LAST UPDATED: March 13, 2012
Avis Budget Group respects and protects personal information of its Employees collected and maintained by or on its behalf. In support of that commitment, Avis Budget Group, Inc., including wholly-owned subsidiaries that are incorporated in the state or territory of the United States (“ABG”) has certified to and complies with the US-EU and US-Swiss Safe Harbor Frameworks regarding personal information collected from the European Economic Area (EEA) and Switzerland for human resources activities. ABG has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access and enforcement and the “Frequently Asked Questions” document. To learn more about the Safe Harbor program, and to view ABG's certification, please visit http://www.export.gov/safeharbor/.
This Safe Harbor Statement sets forth the principles under which ABG manages the processing of Personal Information that it receives from its affiliates and subsidiaries in the EEA and Switzerland in support of our human resources operations. The categories of personal information covered by this Privacy Statement include Personal Information of Employees. In connection with ABG's human resources operations, ABG may now and/or in the future transfer or provide access to Personal Information regarding citizens of the EEA and Switzerland outside of the EEA and to the United States.
The following terms are used through this Statement and are defined as follows:
“Agent” means any third party that processes Personal Information under the instructions of, and solely for, ABG or to which ABG discloses Personal Information for use on ABG’s behalf.
“ABG” means ABG, including its wholly -owned subsidiaries that are incorporated in any state or territory of the United States.
“Personal Information” means any information or set of information whether in electronic or tangible, hard copy form, which identifies or can reasonably be used by or on behalf of ABG to identify an employee. Personal Information does not include encoded or anonymized information, publicly available information that has been combined with non-public personal information or information that is reported in aggregate.
“Sensitive Personal Information” means Personal Information that reveals race, ethnic origin, political opinion, religious or philosophical beliefs, trade union membership, any information that concerns health or sex life, or information relating to the commission of a criminal offense.
“Employees” means current and former individuals employed by ABG located in a country of the EEA or Switzerland.
Notice: Where ABG collects Personal Information about Employees in the EEA or Switzerland, we will notify them about the types of Personal Information we collect about them, the purposes for which we collect such information, the types of third parties to which we disclose such information, and how to contact ABG with any inquiries or complaints. Notice will be provided in clear and conspicuous language when ABG first collects Employee Personal Information, or as soon as practicable thereafter, and before ABG uses or discloses the information for a purpose other than that for which it was originally collected.
Consistent with Safe Harbor requirements, ABG may not be in a position to provide notice in certain limited situations. Notice is not required when the processing of EU or Swiss Personal Information is necessary to respond to a government inquiry; is required by applicable laws, court orders or government regulations; or is necessary to protect ABG’s legal interests and providing notice would interfere with those interests.
Choice: Where ABG collects Personal Information directly from Employees in the EEA or Switzerland, we will offer, where practical and appropriate, the opportunity to choose (opt-out) whether their Personal Information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized or transferred. For Sensitive Personal Information, ABG will obtain the explicit consent (opt-in) of Employees prior to the disclosure of that information to a non-agent third party or to the use of that information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the Employee.
Onward Transfers: ABG will only transfer Personal Information to an Agent when (i) ABG has obtained assurances from the Agent that they will safeguard Personal Information consistently with this Policy; (ii) the Agent is located in the EU or a country deemed “adequate” for privacy by the EU Commission, and therefore required to comply with the EU data protection laws or equivalent privacy laws; or (iii) the Agent has also certified to the Safe Harbor. Where ABG has knowledge that an Agent is using or sharing Personal Information in a way that is contrary to this Policy, ABG will take reasonable steps to prevent or stop such processing. ABG will only transfer Personal Information to a non-agent third party where Employees have been provided notice and have given their consent.
Security: ABG takes reasonable and appropriate administrative, technical and physical precautions to protect the confidentiality, integrity and availability of Personal Information, whether in electronic or tangible, hard copy form.
Access: ABG provides Employees reasonable access, upon written request, to their Personal Information that ABG holds about them, and Employees may request corrections, deletions, or additions, as appropriate, except where the burden or expense of providing access would be disproportionate to the risks to an Employee’s privacy or where the rights of persons other than the Employee would be violated.
Data Integrity: ABG limits the collection, usage, and retention of Personal Information to that which is germane for the intended purposes for which it was collected, and takes reasonable steps to ensure that all Personal Information is reliable, accurate, complete and current. ABG depends upon its Employees to help it keep Personal Information reliable, accurate, complete and current.
Enforcement: ABG has established internal mechanisms to verify its ongoing adherence to this Policy. ABG also encourages Employees covered by this Policy to raise any concerns about the processing of their Personal Information by contacting ABG’s Privacy Office at the address below. ABG will seek to resolve any concerns. Any Employee that violates these privacy principles will be subject to disciplinary procedures in accordance with ABG’s Code of Conduct and Business Principles.
Dispute Resolution: For complaints that cannot be resolved between ABG and the complainant, ABG has agreed to cooperate with the European Data Protection Authorities for the purposes of handling any unresolved complaints regarding Personal Information collected in support of ABG’s for Human Resources operations. If you have any questions or concerns or feel that ABG is not abiding by its policy or is not in compliance wit the Safe Harbor principles, please write to ABG at the address listed below.
Limitation on Scope of Principles
ABG adheres to these privacy principles except, as required or allowed by law, to meet legal, governmental, law enforcement or national security obligations, or to protect the health or safety of an Employee.
How to Contact Us
Please contact us with any questions concerning this Privacy Statement or any of our privacy practices at:
By writing to ABG at:
Attn: Privacy Office
Avis Budget Group, Inc.
6 Sylvan Way
Parsippany, NJ 07054 USA
Via e-mail: ABGPrivacy@avisbudget.com
Changes to this Privacy Statement
This privacy statement may be amended consistent with the requirements of Safe Harbor. Appropriate public notice will be given concerning such amendments, and the “Last Updated” date will be revised at the top of this Policy. Any material change to this privacy statement will also be posted on www.avisbudgetgroup.com.