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PRIVACY AT ADP
Effective Date: May 8, 2018
Last Updated: March 21, 2024
As a Human Capital Management (HCM) provider, ADP processes a vast amount of
personal data. We process the personal data of our Clients’ employees on behalf
of our Clients, and of our business contacts. In order to provide the highest
level of data protection, ADP has adopted Binding Corporate Rules (BCR) for
processing Client employee data and business contact data. In addition, ADP has
implemented BCR for processing personal data of ADP Associates. These BCRs serve
as the basis for our Global Privacy Program. We have implemented a Global
Privacy Policy that is applicable to all ADP Associates worldwide, enabling us
to comply with the commitments we’ve made in our BCRs.
ADP’s Global Chief Privacy Officer is charged with leading and overseeing ADP’s
Global Privacy Programs, along with the members of the global privacy team. The
global privacy team may be contacted at privacy@adp.com.
We invite you to explore this webpage and learn more about Privacy at ADP,
including understanding the steps that we’ve taken to protect personal data
globally. Within this webpage, you may find our Privacy Statements, overview of
our BCRs, and of our Privacy Program, as well as brochures and other
privacy-related materials.
This webpage is complementary to our other Privacy at ADP webpage that you can
find at https://www.adp.com/about-adp/data-privacy.aspx.
* ADP Privacy Statement for Business Contacts
Effective Date: May 8, 2018
Last Updated: June 2, 2023
This Privacy Statement explains how ADP, Inc. and the ADP Group Companies
listed under section 17 of this Statement, (hereinafter “we”), use and
disclose Personal Data that we collect from Individuals who visit our
websites and otherwise engage with us in business activities. This Privacy
Statement also incorporates ADP’s Binding Corporate Rules (BCR) Privacy Code
for Business Data, which includes detailed information about how ADP
processes data of our Business Contacts and the commitments we have made to
protect that data. For more information on the BCR, please click on ADP
Privacy Code for Business Data Overview towards the bottom of this webpage.
If you have additional questions about privacy please contact us at
privacy@adp.com.
For information on how ADP protects the Personal Data we process for Clients,
please see the ADP Privacy Statement for Client Employees, found towards the
bottom of this webpage.
If you are a California resident, please see our California Consumer Privacy
Statement, available here
[https://www.adp.com/-/media/adp/privacy/pdf/ccpaps_en.pdf], for more
information on how we handle your Personal Data and the privacy requests you
may make.
ADP has a Global Data Privacy Policy that applies to all ADP Group Companies
worldwide. An overview of the Global Data Privacy Policy, as it applies to
Client Employee’s data that we process on behalf of our Clients, is located
on this webpage. Every ADP Group Company must respect privacy and protect the
Personal Data that is entrusted to it. This Privacy Statement explains how
ADP collects, uses and discloses Personal Data in particular, from Business
Contacts, as well as from its website visitors. If you are interested in the
practices of a particular ADP Group Company, please check the “Privacy” link
on that company’s website or contact us at privacy@adp.com.
1. Types of Personal Data
This Privacy Statement explains our practices with regard to Personal Data
collected by ADP for its own Business Purposes. Personal Data is any
information that can be used to identify, locate or contact you. Some
examples of Personal Data include your name, username, mailing address,
telephone numbers, email address, geographic location, creditworthiness,
customer account information, or other information about how you use ADP
websites and applications. Personal Data also includes other information that
may be associated with your Personal Data.
2. How ADP collects Personal Data
In most cases, we collect Personal Data directly from you. We will ask you
for Personal Data when you interact with us, such as registering on our
websites, signing up to receive a newsletter, making a purchase, signing up
to receive marketing communications, or to provide ADP with services, goods
or products. We may collect additional information from Third Party data
suppliers who enhance our files and help us better understand our contacts.
If you interact with us online, we use cookies and other technological tools
to collect information about your computer and your use of our website and
applications. We treat this information as Personal Data when it is
associated with your contact information. For more information about cookies
and other technologies, please see the section Cookies and Other Data
Collection Technologies below.
3. How ADP uses Personal Data
ADP uses your Personal Data for the following Business Purposes:
(a) Business Purposes for Processing Personal Data pertaining to
Professionals. Personal Data pertaining to Professionals with whom ADP has a
business relationship may be processed as needed:
(1) To initiate, assess, develop, maintain, or expand a business
relationship, including negotiating, contracting, and fulfilling obligations
under contracts;
(2) For due diligence regarding the Individual’s qualifications and
eligibility for the relationship, including verifying the identity,
qualification, authority, and creditworthiness of the Professional and
obtaining publicly-available information from Third Parties (such as
publicly-available sanction lists from screening companies);
(3) To send transactional communications (such as requests for
information, responses to requests for information, orders, confirmations,
training, and service updates);
(4) For account management, accounting, finance, and dispute resolution
purposes (such as accounts receivable, accounts payable, account
reconciliation, cash management, or money movement) and for consolidated
management and reporting;
(5) To assure quality control and to enforce company standards and
policies;
(6) For risk management and mitigation, including for audit and insurance
functions, and as needed to license and protect intellectual property and
other assets;
(7) For security management, including monitoring Individuals with access
to ADP’s websites, applications, systems, or facilities, investigation of
threats, and as needed for any Data Security Breach notification; and
(8) To anonymize or de-identify the Personal Data.
(b) Business Purposes for Processing Personal Data pertaining to Consumers
and other Individuals. Personal Data pertaining to Consumers and other
Individuals with whom ADP has a business relationship may be processed as
needed:
(1) To provide the information, product, or service requested by the
Individual, and as would be reasonably expected by the Individual given the
context in which the Personal Data were collected, and the information
provided in the applicable privacy statement given to the Individual (such as
for personalization, remembering preferences, or respecting Individual
rights);
(2) For due diligence, including verifying the identity of the
Individual, as well as the eligibility of the Individual to receive
information, products, or services (such as verifying age, employment, or
account status);
(3) To send transactional communications (such as requests for
information, responses to requests for information, orders, confirmations,
training materials, and service updates);
(4) To manage the Individual’s account, such as for customer service,
finance, and dispute resolution purposes;
(5) For risk management and mitigation, including for audit and insurance
functions, and as needed to license and protect intellectual property and
other assets,
(6) For security management, including monitoring Individuals with access
to ADP’s websites, applications, systems, or facilities, investigation of
threats, and as needed for any Data Security Breach notification; and
(7) To anonymize or de-identify the Personal Data.
(c) Business-necessary Processing activities. ADP may process Personal Data
as needed (i) to protect the privacy and security of the Personal Data it
maintains, such as in connection with advanced security initiatives and
threat detection; (ii) for treasury operations and money movement activities;
(ii) for compliance functions, including screening Individuals against
sanction lists in connection with anti-money laundering programs; (iv) for
business structuring activities, including mergers, acquisitions, and
divestitures; and (v) business activities, management reporting, and
analysis.
(d) Development and improvement of products and/or services. ADP may process
Personal Data to develop and improve ADP’s products and/or services, and for
research, development, analytics, and business intelligence.
(e) Relationship management and marketing. ADP may process Personal Data for
relationship management and marketing. This purpose includes sending
marketing and promotional communications to Individuals who have not objected
to receiving such messages as may be appropriate given the nature of the
relationship (or who have opted into such messages in those jurisdictions
where opt-in consent is required), such as product and service marketing,
investor communications, Client communications (e.g., HR compliance alerts,
product updates, and training opportunities and invitations to ADP events),
customer satisfaction surveys, supplier communications (e.g., requests for
proposals), corporate communications, and ADP news.
ADP uses your Personal Data for Secondary Purposes such as:
* Disaster recovery and business continuity, including transferring the
information to an Archive
* Internal audits or investigations
* Implementation or verification of business controls
* Statistical, historical, or scientific research
* Dispute resolution
* Legal or business counseling
* Compliance with laws and company policies
* Insurance purposes
4. Why and How Personal Data is disclosed by ADP
ADP commits to not provide your Personal Data to Third Parties for their own
marketing purposes. We limit our sharing of your Personal Data to:
* ADP Group Companies, which will only use your Personal Data for the
purposes listed above.
* Our service providers, who are bound by law or contract to protect your
Personal Data and only use your Personal Data in accordance with our
instructions.
* Our business partners, but only to the extent you have purchased product
or service from such partner, interacted with such partner, or otherwise
authorized the sharing. For example, if you are referred to ADP from a
business partner website, we may provide that partner with your contact
information and certain economic and financial information, such as bank
account information, to validate the referral. We may also provide your
contact information to companies that offer complementary products and
services if you request information about these solutions.
* Enforce our rights, protect our property, or protect the rights, property
or safety of others, or as needed to support external auditing, compliance
and corporate governance functions. We will also disclose Personal Data
when required to do so by law, such as in response to a subpoena,
including to law enforcement agencies and courts in the United States and
other countries where we operate.
