Effective: January 2021
Updated: January 2021
- Introduction
- Who does this Notice apply to?
- Who controls your personal information?
- Why do we collect your personal information?
- When do we collect your personal information?
- What personal information do we collect and process?
- Who do we share your personal information with?
- Where do we process and store your personal information?
- How long do we keep your personal information?
- What rights do you have over your personal information?
- How do we protect your personal information?
- Will this Notice change?
- Any questions?
Introduction
Around the globe, consumers trust Bright Horizons to provide high-quality education and care, operate with integrity, and empower them to thrive. Respecting the privacy rights of our consumers is an integral part of building and maintaining that trust. This Notice explains how Bright Horizons collects and uses its consumers' personal information.
Who does this Notice apply to?
This Notice applies to any prospective, current or former consumers of Bright Horizons' services, websites, apps and social media (Consumers). Bright Horizons' services include child and adult care (e.g., in-home care, center care, information and resources), parental leave toolkit, coaching, consulting, educational advising and tuition assistance (Services).
This Notice covers our Services globally. Consumers can click on the links below for additional terms that apply to Consumers residing in certain regions or receiving Services in those regions. The region-specific terms only apply to the Services that operate in those geographic locations or as applicable law requires.
A separate Global Staff and Supplier Privacy Notice applies to prospective, current and former staff and suppliers (including employees, apprentices, agency workers and contractors).
For simplicity throughout this Notice, 'we', 'us' and 'our' means Bright Horizons and 'you' or 'your' means Consumer.
Who controls your personal information?
Bright Horizons is made up of a number of companies. This section gives you the legal name of the Bright Horizons' company responsible for processing your personal information.
Bright Horizons has a Global Privacy Officer (who also acts as its Data Protection Officer for the UK and the Netherlands) and can be contacted at dataprivacy@brighthorizons.com.
Why do we collect your personal information?
We limit the collection of your personal information to what is necessary. We do not sell your personal information to any third parties. Below we have highlighted the main reasons for collection:
- Fulfill or meet the reason you provided the personal information to us.
- Respond adequately to your requests for Services or information.
- Provide Services to you and/or your dependents.
- Personalise your website experience and/or the Services.
- Create, maintain, customise, and secure your account with us.
- Facilitate and process purchases, financial transactions and payments.
- Provide information regarding our Services and areas of interest to you.
- Research and analyse existing Services for training and quality purposes and develop new Services.
- If you receive our Services as an employee benefit, to aid your employer in the administration of the employee benefit.
- Comply with laws, regulations and sector standards.
- Fulfil tax, reporting, and other financial requirements and obligations.
- Prevent or detect unlawful acts.
- As described to you when collecting your personal information.
- Evaluate or conduct a merger, divestiture, restructuring, reorganisation, dissolution, or other sale or transfer of some or all assets of Bright Horizons, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.
Consumers receiving Services in the United Kingdom, Ireland, the Netherlands and any other country in the European Economic Area: read additional information that applies to you.
When do we collect your personal information?
There are a variety of contexts under which we will collect your personal information.
When you visit our websites or use our applications (apps) or social media, we collect your personal information from:
- Monitoring your electronic visit and engagement with us.
- The information you provide to us (for instance, by completing one of our webforms).
Our website is not intended for use by children under 16 years of age nor do we knowingly collect personal information from children under 16 through our website. If you are under 16, please do not use or provide any information on our website.
When you call our Contact Centers, we will collect your personal information from:
- The information you provide to us.
- Recording the calls, including the number you call from, for training and quality assurance purposes.
When you receive Services from us, we will collect your personal information from:
- The information you provide to us.
- Providing the Services to you such as completing forms, assessments and other documentation as part of the provision of Services.
- Recorded images at locations with CCTV cameras.
- If you receive Services as part of an employee benefit, we may receive your personal information from your employer on your eligibility to use the Services and other reporting identifiers.
- If you receive government funding, we may receive personal information from the government on your eligibility for the funding and other reporting identifiers.
- Government agencies may provide us with personal information to support their regulatory obligations or investigations.
- Third party marketing companies who provide us with contact details for individuals who have consented to receive marketing materials. You have the right to opt-out of these communications at any time.
What personal information do we collect and process?
If you are a prospective consumer, we will process:
- The personal information you provide to us. This personal information may include health related information relevant to determine the suitability of Services.
