NCI PRIVACY NOTICE (EU)
NCI and its affiliates (collectively referred to as "NCI", "we", "us") takes its data protection and privacy responsibilities seriously. This privacy notice explains how we collect, use and share your personal data as a result of your use of our web sites, including:
- What personal data we collect and when and why we use it
- How we share personal data within NCI and with our service providers, regulators and other third parties
- Transferring personal data globally
- How we protect and store personal data
- Legal rights available to help manage your privacy
- How you can contact us for more support
We may amend this notice from time to time to keep it up to date with legal requirements and the way we operate our business. Please regularly check these pages for the latest version of this notice. If we make significant changes to this privacy notice, we will seek to inform you by notice on our website or email ("Notice of Change").
You might find external links to third-party websites on our website. This privacy notice only applies to personal data collected on this website and does not apply to your use of a third-party site. We have no influence or control over linked third-party websites and your use of other sites is at your own risk and is subject to their privacy statements and policies.
WHAT PERSONAL DATA WE COLLECT AND WHEN AND WHY WE USE IT
In this section, you can find out more about:
- the types of personal data we collect
- when we collect personal data
- how we use personal data
- the legal basis for using personal data
When we collect information
We collect information about you if you register with or use one of our website(s).
We will collect your personal data via the following methods:
- By recording details you provide to us - e.g. blog subscription updates, in responding to a job posting, your communications with us through emails or calls, and/or
- By observing your use of our products and services and our website
IP address and technical details
IP address of the computer/personal device that you use to access our website(s), approximate location information from where you access our website(s) and information about your device and browser
The legal basis for using your personal data
We will only collect, use and share your personal data where we are satisfied that we have an appropriate legal basis to do this. This may be because:
- you have provided your consent to us using the personal data for example by signing up to receive communications from us;
- our use of your personal data is in our legitimate interest as a commercial organization (for example our legitimate interests in communicating with you - in these cases we will look after your information at all times in a way that is proportionate and respects your privacy rights and you have a right to object to processing as explained in the LEGAL RIGHTS AVAILABLE TO HELP MANAGE YOUR PRIVACY section below;
- our use of your personal data is necessary to perform a contract or take steps to enter into a contract with you for example where you apply for a job with us or where you are one of our suppliers; and/or
- our use of your personal data is necessary to comply with a relevant legal or regulatory obligation that we have for example fulfilment of a court order.
If you would like to find out more about the legal basis for which we process personal data, please contact us at contactNCI@nciinc.com
To communicate with you regarding our products and services; to communicate with you in the context of a contractual agreement which we have with you.
- Consent, our legitimate interests, or necessity for performance of a contract
- Employment status, employment history, education history CV, information about security clearance, where necessary, your current salary, and other personal information submitted by job applicants
- To process job applications which we receive from you
- Our legitimate interests, or necessity for performance of the contract
- IP address of the computer/personal device that you use to access our website(s), and information about your device and browser
- To ensure network and information security; to monitor the performance of our website and improve your user experience
- Consent or our legitimate interests
SHARING YOUR PERSONAL DATA
In this section, you can find out more about how we share personal data:
- within NCI
- with third parties that help us provide our products and services; and
- with regulators
We share your information in the manner and for the purposes described below:
- within NCI, where such disclosure is necessary to provide you with our services or to manage our business;
- with third parties who help manage our business and deliver services. These third parties have agreed to confidentiality restrictions and use any personal data we share with them or which they collect on our behalf solely for the purpose of providing the contracted service to us. These include IT service providers who help manage our IT and back office systems;
- with our regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies;
- we may share in aggregate, statistical form, non-personal data regarding the visitors to our website, traffic patterns, and website usage with our partners, affiliates or advertisers; and/or
If, in the future, we sell or transfer some or all of our business or assets to a third party, we may disclose information to a potential or actual third-party purchaser of our business or assets.
TRANSFERRING PERSONAL DATA GLOBALLY
In this section, you can find out more about:
- how we operate as a global business and transfer data internationally.
- the arrangements we have in place to protect your personal data if we transfer it overseas.
NCI operates on a global basis. Accordingly, your personal data may be transferred and stored in countries outside the EU (including Australia, the United States, New Zealand, Singapore and Hong Kong) that are subject to different standards of data protection. NCI will take appropriate steps ensure that transfers of personal data are in accordance with applicable law and carefully managed to protect your privacy rights and interests and transfers are limited to countries which are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangement are in place to protect your privacy rights. To this end:
- we ensure transfers within NCI will be covered by an agreement entered into by members of NCI (an intra-group agreement) which contractually obliges each member to ensure that personal data receives an adequate and consistent level of protection wherever it is transferred within NCI;
- where we transfer your personal data outside NCI or to third parties who help provide our products and services, we obtain contractual commitments from them to protect your personal data. Some of these assurances are well recognized certification schemes like the EU - US Privacy Shield for the protection of personal data transferred from within the EU to the United States; or
- where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any personal data are disclosed.