Please note that we may also use and disclose information about you that is
not personally identifiable. For example, we may publish reports that contain
aggregated, anonymized, and statistical data about our Clients. These reports
do not contain information that would enable the recipient to contact, locate
or identify you. These reports also do not contain identifiable company
information.
5. Cookies and Other Data Collection Technologies
When you visit our website or use our mobile applications, we collect certain
information by automated means, using technologies such as cookies, pixel
tags, browser analysis tools, server logs, and web beacons. For example, when
you visit our website, we place cookies on your computer. Cookies are small
text files that websites send to your computer or other Internet-connected
device to uniquely identify your browser or to store information or settings
in your browser. Cookies allow us to recognize you when you return. They also
help us provide a customized experience and enable us to detect certain kinds
of fraud. In many cases, you can manage cookie preferences and opt-out of
having cookies and other data collection technologies used by adjusting the
settings on your browser. All browsers are different, so visit the “help”
section of your browser to learn about cookie preferences and other privacy
settings that may be available.
ADP also uses flash cookies (also known as local stored objects) and similar
technologies to personalize and enhance your online experience. The Adobe
Flash Player is an application that allows rapid development of dynamic
content, such as video clips and animation. We use flash cookies for security
purposes and to help remember settings and preferences similar to browser
cookies, but these are managed through a different interface than the one
provided by your web browser. To manage flash cookies, please see Adobe’s
website at https://adobe.ly/2Kn1NL2 or visit www.adobe.com. ADP does not use
flash cookies or similar technologies for behavioral or interest-based
advertising purposes.
Pixel tags and web beacons are tiny graphic images placed on website pages or
in our emails that allow us to determine whether you have performed a
specific action. When you access these pages or open or click an email, the
pixel tags and web beacons generate a notice of that action. These tools
allow us to measure response to our communications and improve our web pages
and promotions.
We collect many different types of information from cookies and other
technologies. For example, we collect information from the device you use to
access our website, your operating system type, browser type, domain, and
other system settings, as well as the language your system uses and the
country and time zone where your device is located. Our server logs also
record the Internet Protocol (IP) address assigned to the device you use to
connect to the Internet. An IP address is a unique number that devices use to
identify and communicate with each other on the Internet. We may also collect
information about the website you were visiting before you came to ADP and
the website you visit after you leave our site.
In many cases, the information we collect using cookies and other tools is
only used in a non-identifiable way, without reference to Personal Data. For
example, we use information we collect about website users to optimize our
websites and to understand website traffic patterns. In some cases, we do
associate the information we collect using cookies and other technology with
your Personal Data. This Privacy Statement applies to the information when we
associate it with your Personal Data.
Our website may include embedded YouTube videos. When you click on an
embedded YouTube video that video is loaded from a domain operated by
YouTube. Although we have enabled the Privacy-Enhanced mode for embedded
YouTube videos, which prevents YouTube from placing tracking cookies on your
device when viewing these videos on our site, YouTube may collect your IP
address and other devices information for their own purposes. To learn more
about YouTube’s Privacy-Enhanced mode visit the YouTube support page at
https://support.google.com/youtube/answer/171780. To learn more about
YouTube’s processing of IP addresses visit YouTube’s privacy policy at
https://policies.google.com/privacy.
ADP has relationships with Third Party advertising companies to place
advertisements on this website and other websites, and to perform tracking
and reporting functions for this website and other websites. These Third
Party advertising companies may place cookies on your computer when you visit
our website or other websites so they can display targeted advertisements to
you. These Third Party advertising companies do not collect Personal Data in
this process, and we do not give Personal Data to them as part of this
process. This Privacy Statement does not cover the collection methods or use
of the information collected by these vendors. For more information about
Third Party advertising, please visit the Network Advertising Initiative
(NAI) at www.networkadvertising.org. You may opt out of being targeted by
many Third Party advertising companies by visiting http://bit.ly/2Ig9IgT.
Although our websites currently do not have a mechanism to recognize the
various web browser Do Not Track signals, we do offer Individuals choices to
manage their preferences that are provided in the previous sections above. We
do expect our Third Party advertising companies to use reasonable efforts to
respect browser Do Not Track signals by not delivering targeted
advertisements to website visitors whose browsers have a Do Not Track setting
enabled. However, we understand that some companies do not have this
capability today. To learn more about browser tracking signals and Do Not
Track please visit http://www.allaboutdnt.org/.
ADP uses Google Analytics as a Third Party vendor. For information on how
Google Analytics uses data, please visit “How Google uses data when you use
our partners sites or apps”, located at http://bit.ly/2jXZ13Y.
6. Mobile Applications
ADP offers mobile applications that allow you to access your account,
interact with us online, and receive other information via your mobile
device. Personal Data collected by ADP via our mobile applications is
protected by the terms of this Privacy Statement or our Privacy Statement for
Client Employees, as applicable.
7. Communication Preferences
You may limit the information you provide to ADP. You may also limit the
communications that ADP sends to you. To opt-out of commercial emails, simply
click the link labeled “unsubscribe” at the bottom of any email we send you.
Additionally, you may opt-in or opt-out of communications by navigating to
the Global Preference Center at http://subscribe.adpinfo.com/.
Please note that if you are currently receiving services from ADP and you
have decided to opt-out of promotional emails, this will not impact the
messages we send to you for purposes of delivering such services.
If you have questions about your choices or if you need assistance with
opting-out, please contact us via email to privacy@adp.com. You may also
write us at the address in the How to Contact Us section below. If you send
us a letter, please provide your name, address, email address, and
information about the communications that you do not want to receive.
8. Access, Correction, Erasure, and Other Individual Rights
ADP respects your right to access, correct, and delete your Personal Data, or
object to the processing of your Personal Data. If you have an online
account, you may log into your account to access update, or delete the
information you have provided to us. Additionally, you may contact
privacy@adp.com. to request access to your data, and to exercise any of the
individual rights afforded to you by ADP’s Privacy Code for Business Data, or
by applicable data protection laws and regulations. You may also write to us
at the address in the How to Contact Us section below. If you send us a
letter, please provide your name, address, email address, and detailed
information about the changes you would like to make. ADP will respond to
requests as soon as possible and in accordance with applicable data
protection laws and regulations.
9. Information Security
ADP is committed to maintaining the appropriate organizational, technical,
and physical controls to protect Personal Data entrusted to ADP. These
controls protect Personal Data from anticipated threats and hazards as well
as unauthorized access and use. In each case, ADP will strive to provide
security that is proportional to the sensitivity of the Personal Data being
protected, with the greatest effort being focused on protecting Sensitive
Personal Data and other Personal Data whose compromise could result in
substantial harm or inconvenience to the Individual. Additional information
about ADP’s Global Security Organization may be found at
https://www.adp.com/about-adp/data-security.aspx.
Please note that you should also take steps to protect yourself, especially
online. When you register at ADP websites, choose a strong password, and do
not use the same password that you use on other sites. Do not share your
password with anyone else. ADP will never ask you for your password in an
unsolicited phone call or in an unsolicited email. Also remember to sign out
of the website and close your browser window when you have finished your
work. This is to ensure that others cannot access your Personal Data and
correspondence if others have access to your computer.
10. Data Retention
ADP will only retain your information for as long as necessary for the
Purposes for which the Personal Data is processed. ADP has implemented a
Global Records Information Management (RIM) Policy and has established
records retention schedules for all types of Personal Data that ADP
processes. Personal Data is retained in accordance with the records retention
schedules to ensure that records containing Personal Data are retained as
needed to fulfill the applicable Business Purposes, to comply with applicable
laws, or as advisable in light of applicable statutes of limitations. When
the retention period has expired, records containing Personal Data will be
securely deleted or destroyed, de-identified, or transferred to archive, in
accordance with ADP’s RIM Policy.
11. International Data Transfers
ADP is headquartered in the United States of America. Your Personal Data may
be accessed by or transferred to our Group Companies and Suppliers in the
United States or elsewhere in the world in accordance with the ADP Privacy
Code for Business Data, found towards the bottom of this webpage.
12. Privacy Statements of Third Parties
This Privacy Statement only addresses the use and disclosure of information
by ADP. Our Suppliers, Business Partners, and other Third Party websites that
may be accessible through our https://www.ADP.com website have their own
privacy statements and data collection, use and disclosure practices. We
encourage you to familiarize yourself with the privacy statements provided by
Third Parties prior to providing them with information or taking advantage of
an offer or promotion.
13. Forums, Product Reviews and Other Public Areas
Our websites may provide forums and other public areas where you may
communicate with others and publicly post information. Prior to posting in
these areas, please read our Terms of Use carefully. The information you post
will be accessible to anyone with Internet access, and Personal Data you
include in your posting may be read, collected, and used by others. For
example, if you post your email address on a forum or in a public area, you
may receive unsolicited messages from Third Parties. Please use caution when
posting Personal Data.