- Details of your visits to our websites, apps, and social media, as well as information we gather from the use of cookies. Learn more about how we use cookies and similar technologies.
- For locations with CCTV cameras, we may capture images.
- Your contact details as provided to us by third party marketing companies (for individuals who have consented to receive marketing materials). You have the right to withdraw your consent at any time.
If you are a current or former consumer, we will process:
- All personal information you provide to us. This personal information may include health related information relevant to the provision of Services.
- Personalised registration username and passwords, and swipe card/key fob access records for Bright Horizons premises.
- Details of your visits to our websites, apps, and social media, as well as information we gather from the use of cookies in your web browser. Learn more about how we use cookies and similar technologies.
- For locations with CCTV cameras, we may capture images.
- Care and service records that may include for example: notes from meetings/calls; observations and assessments of you or your dependent's activities while we provide services to them (e.g., illnesses, sleep, diaper changes, meals, medication, learning, interactions with others, and accidents); review and feedback on your or your dependent's education/school applications; photographs to share with you for communication purposes, learning records or identification purposes; and utilisation reports (including dates of service, user of service and reasons for service).
- If you receive our service as part of an employee benefit, we may receive personal information from your employer on your eligibility to use the Services and other reporting identifiers.
- If you receive government funding, we receive personal information from the government on your eligibility for the funding and other reporting identifiers.
- Government agencies may provide us with personal information to support their regulatory obligations or investigations.
- Other personal information provided to us by third parties in order to meet our legal obligations.
- Personal information about you and/or your dependent as necessary to respond to and defend legal claims or to pursue legal claims.
Residents of California: read additional information that applies to you.
Consumers receiving Services in the United Kingdom, Ireland, the Netherlands and any other country in the European Economic Area: read additional information that applies to you.
Who do we share your personal information with?
We consider your personal information confidential and do not share it with anyone else except as described in this Notice. There are limited circumstances that require us to disclose your personal information to others in order to deliver Services and meet our contractual/legal obligations or legitimate business interests. Examples include:
Where do we process and store your personal information?
Electronic Information | Some personal information may remain on electronic storage data systems in the country where we provide the service. However, our primary electronic storage facilities and contact centers are in the United States. Please note that we (or our Affiliates, service providers or agents) may process personal information in other countries, where your personal information may be subject to the laws of that jurisdiction, including laws regarding the disclosure of personal information to government authorities. We ensure appropriate safeguards are in place before we transfer personal information to any other country. Consumers receiving Services in the United Kingdom, Ireland, the Netherlands and other country in the European Economic Area: learn more about how we safeguard your information and comply with privacy laws. | |
Hardcopy Information | The hardcopy of personal information we collect remains in the country where you receive the services or provide the information. |
How long do we keep your personal information?
Whenever we collect or process your personal information, we'll only keep it for as long as is necessary for the purpose for which it was collected and as required under law. At the end of that retention period, your information will either be deleted completely or anonymised, for example by aggregation with other information so that it can be used in a non-identifiable way for research, statistical analysis and business planning.
What rights do you have over your personal information?
To ask for your information to be amended, please follow one of the steps below as applicable to the Services you receive:
- If you have an online account, update the information directly online.
- Call our contact center team to request the amendments.
- Contact the location providing the Service to request the amendments.
To ask for direct marketing communications to stop, please follow the steps below:
- Click the 'unsubscribe' link in any email communication that we send you. We will then stop any further emails from that particular mailing list.
- If you have an account, log in to your account and change your preferences.
- In our apps, you can manage your preferences and opt out from one or all of the different notifications by selecting or deselecting the relevant options in the 'Settings' section.
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.
If you have any questions about your privacy rights, you can contact our Global Privacy Officer at dataprivacy@brighthorizons.com.
Residents of California: read additional information that applies to you.
Consumers receiving Services in the United Kingdom, Ireland, the Netherlands and any other country in the European Economic Area: read additional information that applies to you.
How do we protect your personal information?
We utilise appropriate technical, organisational, and physical safeguards to protect your personal information we process in both physical and electronic formats. We provide data protection, privacy and security training and conduct internal periodic quality assurance audits to ensure we maintain these standards.
