ECI Privacy Notice

Effective Date: May 10, 2021

The Ethics & Compliance Initiative (“ECI”) is committed to protecting your privacy and protecting information that may identify you (“Personal Information”) as described below. This Privacy Notice describes ECI’s privacy practices regarding our processing of information we collect online through the ECI Website and/or other activities through which you may engage with ECI such as joining or renewing membership, registering for a service or event, buying a product, or taking a survey.

Information Collection

ECI may collect the following information when you:

  1. Visit the ECI Website. If you visit the ECI Website, we may collect certain technical information, such as IP address, browser type, operating system, date and time of access, and usage details, such as pages visited.
  2. Join or Renew Membership. If you register to become an ECI member, we may collect your name, email address, payment/billing information, and demographic information, such as:
    • First Name
    • Last Name
    • Email Address
    • IP Address
    • Age
    • Gender
    • Tenure
    • Language
    • Employee ID
    • Job Title
    • Department/Function
    • Salary
    • Veteran Status
    • Location
    • Country
    • State
    • Zip Code
    • Office Address
    • Race/Ethnicity
    • Union Membership
  3. Register for Working Groups. If you register to join a working group, we may collect your name, email address, company, ECI membership status/non status, and working groups of interest.
  4. Donate to ECI. If you donate to ECI, we may collect your name, email address, home address, employer, occupation, contribution amount, and payment/billing information.
  5. Register for Events. If you register for an event, we may collect your username, password, name, email address, and payment/billing information.
    • Event Participation. If you attend an event, ECI may collect visual and audio information that includes you if the event is photographed or recorded. Where practically possible, we will seek your consent to be photographed or recorded in advance of an event. If you wish to withdraw opt-out or request that ECI stop using visual or audio information about you, please contact us at ethics@ethics.org.
  6. Take a Survey Distributed by ECI. If you visit a Survey Website provided by ECI, we may collect certain technical information, such as IP address, browser type, operating system, date and time of access, and usage details, such as pages visited.
    • Survey Participation. If you participate in a survey, we may collect name, email address, and demographic information, such as:
      • First Name
      • Last Name
      • Email Address
      • IP Address
      • Age
      • Gender
      • Tenure
      • Language
      • Employee ID
      • Job Title
      • Department/Function
      • Salary
      • Veteran Status
      • Location
      • Country
      • State
      • Zip Code
      • Office Address
      • Race/Ethnicity
      • Union Membership
    • Contact Us Regarding a Survey. If you contact the survey help desk, for example, by calling ECI or sending a message to an ECI email address, we may collect your name, last name, company, title, email address, phone number, message details, and any information you may submit when sending us an inquiry.

ECI may collect any and all of this information:

  • Directly from you when you provide it to us;
  • Automatically through cookies, web beacons, and other tracking technologies when you visit the ECI Website; and,
  • From third parties, such as customer organizations that ECI may engage with through its Services.

Cookies:

Like many online services, we use “cookies” to collect technical information. Cookies are small pieces of information that a website sends to your computer’s hard drive while you are viewing a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on the Site. We may use cookies to collect information about your IP address, browser type, operating system, device type and identifiers, platform type, as well as your usage of and activity on the Site. These types of information are collected to make the Site more useful to you and to tailor your online experience to meet your interests and expectations. You can use the options in your web browser to notify you when you receive a cookie or you may change your cookie preferences in your internet browser or with third parties. You can control and/or delete cookies we use. For instructions on how to delete cookies using your particular internet browser, visit https://www.aboutcookies.org/. You can delete all existing cookies on your computer and adjust settings for most browsers to prevent cookies from being received.

Information Use

ECI may use your information, including Personal Information, for the following purposes:

  • To provide, develop, and improve its Services, including surveys;
  • To communicate with you and fulfill your requests;
  • To administer, secure, and analyze usage of the ECI Website;
  • To promote ECI membership;
  • To send promotional emails about its Services and those of our partner organizations;
  • To carry out our obligations and enforce our rights arising from any contracts;
  • In any other way we may describe when you provide the information; and,
  • For any other purpose with your consent.

We may use aggregated information and de-identified information without restriction.

Surveys and Research

ECI is engaged by its customers to provide certain services, including survey development, delivery and reporting, interviews and focus groups. These customer organizations may share information with ECI to provide services with individuals selected by the customer organization. If ECI uses Personal Information to administer a survey or other services, we do so on behalf of the customer organization and will only use the information for that purpose, in accordance with our agreement with the customer and applicable law. Please bear in mind that those customer organizations manage Personal Information in accordance with their own policies and procedures. Any questions related to how that customer organization may process your information should be submitted to the customer organization directly.

