Golder Associates is committed to complying with applicable laws, regulations and mandatory government standards regarding the protection of Personal Information (“Data Protection Laws”).
For purposes of this Policy, the following definitions shall apply:
"Agent" means any third party that collects or uses Personal Information under the instructions of, and solely for, Golder or to which Golder discloses Personal Information for use on Golder's behalf.
"Golder" means Golder Associates Corporation, its subsidiaries, affiliates, divisions and groups.
“Information Services” includes the combination of Golder owned or leased technologies and systems and the agents (its administrators and users including Golder employees, Customers and Third Party resources) using those technologies and systems to support Golder operations. Information Services include the collection, management, storage and retrieval/provision of information to agents.
“Personal Information” includes any personally identifiable information or data of or about a person that is the subject of protection under the Data Protection Laws, including, without limitation, a person’s social security number, phone numbers, residence addresses, financial information such as bank account information and credit card numbers and information that constitutes “Protected Health Information” as defined under The US Health Insurance Portability and Accountability Act of 1996 (“HIPAA”).
"Sensitive Personal Information" means Personal Information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns physical or mental health or condition, sexual life and/or orientation, or criminal history. In addition, Golder will treat as Sensitive Personal Information any information received from a third party where that third party treats and identifies the information as sensitive.
4. GENERAL PRIVACY PRINCIPLES
This Policy is based on the following principles:
Where Golder collects Personal Information, it will inform individuals about the purposes for which it collects and uses Personal Information about them and the choices and means, if any, Golder offers individuals for limiting the use and disclosure of their Personal Information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Information to Golder, or as soon as practicable thereafter, and in any event before Golder uses or discloses the information for a purpose other than that for which it was originally collected or discloses information to a non-Agent third party.
Where Golder receives Personal Information from its subsidiaries, affiliates or other entities, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such Personal Information relates.
For Personal Information, Golder will offer individuals the opportunity to choose (opt-out) whether their Personal Information is (a) to be disclosed to a non-Agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
For Sensitive Personal Information, Golder will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-Agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
Golder will provide individuals with reasonable mechanisms to exercise their choices.
4.3 Onward Transfer
Any Personal Information obtained for a business transaction may be processed by a third party service provider under the conditions set forth above.
4.4 Data Security
Golder will take reasonable organizational, technical, logical and physical security measures to protect Personal Information, and will comply with national and local laws and regulations pertaining to data collection and use. Due to the nature of the internet, Golder cannot guarantee the security of any information on or transmitted over the internet.
4.5 Data Integrity
Golder will use Personal Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Golder will take reasonable steps to ensure that Personal Information is relevant to its intended use, accurate, complete, and current. Golder will only collect and store Personal Information where there is a business requirement to fulfil the purpose of the request and will retain such information no longer than appropriate to fulfil the purpose of the request.
Golder may contact an individual to request that he or she update their Personal Information on a regular basis to ensure its integrity for the purposes of ongoing data management. Individuals also have the right on their own initiative to access, modify, supplement or update their Personal Information at any time. Individuals may also contact Golder to request access, modification, or deletion of Personal Information. Contact details are provided in Section 5 of this Policy.
Golder will internally assess compliance to this Policy as part of our self-audit process. Any Golder employee who violates this Policy may be subject to disciplinary action, up to and including dismissal and civil and/or criminal prosecution.
Any person that believes that his or her Personal Information has been processed in violation of this Policy may report the concern to Golder via our secure and confidential global compliance reporting process, which is available at https://golder.alertline.com. As part of this process, Golder 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 Golder and the complainant, Golder will resolve the dispute according to local law; for example in Europe we are committed to cooperating with the European data protection authorities or their authorized representatives.
4.8 Limitations on Application of Principles
Adherence by Golder to these principles may be limited (a) to the extent required or permitted by law or legal process, such as to respond to or investigate a legal or ethical obligation or request or pursuant to court orders, subpoenas, interrogatories or similar directive carrying the force of law; and (b) to the extent expressly permitted by an applicable law, rule or regulation.
5. PERSONAL INFORMATION OF USERS OF GOLDER WEBSITES AND ASSOCIATED INFORMATION SERVICES (EMPLOYEES AND THE PUBLIC)
Access to and use of:
- Any material on internet or intranet sites hosted by Golder;
- Sites hosted by third parties on behalf of Golder; and/or
- Information Services used for Golder business (including but not limited to Financial and HR systems, Customer Management systems and other online systems for the submission and retrieval of information) (hereinafter referred to as “Information Services”)
constitutes acceptance of, and is conditional upon acceptance of and compliance with, the provisions within this Policy. Submission of Personal Information to Golder, serves as consent for disclosures referred to in this Policy. If you disagree with this Policy or refuse to provide consent for the use of your Personal Information as referenced in this Policy, then you should not use Golder’s Information Services or provide Personal Information to Golder.
5.2 Use of Personal Information.
If during use of the Information Services, a form is completed or other information is submitted to Golder, Personal Information may be collected and used in order to:
- Respond to queries or requests;
- Process orders or applications;
- Administer or otherwise carry out our obligations in relation to an agreement ; and/or
- Maintain an internal mailing list for future communications.