14. Job Applicants
If you have applied for employment with ADP, the Personal Data submitted with
your job application will be added to our recruitment system and used for
recruitment and other customary human resources purposes in accordance with
our ADP Applicant Privacy Statement.
15. Individuals Located in the European Economic Area
In addition to the rights already listed in this Privacy Statement under
Section 8, you also have the right to data portability, as well as the right
to be notified of automated decision making or profiling related to your
Personal Data. A Data Protection Officer for the European Economic Area has
been appointed and can be reached at DataProtectionOfficer.ADPEMEA@adp.com
You may reach the Data Protection Officer via mail at the address below.
Data Protection Officer - EMEA
ADP Europe SAS
31 Avenue Jules Quentin
92000 Nanterre
France
16. Changes to this Privacy Statement
From time to time, we may update this Privacy Statement to reflect new or
different privacy practices. We will place a notice online when we make
material changes to this Privacy Statement.
17. Group Companies bound by this Privacy Statement
For a listing of Group Companies bound by this Privacy Statement and the
Privacy Code for Business Data, please click
www.adp.com/-/media/adp/privacy/pdf/A2CoBDC.pdf.
18. How to Contact Us
Please contact us if you have questions, or comments, at privacy@adp.com. You
may reach us via mail at address below. If you send us a letter, please
provide your name, address, email address, and detailed information about
your question, comment, or complaints.
ADP
ADP Global Data Privacy and Governance Team
MS 325
One ADP Boulevard
Roseland, NJ 07068-1728 USA
19. How to Lodge a Complaint
If you believe that ADP has not handled your Personal Data properly or that
it has breached its privacy obligations, under any applicable data protection
laws or the ADP Privacy Code for Business Data or of Applicable Law, you may
file your complaint in writing to the address above, or via email, to the
Global Data Privacy and Governance Team at privacy@adp.com.
* ADP Privacy Code for Business Data - Overview
On December 9, 2020, Automatic Data Processing Inc., based on a decision by
its General Counsel, decided to include the United Kingdom, upon its exit
from the European Union (hereinafter: Brexit) within its definition of
EUROPEAN ECONOMIC AREA (EEA).
The definition of EEA as it is included in the list of definitions of ADP’s
Binding Corporate Rules, should read as follows from the date of Brexit:
EEA or EUROPEAN ECONOMIC AREA means all Member States of the European Union,
plus Norway, Iceland, and Liechtenstein and for purposes of the Codes,
Switzerland and the United Kingdom (UK) after its exit from the European
Union. By decision of the General Counsel – to be published on www.adp.com it
may include other countries with data protection laws having data transfer
restrictions similar to EEA Data Transfer Restrictions.
Introduction
ADP has adopted Binding Corporate Rules (BCR) as a Data Controller. BCR are a
legally binding set of internal rules, recognized by the European Union (EU)
Data Protection Authorities (DPAs), to ensure a consistent approach to
privacy and data protection across Group Companies with the same parent,
including those located outside of the EU.
Scope and Applicability
The ADP Privacy Code for Business Data indicates the commitments ADP has
implemented for Processing Personal Data pertaining to those Individuals with
whom ADP has a business relationship (e.g., Individuals who represent ADP’s
Clients, Suppliers and Business Partners, other Professionals, and Consumers)
and other Individuals whose Personal Data are processed by ADP in the context
of its business activities as a Data Controller.
Implementation
The effective date of the ADP Privacy Code for Business Data is April 11,
2018. ADP will implement the ADP Privacy Code for Business Data across the
relevant ADP Group Companies within 18 months of the effective date.
Glossary for BCR
To access the glossary of terms used throughout ADP BCR related materials,
please click www.adp.com/-/media/adp/privacy/pdf/glossary_en.pdf.
ADP Privacy Code for Business Data Principles
The ADP Privacy Code for Business Data is based on a set of data protection
principles outlined below.
Business Purposes for Processing Personal Data
Personal Data may be processed by ADP in the context of its business
operations for one or more of the following Business Purposes:
A. Business Purposes for Processing Personal Data pertaining to
Professionals:
1. Business relationship management;
2. Business relationship due diligence;
3. Transactional communications;
4. Account management;
5. Quality control;
6. Risk management;
7. Security management; and
8. Anonymize or de-identify Personal Data.
B. Business Purposes for Processing Personal Data pertaining to Consumers and
other Individuals:
1. Provide requested information, products or services;
2. Due diligence;
3. Transactional communications;
4. Account management;
5. Risk management;
6. Security management; and
7. Anonymize or de-identify Personal Data.
C. Business-necessary Processing activities:
1. Protect privacy and security;
2. Treasury operations and money movement activities;
3. Compliance;
4. Business structuring activities; and
5. Reporting and analysis.
D. Development and improvement of products and/or services; and
E. Relationship management and marketing.
Use for Other Purposes
Personal Data may be processed for a secondary purpose, similar to the
legitimate Business Purpose, provided appropriate additional measures are
taken. It is generally permissible to Process Personal Data for the following
purposes (even if not listed as a Business Purpose), provided appropriate
additional measures are taken:
1. Disaster recovery and business continuity, including transferring the
Information to an Archive;
2. Internal audits or investigations;
3. Implementation or verification of business controls;
4. Statistical, historical, or scientific research;
5. Dispute resolution;
6. Legal or business counseling;
7. Compliance with laws and company policies; or
8. Insurance purposes.
Purposes for Processing Special Categories of Data
The following Special Categories of Data may be processed by ADP for the
purposes specified below:
1. Special Categories of Data revealed by Photographic Images.
Photographic images and video recordings may be processed for security,
compliance and other legitimate Business Purposes, such as participating in
video conferences.
2. Racial or ethnic data. ADP may Process racial and ethnic data as
needed to facilitate Supplier and other diversity programs.
3. Criminal data (including data relating to criminal behavior, criminal
records, or proceedings regarding criminal or unlawful behavior). ADP may
Process criminal data as needed to conduct appropriate due diligence on
Individuals and in connection with security and compliance activities as
needed to protect the interests of ADP.
4. Physical or mental health data. ADP may Process physical or mental
health data as needed to accommodate a person’s disability or dietary needs,
address emergency health needs, or in similar circumstances.
5. Biometric data (such as fingerprints). ADP may Process biometric data
for the protection of ADP and Staff assets, system and site access, security
and fraud prevention reasons.
6. Religion or beliefs. ADP may Process data pertaining to religion or
beliefs as needed to meet an Individual’s specific needs, such as
accommodating dietary requests (for kosher or halal meals) or respecting
religious holidays.
Special categories of data may be processed for any other legitimate purpose,
if ADP obtains the prior explicit consent of the Individual.
Quantity and Quality of Data
ADP shall establish and implement retention schedules so that records
containing Personal Data are only retained as needed to fulfill the
applicable Business Purposes, to comply with applicable legal requirements,
or as advisable in light of applicable statutes of limitations.
Personal Data should be accurate, complete, and kept up-to-date to the extent
reasonably necessary for the applicable Business Purposes. It is the
responsibility of Individuals to ensure that their Personal Data are
accurate, complete, and up-to-date.
Individual Rights of Access, Rectification and Objection
Individuals have the right to request a copy of the Personal Data maintained
by or on behalf of ADP. If the personal data are incorrect, incomplete, or
not processed in compliance with applicable law or the ADP Privacy Code for
Business Data, the Individual has the right to have the personal data
rectified, restricted or erased (as appropriate).
Additionally, Individuals have the right to object to a) the Processing of
their Personal Data on the basis of compelling grounds related to their
particular situation, or b) receiving direct marketing communications
(opting-out).
Information around the process for submitting an Individual Rights Request
can be found in Article 7 of the ADP Privacy Code for Business Data.
Security and Confidentiality Requirements
ADP has implemented commercially reasonable and appropriate technical,
physical, and organizational measures to protect Personal Data from misuse or
accidental, unlawful, or unauthorized destruction, loss, alteration,
disclosure, acquisition, or access.
Access to Personal Data will be authorized only to the extent necessary to
serve the applicable Business Purposes and ADP Staff with access to Personal
Data will be subject to confidentiality obligations.
ADP shall investigate all known or suspected Data Security Breaches and shall
document the facts relating thereto, its effects and the remedial actions
taken. ADP shall notify Individuals of a Data Security Breach within a
reasonable period of time following determination of such Data Security
Breach if (a) the Individual is at a high risk of harm as a result of the
Data Security Breach or, (b) (even if the Individual is not at a high risk of
harm), if an applicable breach notification law requires Individual
notification.
