|Sunday, September 21, 2014
International SOS is committed to protecting the privacy of our customers' personal data and we encourage you to read this privacy statement.
- Describes the personal data that we collect;;
- How we collect data and why;;
- How data will be used and who we can disclose or transfer data to and why;;
- How data can be corrected or deleted;;
- The measures that we take to protect data; and;
- The process and contact information that customers can use to raise enquiries, concerns and complaints.
1. Commitment to Personal Data Protection
International SOS is committed to safeguarding our customers' personal data by adherence to the following obligations:
- The International SOS Data Protection Policy, the Information Security Policy and the related policies;;
- The United States Government's Safe Harbor Framework;;
- The Binding Corporate Rules sanctioned by the European Community's data protection authorities;;
- The relevant local data protection laws and regulations; and ;
- The contractual commitments to our customers.;
The Data Protection Policy and the related policies, the United States Safe Harbor Principles can be accessed through the following link,
http://www.internationalsos.com/en/files/Policy_DataProtection.pdf. International SOS Binding Corporate Rules were approved by
the European Comission in 2010. For more information please contact us.
2. To Whom this Statement Applies
This statement applies to the services and products offered by the International SOS group and binds all our employees.
International SOS also expects our service providers to have introduced data protection principals and technical and organizational
measures that are substantially similar to the ones International SOS has adopted in respect of similar personal data.
This statement refers to personal data from our individual customers or the employees of our customers and their families
or the individual customers of our customers, such as a beneficiary under an insurance policy or a beneficiary under credit card
or other financial services and in this statement, we refer to this group of individuals as: "you".
3. What Information is Collected and How is it Collected?
International SOS collects personal data about you when you purchase, use or benefit from International SOS's services or products or
when this data is given to International SOS by third parties, such as companies employing you or your relatives, insurance companies,
private medical insurers, assistance companies, financial institutions, medical service providers, travel agencies and similar companies,
that are permitted to share this personal data.;
"Personal data" includes information that will allow someone to identify or contact you, including, for example, your full name, address,
telephone number (professional & home) or email address, gender, date of birth, nationality, family status (dependent),
industry sector information related to professional activity, status (expatriate or traveller) and destinations.
Personal data does not include aggregated data or data that, by itself, does not permit the identification of individual persons,
such as statistics on the number of expatriates and travellers that are eligible in a member company to receive assistance services
or the number of people visiting the International SOS website each month.
You provide certain personal data to International SOS when, for example, you: (a) call our assistance centers or clinics; visit our clinics;
visit our facilities at remote sites providing services under a medical services contract; seek a consultation with our medical professionals;
and travel with our medical escorts (b) contact us as part of a health assessment; (c) contact us to receive medical consultancy and
patient support services; (d) contact us to receive security consultancy and security services; (e) order services and products
from International SOS websites; (f) submit forms through our web sites; (g) access services through a downloadable electronic application
for mobile devices (""App""); (h) attend our medical and security training courses ; (i) seek assistance with your insurance claims;
or (j) make enquiries, requests or complaints.
Subject to your agreement to the applicable terms and conditions, you may access services through the App, including but not limited to
travel health and security information and other services which may be added by International SOS from time to time.
The App provides personal information including your or your organization's International SOS Membership Number, as well as the email address
of your mobile device. To enable location-specific services, the App also collects and divulges your location. The App also periodically
provides information concerning your usage of particular App features.
When you choose to pay for International SOS services or products by credit card directly from the International SOS website,
you will be required to provide International SOS with the name of your credit card issuer, credit card number, expiration date
and other security information. When you choose to pay for International SOS services or products by other means, we may ask you for
your credit card details, contact details and bank account details.
You also provide information to us when you choose to email data to us, or you participate in marketing and sales initiatives.
International SOS will only gather data that is relevant for the purposes for which it will be used and will not gather excessive or
International SOS shall take reasonable steps to ensure that data is reliable, accurate, complete, and current, bearing in mind its intended use.
You have a responsibility to keep the data you provide to us updated and we will take reasonable steps to facilitate this.
4. Acceptance and Links to other Websites
This International SOS website may contain links to other websites, which are provided solely as a convenience to you and
not as an endorsement by International SOS of the contents of other web sites. The other web sites may have their own policies,
which International SOS does not control, and thus are not addressed or controlled by this statement or the International SOS Data Protection Policy.
a user session, but usage of a cookie is in no way linked to any personally identifiable information while on the International SOS website.
International SOS also uses ‘analytical cookies’. These allow us to recognize and count the number of visitors logging into our web site and
to see how visitors move around the site when they are using it. This helps us make sure sites are meeting users’ needs and to find out
how we could improve. The analytical cookies do not capture any personally identifiable information. Most browsers are initially set up to accept
cookies. Though most cookies expire after a certain period of time, you can choose to delete a cookie file at any time. You can do so
by resetting your browser to refuse all cookies or to indicate when a cookie is sent. However, some International SOS features or services
may not function properly without cookies. Some of our service providers (e.g. International SOS's service providers monitoring
6. How the Personal Data will be used
International SOS will use your personal data to provide you with services and products that: (a) you purchase; (b) are purchased by your employer
or your relative's employer; (c) are purchased by an association or institution (including an educational establishment) of which you are a member;
(d) are part of services provided through an insurance program or as part of financial services that are provided to you.
