ONE CRAWFORD PRIVACY NOTICE
Last Updated: 09 October 2018
This One Crawford Privacy Notice (the “Notice”) applies to the One Crawford Platform (together, “One Crawford” or the “Platform”), which is accessible online and via a mobile application (the “App”) in the Apple and Android app stores. In this Notice, references to “Crawford,” “we,” “our” or “us” mean Crawford & Company and its affiliate and subsidiary companies. This Notice explains how we collect, use and process personal information when Users use One Crawford. It is does not apply to other Crawford-related websites, services or systems, and is provided in addition to any other privacy notice(s) you have received as a Crawford employee. In this Notice, “personal information” means information that identifies or could be used to identify an individual User.
What is One Crawford?
Your privacy is important to us, and we want to be sure that you understand how we collect your personal information when you use One Crawford, how we will use and otherwise process such personal information, and your choices regarding this personal information. One Crawford is an employee social communications Platform that Crawford uses to communicate relevant news and updates to and engage with Crawford personnel (“Users”). Users may receive, share and comment on relevant news and information through One Crawford. For example, Users can view content in their personalized One Crawford newsfeed, review job postings and subscribe to certain channels in order to receive news and information on specific topics. In addition Users may upload additional profile information, share or request to share third party content in One Crawford, and like or engage with content in One Crawford. Users may also be able to share certain content publicly or with their own network or contacts on certain third party social platforms (e.g., LinkedIn, Twitter or Facebook). Participation and engagement in One Crawford is entirely optional and voluntary. You are not expected or required to use One Crawford and you are free to stop using One Crawford at any time.
Information We Collect and Process
We may collect and process information, including personal information, about registered Users as set out below, in order to facilitate their access to and engagement with news, updates and information about Crawford.
Registration and Account Information. In order to access One Crawford content and to participate in social networking activities you need to sign-in with your Crawford credentials. Once you register, your account profile will include your first and last name as well as your email address; this profile information is required for One Crawford. We also give you the option to share a profile picture and other information as part of your One Crawford profile; this information is optional and you can remove it from your profile at any time. You are not obligated to participate in One Crawford and you can delete your account at any time (for further information on how to delete your account see the “Your Rights and Choices” section below).
Content. When you submit comments, posts, pictures or videos, participate in our chat or messaging function, or submit other content we maintain a copy of this content. Along with your content we will display your profile name and a link to your profile page, as well as your picture if you uploaded one to your profile. We may also collect certain information such as metadata associated with your content (for example location, date/ time stamp, IP address, device type). If you request to post or share third-party content within the Platform, Crawford administrators will review your content and approve it before it is shared. Please note that the Crawford Code of Conduct and Social Media Policy apply to the use of One Crawford.
Engagement. We collect and use aggregate information about user engagement in the Platform, such as how many Users read, share, like, comment on certain content and how often it is shared by Users with their external networks. If you choose to share approved content with your external networks, we collect such information for aggregate reporting purposes. We do not analyse engagement information on an individual basis; we use this information to improve our communications and how we engage with Users and others.
Purposes of Use of Your Information
We use and process your personal information related to One Crawford for these purposes:
Providing Services. To provide you with the functionality of the One Crawford platform and promote internal communication between employees. Further we use the information to distribute content and comments to our employees that we think is relevant to you. If you agree, we will send you push notifications to your mobile device about certain featured content in One Crawford. Please see the “Your Rights and Choices” section below on how to manage your push notification preferences.
Personalization. To tailor content we display on the Platform in order to offer location customization and personalized content, and to otherwise personalize your experiences, for instance by providing you with news regarding your local Crawford entity or department and field you work in. For instance, we may display to you internal job openings that are relevant to your background.
Analytics and Improvement. To better understand how Users access and use the Platform, and for other research and analytical purposes, such as to evaluate and improve our communications and engagement with personnel.
