers are not being exploited, that our work environment is safe, and that all employment, health and safety and human right laws are fully adhered to.
105 Our Code of Conduct ( http://northgate-is.com/files/nis-code-conduct2014.pdf ) embodies and reinforces our commitment to these and other key guiding principles, and applies to all of Northgate as well as to our partners and suppliers. As part of our procurement process, we vet our partners and suppliers to identify and help prevent potential modern slavery or human trafficking risks in our supply chain, and require them to ensure that they either have equivalent policies to ours or that they abide by our policies.
106 Additionally, we have adopted and support the Ten Principles of the UN Global Compact ( https://www.unglobalcompact.org/what-is-gc/mission/principles ), which derive from the Universal Declaration of Human Rights, the International Labour Organization's Declaration on Fundamental Principles and Rights at Work, the Rio Declaration on Environment and Development and the United Nations Convention Against Corruption.
107
108 Abridged Data Privacy Policy
109 This document articulates operational and performance guidance for Northgate Information Solutions companies, employees and business partners.
110 To read Northgate's entire Abridged Data Privacy Policy, click here: http://northgate-is.com/files/nis_abriged_data_privacy_policy.pdf
111
112 Equality, Diversity and Dignity Policy
113 This document articulates operational and performance guidance for Northgate Information Solutions companies, employees and business partners.
114 To read Northgate's entire Equality, Diversity and Dignity Policy, click here: http://www.northgate-is.com/files/nis_equality_diversity_dignity_policy.pdf
115
116 Security and Compliance Standard for Outsourced Third Party Service Providers
117 This document articulates operational and performance requirements for Northgate Information Solutions vendors, contractors, subcontractors and suppliers who handle personal data. To read Northgate's Third Party Vendor Security and Compliance Standards, click here: http Learn more about Cookies and how they are used here:
118 www.youronlinechoices.eu/
119 www.allaboutcookies.org/
120 MARKETING
121 We may contact you to provide you information about our Services and offerings, or updates to them, with the information that you have provided to us, or that we have collected through third parties (e.g. external marketing companies).
122 The data we collect is used for internal review and to contact you for marketing purposes and is not shared with other organizations for commercial purposes.
123 What Kinds of Personal Data Do We Collect
124 The following are examples of types of personal data that we may collect. The specific kind of information collected by us will depend on the Services provided:
125 Contact information (name, last name, email address, phone number, address, company, job title)
126 Payment information (billing address, bank account information)
127 NGA HR purchase or service history
128 Your location
129 Your interests and preferences
130 Annual revenue
131 Number of employees
132 Demographic information
133 Biometric data such as voice recordings
134 Details about your computer, devices, applications and networks (including IP address, browser characteristics, device ID, operating system, or language preferences)
135 Activities on our website (including referring URLs or dates and times of website visits)
136 Products and Offerings
137 At NGA HR we have a range of Products and Offerings. Below are some samples of our most important ones and the Personal Data we collect through them:
138 Payroll Exchange
139 Payroll Exchange is a Business Process as a Service (BPaaS) solution for global payroll in the cloud, offering organisations a seamless connection to their Global HRIS system of choice and certified Payroll Services in 188 countries. The solution offers both consistent and coherent access to payroll transactions and data in order to benefit globally compliant payroll outsourcing services based on the most suitable payroll solution for each country.
140 MyHRW
141 MyHRW is a web based multichannel service center application driven by a skill based routing system. Every step taken, document used or email sent o solve an HR issue is logged.
142 euHReka
143 euHReka is a comprehensive preconfigured HCM solutions, supporting HR, employees, managers, line managers and service center agents.
144 NGA cleaHRsky
145 NGA cleaHRsky is the industry's first truly integrated HR-as-a-Service solution, delivering end-to-end HR, payroll and service center processes in 188 countries. It combines secure cloud technology from SAP SuccessFactors with industry-leading HR services from NGA HR.
146 Below are some examples of data we collect and process when using one of NGA HR's Products and Offerings (including but not limited to):
147 Name – First, Middle, Family Name / Surname
148 Date, Country and Place of Birth
149 Employee ID, Job Code, Cost Center, Department, Division and Location
150 Absences from Work, Time Profile and Work Schedule
151 National Social Security Number (or equivalent)
152 Passport Number
153 Driving Licence Number
154 National Identity Card Number
155 IP Address
156 Passwords
157 Address
158 Telephone Numbers (personal and work)
159 Email Addresses (personal and work)
160 Work Address
161 Bank Name, Account Number and Sort Code
162 International Bank Account Number (IBAN)
163 Business Identified Codes (BIC)
164 Salary including Bonus Payments and other Financial Benefits
165 Pension Details
166 Garnishment Details
167 Diversity (e.g. Religion, Race, Ethnic, Political)
168 Trade Union Membership
169 Work permit
170 Data Transfers
171 NGA HR is headquartered in the United Kingdom, with affiliates and subsidiaries throughout the world. The data that we collect may be processed, transferred to, and stored at our various service and data centre locations around the world, and may be located outside of the country where the data is originally collected. This means that data protection standards may be different from the place where the data is collected (such as a destination outside the European Economic Area ('EEA'), a destination outside the USA, or any other destination in the world). Data may be also stored with a cloud service provider (e.g. Microsoft, Salesforce.com, Oracle, Hubspot) and therefore located across those provider's cloud environment. However, NGA HR deploys and enforces a standard global operational, IT and Security control framework across its global service, data center and third-party locations.
