Privacy Policy - Europe, Middle East, Africa

Europe, Middle East, Africa

TheMIGroup, respects your privacy. Accordingly, TheMIGroup has reviewed its policies and practices to ensure that they meet legislation introduced within the European Economic Area (EEA), which includes the European Union (EU), in line with the EU Data Protection Directive (95/46/EC) and the EU Telecommunications Data Protection Directive (97/66EC) ("the Directives") and will continue to ensure that its policies and practices comply in all respects with any future laws and regulations in relation to your privacy. 

The purpose of this document is to inform you of the policies that have been put in place to protect your interests in this respect.

Fair and lawful information-handling

We will process all the data we collect and hold in accordance with applicable law. As further explained in this policy statement, we will ensure the quality and security of your data (even if the data are transferred to other companies in Europe or elsewhere); and we will fully respect your rights, interests and fundamental freedoms with regard to your data.

Legitimate purposes

We will only collect, record, process and store data which are needed to fulfill our contractual obligations towards our customers and clients; to serve other legitimate business interests such as relocation and assignment management; or to comply with legal requirements. We may disclose to any other company or TheMIGroup, and to other parties authorised by us, such information as may be necessary to provide you with the services you or your employer or membership group have requested or for the purpose of verification of details relating to your data held by us for legitimate purposes.

Data quality

We will employ effective procedures and safeguards to ensure that the data we hold on you are adequate, relevant and not excessive in relation to the purposes for which they were obtained, as well as accurate and up-to-date. Where we become aware of any inaccuracies in the data we hold, we will correct and, where appropriate, delete incorrect data. Retention periods are in place to ensure that data are only stored whilst they are required for the purposes in question or to meet data retention, legal and regulatory requirements. Where data are no longer required, we will ensure that they are disposed off in a secure manner.

Information to you

When we collect data from you, we will identify ourselves and inform you of the purpose(s) for which we collect the data. If we are collecting data from you on behalf of one of our clients, we will identify that client (the "controller" in terms of the European data protection regime) and explain that we are acting as the agent (or "processor") for that client. If our client is a non-European company which has appointed a representative in Europe in accordance with the Directives, we will also inform you of the identity of that representative (which may be TheMIGroup). If we have obtained data on you other than directly from you, we will inform you of this as soon as practicable after we have entered the data in our files or computers (unless you were already aware of the fact).

Special restrictions on the use of sensitive data

We will not normally seek data on your racial or ethnic origins, political opinions, religious or other beliefs, trade-union membership, physical or mental health, sex life or criminal convictions. When we do collect such data, it will be limited to data which are: required to be kept by law needed for legal proceedings or to establish, exercise or defend legal rights (including protection against fraud) clearly and strictly necessary to fulfil a contract between you and us (or between you and a company we represent) or needed to protect your vital interests or the vital interests of another person (for instance, if medical data are urgently required after an accident and you cannot give your consent).

Your rights

You have the right to see all the data we hold on you. Should you wish to have access to all or a particular part of your data, please contact us at privacy@themigroup or Joël Gonzalez, Privacy Officer, TheMIGroup, 118 Algonquin Parkway, Whippany, NJ 07981-1602. Such access will be granted in accordance with the requirements of national legislation and subject to any discretionary allowance for TheMIGroup to make a charge payable by you to cover TheMIGroup's administration costs incurred in providing you with such data. Such payment is to be made on application for access to your data and is to be no more than the maximum stipulated by national legislation (if applicable). The information will be forwarded to you within an appropriate period of time in accordance with national legislation. Where any discrepancies are discovered following your enquiry, we will take immediate steps to validate and, where appropriate, correct our records. We will confirm the actions taken in writing to you within an appropriate period of time in accordance with national legislation.

Security of information

We will only provide access to data on you to those of our employees who need such access in order to carry out any necessary processing. We have taken appropriate steps to ensure the security of data, whether it is stored in computer systems, paper files or other storage media. We expect the same high standards of security and confidentiality of any agents or sub-contractors we employ to process data for us.

