Revised and posted April, 2016
Please note that Privacy and Cookie Notices advising Customers and Prospects as to the specific uses that are being made of their Personally Identifiable Information (“PII”) by specific businesses within the Company may also be modified from time to time to reflect changes in business practices. Those changes will appear in the relevant Privacy and Cookie Notice.
The Company also complies with applicable non-U.S. laws that impose additional responsibilities on the Company beyond those stated in this Policy, particularly in connection with the treatment of Personally Identifiable Information about its Customers and Prospects.
The Company is committed to using all reasonable efforts to abide by the following Policy statement:
- Collection. Personally Identifiable Information will only be collected to the extent that the Company deems reasonably necessary to serve a legitimate business purpose. Please be aware that if you disclose Personally Identifiable Information on website message boards or chat areas, that information may be collected and used by third parties without our knowledge and may result in unsolicited communications from third parties. Such activities are beyond the control of the Company.
- Notification. Customers and Prospects will be notified (usually at the point where Personally Identifiable Information is collected) as to the uses the business may make of the Personally Identifiable Information collected from them.
- Choice: Opt-Out for External Distribution of Personally Identifiable Information. Customers and Prospects will be given the opportunity to refuse permission for External Distribution of their name, address or other Personally Identifiable Information through an Opt-Out mechanism. External Distribution does not include certain limited distributions such as sharing Personally Identifiable Information with an entity working on behalf of the Company to serve our customers; transfer of Personally Identifiable Information in conjunction with the sale or similar transfer of a business; or the disclosure of Personally Identifiable Information in connection with legal proceedings, investigations of crimes or other wrongdoing. However, sharing Personally Identifiable Information with an entity working on behalf of the Company or transferring Personally Identifiable Information in conjunction with the sale or similar transfer of a business is considered an Onward Transfer and will be handled as described below.
- Security. Appropriate safeguards will be implemented in an effort to ensure the security, integrity and privacy of Personally Identifiable Information about our Customers and Prospects.
- Access: Review and Correction. Procedures have been developed through which Customers and Prospects can, upon request, review and correct the Personally Identifiable Information that has been collected from them by the Company. These procedures may not, however, compromise the security, integrity and privacy of either the Company’s own proprietary databases or databases licensed from third-party companies.
- Sensitive Data. The collection and use of Sensitive Data carries with it special obligations and responsibilities in order to maintain the data's security, integrity and privacy. Sensitive Data will not be rented or otherwise made available for External Distribution outside the Company (although it may be made available through Onward Transfer as described below). Customers and Prospects will be given the opportunity to refuse permission for their Sensitive Data to be distributed outside of the business that collected the Sensitive Data through use of an Opt-Out mechanism for Internal Distribution within the Company.
- Onward Transfer. Whenever the Company permits a third party outside of the Company to access Personally Identifiable Information through either External Distribution or Onward Transfer, commercially appropriate procedures will be followed to help ensure that the Information is used only for authorized purposes and by authorized persons in a manner consistent with the choices Customers and Prospects have made under this Policy, and that the security, integrity and privacy of the information is maintained. Please note that our websites may contain links to other websites that have their own privacy policies and practices. While the Company will employ commercially appropriate procedures to help ensure that your information is only used for authorized purposes as described above, the Company cannot make any guarantees with respect to the actions or policies of such third parties.
The Company has a standing Privacy & Information Security Committee (the “Committee”), which oversees implementation of and compliance with our Policy and will adapt the Policy to reflect changes in technology and Customer expectations.
The Co-Chairs of the Committee are also charged with handling unresolved Customer concerns. You can reach the Co-Chairs by writing to the Company’s Global Head of Privacy at email@example.com or Privacy, S&P Global Inc., 55 Water Street, New York, NY 10041. The Company conducts periodic reviews of our divisions’ compliance with the Policy. Please read our Corporate Privacy and Cookie Notice, which applies specifically to any PII that may be collected through our Corporate website, among other areas.