However, please note that no computer system or information can ever be fully resilient against every possible hazard or risk. We do maintain appropriate levels of security in accordance with data protection, privacy and security laws and regulations in the territories we operate and keep these under review.
You also play a valuable part in protecting the security of your personal information. You should never share with anyone your password to access any accounts that you created or which we created for you. When using a browser to access your account, after you have finished you should log out and exit your browser to prevent unauthorised users from returning to your account.
If you believe that someone has improperly used your account or provided information about you that you didn't authorise, please contact us immediately at dataprivacy@brighthorizons.com.
Will this Notice change?
This Notice is subject to change in order to remain compliant with data protection and privacy laws in the territories in which we operate. Please check back periodically, especially before you provide any personal information.
This Notice was last updated in November 2020.
Any Questions?
We hope this Notice has been helpful in setting out the way we process your personal information and how we do this in a transparent and accountable manner.
If you have any questions that haven't been covered by this Notice, please contact our Global Privacy Officer at dataprivacy@brighthorizons.com.
Cookie Notice
Effective: December 2019
Updated: November 2020
- Introduction
- Terms used in this Cookie Notice
- What's a Cookie?
- Is a Cookie part of my personal data/personal information?
- Cookies Used on our Website
- Strictly Necessary Cookies
- Performance Cookies
- Functional Cookies
- Targeting Cookies
- Social Media Cookies
- How do I Disable/Enable Cookies?
- Cookies that have been set in the Past
- Further Information
Introduction
This Bright Horizons website uses cookies to distinguish you from other users of this website. This helps us to provide you with an optimised experience when you browse our website and allows us to make continual improvements to this website. A cookie is a small file of letters and numbers that we store on your browser or hard drive of your device used to visit this website. This Global Cookie Notice provides you with information about cookies we use and how to control them for this website.
Terms used in this Cookie Notice
"Affiliate" - an affiliate is a website operator who can send traffic to our website using links from another website. The affiliate is paid an agreed commission from the referral by Bright Horizons.
"First-Party and Third-Party Cookies" - whether a cookie is 'first' or 'third' party refers to the domain placing the cookie. First-Party cookies are those set by us when visited by the user at the time - the website displayed in the URL window. Third-Party cookies are cookies that are set by a domain other than us. If a user visits our website and another entity sets a cookie through our website, then this would be a Third-Party cookie.
"Persistent Cookies" - these cookies remain on a user's device for the period of time specified in the cookie.
"Session Cookies" - these cookies allow us to link the actions of a user during a browser session. A browser session starts when a user opens the browser window and finishes when they close the browser. Session cookies are created temporarily and once you close the browser, all session cookies are deleted.
"Social Media Cookies" - these cookies are also known as "analytics cookies" and collect information about how visitors use our website. This information is aggregated to provide us insights in how the website is being used.
What's a Cookie?
A cookie is a small text file that a website saves on your computer or mobile device when you visit the website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie, to develop a record of the user's online activity. Cookies on this website may be delivered in a first-party (set by the Bright Horizons website) or third-party (set by another website) context and may also be set in association with emails you receive from us.
Cookies help us enhance your experience when using the website. They also help us understand how people use our website, such as which pages are most popular, so that we can make continuous improvements for delivering an optimum experience.
Is a Cookie part of my personal data/information?
"Personal data," "personal information" and "personally identifiable information" have become common terms used across jurisdictions around world and are used in various statutes and regulations in different contexts and are assigned different meanings. For example, under the California Consumer Privacy Act 2018 (CCPA), the term "personal information" refers to any information that "identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household." The CCPA includes a non-exhaustive list of data types that fall within that definition. That list includes "unique personal identifiers," a term which itself is defined as including "cookies" that are used to "recognise a . . . device that is linked to a consumer or family, over time and across different services." In this context, certain cookies will be considered "personal information" for the purposes of the CCPA.
Similarly, the General Data Protection Regulation (GDPR) defines personal data as "any information relating to an identified or identifiable natural person." Where such link exists, then such a cookie becomes part of the set of "personal data."
Cookies Used on our Website
Not all cookies are the same or have the same purpose. We use the following five types of cookies on our website:
- Strictly Necessary Cookies
- Performance Cookies
- Functional Cookies
- Social Media Cookies
- Targeting Cookies
See also How do I Disable/Enable Cookies?
