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Policy

Data Protection Policy

ÎÚÑ»´«Ã½ is committed to protecting the privacy of its clients, employees and partners. In order to do so, ÎÚÑ»´«Ã½ has adopted Binding Corporate Rules (BCR) as its global data protection policy.

ÎÚÑ»´«Ã½ BCR apply to all ÎÚÑ»´«Ã½ entities and their employees, ensuring a strong standard of protection for all personal data processed by ÎÚÑ»´«Ã½, whether on its own behalf and on behalf of its clients.

The EU Binding Corporate Rules (EU BCR) for Controller & Processor activities – initially approved by the European Data Protection Authorities in March 2016 and subsequently updated in January 2019 to comply with the General Data Protection Regulation (GDPR).

ÎÚÑ»´«Ã½ EU BCR were most recently updated in April 2023 in light of the so-called Schrems II decision. Indeed, in order to align with the additional obligations stemming from this decision, the European Data Protection Board (EDPB) – which is composed of representatives from EU national data protection authorities – is in the process of updating the BCR requirements. In the meanwhile, ÎÚÑ»´«Ã½ has been working with its Lead data protection authority, the CNIL, to start the process of updating its BCRs to comply with the upcoming requirements. The public version of ÎÚÑ»´«Ã½â€™s EU BCRs reflects this work.

In order to comply with UK data protection legislation following Brexit, ÎÚÑ»´«Ã½ Group also has the UK Binding Corporate Rules (UK BCR) for Controller & Processor activities, which was approved in March 2022 by the Information Commissioner Office (ICO) – the UK Data Protection AuthorityAccess here to UK BCR.

In addition to being ÎÚÑ»´«Ã½â€™s global data protection policy, BCR allow ÎÚÑ»´«Ã½ to safely transfer personal data among entities of the Group, in compliance with the EU General Data Protection Regulation (GDPR) and UK General Data Protection Regulation (UK GDPR).  

ÎÚÑ»´«Ã½ EU & UK Controller BCR (BCR-C) apply to and cover the processing and transfers of personal data carried out by ÎÚÑ»´«Ã½ entities acting as data controller  i.e. where ÎÚÑ»´«Ã½ is processing and transferring data between entities of the Group as part of its own operations

ÎÚÑ»´«Ã½ EU & UK Processor BCR (BCR-P) apply to and cover the processing and transfers of personal data carried out by ÎÚÑ»´«Ã½ as a data processor i.e. where ÎÚÑ»´«Ã½ is processing and transferring personal data to deliver services to its Clients. More specifically and as provided under the draft EDPB Recommendation 1/2022 (adopted on Nov. 2022) “BCR-P apply to data received from a controller that is not a member of the Group, and which are then processed by the concerned Group members as processors and/or sub-processors.â€