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Notice. Where NTT DATA Business Solutions collects Personal Information directly from an individual, it will inform the individuals to whom the information pertains about the purposes of such collection and usage, how to contact us, the types of third parties with whom we share Personal Information (if applicable), and any ways that individuals may limit the use and sharing of such information. This notice will be provided when individuals are first asked to provide Personal Information to NTT DATA Business Solutions or as soon thereafter as is practicable.
Choice. NTT DATA Business Solutions will offer an individual the opportunity to choose (opt out) whether Personal Information is (a) to be disclosed to a non-agent third party or (b) to be used for a purpose that is incompatible with the purpose(s) for which it was originally collected or subsequently authorized by the individual. Individuals will be provided with clear and conspicuous, readily available, and affordable mechanisms to choose. For Sensitive Information, individuals will be given affirmative or explicit (opt in) choice if the information is to be disclosed to a third party or used for a purpose other than those for which it was originally collected or subsequently authorized by the individual through the exercise of opt in choice.
NTT DATA Business Solutions will only transfer Personal Information to a non-agent third party (i) as permitted under the European Data Privacy Directive or (ii) consistent with the Notice and Choice Principles stated above. If NTT DATA Business Solutions discloses Personal Information to an agent third party, NTT DATA Business Solutions will either (i) ensure that the third party is subject to the safe harbor principles or (ii) require the third party by contract to provide the same level of protection as required by the safe harbor principles.
Security. NTT DATA Business Solutions will take reasonable precautions to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction.
Data Integrity. Consistent with the Principles, Personal Information will only be used if it is relevant for such purposes. NTT DATA Business Solutions will not process Personal Information in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by the individual. To the extent necessary for those purposes, NTT DATA Business Solutions will take reasonable steps to ensure that Personal Information is reliable for its intended use, accurate, complete, and current.
Access. NTT DATA Business Solutions will provide individuals with reasonable access to Personal Information about them and they may request the correction or amendment of Personal Information that they demonstrate to be incorrect or incomplete.
Enforcement. NTT DATA Business Solutions has put in place mechanisms to verify our ongoing adherence to these privacy principles. Any employee that fails to follow the Principles set forth in this Policy will be disciplined. We encourage individuals covered by this statement to raise any concerns that they have about the way we process their Personal Information by contacting us at address below, and we will do our best to resolve them. We have also agreed to participate in the independent dispute resolution program provided by the European Data Protection Authorities Panel.
Dispute Resolution. Any questions or concerns regarding the use or disclosure of Personal Information should be directed to the HR Director of NTT DATA Business Solutions, at the address given below. Any individual presenting a question or concern about Personal Information must submit a written dispute resolution request providing the details of the issue in order for the HR Director to effectively to evaluate the issue. The HR Director will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with the principles contained in this Policy. For complaints that cannot be resolved between NTT DATA Business Solutions and the complainant, NTT DATA Business Solutions elects to participate in the dispute resolution procedures of the home country of the complainant and will cooperate with the European data protection authorities to investigate and resolve disputes pursuant to the Principles. NTT DATA Business Solutions will comply with any advice given by the competent European data protection authority where the European data protection authority takes the view that NTT DATA Business Solutions needs to take specific action to comply with the Principles, including remedial or compensatory measures for the benefit of individuals affected by any non-compliance with the
Principles. NTT DATA Business Solutions will provide the competent European data protection authority with written confirmation that such action has been taken.
Limitation on Application of Principles
Adherence by NTT DATA Business Solutions to these Principles may be limited (a) to the extent required to respond to a legal or ethical obligation (for example a national security requirement); and (b) to the extent expressly permitted or required by an applicable law, rule or regulation.
Questions or comments regarding this Policy should be submitted to our HR Director by mail as follows:
NTT DATA Business Solutions, Inc.
10856 Reed Hartman Highway
Cincinnati, OH 45242
Email: [email protected]
This Policy may be amended from time to time, consistent with the requirements of the Principles.
Agent means any person or third party that collects or uses Personal Information under the instructions of, and solely for, NTT DATA Business Solutions or to whom NTT DATA Business Solutions discloses Personal Information for use on NTT DATA Business Solutions’ behalf.
Personal Information means any information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to physical, physiological, mental, economic, cultural or social identity.
Sensitive Information is defined as Personal Information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying the sex life of the individual.
Effective Date: May 4, 2011
Last Updated: May 5, 2014
Reviewed: April 28, 2015
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