Willis North America Inc.:
Willis North America Inc. (“WNA”) respects your concerns about privacy. WNA has certified that it abides by the Safe Harbor privacy principles, as set forth by the United States Department of Commerce, regarding the collection, storage, transfer, use and other processing of Personal Data (as defined below) transferred from the European Economic Area (“EEA”) or Switzerland to the United States¹. This Policy outlines the company’s general policy and practices for implementing the Safe Harbor privacy principles for Personal Data.
For purposes of this Policy:
“Covered Person” means any natural or legal person (to the extent a legal person is subject to national data protection law) but excludes any individual acting in his or her capacity as an Employee.
“Employee” means any individual employed by Willis Group, any former or prospective employee of Willis Group, and any dependents, beneficiaries and other related individuals about whom they provide information to Willis Group in connection with the employment relationship.
“Personal Data” means any information that is (i) transferred to WNA in the United States from the EEA or Switzerland, (ii) recorded in any form, (iii) about, or relates to, an identified or identifiable Covered Person, and (iv) can be linked to that Covered Person. ²
“Sensitive Data” means Personal Data specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sex life, the commission or alleged commission of any offense, any proceedings for any offense committed or alleged to have been committed by the individual or the disposal of such proceedings, or the sentence of any court in such proceedings.
“Willis Group” means the subsidiaries and affiliates of Willis Group Holdings PLC.
WNA’s Safe Harbor certification can be found at https://safeharbor.export.gov/list.aspx. For more information about the Safe Harbor principles, please visit http://www.export.gov/safeharbor.
Safe Harbor Privacy Principles
WNA’s practices regarding the collection, storage, transfer, use and other processing of Personal Data comply with the Safe Harbor principles of notice, choice, onward transfer, access, security, data integrity, and enforcement and oversight.
WNA takes steps to have Covered Persons located in the EEA or Switzerland notified about the purposes for which it collects and uses Personal Data, the types of third parties to which it discloses the information (for example, service providers that process Personal Data on the company’s behalf), certain privacy rights of Covered Persons (such as the right to access Personal Data and the choices for limiting the use and disclosure of the information), and how to contact WNA about its practices concerning Personal Data.
Purpose of Collection and Use of Personal Data
WNA collects and uses Personal Data in connection with providing support services for the Willis Group’s operations, including, without limitation, to:
- provide data storage, website and application hosting and maintenance, email, telephony, network connectivity, and other similar information technology infrastructure and services;
- provide data back-up and restoration, disaster recovery and business continuity planning, and other similar facilities and services relating to technical and organizational information security measures;
- provide legal, accounting and other corporate administration functions and other resources.
WNA collects certain Personal Data in connection with these purposes, such as:
- names, titles, aliases and employee identification numbers;
- contact details such as telephone numbers, fax numbers, physical addresses, and email addresses;
- demographic information such as gender, age, date of birth, marital status, nationality, employment details, hobbies, family composition and dependents;
- personal characteristics and circumstances of sensitive nature such as racial or ethnic origin, sex life, mental and physical health, details of injuries, medication/treatment received, political or religious beliefs, labor union affiliation, criminal convictions, civil fines and judicial records;
- government-issued identifiers such as passport numbers, driving license numbers, vehicle registration numbers, taxpayer identification numbers and social security numbers (or other national equivalent);
- financial identifiers such as bank account numbers, payment card numbers, payment/transaction identifiers, policy numbers and claim numbers;
- financial information such as salary, bonus, record of earnings, tax code, tax and social security contributions, expenses claimed, creditworthiness, amounts insured, amounts claimed;
- other Personal Data created, obtained, or otherwise processed in connection with services Willis Group affiliates provide to their clients, including but not limited to details of incidents giving rise to an insurance claim and particular facts and circumstances about which Wills Group affiliates are consulted; and
- other Personal Data created, obtained, or otherwise processed by Willis Group affiliates in the course of carrying out their business activities, including but not limited to, CCTV recordings, recordings of telephone conversations, IP addresses and website visit histories.
WNA may share Personal Data with its service providers and among its affiliated entities for the purposes described above. In addition, WNA may disclose Personal Data (i) if the company is required to do so by law or legal process, (ii) to law enforcement authorities or other governmental officials, or (iii) when it believes disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity. WNA also reserves the right to transfer Personal Data in the event it sells or transfers all or a portion of its business or assets (including in the event of a reorganization, dissolution or liquidation). Should such a sale or transfer occur, WNA will use reasonable efforts to direct the transferee to use the Personal Data in a manner that is consistent with WNA’s privacy policies.
Onward Transfer of Personal Data
WNA may share Personal Data with service providers it has retained to perform services on its behalf. WNA requires service providers to whom it discloses Personal Data and who are not subject to laws based on the European Union Data Protection Directive 95/46 or another adequacy finding to either (i) subscribe to the Safe Harbor principles or (ii) contractually agree to provide at least the same level of protection for Personal Data as is required by the relevant Safe Harbor principles.
WNA provides Covered Persons with reasonable access to the Personal Data maintained about them. WNA also provide a reasonable opportunity for Covered Persons to correct, amend or delete that information where it is inaccurate. WNA may limit or deny access to Personal Data where providing such access is unreasonably burdensome or expensive under the circumstances, or as otherwise permitted by the Safe Harbor principles.
Covered Persons may request access to their Personal Data by contacting WNA as indicated in the “How to Contact WNA” section below.
WNA takes reasonable precautions to protect Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction.
WNA takes reasonable steps to ensure that Personal Data the company collects is (i) relevant for the purposes for which it is to be used, (ii) reliable for its intended use, and (iii) accurate, complete and current. WNA depends on Covered Persons and Willis Group affiliates’ corporate customers to update and correct Personal Data to the extent necessary for the purposes for which the information was collected or subsequently authorized by the individuals.
Enforcement and Oversight
WNA has established procedures for periodically verifying its implementation of and compliance with the Safe Harbor principles. The company conducts an annual self-assessment of its practices with respect to Personal Data to verify that representations it makes about the company’s privacy practices are true and that WNA’s privacy practices have been implemented as represented.
Covered Persons may file a complaint concerning WNA’s processing of their Personal Data under the Safe Harbor principles by contacting WNA as specified below. If WNA cannot resolve the complaint through its internal processes, WNA will cooperate with American Arbitration Association in accordance with the applicable commercial rules to address individuals’ complaints regarding privacy issues.
How to Contact WNA
Willis North America Inc.
26 Century Blvd.
Nashville, TN 37214
Attention: Legal Department
¹WNA’s Safe Harbor certification does not cover (i) any information it may receive from the United Kingdom or (ii) any information about Covered Persons it may receive from France.
²As described in note 1, information transferred to WNA from the United Kingdom or France does not constitute Personal Data for purposes of this Policy.