GENERAL PRIVACY POLICY (GDPR COMPLIANT)

Updated: 5-25-2018

  1. INTRODUCTION AND GENERAL INFORMATION

1.1 General information

Best Christian Workplaces Institute respects your privacy and is committed to protecting it through our Privacy Policy.

Best Christian Workplaces Institute (BCWI), is a 501(c)(3) Washington State nonprofit organization, headquartered at 9311 SE 36th Street, Suite 202, Mercer Island, WA. 98040. (“BCWI” “We,” or “Us”), conducts research projects through surveys and other data gathering techniques (focus groups, questionnaires, etc.). www.bcwinstitute.org. BCWI conducts its research on behalf of employers, its clients and customers around the world.

In this privacy policy (this “Policy”), an employer that has contracted with BCWI is called an “Employer.”  Those individuals who access and transmit data for the Employer are called a “User.”  Those individuals who respond to our surveys or answer our questions are called a “Respondent,” and are most often an employee or vendor of an Employer. Anyone who visits our publicly-facing websites, such as www.bcwinstitute.org, is called a “Visitor.”

At BCWI, the privacy and security of Employers, Users, Respondents, and Visitors are of paramount importance. BCWI is committed to protecting the data you share with us. This Policy explains how BCWI collects and processes information that can be used to directly or indirectly identify an individual, included in the definition of Personal Data below.

All information stored on BCWI’s platforms and servers is treated as confidential.

Employee and Volunteer Engagement Surveys.  All information stored on BCWI’s platforms and servers is treated as confidential. BCWI contracts with Tierpoint Data Centers, www.tierpoint.com, which is a subcontractor and private cloud data center that provides us with our data infrastructure platform. Survey responses are stored on cloud-based servers controlled by TierPoint. TierPoint complies with the EU-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. TierPoint adheres to the Privacy Shield principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the EU-US Privacy Shield program and to view TierPoint’s certification please visit https://www.privacyshield.gov   For more certification information please visit https://www.tierpoint.com/about-us/certifications/

360 Surveys.  BCWI contracts with EchoSpan, www.EchoSpan.com, for our 360 Leadership Assessment which is a subcontractor and software vendor that provides us with our 360 Survey administration software platform. 360 Survey responses are stored on cloud-based servers controlled by EchoSpan. More information about EchoSpan’s security and privacy policies can be found at https://www.echospan.com/privacy.asp .

Data, including Personal Data, collected by BCWI that is not stored on EchoSpan’s platform, will be stored on locked and secure servers in BCWI’s headquarters or on secure, hosted servers provided by Tierpoint Web Services.

There is no public access to the servers located in BCWI’s headquarters. These local servers may only be accessed by BCWI personnel onsite or through a secure virtual private network.

As noted, BCWI maintains its own data networks, where it may store Personal Data that is used to prepare and administer its surveys and other research tools. This type of Personal Data will be collected directly from an Employer and its Users.

All responses collected from Respondents will be gathered through EchoSpan’s platform or through the use of paper surveys, which will be shipped using USPS or other reputable common carrier.

BCWI implements and maintains appropriate technical, security, and organizational measures to protect Personal Data against unauthorized or unlawful processing and use, and against accidental loss, destruction, damage, theft or disclosure.

1.2 Sensitive Data

Sensitive Data may be provided by an Employer to BCWI. In addition, BCWI may ask a question on a survey that might ask for Sensitive Data. By answering a survey question, a Respondent is agreeing to the collection and use of the data being provided by the Respondent.

1.3 Definitions

In this Policy, “Sensitive Data” means Personal Data that discloses a Respondent’s race or ethnicity, sex at birth, and gender identity. In this Policy, “Personal Data” includes the following:

Under the laws of the United States, Personal Data shall include any “non-public personal information” as that term is defined in the Gramm-Leach-Bliley Act found at 15 USC Subchapter 1 §6809(4), and “protected health information” as defined in the Health Insurance Portability and Accountability Act found at 45 CFR §160.103.

Under the laws of the countries in the European Economic Area (“EEA”), Personal Data shall have the meaning given to it in Directive 95/46/EC (the “EU Directive”) and in the General Data Protection Regulation (“GDPR”). “EU” means the European Union.

Under the laws of Australia, Personal Data shall include information or an opinion about an identified individual or an individual who is reasonably identifiable: (a) whether the information is true or not; and (b) whether the information or opinion is recorded in a material form or not.

Data Controller” means the party that determines the purposes or means of the processing of the Personal Data.

