EU-U.S. Privacy Shield Policy
Last Updated: May 27, 2020
The Cadmus Group LLC (“Cadmus”) participates in the EU-U.S. Privacy Shield framework (“Privacy Shield”) issued by the U.S. Department of Commerce. Cadmus commits to comply with the Privacy Shield Principles with respect to Consumer Personal Data that the company receives from the EU in reliance on the Privacy Shield. This Policy describes how Cadmus implements the Privacy Shield Principles for Consumer Personal Data.
For purposes of this Policy:
“Client” means any entity that obtains strategic and technical consulting or other services from Cadmus.
“Consumer” means any natural person located in the EU.
“Controller” means a person or organization which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.
“EU” means the European Union and the European Economic area countries of Iceland, Liechtenstein and Norway.
“Personal Data” means any information, including Sensitive Data, that is:
- About an identified or identifiable individual;
- Received by Cadmus in the U.S. from the EU; and
- Recorded in any form.
“Privacy Shield Principles” means the Principles and Supplemental Principles of the Privacy Shield.
“Processor” means any natural or legal person, public authority, agency or other body that processes Personal Data on behalf of a Controller.
“Sensitive Data” means Personal Data specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership (including trade union-related views or activities), sex life (including personal sexuality), information on social security measures, 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 (including administrative proceedings and criminal sanctions).
Types of Personal Data Cadmus Collects
As a Processor, Cadmus may receive Personal Data about its clients’ Consumers located in the EU in connection with providing strategic and technical consulting or other services to its Clients.
As a Controller, Cadmus obtains Personal Data from subsidiary ifok GMbH under an intracompany data transfer agreement. This includes Personal Data such as contact information of Consumers who are current, former, and potential employees, vendors, subcontractors, and clients. Cadmus uses this Personal Data in connection with maintaining the firm’s Client relationships and providing services to Clients.
Cadmus collects Personal Data directly from Consumers when they visit our website through automated means and voluntarily when a Consumer fills out a contact form. We use the information we collect for one or more of the following business purposes:
- To provide Consumers with information on services that they request from us;
- To provide Consumers with newsletters, event registrations, white papers, and other items that may be of interest;
- To improve our web site; or
- To fulfill the purpose described to Consumers when collecting their Personal Data.
In addition, Cadmus collects Personal Data, such as contact information, in connection with maintaining the firm’s Client relationships and providing services to Clients.
Our privacy practices regarding the processing of Consumer Personal Data comply, as appropriate, with the Privacy Shield Principles of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement and Liability.
When Cadmus acts as a Processor and Consumer Personal Data is transferred to Cadmus in the U.S. on behalf of a Client, the Client is responsible for providing appropriate notice to its Consumers and obtaining the requisite consent.
Relevant information also may be found in privacy notices pertaining to specific data processing activities.
When Cadmus maintains Personal Data about Consumers with whom Cadmus does not have a direct relationship because Cadmus obtained or maintains the Consumers’ data as a Processor, the Client is responsible for providing the relevant Consumers with certain choices with respect to the Client’s use or disclosure of the Consumers’ Personal Data.
Cadmus shares Consumer Personal Data with its clients, subcontractors, and service providers. Cadmus may disclose Consumer Personal Data without offering an opportunity to opt out, and may be required to disclose the Personal Data:
- To third-party Processors the company has retained to perform services on its behalf and pursuant to its instructions;
- If it is required to do so by law or legal process; or
- In response to lawful requests from public authorities, including to meet national security, public interest or law enforcement requirements.
Cadmus also reserves the right to transfer Personal Data in the event of an audit or if the company sells or transfers all or a portion of its business or assets (including in the event of a merger, acquisition, joint venture, reorganization, dissolution or liquidation).
Accountability for Onward Transfer of Personal Data
To the extent Cadmus acts as a Controller, except as permitted or required by applicable law, Cadmus provides Consumers with an opportunity to opt out of sharing their Personal Data with third-party Controllers. Cadmus requires third-party Controllers to whom it discloses Consumer Personal Data to contractually agree to:
- Only process the Personal Data for limited and specified purposes consistent with the consent provided by the relevant Consumer;
- Provide the same level of protection for Personal Data as is required by the Privacy Shield Principles; and
- Notify Cadmus and cease processing Personal Data (or take other reasonable and appropriate remedial steps) if the third-party Controller determines that it cannot meet its obligation to provide the same level of protection for Personal Data as is required by the Privacy Shield Principles.
With respect to transfers of Consumer Personal Data to third-party Processors, Cadmus:
- Enters into a contract with each relevant Processor;
- Transfers Personal Data to each such Processor only for limited and specified purposes;
- Ascertains that the Processor is obligated to provide the Personal Data with at least the same level of privacy protection as is required by the Privacy Shield Principles;
- Takes reasonable and appropriate steps to ensure that the Processor effectively processes the Personal Data in a manner consistent with Cadmus’ obligations under the Privacy Shield Principles;
- Requires the Processor to notify Cadmus if the Processor determines that it can no longer meet its obligation to provide the same level of protection as is required by the Privacy Shield Principles;
- Upon notice, takes reasonable and appropriate steps to stop and remediate unauthorized processing of the Personal Data by the Processor; and
- Provides a summary or representative copy of the relevant privacy provisions of the Processor contract to the Department of Commerce, upon request.
