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Anti-Corruption, Anti-Bribery, Compliance Provisions
PRIVACY PROVISIONS
9. PERSONAL DATA
Premier staff, consultants, contactors and/or agents, as well as Suppliers collect, use, transfer and process personal information to facilitate the provision of our service offering, including but not limited to client services, billing and marketing (“Personal Data”). Personal Data may also include contact details (i.e. name, work address, telephone number and email address), work history (i.e. work function, education, training and details of former/current employment), identification information (i.e. passport details, visa and immigration status, date and place of birth) and billing information (i.e. account numbers and tax information). For further information, please review our Data Protection Policy.
10. USAGE
Premier staff, consultants, contactors and/or agents, as well as Suppliers collect Personal Data through direct contact with clients, potential clients, their affiliates and affiliated individuals, and others within Premier’s supply chain through various means, including but not limited to, publicly available information on websites or from subscription services. This processing is regulated by data protection laws, rules and regulations where Premier operates and from May 2018 the European Union’s General Data Protection Regulation (“GDPR”).
During the course of Premier’s business relationship with staff, consultants, contactors and/or agents, as well as Suppliers, Personal Data may be transferred to other offices within Premier affiliates or by Suppliers to facilitate and centralize the operation of services. Premier expects staff, consultants, contactors and/or agents, as well as Suppliers to handle Personal Data diligently and according to all applicable Laws, including GDPR.
11. CONSENT
Premier staff, consultants, contactors and/or agents, as well as Suppliers agree not to use or disclose without consent, Personal Data for any purpose other than the purpose for which Premier provide services. It also agreed Suppliers would store all Personal Data, in a secure environment and to make all reasonable efforts to maintain the security of Personal Data and other confidential information. Please take note Premier may request from time to time, information regarding such care in order to comply with Premier’s legal obligations. For further information in relation to consent, including but not limited to, how Premier requests consent please see Primer’s Data Protection Policy.
12. INTEGRITY
Premier staff, consultants, contactors and/or agents, as well as Suppliers will always handle Personal Data with absolute confidentiality, and will not alienate, disclose or appropriate Personal Data obtained in the course of our service offering, nor share with a third party unless otherwise authorized by Premier and in accordance to the Laws, including GDPR. Consistent with Premier legal obligations, Premier staff, consultants, contactors and/or agents, as well as Suppliers are expected to exercise the utmost discretion regarding the Personal Data Premier’s clients and others entrust to them. Personal Data is only collected and processed to the extent necessary for the purposes described above. Suppliers will update, correct and erase Personal Data on a regular basis. Suppliers must store and process Personal Data only for the term of their business relationship with Premier and for a period thereafter reasonably determined by business necessity and/or professional obligations, or as may be required by Laws.
13. SECURITY & PROTECTION
Premier staff, consultants, contactors and/or agents, as well as Suppliers will take all commercially reasonable steps consistent with industry practice and all laws, including GDPR, to protect Personal Data by using established security standards and procedures. Please be assured that Premier adopted various procedural and technical safeguards to protect Personal Data within Premier’s global network, therefore Suppliers are expected to follow strict safeguards as well. To prevent the loss, misuse, unauthorized access, disclosure, alteration and destruction of Personal Data, all of such Personal Data in possession of Suppliers will be stored on a secure server. In addition, Personal Data provided through online forms and/or other electronic means, will be protected with absolute confidentiality by Suppliers.
RESPONSIBILITIES & IMPLEMENTATION OF PREMIER POLICIES
14. MONITORING & REVIEW
Premier must comply with the Laws in all of the countries where it operates and has offices. The exact nature of the Laws varies from country, however in order to make sure all of Premier activities (and those from others) are covered by these Policies, Premier will monitor and review them annually to measure its progress and judge its effectiveness. Premier staff, consultants, contactors and/or agents, as well as Suppliers should make sure to constantly review their compliance to these Policies.
15. ENFORCEMENT
Premier staff, consultants, contractors and/or agents, as well as Suppliers who depart from these Policies are subject to strict measures, which may include termination of their agreement. Questions or concerns about the protection these Policies should be directed to the Supplier’s Premier contact. Premier and Suppliers will work in good faith to resolve any concerns related to these Policies. In addition, Premier and Suppliers will cooperate with the relevant data protection and privacy authorities in any jurisdiction in which Premier and Suppliers maintain an office and/or have operations.
These Policies were issued in order to help Premier staff, consultants, contactors and/or agents, as well as Suppliers avoid risk areas, and enable them to recognize situations where they should consult Premier regarding Anti-Bribery, Anti-Corruption, Compliance and Privacy (including Data Protection) concerns. Premier will provide assistance to determine whether the behavior or project is within Premier’s guidelines and lawful and help to identify ways to achieve the same results without the risk of breaching any of applicable Laws. Premier reserves the right to change these Policies at any time without advance notice. If the changes are significant or substantive, Premier will advise them to Premier staff, consultants, contactors and/or agents, as well as Suppliers. Therefore, it is accepted all them must:
- Read, understand and comply with these Policies.
- Avoid any activity that might lead to or suggest a breach of these Policies.
- Notify Premier as soon as possible if believe a breach of these Policies has occurred.
- These Policies supersede all previous notices with respect to matters described herein.
Premier appreciates confirmation by Premier staff, consultants, contactors and/or agents, as well as Suppliers of the acceptance of these Policies, a copy of which will be part of any existing file for all Suppliers.
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