Data Processor” means the party that processes the Personal Data on behalf of the Data Controller.

 

  1. COLLECTION AND USE

2.1 General

The following sections cover the specifics of each of the four groups from which data is collected: Employers, Users, Respondents, and Visitors.

2.2 Website Visitors

If you are a Visitor to our website only, and not a Respondent, Employer, or User, then this Section 2.2 is relevant for you.

By visiting our public websites, you consent to the collection and use of your Personal Data as described herein. If you do not agree with the terms set out herein, please do not visit our public websites. If required by applicable law, we will seek your explicit consent to process Personal Data collected on this website or volunteered by you. Kindly note that any consent will be entirely voluntary. However, if you do not grant the requested consent to the processing of your Personal Data, the use of our public websites may not be possible.

BCWI may collect, record and analyze information of Visitors to its public websites. We may record your IP address and use cookies. BCWI may add information collected by way of page-view activity. Furthermore, BCWI may collect and process any Personal Data that you volunteer to us in a website form, such as when you register for events or sign up for information, White Papers, and newsletters. If you provide BCWI with your social media details, BCWI may retrieve publicly available information about you from social media.

Personal Data may comprise your IP address, first and last name, your postal and email address, your telephone number, your job title, data for social networks, your areas of interest, interest in BCWI products, and certain information about the company you are working for (company name and address), as well as information as to the type of relationship that exists between BCWI and yourself.

BCWI gathers data about visits to its public websites, including numbers of Visitors and visits, Geo-location data, length of time spent on the site, pages clicked on, and/or from where Visitors have come.

2.2.1 Purpose of processing Visitor Personal Data

BCWI uses collected data from Visitors to communicate with Visitors, to customize content for Visitors, to show ads on other websites to Visitors, and to improve its websites by analyzing how Visitors navigate and use its websites.

We may process Personal Data if we have your consent or for legitimate business purposes, which include the following:

  • Where the processing enables us to enhance, modify, personalize, or otherwise improve our services and communications for the benefit of Visitors and customers.
  • To identify and prevent fraud.
  • To enhance the security of our network and information systems.
  • To better understand how people interact with our websites.
  • To provide communications which we think will be of interest to you.
  • To determine the effectiveness of promotional campaigns and advertising.

Whenever we process data for these business purposes, we will ensure that we always keep your Personal Data rights in high regard and take account of these rights. If you object to this processing, please do not use our public websites.

2.2.2 Sharing Personal Data

BCWI may also share Personal Data with service vendors or contractors in order to provide a requested service or in order to analyze the Visitor behavior on its website. BCWI does not transfer your Personal Data to anyone other than to these limited third parties (vendors to BCWI) who are specifically using your Personal Data to help BCWI improve its website experiences or to use the data to inform and improve BCWI ’s marketing efforts.

BCWI will never sell your Personal Data to anyone. BCWI will never transfer your Personal Data to a third party who will use your Personal Data for any purpose other than to help BCWI with its marketing efforts.

2.2.3 Cookies

Cookies are small pieces of information sent by a website to a Visitor’s computer. Cookies cannot be used to run programs or deliver viruses to your computer. By continuing to visit our websites, you agree to the placement of cookies on your device. If you choose not to accept our cookies, we cannot guarantee that your experience will be as fulfilling as it would otherwise be. We may also place cookies from third parties for functional and marketing purposes. The use of cookies is widespread on the internet and benefits a Visitor.

Our Engagement Survey Site use cookies only to manage individual survey sessions. The cookies allow the site to accurately move survey-takers from page to page. Once finished, the cookie session is over and does not persist and does not store any personally identifiable information.

2.2.4 Links to other websites

Please be aware that while visiting our websites, Visitors can follow links to other websites that are beyond our sphere of influence. BCWI is not responsible for the content or privacy policy of these other websites.

2.2.5. Email Policies

We are committed to keeping your e-mail address confidential.  We do not sell, rent, or lease our subscription lists to third parties and will not disclose your email address to any third parties except as allowed in the section titled Disclosure.

We will maintain the information you send via e-mail in accordance with applicable federal law.

In compliance with the CAN-SPAM Act, all emails sent from our organization will clearly state who the e-mail is from and provide clear information on how to contact the sender.  Users who no longer wish to receive our newsletter or promotional materials may opt-out of receiving these communications by clicking on the unsubscribe link in the e-mail.

2.3 Respondents

If you are a Respondent, and not a Visitor, Employer, or User, then this Section 2.3 is relevant for you.