Direct Marketing
ADP respects the choices of Individuals and provides Individuals the choice
to opt-in and opt-out of direct marketing. ADP will send direct marketing
materials if the Individual has provided opt-in consent or if Applicable Law
permits ADP to send marketing communications without explicit consent based
on an existing business relationship.
Transfer of Personal Data to Third Parties and Internal Processors
ADP may transfer Personal Data to a Third Party and to Internal Processors to
the extent necessary to serve the applicable Business Purposes. ADP will only
transfer Personal Data to a Third Party or to an Internal Processor if a
written contract has been entered into with the ADP Group Company ensuring
that the same level of data protection will be applied as described in the
ADP Privacy Code for Business Data.
Governance
ADP’s privacy program is managed by ADP’s Global Chief Privacy Officer and
the members of the Data Privacy and Governance Team. ADP has implemented a
Privacy Network comprised of the members of the Data Privacy and Governance
Team and other members of the Legal department, including compliance
professionals, and Data Protection Officers, who are in charge of privacy
compliance within their respective regions, countries, Business Units or
Functional areas.
Additionally, Privacy Stewards are Executives who have been appointed by ADP
senior leaders to implement and enforce compliance with ADP’s privacy program
within their respective Business Units or Functional areas. Privacy Stewards
and selected members of the Privacy Network serve on ADP’s Privacy Leadership
Council, led by ADP’s Global Chief Privacy Officer, to oversee privacy
compliance at ADP.
Monitoring and Audit
ADP shall audit business processes and procedures that involve the Processing
of Personal Data for compliance with the ADP Privacy Code for Business Data
on a regular basis. Additionally, ADP will allow its Processing facilities to
be audited by the Lead DPA and DPAs of an EEA Country, as defined in the ADP
Privacy Code for Business Data.
The Global Chief Privacy Officer shall produce an annual report for the ADP
Executive Committee on compliance with the ADP Privacy Code for Business
Data, privacy, data protection risks, and other relevant issues.
Complaints Procedure
Individuals covered by the ADP Privacy Code for Business Data may file a
written complaint if they suspect that a member(s) of the ADP Group Companies
has violated the commitments made in the ADP Privacy Code for Business Data,
as further defined in the ADP Privacy Code for Business Data.
Complaints must be submitted in writing to the ADP Global Data Privacy and
Governance Team. Complaints may be submitted via email to privacy@adp.com. or
via mail to:
ADP Delegated Entity
ADP Nederland B.V.
Lylantse Baan 1, 2908
LG CAPELLE AAN DEN IJSSEL
THE NETHERLANDS
Individuals may also file a complaint or claim with the relevant DPAs or the
Courts.
ADP Privacy Code for Business Data
For the full text of the ADP Privacy Code for Business Data, please click
www.adp.com/-/media/adp/privacy/pdf/bcrbc_en.pdf. For a list of Group
Companies bound by the ADP Privacy Code for Business Data, please click
www.adp.com/-/media/adp/privacy/pdf/A2CoBDC.pdf.
Contact Us
For more information about ADP’s Privacy Program, including the ADP Privacy
Code for Business Data, please contact the Global Data Privacy and Governance
team at privacy@adp.com.
* ADP Privacy Statement for Client Employees
Effective Date: May 8, 2018
Last Update: May 25, 2023
ADP has an internal Global Data Privacy Policy that applies to all affiliates
and associates worldwide. The Global Data Privacy Policy helps us ensure that
personal data is handled properly. The Global Data Privacy Policy governs
personal data collected by ADP for its own purposes as well as information
provided to us as a processor for our Clients. It protects information
collected online as well as offline. ADP is committed to protecting the
privacy and security of personal data that we process in order to provide
services to our Clients. We receive personal data from our Clients about
their current, prospective and former employees as well as employee
dependents and family members, as needed to provide benefits. This Privacy
Statement explains our practices with regard to the personal data we receive
from our Clients as a processor.
ADP will collect and process your personal data only as instructed or
permitted by our Client (your employer or prospective employer) or you. ADP
maintains appropriate security controls to protect your information.
For our Client employees located in the European Economic Area and in
Switzerland, ADP has established Binding Corporate Rules (BCR) Privacy Code
for Client Data Processing Services which have been approved by the European
Union Data Protection Authorities.
ADP will disclose your personal data to your employer and to other entities
when instructed by your employer. We may disclose your personal data to our
affiliates and third party processors as needed to provide the services that
you and your employer have requested. These entities are contractually bound
to limit the use of your personal data as needed to perform the services. We
will also disclose personal data when required to do so by law, such as in
response to a subpoena, including to law enforcement agencies and courts in
the United States and other countries where we operate.
For Registered ADP Mobile Users: If your ADP Mobile account is inactive for
more than 480 days, your login credentials will be suspended. The account
will be deleted 180 days after account suspension. If you would like to
expedite your account deletion, contact your Human Resources administrator.
If you have questions about your privacy rights, please contact your
employer’s human resources department.
International Data Transfers
Where authorized by your employer, ADP will transfer personal data pertaining
to individuals located outside of the United States to our affiliates and
suppliers in the United States and elsewhere in the world, pursuant to
applicable data protection laws. We will only transfer personal data
pertaining to individuals located in the European Economic Area as permitted
by the ADP Privacy Code for Client Data Processing Services. For an overview
of the ADP Privacy Code for Client Data Processing Services, which includes
the list of our affiliates bound by the ADP Privacy Code for Client Data
Processing Services, please click
www.adp.com/-/media/adp/privacy/pdf/bcrpc_en.pdf.
Sensitive Personal Data
In the ordinary course of its business, ADP processes sensitive personal data
on behalf of your employer, such as social security numbers. ADP has
implemented reasonable technical, physical and administrative safeguards to
help protect the sensitive personal data from unlawful use and unauthorized
disclosure. All ADP associates and contingent workers are required to follow
these established procedures, both online and offline. Access to sensitive
personal data is limited to those associates and contingent workers who have
a need to access the information to perform tasks for ADP. ADP will only
disclose sensitive personal data to those service providers, auditors, and/or
advisors who are legally or contractually obligated to protect them or as
required or permitted by law.
Anti-Money Laundering
If your employer has elected to receive services such as money movement
services from ADP, ADP may be required by applicable laws to process Client
employee data for monitoring and other controls needed to safeguard the
security and integrity of financial transactions including for due diligence,
such as verifying the identifying of the individual, and the individual’s
eligibility to receive products or services, such as verifying employment or
account status.
How to Lodge a Complaint (European Economic Area (EEA) and Switzerland Client
Employees only)
Client employees located in the EEA and Switzerland, as a third party
beneficiary, may file a complaint in respect of a claim they have for
violation of the ADP Privacy Code for Client Data Processing Services or
applicable law, by contacting the Global Data Privacy and Governance Team at
privacy@adp.com.
ADP
Global Data Privacy and Governance Team
MS 325
One ADP Boulevard
Roseland, NJ 07068-1728 USA
If ADP’s response to your complaint is unsatisfactory, you may file a
complaint or claim with the relevant regulatory authorities or the courts, in
accordance with the provisions of the ADP Privacy Code for Client Data
Processing Services.
Questions about Your Personal Data
ADP is committed to transparency. We want individuals to understand how we
collect and use personal data so they may interact with ADP with confidence.
The materials provided on this webpage may help you find the information you
need about privacy at ADP. If you have questions related to the content of
this webpage, please contact us at privacy@adp.com. As an employee or
prospective employee of an ADP Client, please reach out directly to them for
more information regarding the collection and processing of your personal
data or to exercise your data privacy rights (e.g. the right to deletion or
erasure).
* U.S. Biometric Information Privacy Policy
U.S. Biometric Information Privacy Policy (English)
U.S. Biometric Information Privacy Policy (Spanish)
* ADP Privacy Code for Client Data Processing Services (European Data Only) –
Overview
On December 9, 2020, Automatic Data Processing Inc., based on a decision by
its General Counsel, decided to include the United Kingdom, upon its exit
from the European Union (hereinafter: Brexit) within its definition of
EUROPEAN ECONOMIC AREA (EEA).
The definition of EEA as it is included in the list of definitions of ADP’s
Binding Corporate Rules, should read as follows from the date of Brexit:
EEA or EUROPEAN ECONOMIC AREA means all Member States of the European Union,
plus Norway, Iceland, and Liechtenstein and for purposes of the Codes,
Switzerland and the United Kingdom (UK) after its exit from the European
Union. By decision of the General Counsel – to be published on www.adp.com it
may include other countries with data protection laws having data transfer
restrictions similar to EEA Data Transfer Restrictions.
Introduction
ADP has adopted Binding Corporate Rules (BCR) as a Data Processor. BCR are a
legally binding set of internal rules, recognized by the European Union (EU)
Data Protection Authorities (DPAs), to ensure a consistent approach to
privacy and data protection across Group Companies with the same parent,
including those located outside of the EU.