Strictly Necessary Cookies
These cookies are also referred to as "first-party essential cookies" and "session cookies". These session cookies are essential to enable you to navigate the website and use its features, such as accessing secure areas of the website. These cookies are strictly necessary for the website to function and can't be switched off in our systems. They're usually only set in response to actions made by you that amount to a request for services, such as booking a tour of a nursery or center; setting your privacy preferences; logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the website won't work as a result. These cookies don't store any personal data/information or personally identifiable information (PII).
Examples include:
- Remembering the settings you've applied to our website such as layout, font size, preferences, colours etc.
- Remembering a choice such as not to be asked again to fill in a questionnaire.
- Detecting if a service has already been offered, such as offering a tutorial on future visits to the website.
- Providing information to allow an optional service to function such as offering a live chat session.
- Fulfilling a request by you, such as submitting a comment.
Performance Cookies
These cookies are also referred to as "first-party cookies", "third-party cookies" or "performance cookies". These cookies allow us or third-parties to count visits, traffic sources and collect information about how visitors use our website. We do this so we can measure and optimise the user experience. For example, we can learn which pages visitors go to most often and if they get error messages from webpages. All information these cookies collect is aggregated and therefore anonymous, so won't identify you personally. If you don't allow these cookies on the device you use to visit the website, we'll not know when you've visited our website and won't be to monitor its performance.
Examples include:
- Web analytics - where the data collected is used in managing the performance and design of the website. These cookies can be third-party cookies, but the information is for our exclusive use only of the publisher of the website visited.
- Advertising response rates - where the data is used exclusively for calculating response rates (click-through rates) to improve the effectiveness of advertising purchased on a site external to the destination website. This data can't be used to re-target adverts on a third-party site.
- Affiliate tracking - where the cookie allows the affiliate of Bright Horizons to improve the effectiveness of their website. This data can't be used to re-target adverts on a third-party site.
- Error management - this cookie measures errors presented on our website, typically this will be to support service improvement or complaint management and will generally be closely linked with web analytics.
- Testing designs - cookies allow us to test variations of website design, typically using A/B or multivariate testing, to ensure a consistent look and feel is maintained for the user of the website in the current and subsequent sessions.
Functional Cookies
These cookies enable the website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.
Examples include:
- Cookies which record your preferred settings to enable localisation functionality such as language.
- Cookies which ensure consistency in the information displayed to you (for instance, ensuring a consistent contact number for us is provided to you).
Targeting Cookies
These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They don't store directly personal information, but are based on uniquely identifying your browser and internet device. If you don't allow these cookies, you'll experience less targeted advertising.
Examples include:
- Cookies may be used to limit the number times a user sees a particular ad on our website and to measure the effectiveness of a particular campaign.
- Cookies placed by advertising networks to collect browsing habits in order to target relevant adverts to the user. The website the user is visiting need not actually be serving adverts, but often this will also be the case.
- Cookies placed by advertising networks in conjunction with a service implemented by the website to increase functionality, such as commenting on a blog, adding a website to the user's social network, providing maps or counters of visitors to a website.
Social Media Cookies
These cookies are also referred to as "analytics cookies" and are always "third-party cookies". These cookies may be set through our website by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other websites. They don't store personal data/information directly but are based on uniquely identifying your browser and internet device. If you don't allow these cookies, you will experience less targeted advertising.
These cookies are set by a range of social media services, such as Facebook that we've added to the website to enable you to share our content with your friends and networks. These cookies can track your browser across other websites and building up a profile of your interests and can impact the content and messages you see on other websites you visit. If you don't allow these cookies you may not be able to use or see these social media sharing tools.
Examples include:
- Google Analytics cookies are used to collect information about how visitors use our website. These cookies collect information in the aggregate to give us insight into how our website is being used. We anonymise IP addresses in Google Analytics, and the anonymised data is transmitted to and stored by Google on servers in the US.
- Cookies may be used to collect personal information (such as name, pages visited, and purchase history) to link a visitor to the recipient of an email marketing campaign. This marketing cookie only stores your unique identifying browser and device information.
How do I Disable/Enable Cookies?
To manage cookies in a web browser, you should go to Tools/Internet options/Security and Privacy Tabs to adapt the browser to your preferences. If you use different devices in different locations, you'll need to ensure that each browser is adjusted to suit your cookie preferences.