Transfer of information outside the EEA

Data on you may, on occasion, be transferred to TheMIGroup facilities, or to any other service companies authorised by TheMIGroup, data processing agencies ("processors") or third parties, outside the EU or the EEA for analysis, technical processing or other legitimate purposes. The countries where such other facilities or companies are situated may have no data protection legislation, or laws which are less rigorous than the legislation introduced by the Member States of the EU and the EEA. In such cases, we will ensure that your rights with regards to any such processing and your data will still be adequately protected. Within TheMIGroup we have agreed worldwide acceptance of the European standards with regard to the processing of personal data from all our European companies, including TheMIGroup. If we transfer your data to agencies or third parties outside the EEA, we require similar, binding contractual undertakings, and we monitor compliance.

Direct marketing

TheMIGroup may market to you directly by e-mail or telephone to keep you informed of further services from us but only if related to your relocation or international assignment or as requested by your employer or membership organisation (unless you write to us asking us to exclude you from such offers or alternatively telephone, fax or e-mail us to that effect or you have done so previously and such exclusion is still operative) and for our own administration, market analyses and operational reviews. TheMIGroup may make contact with you by post, e-mail, or telephone for the purposes set out herein. (If you use more than one e-mail address to communicate with us, please notify us of each e-mail account you use.) TheMIGroup will always act according to your wishes and preferences. Whenever TheMIGroup directly markets to you by telephone or e-mail as described above we will comply beforehand with the requirements of national legislation under and by which you have recorded your desire not to be contacted by telephone and/or e-mail, as the case may be, for the purposes of direct marketing by any organisation. If you have notified such desire according to the laws of your country of domicile, then we will not call or e-mail you unless you subsequently notify us directly (either in writing, or by telephone, fax or e-mail) that this no longer applies.

Internet

At TheMIGroup, we are committed to protecting your privacy in the following ways:

When you use this Website, we may monitor customer traffic patterns and site usage to help us develop its design and layout. When you use this Website, we may also use the data we collect to occasionally notify you about important functionality changes to it, and to notify you of new products or services, and special offers related to your relocation or international assignment that we think you'll find valuable and of interest (unless you write to us asking us to exclude you from such offers or alternatively telephone, fax or e-mail us to that effect). When you use this Website, we may provide aggregate statistics about customers of TheMIGroup entering into transactions on-line, sales, traffic patterns and related Web-site information to reputable third parties, but these statistics will include no personally identifying data. TheMIGroup is the sole controller in the EEA/EU Member States of all data held in relation to use of this Website for information and transactional purposes on-line and all processing of data relating to your requirements and requests is therefore (in accordance with EC Directives 95/46/EC and 97/66/EC) subject to the data protection laws and regulations of your country of domicile. If no such laws and regulations exist in your country of domicile, then all processing of data relating to your requirements and requests is subject to United Kingdom data protection laws and regulations only in accordance with the provisions of the Data Protection Act 1998. We will maintain records relating to your use of this Website for information and transactional purposes on-line (including information about you provided by yourself or by third parties). We shall be entitled to process those data for the purpose of providing your requirements and requests and to keep you informed of further offers from us related to your relocation or international assignment which may be of interest (unless you write to us asking us to exclude you from such offers or alternatively telephone, fax or e-mail us to that effect). (If you use more than one e-mail address to communicate with us, please notify us of each e-mail account you use.) We shall be entitled to disclose such information as may be necessary to provide your requirements and requests or for the purpose of verification of details relating to any requests for information or transactions on-line you may make with TheMIGroup. We will not send you e-mails that you do not want, but we cannot guarantee that third parties to whom your details are sent will not do so. We will always seek your consent before disclosing data relating to you for the making of offers by third parties, by informing you of an intention to process your data for such purposes, and offering you the opportunity to opt out of such use of your data, in a form or document returned to us or by notifying us by telephone, fax or e-mail.

If at any time you feel that TheMIGroup has not adhered to these principles, please either notify us in writing or by telephone, fax or e-mail (privacy@themigroup.com) and we will use all commercially reasonable efforts to determine and correct the problem promptly. TheMIGroup welcomes your questions and comments about privacy.

This Privacy Policy was revised and effective as of February 28, 2008.