The ADP Privacy Code for Client Data Processing Services indicates the
commitments ADP has implemented for the processing of personal data
pertaining to client employees by ADP, in connection with providing client
services and client support activities.
Scope and Applicability
The ADP Privacy Code for Client Data Processing Services addresses the
processing of personal data of client employees by ADP in its role as a data
processor for clients in the course of delivering client services, where such
personal data are:
a. Subject to EEA Applicable Law (or were subject to EEA Applicable Law
prior to the transfer of such personal data to a Group Company outside the
EEA in a country which has not been deemed to provide an adequate level of
data protection by competent EEA institutions);
b. Collected originally in the context of the activities of an EEA
establishment of a Client;
c. Subject to EEA Data Transfer Restrictions;
d. Processed by ADP outside the EEA in a country which has not been
deemed to provide an adequate level of data protection by competent EEA
institutions; and
e. Processed pursuant to a Service Agreement that specifically provides
that the ADP Privacy Code for Client Data Processing Services shall apply to
such personal data.
Implementation
The effective date of the ADP Privacy Code for Client Data Processing
Services is April 11, 2018. ADP will implement the ADP Privacy Code for
Client Data Processing Services across the relevant ADP Group Companies
within 18 months of the effective date.
Glossary for BCR
To access the glossary of terms used throughout ADP BCR related materials,
please click www.adp.com/-/media/adp/privacy/pdf/glossary_en.pdf.
ADP Privacy Code for Client Data Processing Services Principles
The ADP Privacy Code for Client Data Processing Services is based on a set of
data protection principles outlined below.
Data Processing Purposes
ADP shall Process Client Data on behalf of the Client, only in accordance
with the Service Agreement, pursuant to any documented instructions received
from the Client, or as needed to comply with Applicable Law.
ADP processes personal data (including Special Categories of Data) pertaining
to client employees as needed to provide client services, client support
activities, as required by EEA applicable law and for the following
additional purposes:
a. Hosting, storage, and other processing needed for business continuity
and disaster recovery;
b. System and network administration and security, including
infrastructure monitoring, identity and credential management, verification
and authentication, and access control;
c. Monitoring and other controls needed to safeguard the security and
integrity of transactions;
d. Enforcing contracts and protecting ADP, its associates, clients,
client employees, and the public against theft, legal liability, fraud, or
abuse; and
e. Approved ADP internal business processes.
Upon termination of the Service Agreement, ADP shall fulfill its obligations
to the client with regard to the returning the data and securely destroying
the data, subject to EEA applicable law.
Security Requirements
ADP has implemented commercially reasonable and appropriate technical,
physical, and organizational measures to protect Client Data from misuse or
accidental, unlawful, or unauthorized destruction, loss, alteration,
disclosure, acquisition, or access during the Processing, which will meet the
requirements of EEA Applicable Law, or any stricter requirements, as imposed
under the Service Agreement.
Access to Client Data will be authorized only to the extent necessary to
serve the applicable Data Processing Purposes and requirements of the Service
Agreements. ADP staff with access to client data will be subject to
confidentiality obligations.
ADP shall notify the client of a data security breach without undue delay
after becoming aware that such a breach has occurred, unless a law
enforcement official or supervisory authority determines that notification
would impede a criminal investigation, or cause damage to national security
or a breach of trust in the relevant industry sector.
Transparency to Client Employees
ADP shall promptly notify the Client of requests or complaints related to the
Processing of personal data by ADP that are received directly from client
employees without responding to such requests or complaints, unless otherwise
provided in the Service Agreement or instructed by the client.
Subprocessors
Third Party Subprocessors may only Process Client Data pursuant to a
Subprocessor Contract. The Subprocessor Contract shall impose similar data
protection-related Processing terms on the Third Party Subprocessor that will
be not less protective than those imposed on the ADP Contracting Entity by
the Service Agreement and the ADP Privacy Code for Client Data Processing
Services.
ADP shall publish an overview of the categories of Subprocessors involved in
the performance of the relevant Client Services and ADP shall provide notice
to the Client of any new Subprocessors engaged by ADP for the delivery of the
Client Services. Clients have 30 days from notification date to object to the
use of new Subprocessors engaged by ADP.
Governance
ADP’s privacy program is managed by ADP’s Global Chief Privacy Officer and
the members of the Data Privacy and Governance Team. ADP has implemented a
Privacy Network comprised of the members of the Data Privacy and Governance
Team and other members of the Legal department, including compliance
professionals, and Data Protection Officers, who are in charge of privacy
compliance within their respective regions, countries, Business Units or
Functional areas.
Additionally, Privacy Stewards are Executives who have been appointed by ADP
senior leaders to implement and enforce compliance with ADP’s privacy program
within their respective Business Units or Functional areas. Privacy Stewards
and selected members of the Privacy Network serve on ADP’s Privacy Leadership
Council, led by ADP’s Global Chief Privacy Officer, to oversee privacy
compliance at ADP.
Compliance
ADP shall respond promptly and appropriately to requests for assistance from
the Client to enable the Client to comply with its obligations, subject to
Applicable Law and in accordance with the Service Agreement.
Monitoring and Audit
ADP will address Client audit requests and will answer questions asked by the
Client regarding the Processing of Client Data by ADP. If further information
is requested, in agreement with Client, ADP will either a) allow an
independent third party assessor to conduct an audit, no more than annually
per client, subject to a 45 day written notice and bound by confidentiality
terms, or b) provide the Client with a statement from a third party assessor,
indicating ADP’s compliance with the ADP Privacy Code for Client Data
Processing Services. Additionally, ADP will allow its Processing facilities
to be audited by any DPA of an EEA Country which is competent to audit an ADP
Client.
The Global Chief Privacy Officer shall produce an annual report for the ADP
Executive Committee on compliance with the ADP Privacy Code for Client Data
Processing Services, privacy, data protection risks, and other relevant
issues.
Complaints Procedure
Client Employees covered by the ADP Privacy Code for Client Data Processing
Services may file a written complaint if they suspect that a member(s) of the
ADP Group Companies has violated the commitments made in the ADP Privacy Code
for Client Data Processing Services, as further defined in the ADP Privacy
Code for Client Data Processing Services.
Complaints must be submitted in writing to the ADP Global Data Privacy and
Governance Team. Complaints may be submitted via email to privacy@adp.com or
via mail to:
ADP Delegated Entity
ADP Nederland B.V.
Lylantse Baan 1, 2908
LG CAPELLE AAN DEN IJSSEL
THE NETHERLANDS
Client Employees may also file a complaint or claim with the relevant DPAs or
the Courts.
ADP Privacy Code for Client Data Processing Services
For the full text of the ADP Privacy Code for Client Data Processing
Services, please click www.adp.com/-/media/adp/privacy/pdf/bcrpc_en.pdf. For
a list of the Group Companies bound by ADP’s Privacy Code for Client Data
Processing Services, please click
www.adp.com/-/media/adp/privacy/pdf/A3CoPC3.pdf.
Contact Us
For more information about ADP’s Privacy Program, including the ADP Privacy
Code for Client Data Processing Services, please contact the Global Data
Privacy and Governance team at privacy@adp.com.
* ADP UK Privacy Code for Client Data Processing Services
ADP UK Privacy Code for Client Data Processing Services (pdf)
* ADP Cookie Privacy Statement
Effective Date: May 8, 2018
Last Updated: June 1, 2023
When you visit our website or use our mobile applications, we collect certain
information by automated means, using technologies such as cookies, pixel
tags, browser analysis tools, server logs, and web beacons. For example, when
you visit our website, we place cookies on your computer. Cookies are small
text files that websites send to your computer or other Internet-connected
device to uniquely identify your browser or to store information or settings
in your browser. Cookies allow us to recognize you when you return. They also
help us provide a customized experience and enable us to detect certain kinds
of fraud. In many cases, you can manage cookie preferences and opt-out of
having cookies and other data collection technologies used by adjusting the
settings on your browser. All browsers are different, so visit the “help”
section of your browser to learn about cookie preferences and other privacy
settings that may be available.
ADP also uses flash cookies (also known as local stored objects) and similar
technologies to personalize and enhance your online experience. The Adobe
Flash Player is an application that allows rapid development of dynamic
content, such as video clips and animation. We use flash cookies for security
purposes and to help remember settings and preferences similar to browser
cookies, but these are managed through a different interface than the one
provided by your web browser. To manage flash cookies, please see Adobe’s
website at https://adobe.ly/2Kn1NL2 or visit www.adobe.com. ADP does not use
flash cookies or similar technologies for behavioral or interest-based
advertising purposes.
Pixel tags and web beacons are tiny graphic images placed on website pages or
in our emails that allow us to determine whether you have performed a
specific action. When you access these pages or open or click an email, the
pixel tags and web beacons generate a notice of that action. These tools
allow us to measure response to our communications and improve our web pages
and promotions.