172 Data may also be processed by staff, operating outside any other countries where the data is collected, who work for us as an employee or contractor or for one of our third-party suppliers (i.e. agents, service vendors, business partner and other). Such staff may be engaged in, among other things, the fulfilment of your request and the provision of any kind of support services. By submitting your personal data to us, you agree to this transfer, storing or processing at any location in the world. We execute the appropriate legal and contractual documentation to effectuate these transfers such as data processing and data transfer agreements.
173 NGA HR will take reasonable steps necessary to ensure that your data is treated securely, with appropriate technical and organizational measures, and in accordance with this privacy notice. Our Information Security Management System is designed to maintain an appropriate level of confidentiality, integrity and availability.
174 If you are located in the EEA or Switzerland, we provide adequate protection for the transfer of personal data to countries outside the EEA or Switzerland through a series or intercompany data transfer agreements based on the EU Standard Contractual Clauses, authorized by the European Commission.
175 Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, our products or services you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
176 Your Rights and Choices
177 If you would not wish us to contact you (via phone, email, SMS or any other way), nor use your data in the way described in this Privacy Notice, nor you would want us to pass your details on to third parties, please do not hesitate to contact us at the following email address: marketing@ngahr.com .
178 As an individual, you have the following rights in regards to the protection of your personal data, which you may exercise at any moment:
179 Right to be Informed
180 Right of Access
181 Right of Rectification
182 Right to Erasure
183 Right to Restrict Processing
184 Right to Data Portability
185 Right to Object
186 Rights in Relation to Automated Decision Making and Profiling
187 The exercise of these rights is free of charge for you and NGA HR has the obligation to respond to you without undue delay upon a raised request. We may request certain confirmation that you are authorized to exercise this request or ask for proof of your identity, before responding to your request.
188 Should we not satisfy your request, you have the right to raise a complaint to the relevant data protection authority. A link to the relevant data protection authorities can be found here .
189 Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and any other third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.
190 Please check these policies before you submit any personal data to these websites. NGA HR does not have any responsibility or liability for any tracking, data collection or other activities of third parties.
191 Sharing of Your Personal Data
192 As a global business operating company, we may disclose your personal data to any member of the NGA HR group of companies, which means our subsidiaries and affiliates, our ultimate holding company and its subsidiaries located at any place in the world.
193 We may disclose your personal data to third parties in the following cases:
194 In the event that we sell, buy, merge, consolidate, transfer, change in control any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
195 In the event of reorganisation or liquidation of our company whereby in some countries such a transaction may involve, in accordance with applicable laws, the disclosure of personal data to prospective or actual purchasers, or the receipt of it from sellers;
196 If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or any other governmental request;
197 If we may be required to provide personal data in response to a court order, subpoena, warrant, government investigation, any procedure issued by authority, or as otherwise required by law. We also may choose to establish or exercise our legal rights or defend against legal claims;
198 If we believe that there is a threat to the information stored in this website, or in order to protect or defend our rights or the well-being of our users. In general, we may release certain personal data in cases where we believe that the release of the information is reasonably necessary to protect the rights, property, and safety of others and ourselves;
199 We may contract with any third-party supplier to provide any services for operating this website, for any requests or for the purpose of supporting our business activities. Any third party providing services to us may be allowed, on our behalf, to access your personal data provided by you for their proper use in connection with the specific services provided.
200 In cases where you provide us with your consent to do so. In those cases we will ask you for an explicit written consent confirmation.
201 How We Secure Your Personal Data
202 In accordance with NGA HR policies, the group is committed to protect any personal data divulged to us. NGA HR implemented appropriate security measures, technologies and procedures in order to protect your personal data from loss, misuse, alteration or destruction. Our management team, employees and partners are required to keep personal data confidential.
203 Unfortunately, the transmission of information via the internet (by way of an email or other) is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use internal procedures and security features trying to prevent unauthorised access.
204 Data Retention Information
205 NGA HR is retaining information for legitimate business or for legal purposes and will not hold information for a period longer than is reasonably necessary to fulfil the purposes for which it was collected.
206 Children's Privacy
207 NGA HR does not knowingly collect personal data from children without obtaining parental consent in accordance with applicable laws and regulations. We do not knowingly process personal data of children for any purpose other than to deliver certain types of services to our clients. If you believe that we have collected information from your child in error or have any other questions or concern, please notify us and we will promptly respond.