BCWI collects Personal Data from Respondents when they respond to a survey invitation or answer questions from BCWI. Before you respond to an online survey from BCWI, you will be given the opportunity to consent to the collection of your Personal Data.

We are U.S.-based, and all information submitted on this is site is voluntary and – for survey takers – anonymized. We do not request or store personally identifiable information except for the surveying Organization’s Contact and any information s/he has provided. No information is shared with any 3rd party whatsoever.  If you receive a paper survey from BCWI, your consent is given when you return the paper survey to us.

Respondents should be aware that in responding to surveys or survey invitations, they will be disclosing information that may make them personally identifiable to BCWI. In addition, Personal Data about the Respondent may be provided to BCWI by the Respondent’s Employer.

As a general matter, BCWI collects the following types of Personal Data from its Employers and associated Respondents:

  • Years of tenure
  • Age in years
  • Gender
  • Employee department
  • Ethnic origin
  • General job type level
  • Employee Contact Information for the Employer (not survey Respondents), such as work e-mail, work phone numbers, etc.

When an Employer, User, or a Respondent uses our services online, we may collect her/his IP address and browser type. We may associate IP address and browser type with a specific person. We also may collect Personal Data from persons who contact us through our websites to request additional information; in such a situation, we may collect contact information (as discussed above) and any other information that the person chooses to submit through our websites.

BCWI is a third-party service provider to an Employer. In our capacity as a service provider, we will receive, store, and/or process Personal Data that is owned and/or controlled by the Employer and the Respondents associated with the Employer, including information about the Employer’s employees, agents, contractors, or other individuals. In such cases, we will process the Personal Data on behalf of and under the direction of the Employer. The information we collect from the Employer and Respondents in this capacity is used for preparing reports, managing transactions, invoicing, renewals, and other operations related to providing our services to the Employer, and as otherwise requested by the Employer.

BCWI uses Personal Data that it collects from the Respondents and Employers in its role as a service provider for the following business purposes, without limitation: (1) to gather and process survey feedback from Respondents (including managing transactions, reporting, invoices, renewals, preparing certification certificates and other operations related to providing services to an Employer); (2) satisfying governmental reporting, tax, and other requirements (e.g., import/export); (3) storing and processing data, including Personal Data, in computer databases and servers located in the United States; (4) verifying identity (e.g., for online access to accounts); (5) as requested by the Employer or a Respondent; (6) for other business-related purposes permitted or required under applicable local law and regulation; and (7) as otherwise required by law.

All data collected online is done so through encrypted (SSL) channels.

2.3.1. Inquiries by Respondents

If you wish to inquire about your Personal Data that may have been collected by BCWI, we recommend that you contact your Employer, or you may contact us as explained in Section 6 below.

2.4 Users and Employers

2.4.1. General

If you are a User or Employer, and not a Visitor or Respondent, then this Section 2.4 is relevant for you. We will act on an Employer’s and User’s consent to process and collect Personal Data based on our written contract with the Employer.

An Employer interfaces with BCWI through its Users. In order to provide services and data reports to a User, BCWI collects certain types of data from the Users, such as passwords, logins, IP addresses, security tokens (for single-sign-on functionality, SSO), etc.

2.4.2 Collection of User data

During a User’s registration on our platforms, they provide information such as name, company name, email, address, telephone, and other relevant data. This information is used by BCWI to identify the User and provide the User with secure access to BCWI ’s platforms. BCWI Users can at any time access and edit, update or delete their contact details by contacting the BCWI representative that has been assigned to their account.

All data collected online is done so through encrypted (SSL) channels.

2.4.3 Collection of Respondent data as it relates to Users and Employers

The purpose of collecting Personal Data from Respondents as part of a survey will vary depending on the survey set up by BCWI. As BCWI provides surveys to a wide group of Respondents and Employers, the purposes may vary. For Respondents in the EEA, BCWI will be the Data controller, as defined in the EU Directive and the GDPR. All data collected online is done so through encrypted (SSL) channels.

2.4.4 Geographical locations for data storage and data transfers to the United States via the EU U.S. Privacy Shield Framework

BCWI’s Employee Engagement Survey data center provider, TierPoint, stores Personal Data in secure servers located in the United States. Personal Data is transferred to the United States via the transfer mechanism known as the EU – U.S. Privacy Shield Framework (“Privacy Shield”). TierPoint complies with Privacy Shield as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. TierPoint adheres to the Privacy Shield Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov.

No other person has access to your Personal Data while on these servers except for BCWI personnel, our Engagement Platform developer Coho Web, or EchoSpan personnel.  Third parties, except for EchoSpan & Coho Web, do not have any access to any data or Personal Data.