ECI uses the third-party platforms to administer employee surveys. While ECI uses third-party platforms to collect the data, ECI owns all data collected through the survey and controls all access to the survey data. Further, ECI ensures that its third-party contractors implement and maintain appropriate security controls to safeguard Personal Information collected and processed on behalf of ECI.

Lawful Bases for Processing

We rely on the following lawful bases to process your Personal Information for these non-exhaustive purposes:

Consent

We may obtain your consent to process your Personal Information in certain circumstances, which may include when you elect to receive information from us. We may also rely upon our legitimate interest in developing our business as a basis for sending you marketing information and information about our Services (see below).

Performance of a Contract

We rely on this lawful processing ground when we process your Personal Information to perform a contract which we have with you, or when we take steps in anticipation of entering into a contract with you, for example in connection with the provision of our Services to you and the management of our relationships with third parties.

Compliance with a Legal Obligation

We rely on this lawful processing ground when we process your Personal Information to meet legal and regulatory obligations which apply to us.

Legitimate Interests

We rely on this lawful processing ground when we process your Personal Information to provide our Services, to respond to specific requests, to manage our business operations, and to manage our relationships with you and with third parties in connection with our business

If you wish to have more information regarding the legitimate interests we rely on, please contact us at ethics@ethics.org.

Information Disclosure

We may disclose information, including Personal Information:

  1. To our partner organizations and sponsors.
  2. To customer organizations in aggregated form when they conduct a survey or assessment.
    • In the case of surveys or assessments, individual Personal Information is never provided.
  3. To contractors, service providers, and other third parties we use to support our organization, such as Qualtrics and Google Analytics (see Google Analytics privacy practices).
  4. To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  5. If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of ECI, our customers, or others.
  6. For any other purpose disclosed by us when you provide the information.
  7. With your consent.

We may disclose aggregated information and de-identified information without restriction.

Information Transfers

Our servers are either located in the United States or, if located in other countries, may be accessed from the United States. Please note that in countries outside your own country, and in particular outside the European Union (EU) and European Economic Area (EEA), a different standard on data protection might apply than you are used to in your own country.

By sending Personal Information to us, you acknowledge and consent that your information will be transferred across national borders, including to countries outside the EU/EEA.

If you live in the EEA, we may transfer Personal Information to countries for which adequacy decisions have been issued, use contractual protections for the transfer of Personal Information to third parties, such as an intra-company agreement which complies with the European Commission’s Standard Contractual Clauses or their equivalent under applicable law.

You may contact us at ethics@ethics.org to obtain a copy of the safeguards we use to transfer Personal Information outside of the EEA.

Information Security

We have implemented measures designed to secure your Personal Information from unauthorized access, use, alteration, and disclosure. Information collected through the ECI Website or Survey Website is encrypted, and access is governed by the End-User License Agreement and/or such other agreement which is in place to govern the provision of services.

Information Retention

When determining the appropriate retention period for Personal Information, we take into account various criteria, such as the amount, nature and sensitivity of the Personal Information, potential risk of harm from unauthorized use or disclosure, purposes for which we process your Personal Information, whether we can achieve those purposes through other means, and our business operations and legal requirements.

European Economic Area Privacy Rights

If you live in the EEA, you may have the right to (1) request access to, rectification, or erasure of your Personal Information or restrict the processing of your Personal Information; (2) object to processing; (3) data portability (receive and transfer your Personal Information); (4) lodge a complaint with a supervisory authority; and, (5) where processing of your Personal Information is based on consent, withdraw your consent at any time without affecting the lawfulness of the processing of Personal Information that occurred before you withdraw consent. To make such a request, please email us at ethics@ethics.org.

California Privacy Rights

California residents may have the right to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please email us at ethics@ethics.org.

Contact Us

Please submit questions, concerns, or requests to exercise your applicable rights to ECI by email to ethics@ethics.org.

If you live in the EEA, The Ethics & Compliance Initiative is the entity responsible for the processing of your Personal Information. Please submit questions, concerns, or requests to exercise your applicable rights by email to ethics@ethics.org or write to:

Ethics & Compliance Initiative
2650 Park Tower Drive, Suite 802
22180 Vienna, Virginia
United States

Ethics & Compliance Initiative
Bethmannstaße 8 / Berliner Straße 51
Innenstadt I
Frankfurt, Germany
60311

You may also make a complaint to your local data protection authority.