European Safe Harbor Privacy Policy

European Safe Harbor Privacy Policy

Huron Consulting Group Inc. (“Huron”) strives to collect, use and disclose Personally Identifiable Information (defined below) in a manner consistent with the laws of the countries in which it does business and has a tradition of upholding the highest ethical standards in its business practices. Huron abides by the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. Huron has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Huron’s certification, please visit http://www.export.gov/safeharbor/

“Personally Identifiable Information” shall mean any information relating to an identified or identifiable natural person; an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity.

The following privacy principles apply solely to the extent that Huron collects Personally Identifiable Information directly from individuals.

Notice
Huron will inform individuals about the purposes for which it collects and uses Personally Identifiable Information about them, the types of non-agent third parties to which Huron discloses that information, and the choices and means, if any, Huron offers individuals for limiting the use and disclosure of their Personally Identifiable Information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personally Identifiable Information to Huron, or as soon as practicable thereafter, and in any event before Huron uses the information for a purpose other than that for which it was originally collected.

Choice
Huron will offer individuals the opportunity to choose (opt out of) whether their Personally Identifiable 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 by the individual. For sensitive Personally Identifiable Information, Huron will give individuals the opportunity to affirmatively and explicitly (opt in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

Huron will provide individuals with reasonable mechanisms to exercise their choices should requisite circumstances arise.

In order to request that Huron not use an individual’s non-public Personally Identifiable Information, such individual should contact Huron by sending Huron an e-mail message at kjones@huronconsultinggroup.com to request access to, correct or delete any Personally Identifiable Information that you have provided to us.

Individuals may also opt out of receiving marketing messages from Huron by notifying Huron at Huron@huronconsultinggroup.com.

Prior to making any alterations in its information, Huron will require that individuals confirm their identity.

Data Integrity
Huron will use Personally Identifiable Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Huron will take reasonable steps to ensure that Personally Identifiable Information is relevant to its intended use, accurate, complete, and current.

Onward Transfer
Huron will comply with the notice and choice principles as described above for all data which is disclosed or transferred to a third party.

Huron will obtain assurances from its agents that they will safeguard Personally Identifiable Information consistently with this Policy. Huron will require that its agents either: (i) subscribe to the EU Safe Harbor Principles, the EU Data Protection Directive or another adequacy finding; or (ii) enter into a written agreement with Huron requiring them to provide the same level of protection as Huron.

Security
Huron will take reasonable precautions to protect Personally Identifiable Information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction. Huron limits access to Personally Identifiable Information and data to those persons in the Huron organization, or agents of Huron, that have a specific business purpose for maintaining and processing such information and data. Individuals who have been granted access to Personally Identifiable Information are aware of their responsibilities to protect the security, confidentiality and integrity of that information.

Access
Upon request, Huron will grant individuals reasonable access to Personally Identifiable Information that it holds about them. In addition, Huron will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete. Huron agrees to process all reasonable requests for access within a reasonable time period, but reserves the right to deny access or limit access in cases where the burden or cost of providing access would be disproportionate to the risks to the individual’s privacy or in the case of a vexatious or fraudulent request. Any employee of Huron that desires to review or update their Personally Identifiable Information can do so by contacting their human resources representative.

Enforcement
Individuals who wish to file a complaint or who take issue with this Policy should direct such communication to Huron via e-mail at the address provided above. Huron will explain the process to be followed when filing a complaint. Filing a complaint in English will expedite the process. Huron will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personally Identifiable Information in accordance with the principles contained in this Policy. For complaints that cannot be resolved between Huron and the complainant, complaints will be submitted to the American Arbitration Association (“AAA”) for mediation and then if necessary, to binding arbitration for final resolution. Information about AAA services can be found at its website: www.adr.org.

Huron is also subject to the jurisdiction of the US Federal Trade Commission. The Federal Trade Commission may be contacted at the following address:

Federal Trade Commission
Attn: Consumer Response Center
600 Pennsylvania Avenue NW
Washington, DC 20580
Email: consumerline@ftc.gov
www.ftc.gov

Comments
If you have any questions, comments or concerns about our privacy practices, please contact us by e-mail at csecretary@huronconsultinggroup.com or telephone at 1-312-583-8700.

© 2008-2012 Huron Consulting Group Inc.
All rights reserved.
Effective as of January 1, 2008