All data collected by BCWI that is not stored on TierPoint or EchoSpan’s platforms, will be stored on locked and secure servers in BCWI ’s headquarters or on secure hosting facilities provided by TierPoint.

With respect to Personal Data received or transferred pursuant to the Privacy Shield Framework, TierPoint is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.

2.4.5 Data Processor/Data Controller

BCWI processes Personal Data both as a Data Processor and as a Data Controller, as defined in the EU Directive and the GDPR. BCWI adheres to the EU Directive and the GDPR from May 25, 2018 onward.

  1. RETENTION AND DELETION OF PERSONAL DATA

3.1 Personal Data provided by Users, Employers, and Respondents

BCWI will not retain Personal Data from our employee engagement and 360 survey longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations. For Personal Data provided by Users, Employers, and Respondents, it will be stored with TierPoint or EchoSpan or BCWI for no more than 1 year (with deletion taking place near the end of each fiscal year).

The term “Research Data” means Personal Data that has been transformed into strictly anonymized data for research and trending purposes and which may be kept indefinitely. Research Data will not retain any characteristic whereby it could be reverse-engineered to make it personally identifiable. Anonymized data will have all identifiable information permanently deleted, and not merely rendered anonymous by having the data encrypted or hashed.

  1. ACCEPTANCE OF THIS POLICY

We assume that all Visitors to our websites, Respondents to surveys powered by BCWI, and Users and Employers have carefully read this Policy and agree to its contents. If someone does not agree with this Policy, they should refrain from using our websites and platforms. We reserve the right to change our Policy as necessity dictates. Continued use of BCWI’s websites and platforms after having been informed of any such changes to these conditions implies acceptance of the revised privacy policy. This Policy is an integral part of BCWI’s terms of use.

We may update this Policy to reflect changes to our information practices. If we make any material changes we will notify you by means of a notice on this website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

  1. DISCLOSURE

We may also disclose your Personal Data as required by law such as to comply with a subpoena or other legal process when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. If BCWI is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email or a prominent notice on our website of any change in ownership, changes to the use of your Personal Data, and choices you may have regarding your Personal Data.

We will reveal a user’s Personal Data without his/her prior permission only when we have reason to believe that the disclosure of this information is required to establish the identity of, to contact or to initiate legal proceedings against a person or persons who are suspected of infringing rights or property belonging to BCWI or to others who could be harmed by the user’s activities or of persons who could (deliberately or otherwise) transgress upon these rights and property. We are permitted to disclose Personal Data when we have good reason to believe that this is legally required.

  1. MISCELLANEOUS, DATA PROTECTION OFFICER; EU REPRESENTATIVE

BCWI has a “Data Protection Officer” who is responsible for matters relating to privacy and data protection. Our Data Protection Officer can be reached as follows:

Best Christian Workplaces Institute
Attn: Data Protection Officer
9311 SE 36th Street, Suite 202
Mercer Island, WA. 98040

+1-206-230-8111

privacy@bcwinstitute.org

We do not have offices in the EU, but we are in the process of retaining an EU representative pursuant to Article 27 of the GDPR.  We will soon provide the contact information for our EU representative.

EU Representative (GDPR Article 27)
(More information coming soon)

If you have any questions about how we use your personal data or about this Policy, you may send an email to privacy@bcwinstitute.org. If you would like to reach our Data Protection Officer (as defined under the GDPR) you can contact that person at privacy@bcwinstitute.org or at +1 206 230 8111

If you have an unresolved privacy or Personal Data use concern that we have not addressed satisfactorily, please contact us for a list of the EU data protection authorities (DPA) who you may contact for further, independent resolution.

Upon request, BCWI will provide you with information about whether we control any of your Personal Data on our own behalf. If you wish to obtain a copy of particular information that you provided to BCWI, if you become aware that the information is incorrect and you would like us to correct it, update it, or delete it, if you would like to exercise any of your legal rights such as those in relation to updating your preferences regarding how we use your personal data, or to withdraw consent, contact us at privacy@bcwinstitute.org. We will respond to your access request within a reasonable timeframe and within the timelines prescribed by applicable law.  Before BCWI is able to assist you, provide you with any information, or correct any inaccuracies, we may ask you to verify your identity and to provide other details to help us to respond to your request. We will endeavor to respond within an appropriate timeframe.

Should you want to report an incident relating to our security, confidentiality, or privacy, you are welcome to file a report by contacting us or emailing us at privacy@bcwinstitute.org.