Some modern browsers have a feature that will analyse website privacy policies and allow a user to control their privacy preferences. These are known as 'P3P' features (Privacy Preferences Platform).
You can easily delete any cookies that have been installed in the cookie folder of your browser. For example, if you're using Microsoft Windows Explorer:
- Open 'Windows Explorer'
- Click on the 'Search' button on the tool bar
- Type "cookie" into the search box for 'Folders and Files'
- Select 'My Computer' in the 'Look In' box
- Click 'Search Now' Double click on the folders that are found
- 'Select' any cookie file
- Hit the 'Delete' button on your keyboard
If you're not using Microsoft Windows Explorer, then you should select 'cookies' in the 'Help' function for information on where to find your cookie folder.
Cookies that have been set in the Past
Collection of your personal data/information from our analytics cookies can be deleted. If cookies are deleted, the information collected prior to the preference change may still be used, however, we'll stop using the disabled cookie to collect any further information from your user experience. When a user opts out of being tracked for marketing purposes, a new cookie is placed to prevent user data from being tracked. Users who have opted out may still see these cookies in a web browser, but data will not be collected.
Further Information
For further information, contact the Global Privacy Officer at dataprivacy@brighthorizons.com.
Data Protection Act and General Data Protection Regulation (DPA/GDPR) Addendum to the Global Consumer Privacy Notice
Effective: November 2020
Updated: November 2020
- Introduction
- What legal basis do we rely on to process your personal information?
- International Transfers
- Adherence to the EU-US Privacy Shield Framework
- What rights do you have over your personal information?
Introduction
We are disclosing information about our data processing practices as required by the United Kingdom's Data Protection Act 2018 (DPA) and the General Data Protection Regulation (GDPR). This DPA/GDPR Addendum supplements the information contained in the Bright Horizons Global Privacy Consumer Notice and applies exclusively to Consumers using Services in the United Kingdom, Ireland, the Netherlands and any other country within the European Economic Area.
What legal basis do we rely on to process your personal information?
Bright Horizons relies on the following legal basis for processing your personal information.
- Performance under a Contract: For Consumers, most of the personal information we process is necessary for us to perform our obligations under a contract we have with you, and, if applicable, your employer when you receive the Service as an employee benefit.
- Legal Obligations: For Consumers, there are many laws that require us to process your personal information. Examples include law and regulations for child/adult care, safeguarding, health and safety, tax and government funding.
- Legitimate Interest: For Consumers, we have a legitimate interest in processing some of your personal information in some circumstances. We will only process your personal information if our legitimate interests do not override your fundamental rights, freedoms and interests. For any questions regarding this legal basis, please contact our Global Privacy Officer at dataprivacy@brighthorizons.com.
Some examples of our legitimate interests include:
- Use of your email address to send you newsletters, invitations to webinars, or information about your services or new/enhanced Service updates.
- Analysing your IP and browser information to improve the website experience for you. 'Session' cookies help you navigate through BH websites efficiently and are temporary and 'persistent' cookies are small files left on your device that store your user preferences for current and successive visits to Bright Horizons websites. Learn more about how we use cookies and similar technologies.
- In some locations, we use Closed Circuit (CCTV) for security/safety of our consumers, staff and premises; to help prevent and detect crime; to support learning and training; and/or to defend legal claims.
- Recording your contact center calls to assist us with monitoring our policies and procedures; identifying opportunities for training and development; and improving Services to you.
- Special Categories of Personal Information: Depending upon the Services you receive, we may need to process special categories of personal information in order to evaluate whether Services are suitable for the care requested and/or to provide the Services safely and/or effectively. In some locations, government regulations/laws require us to process special categories of personal information and in some circumstances, you provide us your consent. Special categories of personal information that we may process include information relating to:
- Health data:
- when receiving adult/child care services, in order for us to provide the Services safely and/or in compliance with applicable law, you may need to provide us with health data of the dependent we care for (for example to inform us of allergies, medicines, special physical or educational requirements, health conditions). In addition, this type of information may be provided to us by a government body;
- when receiving personal or family coaching or special educational needs services, you may voluntarily provide us with health data about you / your dependents to enable us to provide the advice services.