We collect many different types of information from cookies and other
technologies. For example, we collect information from the device you use to
access our website, your operating system type, browser type, domain, and
other system settings, as well as the language your system uses and the
country and time zone where your device is located. Our server logs also
record the Internet Protocol (IP) address assigned to the device you use to
connect to the Internet. An IP address is a unique number that devices use to
identify and communicate with each other on the Internet. We may also collect
information about the website you were visiting before you came to ADP and
the website you visit after you leave our site.
In many cases, the information we collect using cookies and other tools is
only used in a non-identifiable way, without reference to Personal Data. For
example, we use information we collect about website users to optimize our
websites and to understand website traffic patterns. In some cases, we do
associate the information we collect using cookies and other technology with
your Personal Data. This Privacy Statement applies to the information when we
associate it with your Personal Data.
Our website may include embedded YouTube videos. When you click on an
embedded YouTube video that video is loaded from a domain operated by
YouTube. Although we have enabled the Privacy-Enhanced mode for embedded
YouTube videos, which prevents YouTube from placing tracking cookies on your
device when viewing these videos on our site, YouTube may collect your IP
address and other devices information for their own purposes. To learn more
about YouTube’s Privacy-Enhanced mode visit the YouTube support page at
https://support.google.com/youtube/answer/171780. To learn more about
YouTube’s processing of IP addresses visit YouTube’s privacy policy at
https://policies.google.com/privacy.
ADP has relationships with Third Party advertising companies to place
advertisements on this website and other websites, and to perform tracking
and reporting functions for this website and other websites. These Third
Party advertising companies may place cookies on your computer when you visit
our website or other websites so they can display targeted advertisements to
you. These Third Party advertising companies do not collect Personal Data in
this process, and we do not give Personal Data to them as part of this
process. This Privacy Statement does not cover the collection methods or use
of the information collected by these vendors. For more information about
Third Party advertising, please visit the Network Advertising Initiative
(NAI) at www.networkadvertising.org. You may opt out of being targeted by
many Third Party advertising companies by visiting http://bit.ly/2Ig9IgT.
Although our websites currently do not have a mechanism to recognize the
various web browser Do Not Track signals, we do offer Individuals choices to
manage their preferences that are provided in the previous sections above. We
do expect our Third Party advertising companies to use reasonable efforts to
respect browser Do Not Track signals by not delivering targeted
advertisements to website visitors whose browsers have a Do Not Track setting
enabled. However, we understand that some companies do not have this
capability today. To learn more about browser tracking signals and Do Not
Track please visit http://www.allaboutdnt.org/.
ADP uses Google Analytics as a Third Party vendor. For information on how
Google Analytics uses data, please visit “How Google uses data when you use
our partners sites or apps”, located at http://bit.ly/2jXZ13Y.
* California Consumer Privacy Statement
Effective Date: January 1, 2020
Last Updated: February 23, 2023
Pursuant to the California Consumer Privacy Act of 2018, as amended by the
California Privacy Rights Act (collectively, the “CCPA”), ADP, Inc. and its
affiliates (“ADP,” “we,” or “us”) are providing the following Privacy
Statement to explain how ADP collects, uses and discloses Personal Data that
we collect from individuals who are residents of California, including but
not limited to users who visit our websites or consumers who receive services
directly from ADP. This Privacy Statement does not apply to Personal Data
pertaining to ADP employees or employees of ADP clients where ADP is acting
in its capacity as a service provider.
For purposes of this Privacy Statement, Personal Data is information that
identifies, relates to, or could reasonably be linked with a particular
California resident or household.
ADP also has a Global Data Privacy Policy that applies to all ADP companies
worldwide. An overview of our Privacy Program is located at
https://www.adp.com/about-adp/data-privacy.aspx.
Collection, Disclosure, and Sharing of Personal Data
The following details which categories of Personal Data we collect and
process, which categories of third parties may have access to your Personal
Data for operational business purposes, as well as which categories of
Personal Data we “share” for purposes of cross-context behavioral
advertising, including within the 12 months preceding the date this Privacy
Statement was last updated.
Sources of Personal Data
We collect this Personal Data actively (e.g. direct input from individual) or
passively (e.g. website cookies) from you. Additionally, we may also collect
Personal Data from third-party sources, such as our affiliates, business
partners, and service providers, listed above where applicable.
Purposes for the Collection, Use and Sharing of Personal Data
ADP uses your Personal Data for the following Business Purposes and
objectives:
Categories of Personal Information Disclosed to Which Categories of Third
Parties for Operational Business Purposes (see below for a more detailed
description of these categories) Shared with Which Categories of Third
Parties for Cross-Context Behavioral Advertising Identifiers, such as name,
contact information, unique personal identifiers, email address, IP address,
online identifiers, government-issued identifiers. Service
Providers/Subcontractors, Related Entities, Law enforcement/Legal
authorities, Third Parties in the event of a Corporate Transaction, with your
consent. Ad networks. Personal information as defined in the California
customer records law, such as name, contact information, financial,
education, employment information. Service Providers/Subcontractors, Related
Entities, Law enforcement/Legal authorities, Third Parties in the event of a
Corporate Transaction, with your consent. None. Characteristics of protected
classifications under California or federal law, such as race, religious
creed, color, national origin, ancestry, physical disability, mental
disability, medical condition, marital status, sex, gender expression, gender
identify, age, sexual orientation, military or veteran status. Service
Providers/Subcontractors, Related Entities, Law enforcement/Legal
authorities, Third Parties in the event of a Corporate Transaction, with your
consent. None. Commercial Information, such as transaction information and
purchase history, including purchases considered, consuming histories or
tendencies. Service Providers/Subcontractors, Related Entities, Law
enforcement/Legal authorities, Third Parties in the event of a Corporate
Transaction, with your consent. None. Biometric Information, such as
fingerprints, voiceprints and faceprints. Not Applicable. Not Applicable.
Internet or network activity information, such as IP address, mobile device
ids, MAC address, browsing history, search history. Service
Providers/Subcontractors, Related Entities, Law enforcement/Legal
authorities, Third Parties in the event of a Corporate Transaction, with your
consent. Ad networks. Geolocation Data, such as precise location/tracking
data and coarse location/tracking data. Service Providers/Subcontractors,
Related Entities, Law enforcement/Legal authorities, Third Parties in the
event of a Corporate Transaction, with your consent. None. Audio/Video Data,
such as photographs. Service Providers/Subcontractors, Related Entities, Law
enforcement/Legal authorities, Third Parties in the event of a Corporate
Transaction, with your consent. None. Education Information subject to the
federal Family Educational Rights and Privacy Act such as education and
training history, education degrees, qualifications/certifications. Service
Providers/Subcontractors, Related Entities, Law enforcement/Legal
authorities, Third Parties in the event of a Corporate Transaction, with your
consent. None. Employment Information. Professional or employment-related
information, such as professional or employment related information such as
work history and prior employer, background checks, performance rating or
feedback, employer, occupation title/job role. Service
Providers/Subcontractors, Related Entities, Law enforcement/Legal
authorities, Third Parties in the event of a Corporate Transaction, with your
consent. None. Inferences such as any assumptions drawn from any of the
Personal Data listed above to create a profile about, for example, an
individual’s preferences or characteristics. This is only applicable to
consumers that purchase our TMBC product due to the nature of the product.
Service Providers/Subcontractors, Related Entities, Law enforcement/Legal
authorities, Third Parties in the event of a Corporate Transaction, with your
consent. None. Sensitive Personal Information, such as social security,
driver’s license, state identification card, or passport number; account
log-in, financial account, debit card, or credit card number in combination
with any required security or access code, password, or credentials allowing
access to an account; precise geolocation; racial or ethnic origin, religious
or philosophical beliefs, citizenship, immigration status, union membership.
Service Providers/Subcontractors, Related Entities, Law enforcement/Legal
authorities, Third Parties in the event of a Corporate Transaction, with your
consent. None.
Detailed Description of Categories of Third Parties
Third Parties that ADP may disclose your Personal Data are as follows:
(a) Service Providers/Subcontractors
ADP may share your Personal Data with our subcontractors for certain business
purposes. This information is provided in order for them to provide ADP with
services such as payment processing, advertising services, marketing
partners, web analytics, data processing, IT services, customer support and
other services such as for the purpose of auditing and fraud investigations.