Cadmus remains liable under the Privacy Shield Principles if the company’s third-party Processor onward transfer recipients process relevant Personal Data in a manner inconsistent with the Privacy Shield Principles, unless Cadmus proves that it is not responsible for the event giving rise to the damage.
Cadmus takes reasonable and appropriate measures to protect Consumer Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction, considering the risks involved in the processing and the nature of the Personal Data.
Data Integrity and Purpose Limitation
Cadmus limits the Consumer Personal Data it processes to that which is relevant to the intended use. Cadmus does not process Consumer Personal Data in ways that are incompatible with the purposes for which the information was collected or subsequently authorized by the relevant Consumer. In addition, to the extent necessary for these purposes and consistent with its role as a Controller or Processor, Cadmus takes reasonable steps to ensure that the Personal Data the company processes is appropriate for its intended use, and accurate, complete and current. In this regard, Cadmus relies on its Consumers and Clients (with respect to Personal Data of Consumers with whom Cadmus does not have a direct relationship) to update and correct the relevant Personal Data to the extent necessary for the purposes for which the information was collected or subsequently authorized. Consumers (and Clients, as appropriate) may contact Cadmus as indicated below to request that Cadmus update or correct relevant Personal Data.
Subject to applicable law, Cadmus retains Consumer Personal Data in a form that identifies or renders identifiable the relevant Consumer only for as long as it serves a purpose that is compatible with the purposes for which the Personal Data was collected or subsequently authorized by the Consumer.
Consumers generally have the right to access their Personal Data. Accordingly, to the extent Cadmus acts as a Controller, where appropriate, Cadmus provides Consumers with reasonable access to the Personal Data Cadmus maintains about them. Cadmus also provides a reasonable opportunity for those Consumers to correct, amend or delete the information where it is inaccurate or has been processed in violation of the Privacy Shield Principles, as appropriate.
Cadmus may limit or deny access to Personal Data where the burden or expense of providing access would be disproportionate to the risks to the Consumer’s privacy in the case in question, or where the rights of persons other than the Consumer would be violated. Consumers may request access to their Personal Data by contacting Cadmus as indicated below.
When Cadmus maintains Personal Data about Consumers with whom Cadmus does not have a direct relationship because Cadmus maintains the Consumers’ data as a Processor for its Clients, Cadmus’ Clients are responsible for providing Consumers with access to the Personal Data and the right to correct, amend or delete the information where it is inaccurate or has been processed in violation of the Privacy Shield Principles, as appropriate. In such circumstances, Consumers should direct their questions to the appropriate Cadmus Client. When a Consumer is unable to contact the appropriate Client, or does not obtain a response from the Client, Cadmus will provide reasonable assistance in forwarding the Consumer’s request to the Client.
Recourse, Enforcement and Liability
Cadmus has mechanisms in place designed to help assure compliance with the Privacy Shield Principles. Cadmus conducts an annual self-assessment of its Consumer Personal Data practices to verify that the attestations and assertions Cadmus makes about its Privacy Shield privacy practices are true and that Cadmus’ privacy practices have been implemented as represented and in accordance with the Privacy Shield Principles.
In compliance with the Privacy Shield principles, Cadmus commits to resolve complaints about our collection or use of your Personal Data. EU Consumers with inquiries or complaints regarding our Privacy Shield policy should first contact Cadmus at email@example.com.
If a Consumer’s complaint cannot be resolved through Cadmus’ internal processes, Cadmus will cooperate with the JAMS Foundation pursuant to the JAMS Privacy Shield Program, which is described on the JAMS website. JAMS mediation may be commenced as provided for in the JAMS rules. Following the dispute resolution process, the mediator or the Consumer may refer the matter to the U.S. Federal Trade Commission, which has Privacy Shield investigatory and enforcement powers over Cadmus. Under certain circumstances, Consumers also may be able to invoke binding arbitration to address complaints about Cadmus’ compliance with the Privacy Shield Principles.
When Cadmus maintains Personal Data about Consumers with whom Cadmus does not have a direct relationship because Cadmus maintains the Consumers’ data as a Processor for its Clients, Consumers may submit complaints concerning the processing of their Personal Data to the relevant Client, in accordance with the Client’s dispute resolution process. Cadmus will participate in this process at the request of the Client or the Consumer.
Privacy Shield Website
To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.
How to Contact Cadmus
If you have any questions or comments about this Policy, the ways in which we collect and use your Personal Data, your choices and rights regarding such use, or wish to exercise your rights, contact us in writing at:
Data Protection Officer
The Cadmus Group LLC
100 Fifth Ave., Ste. 100
Waltham, MA 02451
Please note that you may be required to prove your identity before we can fulfill your request.