- Religious beliefs: you may provide this information to us voluntarily when receiving child/adult care services (for example to inform us about dietary requirements or family celebrations, etc.);
- Race/ethnic origin: you may provide this information to us voluntarily when receiving College Coach services (for example to assist with identifying schools, scholarships, etc.);
- Trade union membership: your employer may provide this information to us to assist with determining levels of employee's eligibility for our EdAssist services;
- Sexual orientation: you may provide this information to us voluntarily when receiving Services (for example when completing spouse/partner information on childcare registration forms, to assist with identifying schools, to inform us of family celebrations and relationships, etc.)
- Health data:
International Transfers
We may process some of your personal information outside the European Economic Area (EEA). Whenever we transfer personal information out of the EEA, we ensure a similar degree of protection is afforded to it by putting in place appropriate safeguards and protections.
For transfers to the United States, we rely on the Standard Contractual Clauses approved by the European Commission that afford personal information the same protections it has in Europe and have completed appropriate risk assessments as required under the European Court of Justice ruling for Case C-311/18 Data Protection Commissioner v Facebook Ireland Ltd and Maximilian Schrems ("Schrems II").
Please contact the Global Privacy Officer at dataprivacy@brighthorizons.com if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA.
Adherence to the EU-US Privacy Shield Framework
Bright Horizons Family Solutions LLC does not rely on the EU-US Privacy Shield Framework to transfer your personal information out of the European Economic Area. However, Bright Horizons Family Solutions LLC remains certified under the EU-US Privacy Shield Framework and does comply with its requirements as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information we transfer from the United Kingdom and European Union to the United States. Bright Horizons Family Solutions LLC certified to the Department of Commerce that it adheres to the Privacy Shield Principles. The Federal Trade Commission has jurisdiction over our compliance with the Privacy Shield.
If there is any conflict between the terms in our Global Privacy Notice, DPA/GDPR Notice and the Privacy Shield Principles, the Privacy Shield Principles shall apply. Learn more about the Privacy Shield program and view our certification.
Under certain circumstances, you have the right to invoke binding arbitration for complaints regarding our Privacy Shield compliance that you have been unable to resolve through any of the other Privacy Shield mechanisms. Learn more about the binding arbitration mechanism.
In compliance with the Privacy Shield Principles, Bright Horizons Family Solutions LLC commits to the following:
- Resolve complaints about our collection or use of your personal information. If you have questions or complaints regarding our adherence to the EU-US Privacy Shield Framework, please contact our Global Privacy Officer at dataprivacy@brighthorizons.com or Pioneer House, 7 Rushmills, Northampton, NN4 7YB, United Kingdom.
- Cooperate with the panel established by the EU data protection authorities (DPAs) and comply with the advice given by the panel with regard to personal information transferred from the European Union.
- Remain responsible and liable for the processing of personal information we receive under the Privacy Shield and subsequently transfer to a third party acting as an agent on our behalf.
What rights do you have over your personal information?
You have the right to request:
- Access to the personal information we hold about you, free of charge in most cases.
- The rectification of your personal information to ensure that it's up-to-date, accurate and complete.
- The erasure of your personal information (subject to certain exemptions).
- We stop processing your personal information for direct marketing purposes (either through specific channels or all channels).
- We and other third parties cease processing your personal information when this was previously undertaken based on your consent and you've now withdrawn that consent.
Please contact the Global Privacy Officer at dataprivacy@brighthorizons.com if you would like to:
- access your personal information that is not available to you directly;
- request we erase your personal information; or
- exercise any of your other rights.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
In circumstances where we are processing your personal information based on our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal information that doesn't infringe your rights and freedoms. You have the right to challenge our decision to the Supervisory Authority or seek legal redress through the courts.
If you feel that your personal information hasn't been handled correctly, or you are unhappy with our response to any requests you have made regarding the use of your personal information, you have the right to lodge a complaint with the relevant Supervisory Authority.
- UK Supervisory Authority: Information Commissioner's Office (opens in a new window; please note we can't be responsible for the content of external websites.)
- Ireland Supervisory Authority: Data Protection Commissioner/An Coimisinéir Cosanta Sonraí (opens in a new window; please note we can't be responsible for the content of external websites.)
- The Netherlands Supervisory Authority: Autoriteit Persoonsgegevens (Dutch Data Protection Authority - Dutch DPA) (opens in a new window; please note we can't be responsible for the content of external websites.)