(b) Related Entities
ADP may share Personal Data between and among ADP, its subsidiaries, and
affiliated companies for purposes of management and analysis, and other
business purposes. For instances, ADP may share your Personal Data with our
subsidiaries and affiliated companies to expand and promote our product and
service offerings. (c) Law Enforcement/Legal Authorities
ADP may be required to disclose your Personal Data to third parties including
law enforcement agencies when required to protect and defend our legal
rights, protect the safety and security of users of our Services, prevent
fraud, respond to legal process, or a request for cooperation by a government
entity, as required by law. (d) Corporate Transactions
In the event of sale, transfer, merger, reorganization, or similar event, ADP
may transfer your Personal Data to one or more third parties as part of that
transaction with the business entities or people involved in the deal
negotiation or transfer. (e) With Your Consent
ADP may share Personal Data about you with other third-party companies if you
give us permission or direct us to share the information. ADP will share
Personal Data with authorized agents that you authorize ADP to communicate
to. We do not sell and have not sold Personal Data, including your Sensitive
Personal Data, in the preceding 12 months. Without limiting the foregoing, we
do not sell the Personal Data, including the Sensitive Personal Data, of
minors under 16 years of age. We do not knowingly “share” the Personal Data,
including the Sensitive Personal Data, of minors under 16 years of age.
Sources of Personal Data
We collect this Personal Data actively (e.g. direct input from individual) or
passively (e.g. website cookies) from you. Additionally, we may also collect
Personal Data from third-party sources, such as our affiliates, business
partners, and service providers.
Purposes for the Collection, Use and Sharing of Personal Data
ADP uses your Personal Data for the following Business Purposes and
objectives:
(a) Business Purposes for processing Personal Data pertaining to consumers.
Personal Data pertaining to consumers with whom ADP has a business
relationship may be processed as needed: (1) To provide the information,
product, or service requested by the individual, and as would be reasonably
expected by the individual given the context in which the Personal Data was
collected, and the information provided in the applicable privacy statement
given to the individual (such as for personalization, remembering
preferences, or respecting individual rights); (2) For due diligence,
including verifying the identity of the individual, as well as the
eligibility of the individual to receive information, products, or services
(such as verifying age, employment, or account status); (3) To send
transactional communications (such as requests for information, responses to
requests for information, orders, confirmations, training materials, and
service updates); (4) To manage the individual's account, such as for
customer service, finance, and dispute resolution purposes; (5) For risk
management and mitigation, including for audit and insurance functions, and
as needed to license and protect intellectual property and other assets;
(6) For security management, including monitoring individuals with access to
the website; applications, systems, or facilities, investigation of threats,
and as needed for any data security breach notification; and (7) To
anonymize or de-identify the Personal Data. Where we maintain or use
de-identified information, we will continue to maintain and use such
information only in a de-identified fashion and will not attempt to
re-identify such information. (b) Business-necessary processing activities.
ADP may process Personal Data as needed (i) to protect the privacy and
security of the Personal Data it maintains, such as in connection with
advanced security initiatives and threat detection; (ii) for treasury
operations and money movement activities; (iii) for compliance functions,
including screening individuals against sanction lists in connection with
anti-money laundering programs; (iv) for business structuring activities,
including mergers, acquisitions, and divestitures; and (v) for business
activities, management reporting, and analysis. (c) Development and
improvement of products and/or services. ADP may process Personal Data to
develop and improve its products and/or services, and for research,
development, analytics, and business intelligence. (d) Relationship
management and marketing. ADP may process Personal Data for relationship
management and marketing. This purpose includes sending marketing and
promotional communications to individuals who have not objected to receiving
such messages, such as product and service marketing communications, investor
communications, Client communications (e.g., HR compliance alerts, product
updates, and training opportunities and invitations to ADP events), customer
satisfaction surveys, supplier communications (e.g., requests for proposals),
corporate communications, and ADP news. (e) Operational purposes.
Additionally, ADP uses your Personal Data for purposes such as: (i) disaster
recovery and business continuity; (ii) internal audits or investigations;
(iii) implementation or verification of business controls; (iv) statistical,
historical, or scientific research; (v) dispute resolution; (vi) legal or
business counseling; (vii) compliance with laws and company policies; and/or
(viii) insurance purposes.
Purposes for the Collection and Use of Sensitive Personal Data
Subject to your consent where required by applicable law, we may use
Sensitive Personal Data for purposes of performing services for our business,
providing goods or services as requested by you, ensuring security and
integrity, short term transient use such as displaying first party,
non-personalized advertising, servicing accounts, providing customer service,
verifying customer information, processing payments, and activities relating
to quality or product improvement.
Retention Period
We retain Personal Data for as long as needed or permitted in light of the
purpose(s) for which it was collected. The criteria used to determine our
retention periods include:
(a) The length of time we have an ongoing relationship with you and provide
services to you (for example, for as long as you have an account with us or
keep using our services) and the length of time thereafter during which we
may have a legitimate need to reference your Personal Data to address issues
that may arise; (b) Whether there is a legal obligation to which we are
subject (for example, certain laws require us to keep records of your
transactions for a certain period of time before we can delete them); or (c)
Whether retention is advisable in light of our legal position (such as in
regard to applicable statutes of limitations, litigation or regulatory
investigations).
California Consumer Rights
If you are a California resident you may make the following requests, subject
to applicable law:
(a) Right to Access and Know -- You may request that we disclose to you the
following information covering the 12 months preceding your request: (1)
The categories of Personal Data we collected about you and the categories of
sources from which we collected such Personal Data; (2) The specific
pieces of Personal Data we collected about you; (3) The business or
commercial purpose for collecting or sharing Personal Data about you; (4)
The categories of Personal Data about you that we shared (as defined under
the applicable privacy law) and the categories of third parties with whom we
shared such Personal Data; and (5) The categories of Personal Data about
you that we otherwise disclosed, and the categories of third parties to whom
we disclosed such Personal Data (if applicable). (b) Right to Request
Correction of your Personal Data -- You may request to correct inaccuracies
in your Personal Data; (c) Right to Request Deletion of your Personal Data
-- You may request to have your Personal Data deleted; and (d) Right to
Opt-out of Sharing for Cross-Context Behavioral Advertising -- You may
request to opt out of the “sharing” of your Personal Data for purposes of
cross-context behavioral advertising.
We will not unlawfully discriminate against you for exercising your rights
under the CCPA.
How to submit a California Rights Request
To make a privacy request, please contact us by clicking here or by emailing
us at privacy@adp.com. We will verify and respond to your request consistent
with applicable law, taking into account the type and sensitivity of the
Personal Data subject to the request. We may need to request additional
Personal Data from you, such as your name and email address, in order to
verify your identity and protect against fraudulent requests. If you maintain
a password-protected account with us, we may verify your identity through our
existing authentication practices for your account and require you to
re-authenticate yourself before disclosing or deleting your Personal Data. If
you make a request to delete, we may ask you to confirm your request before
we delete your Personal Data.
To request to opt out of any future sharing of your Personal Data for
purposes of targeted advertising, please go to https://www.adp.com and click
the Cookie Preferences – Do Not Share My Data link at the bottom of the page
and toggle off advertising cookies.
Authorized Agents Submitting a Request on Behalf of a Consumer
You may choose to designate an authorized agent to make a request under the
CCPA on your behalf. No information will be disclosed until the authorized
agent’s authority has been reviewed and verified. Agents may be asked to
provide proof of their status as an authorized agent. Once a request has been
submitted by an authorized agent, we may require additional information from
you to verify your identity as described in the section entitled “How to
Submit a California Rights Request” or confirm that you provided the agent
permission to submit the request. Authorized agents click here to submit a
request.
Changes to this California Consumer Privacy Statement
We may change or update this Privacy Statement from time to time. When we do,
we will communicate updates to this Privacy Statement by posting the updated
Statement on this page with a new “Last Updated” date. For a printable copy
of this Privacy Statement, please go to
www.adp.com/-/media/adp/privacy/pdf/ccpaps_en.pdf.
Contact Us
If you have any questions regarding this California Consumer Privacy
Statement, please contact us at privacy@adp.com. You may also reach us at:
ADP
ADP Global Data Privacy and Governance Team
MS 325
One ADP Boulevard
Roseland, NJ 07068-1728 USA
* Colorado, Connecticut, Utah & Virginia Consumer Privacy Statement
Effective Date: January 1, 2023
LAST UPDATED: February 23, 2023
ADP, Inc. and its affiliates (“ADP,” “we,” or “us”) are providing the
following Privacy Statement to explain how ADP collects, uses and discloses
Personal Data that we collect from consumers (“you”) who are residents of
Colorado, Connecticut, Utah, and Virginia, including but not limited to users
who visit our websites and consumers who receive services directly from ADP.
Personal Data is information that identifies, relates to, or could reasonably
be linked with a particular individual. Please note that this Privacy
Statement does not apply to individuals residing in Colorado, Connecticut,
Utah, and Virginia who are acting in an employment or commercial context,
including employees of ADP clients.
ADP also has a Global Data Privacy Policy that applies to all ADP companies
worldwide. An overview of our Privacy Program is located at
https://www.adp.com/about-adp/data-privacy.aspx.