From time to time Personal Information may be used for purposes other than as set out above, if it is Golder’s belief that these additional uses will be beneficial. However, Golder will not use Personal Information for the purposes set out below if it has been indicated otherwise when the Personal Information was submitted.
Personal Information may be used in the following additional ways:
- Communication. For example, to provide information relating to applications for jobs, seminars, etc.
- Marketing or research purposes. For example, to conduct market research or to disseminate information about products, services or promotions Golder may offer.
- Legal requirements. Golder may be obligated by law to disclose Personal Information to certain authorities or other third parties. For example, Golder may disclose Personal Information to law enforcement agencies in the countries where Golder (or third parties acting on Golder’s behalf) operate. Golder may also disclose and otherwise process Personal Information in accordance with applicable law to defend Golder's legitimate interests, for example, in civil or criminal legal proceedings.
5.3 Sensitive Personal Information
Golder does not seek any Sensitive Personal Information from users of Golder’s Information Services unless legally required to do so. Please do not provide Sensitive Personal Information outside of that which is required by law. However, if you provide Sensitive Personal Information, Golder considers that explicit consent to use that data in the ways described in this Policy or in the ways described when such information is disclosed.
5.4 Current Employees
The nature of Golder’s business and operations require the transfer of Personal Information to/between Golder operating companies, properties, centers of operations, data centers, or service providers that may be located internationally with different data protection laws in place than the Personal Information’s country of origin. If Personal Information is transferred in this way, Golder will take reasonable steps to protect such Personal Information. By submitting information (which may include Personal Information) to our Information Services, explicit consent is being given to these transfers.
Additionally, if Golder decides to sell, buy, merge or otherwise reorganize its businesses in certain countries, it may involve disclosure Personal Information to prospective or actual purchasers and their advisers, or receiving Personal Information from sellers and their advisers.
5.5 Prospective Employees
Personal Information submitted by candidates applying for a job at Golder may be used for reviewing applications to a specific open position and retained on file. In addition, such Personal Information and any additional information submitted or obtained otherwise in connection with a specific job posting may be transferred worldwide, where the data may be processed by a third party service provider in accordance with this Policy and laws that are applicable in each country.
5.6 Accuracy of Personal Information
It is Golder’s intent to keep Personal Information as accurate as reasonably possible. Details provided by users of Golder’s website or associated Information Services may be reviewed or changed at any time by logging in and making the appropriate modifications. If there are questions regarding the accuracy or processing of Personal Information, please refer to the Contact section of this Policy.
6.1 Information Placed on Your Computer and Cookies
Some information (commonly known as a "cookie") may be stored on a person’s computer when such person is looking at Golder’s internet facing Information Services. Golder is able to read these cookies for informational purposes when a person revisits Golder’s Information Services. The type of information collected as a result of a cookie being accepted is specific to an individual computer and includes the IP address, the date and time the PC visited the site, what parts of Golder’s websites were viewed, and whether the web pages relating to the related Information Services were delivered successfully when requested. This information is anonymous; it represents a computer rather than a person.
Cookie information is used to improve Golder’s knowledge of the use of our Information Services and to enable Golder to ascertain whether the Information Services are operating at an optimal level. This allows Golder to enhance its web offerings and to provide an enjoyable and an innovative online experience.
This information can be erased or blocked by changing the computer settings (please refer to help screens or manuals). If this information is erased or blocked, some features of the website or associated Information Services may not be accessed or utilized.
Golder does not seek, nor does it wish to obtain or receive, Personal Information directly from minors; however, the age of persons who access and use Golder Information Services cannot always be accurately determined. If a minor (as defined by applicable law) provides Golder with Personal Information without parental or guardian consent, Golder can be contacted to have this information removed and the minor unsubscribed from future Golder communications. Please refer to the Contact section of this Policy.
6.3 Links to/from Other Websites/Systems
Any linking to our Information Services, and any linking to internet pages within our Information Services or framing of content from our Information Services is prohibited without Golder’s prior written consent. Any reference on Golder’s Information Services to any product or service by trade name, trade-mark, hypertext link or otherwise is provided for convenience only and does not constitute or imply Golder’s endorsement or recommendation. To the extent Golder’s Information Services contain links to other websites, Golder does not control the availability or content of such websites, and such links do not signify that Golder endorses the websites. The use of any linked websites is at the user’s own risk.
Golder has implemented technology and policies with the objective of protecting a user’s privacy from unauthorised access and improper use and will update these measures as new technology becomes available, as appropriate.
Golder cannot and is not responsible for the privacy policies and practices of other websites even if:
- The third party web site was accessed using links from Golder’s Information Services; or
- Golder’s Information Services were linked from a third party site.
Golder recommends that the policy be checked of each website visited and that the owner or operator of such web site be contacted if you have any concerns or questions.
6.4 Feedback, Discussions Forums, and Notice Boards
If at any time Golder’s Information Services offer any discussion forums or notice board or feedback facilities, the information disclosed will be used in accordance with this Policy. Please note that Golder cannot and is not responsible for other parties' use of the Personal Information which is made available to such third parties through any discussion forums or notice boards or feedback facilities via our Information Services. Please be careful about what Personal Information is disclosed in this way.