Protect Our Legal Rights and Prevent Misuse. To protect the Platform and our business operations; to prevent and detect unauthorized activities and access, and other misuse; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party or violations of our relevant policies.
Legal Bases for Processing under EU Data Protection Law: For Users in the EU, we process your personal information for the above purposes on the basis that our processing is necessary to our legitimate business interests, in particular our interest in informing employees, increasing employee awareness and engagement, disseminating Crawford news and developments, providing personalized news and information to employees and improving or overall communications. When our processing is based on our legitimate interests, we believe that our interests are not overridden by your privacy rights; you may however, object to our processing of your personal information on this basis as explained the “Your Rights and Choices” section below. In addition to our legitimate business interests, We may also process your personal information where necessary to carry out your specific requests (e.g., to facilitate your sharing of approved content to you external networks), as well as where the processing is necessary to establish, defend and protect our legal rights and interests or those of third parties.
How We Disclose Your Information
We may disclose your information in the following cases:
Other One Crawford Users. Other One Crawford Users will see your profile information unless you have chosen the “private” setting for your account. If an account is set to “private” other One Crawford Users may not view or access your profile information (however Crawford administrators may view your profile and associated information).
Crawford Group. As a global company, your personal information may be transferred to our affiliated and subsidiary companies, whose handling of personal information is subject to this Notice.
Service Providers. We may disclose your information to third-party service providers who use this information to perform services for us, such as hosting providers, auditors, advisors, consultants, and customer service and support providers. For example, our service provider, Social Chorus, hosts the App and Platform.
Business Transfers. We may disclose or transfer information, including personal information, as part of any merger, sale, and transfer of our assets, acquisition or restructuring of all or part of our business, bankruptcy, or similar event.
Legally Required. We may disclose your personal information if we are required to do so by law (e.g., to law enforcement, courts or others, e.g., in response to a subpoena or court order).
Protect our Rights. We may disclose information where we believe it necessary to respond to claims asserted against us or, comply with legal process (e.g., subpoenas or warrants), enforce or administer our agreements and terms, investigation, and protect the rights, property or safety of Crawford or others.
Anonymized and Aggregated Data. We may share aggregate or de-identified information with third parties for research, marketing, analytics and other purposes, provided such information does not identify a particular individual.
Sharing Content. We may enable you to share approved content externally, such as with your contacts or network on LinkedIn, Facebook and Twitter. We do not expect or require you to share any content externally; if you do, your personal information and associated activities within that external social network are subject to such networks’ own privacy notice and associated policies. We do not track your activities within these networks, though we may collect information about how content is shared for the purpose of compiling aggregate reports.
We are a global company, and the data that we collect from you may be transferred to, accessed or stored in, and subject to requests from law enforcement in, jurisdictions outside of your home jurisdiction, including the United States, the Philippines, Australia, Canada, the European Union and other jurisdictions in which we or our service providers operate. Some of these jurisdictions, including the United States and the Philippines, may not provide equivalent levels of data protection as your home jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it, including through appropriate written data processing terms and/or data transfer agreements.
If you are in the European Economic Area (“EEA”) and we process your personal information in a jurisdiction that the European Commission has deemed to not provide an adequate level of data protection (a “third country”), we will implement measures to adequately protect your personal information, such as putting in place standard contractual clauses approved by the European Commission or another measure that has been approved by the European Commission as adducing adequate safeguards for the protection of personal information when transferred to a third country. You have the right to obtain a copy with details of the mechanism under which your personal information is transferred outside of the EEA; you may request such details by contacting us as set forth below.
Cookies & Tracking
Cookies. Cookies are alphanumeric identifiers that are transferred to your computer’s hard drive through your web browser to facilitate your log-in and make it easier for you to navigate the Platforms, as well as to collect usage and analytics data on the Platform. Most web browsers allow you to edit your browser options to delete, review or block cookies; see the Help portion of your browser for more information. If you block or disable cookies, you will not be able to login or use many of the Platform features.
Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on by your browser, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (also referred to as web beacons, web bugs or pixel tags), in connection with cookies to, among other things, collect usage and analytics data, help us manage content and to compile statistics about how Users engage with the Platform.
We have implemented safeguards and technical measures to protect the personal information that we have under our control from unauthorized access, use or disclosure. However, no data security measures can guarantee 100% security. Please use caution when using One Crawford.
As a general rule, we retain your personal information for as long as necessary to fulfil the purposes for which it was collected in accordance with the Crawford Global Records and Information Management Policy or as necessary to comply with our legal obligations, resolve disputes, maintain appropriate business records, and enforce our agreements.
Your Rights and Choices
You can update, correct, or delete your personal information in your One Crawford profile yourself by adjusting your profile or deleting information in your account. You may also set your account to “private”, in which case other One Crawford Users may not view or access your profile information anymore as long as your account is set to the private status, unless you share content through the App. Further, you may opt-out of receiving push notifications in the settings of your mobile device. You may also contact your HR manager or email firstname.lastname@example.org to ask us to update, correct, or delete your personal information or exercise any of your rights under data privacy law. You may also lodge a complaint with the privacy regulator or supervisory authority where you are located.
Under applicable EU data protection laws, Users in the EU have the following rights regarding their personal information processed related the use of One Crawford:
Right of access, erasureand rectification. You have the right to request access to and obtain a copy of any of your personal information that we may hold, and to request the deletion of your personal information under certain circumstances. You can see and update most of this information yourself online, or by contacting us directly at email@example.com. If the personal information we hold about you is inaccurate or incomplete, you are entitled to request we correct it, and if we have shared your personal information with others, we will let them know about the rectification where possible.
Right to restrict of processing. You can ask us to restrict the processing of your personal information in certain circumstances, such as where you contest the accuracy of that personal information or you object to our use or stated legal basis. Where your personal information is subject to restriction we will only process it with your consent or for the establishment, exercise or defence of legal claims.
Right to data portability. Where we are relying (as the justification for processing) upon your consent, or the fact that the processing is necessary to perform a contract to which you are party or to take steps at your request prior to entering a contract, and the personal information is processed by automated means, you have the right to receive a copy of personal information we have obtained from you in a structured, commonly used and machine readable format, and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
Right to object to processing (including profiling and marketing). Where we are relying upon legitimate interests basis to process your personal information, you have the right to object to that processing. If you object, we must stop that processing unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or we need to process the personal information for the establishment, exercise or defence of legal claims. Where we rely upon legitimate interest as a basis for processing we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis.
Right to withdraw your consent. In the event your personal information is processed on the basis of your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
Changes to this Notice
We may update this Notice from time to time to reflect changes. We will post changes by updating the Notice and effective date on this page. If we make any material changes that affect how we treat your personal information, we will endeavour to notify you in advance, such as by prominently posting a notice on the Platform or notifying you by email. We encourage you to periodically review this Notice to understand how Crawford protects your personal information. Once effective, the revised Notice will apply to you and your personal information.
Questions, Complaints and Contact Details
The data controller for personal information processed related to the One Crawford Platform is Crawford & Company, 5335 Triangle Parkway NW, Peachtree Corners, GA 30092 USA. If you have any questions or concerns regarding our use of your personal information or if you believe your privacy rights have been violated, please contact your local HR Manager directly. You may also contact the Crawford Global Privacy Office at firstname.lastname@example.org.
EU Users. If you are in the EU, you may also contact our EU Data Protection Officer directly at:
Crawford & Company
Attn: EU Data Protection Officer
70 Mark Lane
London EC3R 7NQ UK
If you are in Germany or Poland, you may contact your respective Data Protection Officer at:
Crawford & Company (Deutschland) GmbH
Attn: Data Protection Officer
Crawford Poland Sp. o.o.
Attn: Data Protection Officer