208 Contact
209 Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to marketing@ngahr.com . In addition, please do not hesitate to contact us if you suspect any privacy or security breaches.
210
211 Safe Harbor Privacy Statement
212 On October 6, 2015, the European Court of Justice deemed Safe Harbor inadequate for the protection of EU citizen data, particularly in light of the access that the U.S. government had/has to data held on servers in the U.S. NorthgateArinso, Inc. (NGAHR's U.S. company) complied until then 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.
213 NGA HR relies on EU Model Clauses for the safe transfer of personal data from the EU to the US. NGA HR is considering to certify for the EU-US Privacy Shield, replacing the EU-US Safe Harbor Framework.
214 To read NGA's statement on the ECJ ruling of October 6, 2015 on the Safe Harbor Framework please follow this link:
215 http://www.ngahr.com/blog/faqs-regarding-invalidity-eu-us-safe-harbor-agreement
216
217 Code Of Conduct
218 The NGA HR Code of Conduct document articulates ethical and behavioral guidance for all NGA HR companies.
219 At NGA HR, we understand the great privilege and yet even greater responsibility we have in managing some of our clients' most sensitive assets – including their financial, HR and Payroll Data. Therefore, we make every effort to ensure that everyone at Northgate not only understands this responsibility but also embraces it with the highest standards of care and professionalism.
220 To read NGA HR's entire Code of Conduct, click here:
221 http://northgate-is.com/files/nis-code-conduct2014.pdf
222
223 Anti-Corruption Policy
224 This document defines NGA HR's policy on the avoidance of bribery and corruption. It is applicable globally to all companies in the NGA HR group, their employees, and business partners. It will be regularly reviewed to ensure that it reflects any changes in applicable laws and developments in acceptable standards for the conduct of business. We are committed to maintaining the highest ethical standards and vigorously enforcing the integrity of our business practices wherever we operate throughout the world. NGA HR will not engage in bribery or corruption of any kind. Adherence to the guidelines set out in this policy will help ensure that we comply with anti-bribery and anti-corruption laws and governmental guidance.
225 To read NGA HR's entire Anti-Corruption Policy, click here:
226 https://www.ngahr.com/sites/default/files/files/nga_hr_anti-corruption_policy.pdf
227
228 Anti-Money Laundering Policy
229 This document articulates operational and performance guidance for NGA HR companies, employees and business partners.
230 To read NGA HR's entire Anti-Money Laundering Policy, click here:
231 https://www.ngahr.com/sites/default/files/files/nga_hr_anti-money_laundering_policy.pdf
232
233 Modern Slavery and Human Trafficking Statement
234 At NGA HR we take seriously our responsibility to help prevent the crime of modern slavery and human trafficking across our own business as well as that of our partners and suppliers. As part of our commitment, we ensure that our workers are not being exploited, that our work environment is safe, and that all employment, health and safety and human right laws are fully adhered to.
235 Our Code of Conduct ( http://northgate-is.com/files/nis-code-conduct2014.pdf ) embodies and reinforces our commitment to these and other key guiding principles, and applies to all of NGA HR as well as to our partners and suppliers. As part of our procurement process, we vet our partners and suppliers to identify and help prevent potential modern slavery or human trafficking risks in our supply chain, and require them to ensure that they either have equivalent policies to ours or that they abide by our policies.
236 Additionally, we have adopted and support the Ten Principles of the UN Global Compact ( https://www.unglobalcompact.org/what-is-gc/mission/principles ), which derive from the Universal Declaration of Human Rights, the International Labour Organization's Declaration on Fundamental Principles and Rights at Work, the Rio Declaration on Environment and Development and the United Nations Convention Against Corruption.
237
238 Abridged Data Privacy Policy
239 This document articulates operational and performance guidance for NGA HR companies, employees and business partners.
240 To read NGA HR's entire Abridged Data Privacy Policy, click here:
241 https://ngahr.com/sites/default/files/files/nga_hr_abriged_data_privacy.pdf
242
243 Equality, Diversity and Dignity Policy
244 This document articulates operational and performance guidance for NGA HR's, employees and business partners.
245 To read NGA HR's entire Equality, Diversity and Dignity Policy, click here:
246 https://www.ngahr.com/sites/default/files/files/nga_hr_equality_diversity_dignity_policy.pdf
247
248 Security and Compliance Standard for Outsourced Third Party Service Providers
249 This document articulates operational and performance requirements for NGA HR vendors, contractors, subcontractors and suppliers who handle personal data. To read NGA HR's Third Party Vendor Security and Compliance Standards, click here:
250 ://ngahr.com/sites/default/files/tpv_security_standard_2017.pdf https://ngahr.com/sites/default/files/tpv_security_standard_2017.pdf