Safe Harbor Privacy Statement

PureWorks Inc. – dba UL Workplace Health and Safety “UL Workplace Health and Safety” is committed to protecting the privacy of its customers, employees, business partners and others.  UL Workplace Health and Safety complies with the U.S.-EU Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Economic Area. UL Workplace Health and Safety has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement.

This Safe Harbor Privacy Statement (this “Statement”) sets forth the privacy principles UL Workplace Health and Safety follows with respect to transfers of personal information from the European Economic Area (“EEA”) (which includes the twenty-seven member states of the European Union (“EU”) plus Iceland, Liechtenstein and Norway).

For further information about the Safe Harbor Program, please visit the U.S. Department of Commerce website at www.export.gov/safeharbor/.

Effective Date: 22 April 2013

Scope

This Statement applies to all Personal Information received from individuals by UL Workplace Health and Safety in the U.S. from the EEA, in any format.

Definitions

“Agent” means any third party that collects or uses Personal Information under the instructions of, and solely for, UL Workplace Health and Safety or to which UL Workplace Health and Safety discloses Personal Information for use on UL Workplace Health and Safety’s behalf.

“Personal Information” means any information or set of information that identifies or could be used by or on behalf of UL Workplace Health and Safety to identify an individual. Personal information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal information.

“Sensitive Personal Information” means Personal Information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, views or activities, that concerns health or sex life, information about social security benefits, or information on criminal or administrative proceedings and sanctions other than in the context of pending proceedings. In addition, UL Workplace Health and Safety will treat as Sensitive Personal Information any information received from a third party where that third party treats and identifies the information as sensitive.

Safe Harbor Privacy Principles

The following privacy principles apply to the transfer, collection, use or disclosure of Personal Information by UL Workplace Health and Safety.

Notice – When UL Workplace Health and Safety collects Personal Information directly from individuals in the EEA, it will inform them about (1) the purposes for which their Personal Information is being collected; (2) the types of third parties to which information about them may be disclosed; (3) the choices UL Workplace Health and Safety offers individuals regarding the uses and disclosure of their Personal Information, if applicable; and (4) how to contact UL Workplace Health and Safety with any questions or complaints in connection with this Statement.  Notice will be provided in clear and conspicuous language when individuals are asked to provide Personal Information to UL Workplace Health and Safety, or as soon as practicable thereafter, and in any event before UL Workplace Health and Safety uses or discloses the information for a purpose other than that for which it was originally collected.

Where UL Workplace Health and Safety receives Personal Information from its clients or other entities in the EEA, UL Workplace Health and Safety will use and disclose such information in a manner consistent with the notices provided by such entities and the choices exercised by the individuals to whom such Personal Information relates.

Choice – UL Workplace Health and Safety will provide individuals with an opportunity to choose (opt out) whether their Personal Information is to be (1) disclosed to a non-Agent third party; or (2) used for a purpose that is incompatible with the purpose(s) for which it was originally collected or subsequently authorized by the individual.  UL Workplace Health and Safety will provide individuals with an affirmative or explicit (opt in) prior to disclosure of their Sensitive Personal Information to a non-Agent third party or use of their Personal Information for a purpose other than those for which it was originally collected or subsequently authorized by the individual. Where UL Workplace Health and Safety receives Personal Information from its clients or other entities in the EEA, UL Workplace Health and Safety will not knowingly use or share such Personal Information in ways incompatible with the authorizations obtained by such entities with respect to such Personal Information without providing you a choice.

Onward Transfer – When disclosing Personal Information from individuals in the EEAto any third-party Agents, UL Workplace Health and Safety will obtain assurances from its Agents that they will safeguard Personal Information consistent with this Statement.  Examples of appropriate assurances that may be provided by agents include: (1) a written agreement requiring the Agent provide at least the same level of privacy protection as is required by the Safe Harbor Privacy Framework; or (2) the Agent is subject to EU Directive 95/46/EC and/or another adequacy finding, Safe Harbor certification by the Agent, or is subject to another European Commission adequacy finding (e.g., companies located in Canada). If UL Workplace Health and Safety has knowledge that an Agent is using or disclosing Personal Information in a manner contrary to this Statement, UL Workplace Health and Safety will take reasonable steps to prevent or stop such use or disclosure.

Security – UL Workplace Health and Safety takes reasonable precautions to protect EEA Personal Information in its possession from loss, misuse, unauthorized access, disclosure, alteration and destruction.

Data Integrity – UL Workplace Health and Safety takes reasonable steps to ensure that any Personal Information is accurate, complete, current and otherwise reliable in relation to the purposes for which the information was obtained or authorized by an individual.

Access and Opportunity to Correct – Upon written request to UL Workplace Health and Safety, UL Workplace Health and Safety will provide individuals in the EEA with reasonable access to Personal Information that it holds about them. UL Workplace Health and Safety will also take reasonable steps to allow individuals to review their Personal Information for purposes of correcting their Personal Information that is demonstrated to be inaccurate or incomplete, except where the burden or expense of providing access would be disproportionate to the risks of the individual privacy in the case in question or the rights of persons other than the individual would be violated.

Enforcement – UL Workplace Health and Safety has established internal procedures for verifying its compliance with this Statement and periodically conducts a self-assessment of its practices with respect to EEA Personal Information. Individuals covered by this Statement may raise any concerns about our processing of their Personal Information by contacting UL Workplace Health and Safety at the address below, and UL Workplace Health and Safety will seek to resolve any concerns. If a complaint or concern cannot be resolved though UL Workplace Health and Safety’s internal process, UL Workplace Health and Safety will submit such complaints for resolution with the Judicial Arbitration and Mediation Services (“JAMS”) in accordance with the expedited rules of JAMS. UL Workplace Health and Safety has also agreed to participate in the dispute resolution programs provided by the European Data Protection Authorities solely with respect to Personal Information that constitutes human resources data.

Limitation on Scope of Principles – Adherence to these Safe Harbor Principles may be limited to the extent required to meet legal, governmental or national security obligations, including requirements to cooperate with law enforcement.

Changes to this Statement – This Statement may be amended from time to time, consistent with the requirements of the Safe Harbor Privacy Principles. The revisions will take effect on the date of publication of the amended Statement.

Contact Information – Please address any questions, comments or complaints about this Statement or any rights set forth in this Statement by contacting UL Workplace Health and Safety by any of the methods identified below

E-mail:

Francesca Wolf
francesca.wolf@ul.com

Address:

PureWorks Inc. – dba UL Workplace Health and Safety
5000 Meridian Blvd., Suite 600
Franklin, TN USA 37067
Telephone: 615.367.4404