Collection and Disclosure of Personal Data
The following details which categories of Personal Data we collect and
process, as well as which categories of third parties may have access to your
data for operational business purposes.
(a) Categories of Personal Data
1. Identifiers
Such as name, contact information, unique personal identifiers, email
address, IP address, online identifiers, government-issued identifiers.
2. Personal Data
Such as name, contact information, financial, education, employment
information.
3. Characteristics of Protected Classifications
Such as race, religious creed, color, national origin, ancestry,
physical disability, mental disability, medical condition, marital
status, sex, gender expression, gender identify, age, sexual
orientation, military and veteran status.
4. Commercial Information
Such as transaction information and purchase history, including
purchases considered, consuming histories or tendencies.
5. Biometric Information
Not Applicable.
6. Internet or Network Activity Information
Such as IP address, mobile device ids, MAC address, browsing history,
search history.
7. Geolocation Data
Such as precise location/tracking data and coarse location/tracking
data.
8. Audio/Video Data
Such as photographs.
9. Education Information
Such as education and training history, education degrees,
qualifications/certifications.
10. Employment Information
Such as professional or employment related information such as work
history and prior employer, background checks, performance rating or
feedback, employer, occupation title/job role.
11. Inferences
Such as any assumptions drawn from any of the Personal Data listed above
to create a profile about, for example, an individual’s preferences or
characteristics. This is only applicable to consumers that purchase our
TMBC product due to the nature of the product.
12. Sensitive Personal Data
Such as racial or ethnic origin, religious beliefs, mental or physical
health diagnoses, condition, history or treatment, sexual orientation
and sex life, citizenship or immigration status, genetic data, biometric
data, precise geolocation data, Personal Data collected from a known
child.
(b) Disclosure of Personal Data to Third Parties
ADP may disclose all of the above categories of Personal Data to the
following categories of Third Parties:
1. Service Providers/Subcontractors
ADP may share your Personal Data with our subcontractors for certain
business purposes. This information is provided in order for them to
provide ADP with services such as payment processing, advertising
services, marketing partners, web analytics, data processing, IT
services, customer support and other services such as for the purpose of
auditing and fraud investigations.
2. Related Entities
ADP may share Personal Data between and among ADP, its subsidiaries, and
affiliated companies for purposes of management and analysis, and other
business purposes. For instances, ADP may share your Personal Data with
our subsidiaries and affiliated companies to expand and promote our
product and service offerings.
3. When Required by Law
ADP may be required to disclose your Personal Data to third parties
including law enforcement agencies when required to protect and defend
our legal rights, protect the safety and security of users of our
Services, prevent fraud, respond to legal process, or a request for
cooperation by a government entity, as required by law.
4. Corporate Transactions
In the event of sale, transfer, merger, reorganization, or similar event,
ADP may transfer your Personal Data to one or more third parties as part
of that transaction with the business entities or people involved in the
deal negotiation or transfer.
5. With Your Consent
ADP may share Personal Data about you with other third-party companies if
you give us permission or direct us to share the information. ADP will
share Personal Data with authorized agents that you authorize ADP to
communicate to.
We do not sell Personal Data.
Purposes for the Collection, Use and Sharing of Personal Data
ADP uses your Personal Data for the following business purposes and
objectives:
(a) Business purposes for processing Personal Data pertaining to consumers.
Personal Data pertaining to consumers with whom ADP has a business
relationship may be processed as needed:]]
1. To provide the information, product, or service requested by the
individual, and as would be reasonably expected by the individual given
the context in which the Personal Data was collected, and the information
provided in the applicable privacy statement given to the individual
(such as for personalization, remembering preferences, or respecting
individual rights);
2. For due diligence, including verifying the identity of the individual, as
well as the eligibility of the individual to receive information,
products, or services (such as verifying age, employment, or account
status);
3. To send transactional communications (such as requests for information,
responses to requests for information, orders, confirmations, training
materials, and service updates);
4. To manage the individual's account, such as for customer service,
finance, and dispute resolution purposes;
5. For risk management and mitigation, including for audit and insurance
functions, and as needed to license and protect intellectual property and
other assets;
6. For security management, including monitoring individuals with access to
the website; applications, systems, or facilities, investigation of
threats, and as needed for any data security breach notification; and
7. To anonymize or de-identify the Personal Data. Where we maintain or use
de-identified information, we will continue to maintain and use such
information only in a de-identified fashion and will not attempt to
re-identify such information.
(b) Business-necessary processing activities. ADP may process Personal Data
as needed (i) to protect the privacy and security of the Personal Data it
maintains, such as in connection with advanced security initiatives and
threat detection; (ii) for treasury operations and money movement activities;
(iii) for compliance functions, including screening individuals against
sanction lists in connection with anti-money laundering programs; (iv) for
business structuring activities, including mergers, acquisitions, and
divestitures; and (v) for business activities, management reporting, and
analysis.
(c) Development and improvement of products and/or services. ADP may process
Personal Data to develop and improve its products and/or services, and for
research, development, analytics, and business intelligence.
(d) Relationship management and marketing. ADP may process Personal Data for
relationship management and marketing. This purpose includes sending
marketing and promotional communications to individuals who have not objected
to receiving such messages, such as product and service marketing
communications, investor communications, Client communications (e.g., HR
compliance alerts, product updates, and training opportunities and
invitations to ADP events), customer satisfaction surveys, supplier
communications (e.g., requests for proposals), corporate communications, and
ADP news.
(e) Operational purposes. Additionally, ADP uses your Personal Data for
purposes such as: (i) disaster recovery and business continuity; (ii)
internal audits or investigations; (iii) implementation or verification of
business controls; (iv) statistical, historical, or scientific research; (v)
dispute resolution; (vi) legal or business counseling; (vii) compliance with
laws and company policies; and/or (viii) insurance purposes.
Consumer Rights
Subject to applicable law, you may make the following requests:
(a) Right to Know -- You may request to know whether we process your
Personal Data and request to access such Personal Data, including, where
applicable, a request to obtain a copy of the Personal Data you provided to
us in a portable format; (b) Right to Request Correction of your Personal
Data -- You may request to correct inaccuracies in your Personal Data; (c)
Right to Request Deletion of your Personal Data -- You may request to have
your Personal Data deleted; and (d) Right to Opt-out of Targeted Advertising
-- You may request to opt out of targeted advertising.
We will not unlawfully discriminate against you for exercising your rights
under applicable privacy law.
How to Submit a Rights Request
To make a privacy request, please contact us by emailing us at
privacy@adp.com or by mailing us at: ADP, ADP Global Data Privacy and
Governance Team MS 325, One ADP Boulevard, Roseland, NJ 07068-1728 USA. We
will verify and respond to your request consistent with applicable law,
taking into account the type and sensitivity of the Personal Data subject to
the request. We may need to request additional Personal Data from you, such
as your name and email address, in order to verify your identity and protect
against fraudulent requests. If you maintain a password-protected account
with us, we may verify your identity through our existing authentication
practices for your account and require you to re-authenticate yourself before
disclosing or deleting your Personal Data. If you make a request to delete,
we may ask you to confirm your request before we delete your Personal Data.
To request to opt out of any future sharing of your Personal Data for
purposes of targeted advertising, please go to https://www.adp.com and click
the Cookie Preferences – Do Not Share My Data link at the bottom of the page
and toggle off advertising cookies.
Appeal Process
If you are a Colorado, Virginia, or Connecticut consumer, and we refuse to
take action on your request, you may appeal our refusal within a reasonable
period after you have received notice of the refusal. You may file an appeal
by contacting us via email at privacy@adp.com.
Changes to this Consumer Privacy Statement
We may change or update this Privacy Statement from time to time. When we do,
we will communicate updates to this Privacy Statement by posting the updated
Statement on this page with a new “Last Updated” date. For a printable copy
of this Privacy Statement, please go to
www.adp.com/-/media/adp/privacy/pdf/ccvucps_en.pdf.
Contact Us
If you have any questions regarding this Consumer Privacy Statement, please
contact us at privacy@adp.com. You may also reach us at:
ADP
ADP Global Data Privacy and Governance Team
MS 325
One ADP Boulevard
Roseland, NJ 07068-1728 USA
* Nevada Privacy Rights
ADP collects personal information from you in the course of providing
requested services. Unless otherwise stated, ADP does not sell any Covered
Information, as defined under Nevada law (S.B. 220). If you would like to
make a further inquiry regarding the selling of your Covered Information, as
defined under Nevada law, please contact privacy@adp.com.
* ADP Privacy Program Details and How to Contact Us
Privacy Program Brochures:
Complying with Privacy Laws Across the Globe
How ADP Helps Companies Comply with GDPR
Glossary: www.adp.com/-/media/adp/privacy/pdf/glossary_en.pdf
Contact the Privacy Team at privacy@adp.com.
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