You have a right to contact us at contactNCI@nciinc.com for more information about the safeguards we have put in place (including a copy of relevant contractual commitments) to ensure the adequate protection of your personal data when this is transferred as mentioned above.
HOW WE PROTECT AND STORE YOUR INFORMATION
We have implemented and maintain appropriate technical and organizational security measures, policies and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such information appropriate to the nature of the information concerned. As the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect User IDs and passwords please take appropriate measures to protect this information.
Storing your personal data
We will store your personal data for as long as is reasonably necessary for the purposes for which it was collected, as explained in this notice. In some circumstances we may store your personal data for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, accounting requirements.
In specific circumstances, we may store your personal data for longer periods so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal data or dealings.
LEGAL RIGHTS AVAILABLE TO HELP MANAGE YOUR PRIVACY
Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to your personal data. Click on the links below to learn more about each right you may have:
- To access personal data
- To rectify / erase personal data
- To restrict the processing of your personal data
- To transfer your personal data
- To object to the processing of personal data
- To object to how we use your personal data for direct marketing purposes
- To obtain a copy of personal data safeguards used for transfers outside your jurisdiction
- To lodge a complaint with your local supervisory authority
We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal data requested to you. In some instances, we may not be able to fully address your request; for example, if your request for access to Personal Data affects NCI’s duty of confidentiality owed to others or if your request is to erase Personal Data that is still required to fulfil a contractual obligation. In other instances, we may be legally entitled to deal with your request in a different manner. Furthermore, we reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
You can exercise your rights by contacting us at contactNCI@nciinc.com. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfil your request.
We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
Right to access personal data
You have a right to request that we provide you with a copy of your personal data that we hold and you have the right to be informed of; (a) the source of your personal data; (b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entities to whom your personal data may be transferred.
Right to rectify or erase personal data
You have a right to request that we rectify inaccurate personal data. We may seek to verify the accuracy of the personal data before rectifying it.
You can also request that we erase your personal data in limited circumstances where:
- it is no longer needed for the purposes for which it was collected; or
- you have withdrawn your consent (where the data processing was based on consent), and where there is no other legal ground for the processing; or
- following a successful right to object (see right to object); or
- it has been processed unlawfully; or
- to comply with a legal obligation to which NCI is subject.
We are not required to comply with your request to erase personal data if the processing of your personal data is necessary:
- for compliance with a legal obligation; or
- for the establishment, exercise or defense of legal claims.
Right to restrict the processing of your personal data
You can ask us to restrict your personal data, but only where:
- its accuracy is contested, to allow us to verify its accuracy; or
- the processing is unlawful, but you do not want it erased; or
- it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or
- you have exercised the right to object, and verification of overriding grounds is pending.
We can continue to use your personal data following a request for restriction, where:
- we have your consent; or
- to establish, exercise or defend legal claims; or
- to protect the rights of another natural or legal person.
Right to transfer your personal data
You can ask us to provide your personal data to you in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller, but in each case only where:
- the processing is based on your consent or on the performance of a contract with you; and
- the processing is carried out by automated means.
- Right to object to the processing of your personal data
You can object to any processing of your personal data which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests.
If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
Right to object to how we use your personal data for direct marketing purposes
You can request that we change the manner in which we contact you for marketing purposes.
You can request that we do not transfer your personal data to unaffiliated third parties for the purposes of direct marketing or any other purposes.
Right to obtain a copy of personal data safeguards used for transfers outside your jurisdiction
You can ask to obtain a copy of, or reference to, the safeguards under which your personal data is transferred outside of the European Union.
We may redact data transfer agreements to protect commercial terms.
Right to lodge a complaint with your local supervisory authority
You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your personal data.
We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.
If you believe any work on our site constitutes GDPR infringement, please contact us at:
Attention: Legal Department
11730 Plaza America Drive
Reston, VA 20190
To contact your data protection supervisory authority
You have a right to lodge a complaint with your local data protection supervisory authority (i.e. your place of habitual residence, place or work or place of alleged infringement) at any time. We ask that you please attempt to resolve any issues with us before your local supervisory authority.
We may update our policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy.