Effective September 15, 2020
TRC Global Mobility (“TRC”, “we”, “us” or “our” in this document) recognizes the importance of protecting the privacy of our users and visitors to our site(s). We exercise due care in gathering and sharing information via our public website, www.trcglobalmobility.com, and any private portals used by our clients, their relocating employees or other authorized users. We gather information to provide contracted employee relocation and assignment management services to our clients and their relocating employees.
The following information outlines our compliance mechanisms and practices and outlines actions available to you as a user.
Note on Privacy Shield
The EU-U.S. Privacy Shield Framework was designed by the U.S. Department of Commerce and European Commission to provide companies on both sides of the Atlantic with a mechanism to comply with EU data protection requirements when transferring personal data from the European Union to the United States in support of transatlantic commerce.
More than 5,000 companies, including those in the workforce mobility industry, use the system, as it is integral to protecting the data of transferees. TRC is a Privacy Shield certified company, and we have abided by Privacy Shield principles since 2016.
In July 2020, Europe’s top court struck down the EU-U.S. Privacy Shield, and currently, there is no official replacement program. TRC will continue to follow developments and recommendations from Worldwide ERC®, the European Relocation Association (EuRA), the U.S. Department of Commerce, which administers Privacy Shield, and other experts. TRC will continue to safeguard the personal data of our clients and their relocating employees and to comply with the existing Privacy Shield framework until we have clearer direction on the path forward.
We also comply with the EU Data Privacy Directive on the use of employee and company data for direct marketing, as opposed to transactional purposes, without permission. It is TRC policy to only require information that is absolutely necessary to meet our contracted obligations for our clients and their employees. Confidential information is available only to those TRC employees who require it to provide services or to comply with legal requirements. All TRC employees sign confidentiality agreements before joining the company and are trained in the appropriate management of sensitive data.
EU-U.S. and Swiss-U.S. Privacy Shield
TRC is responsible for data is processes under the Privacy Shield Framework and subsequently transfers to a third party acting as an agent on our behalf. We comply with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, TRC is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, TRC may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have concerns regarding data privacy, you may file a written complaint with TRC and we must respond to you within 45 days. You are entitled to have any concerns or complaints that TRC has not resolved to your satisfaction be reviewed by an independent professional third party administrator, the American Arbitration Association/International Centre for Dispute Resolution: http://go.adr.org/privacyshield.html. There is no cost to you. Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov/article ?id=How-to-Submit-a-Complaint, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
Information TRC Collects on our Public Site
Users can visit our public website, www.trcglobalmobility.com, without providing any personal information. Data captured is limited to the following:
- Data that is provided by users who have logged on to our website and completed forms and information requests. Usage data is collected on known users for client-specific targeted content.
- IP addresses, and non-personal information related to that IP address, such as the referring web site, date and time of visit, and the browser type and version used for those individuals browsing the public site. This information is in no way linked to any personal information. It is kept completely anonymous, and used for site administration only. This includes, but is not limited to, evaluation of our own advertising methods, writing browser-specific code, etc.
TRC does not share information collected with any third party beyond the scope of employee relocation services. TRC does not sell, trade, or provide collected information to third parties for marketing purposes.
In delivering relocation services, we work with affiliated partners, such as household goods companies, temporary housing providers, real estate agencies, destination service providers, and other related service providers. We may share your information with third parties who provide services on our behalf. These companies are authorized to use your personal information only as necessary to provide the authorized services.
Private Website Only
Use of TRC’s private website is optional. To enable us to deliver relocation services, we receive personal information from your employer or from you on a voluntary basis. Personal information includes names, addresses, telephone numbers, email addresses and benefit eligibility instructions. Additional information may come from suppliers who assist us in providing services to you and your dependents. This information is used only for the limited purposes for which it is provided.
We may retain your information for as long as your account is active or as needed to deliver service, comply with applicable laws and regulations, resolve disputes and meet our contractual agreements to clients.
We enter into agreements with suppliers to provide services to us or to make products and services available directly to you. These agreements allow them to receive information about you, but only as long as these suppliers are able to maintain applicable compliance. Additionally, these agreements state that they must safeguard this information and use it only to the extent needed to provide those services specifically authorized by your employer and for no other purposes.
TRC has implemented administrative and technical safeguards to protect your data and personal identity. This is accomplished through:
- The assignment of usernames and passwords to those individuals seeking information pertinent to their relocation process.
- Encryption technology used to create a secure session between your web browser and our web site, so that no information can be intercepted by a third party.
- TRC’s practice of not storing Social Security numbers on our Web site.
- Limiting access to information to only those employees who need it to service the client or relocating employee.
- Requiring supplier partners to safeguard relocating employee information and use it only to the extent needed to provide services authorized by our client.
Links to Third Party Sites
Disclosure to Public Authorities
If required, TRC will disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements or to comply with a subpoena or other legal process.
TRC's acknowledges that under GDPR, we must have a lawful basis to store and process your data and to communicate with you. Within our information systems, we have established numerous checkpoints to ensure we have this consent.
User Options and Opt Out (The Right to be Forgotten)
Upon request TRC will advise you of whether we hold any of your personal information. You can ask us to amend, correct or delete any of this information, or if you are using a TRC private website, you can make these changes yourself. Be advised that if you are currently engaged in transactions with TRC, this personal information is needed to continue to provide services. You may also opt out of regular TRC newsletters or communications by contacting your Relocation Counselor or Account Manager or Carrie Morales at firstname.lastname@example.org. You may unsubscribe to our blog or other opt-in informational communications at any time.
Limitation of Liability
Under no circumstances shall TRC be held liable for any special, incidental or consequential damages, which may result from the use of information or materials made available on TRC’s web sites.
Questions or Concerns
Director of Information Technology/Data Protection Officer
TRC Global Mobility World Headquarters
1042 E. Juneau Ave.
Milwaukee, WI USA 53202