6.5 User Conduct
All users of Golder’s Information Services, including use any of the features and tools on within, (including Golder Extranet Workspace) agree not to post or otherwise submit any Information that either causes any harm to any person or that is illegal or otherwise unlawful, including without limitation any hateful, harassing, pornographic, morally offensive, racist, criminal, quasi-criminal, obscene, profane, defamatory, libelous, threatening, constitutes or may encourage conduct that would be considered a criminal offense, give rise to civil liability or otherwise violate any law or regulation. Without limiting the generality of the foregoing, all users agree that Golder’s Information Services are not to be used in any manner, including the submission, posting and uploading of Information, or to any extent, to do any of the following:
- Commit any criminal or quasi-criminal offense, including without limitation, any pornography, hate, assault, or economic crime whatsoever;
- Upload, post or otherwise submit any content that shall harm, injure, damage or detrimentally affect any person, whether by tort, negligence, defamation or injury to reputation;
- Defame, abuse, harass, stalk, threaten or otherwise violate the legal rights (such as rights of privacy and publicity) of others;
- Infringe, contravene, breach or otherwise interfere with or harm the rights of any other person, including without limitation, any contractual, personality, confidentiality, privacy, moral, statutory, common law or intellectual property rights;
- Falsify the origin or source of software, information or other material contained in a file that is uploaded;
- Harm minors in any way;
- Forge headers or otherwise manipulate identifiers in order to disguise the origin of any content transmitted through the Information Services or develop restricted or password-only access pages, or hidden pages or images (those not linked to from another accessible page);
- Upload, post or otherwise submit any content without the right to transmit such content under any law or under contractual or fiduciary relationships (such as inside information, proprietary and confidential information learned or disclosed as part of employment relationships or under nondisclosure agreements);
- Upload, post or otherwise submit any content that contains software viruses, network worms, Trojan horses, logic bombs, bugs, worms, destructive features or any other computer code, files or programs designed to interrupt, destroy or limit the functionality of any computer software or hardware or telecommunications equipment, including the Site;
- Interfere with or disrupt the content or servers or networks connected to the Information Services, or disobey any requirements, procedures, policies or regulations of networks connected to the Information Services; or
- Promote or provide instructional information about illegal activities, promote physical harm or injury against any group or individual, or promote any act of cruelty to animals. This may include, but is not limited to, providing instructions on how to assemble bombs, grenades and other weapons, and creating "Crush" sites.
6.6 Intellectual Property Rights
Golder either owns the intellectual property rights in the underlying HTML, Java scripts, text, audio clips, video clips and other content that is made available to you via the Information Services ("Intellectual Property), or has obtained the permission of the owner of the Intellectual Property in such content to use the content in the Information Services. The display of trade-marks or trade-names within these Information Services does not convey or create any license or other rights in these marks or names. Any unauthorized use of them is strictly prohibited.
6.7 Limited License
Golder grants to users of its Information Services a limited license to display on individual computers, print, download and use the underlying HTML, text, audio clips, video clips and other content that is made available on Golder’s Information Services, for non-commercial, personal, or educational purposes only, provided that such content is not modified and any associated copyright notice(s) are included with and displayed on each copy of such content. No other use is permitted. Without limiting the generality of the foregoing, a user may not:
- Make any commercial use of such content;
- Include such content in or with any product that a user create or distribute; or
- Copy such content onto any website.
Notwithstanding the above, nothing contained in this license shall be construed as conferring any right under any copyright or any other person who owns the copyright in content provided on Golder’s website.
6.8 No Warranties
Unless otherwise stated, Golder does not warrant the quality, accuracy, completeness or suitability of any information on its Information Services. Such information is provided "as is" without representations, warranties or conditions of any kind, express or implied. Use of any information or materials on Golder’s Information Services is entirely at the user’s own risk. In no event shall Golder be liable for any damages whatsoever, including special, indirect or consequential damages, arising out of or in connection with the use or performance of information available via our Information Services.
6.9 Ontario Law Applies
The laws of the Province of Ontario and the laws of Canada applicable therein shall govern use of these Information Services and the interpretation, validity and effect of this Policy, notwithstanding any conflict of laws, provisions or your domicile, residence or physical location. Users of Golder’s Information Services are hereby consenting and submitting to the exclusive jurisdiction of the courts of the Province of Ontario in any action or proceeding related to our Information Services and agreeing not to commence any such action or proceeding except in Toronto, Ontario, Canada.
7. CHANGES TO THIS POLICY
Although most changes are likely to be minor, Golder may change this Policy from time to time and in Golder’s sole discretion. Golder encourages visitors to frequently check this page for the most recent version of the Policy. If any substantial changes are made to this Policy and the way in which Personal Information is used, such changes will be posted here.
8. CONTACT INFORMATION
Any questions, comments, or concerns regarding this Policy should be directed to Golder’s Information Security Office by email to firstname.lastname@example.org or in writing to:
Paul Beswick | Global Chief Information Security Officer
Golder Associates Corporation
Browns Lane Business Park
NG12 5BL, UK