Many of these services and products are designed to provide tools for risk management by providing medical and security assistance.;
International SOS may collect or you may provide to International SOS, medical data to provide medical assistance, managing medical and
health assessment reports, create an emergency medical record, data about your travel plans to enable International SOS to provide you
with security assistance and travel information and support. We may also gather your personal data to assist us in managing services or
products provided to you or your employer.
The personal information collected from the App enables International SOS to provide better and more relevant services.
Location information collected by the App is used to provide the best assistance centre number for you to call as well as to provide medical
and security alerts and other information relevant to your location. If you opt in to Location Check-in (where available), location information
may also be collected and used to help locate you in emergency situations or where your life or safety may be jeopardized. The usage information
is used to help International SOS better understand how you make use of the App, in order to make improvements to it.
Your personal data may be transferred to companies within the International SOS group or to service providers that are performing services for
International SOS or acting as International SOS's agents. International SOS will require that any such service providers agree to keep
your personal data secure and confidential, use it only for the purposes for which the personal data is transferred and use it
only in accordance with International SOS's directions.
With your consent and in compliance with relevant personal data protection and privacy laws, for similar purposes as those outlined above,
your personal data may also be transferred to: your employer; or your relative's employer; or the insurance company; or private medical insurer;
or credit card company or other financial institution; or the association or other institution or company that purchased the
International SOS services or products on your behalf or under which you receive the benefit of such services or products.
Your personal data may be transferred to Government authorities, agencies and institutions as required or permitted by applicable laws
International SOS shall not collect, use, disclose or transfer your personal data except as described in this Statement unless you
give us your permission to collect, use, disclose or transfer it for other purposes.
7. Data Protection for Children
International SOS does not knowingly collect any information on persons who have not attained the age of 18 years through the online services
and the International SOS website.
8. What Choices are Available to Users Regarding Collection, Use, Storage, Disclosure or Transfer of the Personal Data?
You are given the opportunity to choose or ,opt-in, to have sensitive personal data (such as medical data) collected, used, stored, disclosed
or transferred for purposes of providing services and products at the point where we ask you for the sensitive personal data.
The collection of personal data through our online service for the emergency medical records will include an 'opt-in' mechanism for you
to give us your consent to use and disclose your personal medical data to enable us to provide you with medical care and related services.
We may, by way of example, transfer your medical data to other companies in the International SOS group, service providers that provide
medical services, travel services or to local clinics or physicians who we arrange to treat you or provide you with a health assessment.
We may also transfer personal data to local authorities if necessary or desirable to assist in arranging emergency medical care for you.
You may also 'opt-out' of receiving our services and products.
You may opt-out of email alerts for instance by replying to the email or clicking the "unsubscribe" link.
We may collect your personal medical data from you or from other sources with your permission. We may disclose that data to other companies in
the International SOS group of companies and to service providers that provide security, travel and medical services, in order to manage
the services and products that we provide.;
You will also be given the choice to prohibit International SOS from disclosing your personal data to a third party or for purposes
other than to provide services and products.
If you are receiving services as an employee or as a member of an employee's family, or as a member of an association or institution,
as a credit card holder or the recipient of other financial services, the company, association or institution that has contracted for
our services and products on your behalf will determine the method and means by which you can opt-out and opt-in.
Note that if you choose to ,opt-out,, withhold, block or request that we delete your personal data, you may not be able to receive
the benefit of International SOS's services and products.
9. How Can Users Correct Inaccuracies in their Personal Data?
You can review the personal data that International SOS has collected from you by contacting our: assistance centre; customer service personnel;
clinic; medical service facility; or sales person; or by using your password to access your records through our website.
In order to update, delete, amend or block any personal information that we create and that we are able to change, contact us using
the following e-mail address: [firstname.lastname@example.org] or through the contact link on our website. Should you need our assistance to access
or make changes to your personal information, please submit your request to us. Corrections or deletions of data resulting solely from errors
by International SOS or our service providers shall be paid for by International SOS.
If you do not wish to contact International SOS through our website, you may contact our Data Protection Officers who are also our
Country General Managers, responsible for the country in which you are residing or receiving products or services. You can contact our
Data Protection Officers by clicking here.
In making your request to review, update, amend or block data, you will be required to provide International SOS with details of the data requested
and the reasons why the data needs correction. International SOS will ask for proof of your identity. International SOS may ask you to assist
in verifying the accuracy of the updates and the amendments to the personal data.
International SOS may ask you to cover the reasonable cost of accessing and providing copies of your personal data if this is not provided through
the International SOS website.
International SOS will strive to address your request as soon as practicable and no later than thirty (30) calendar days from the date
your request is received and understood.
If International SOS is asked to destroy the personal data, International SOS shall use means that prevents its recreation and
International SOS shall take reasonable care to ensure that there is no unauthorised disclosure during the destruction of the data.
10. What Kind of Security Procedures are Used to Protect the Loss, Misuse, or Alteration of Your Personal Data under
International SOS's Control?
International SOS takes precautions to protect its users, information. International SOS has implemented policies that forbid its employees
from using or disclosing personal data in an inappropriate or unlawful manner and maintains security measures to safeguard the personal data
that it maintains from unauthorized access, misuse, alteration, loss or destruction.
Information Collected by Electronic Means
When you provide International SOS with personal data through online forms and other electronic methods, the data is protected using
The Information Security Policy and the Information Security Procedures and Processes
All International SOS employees are required to follow the Information Security Policy. The policy is implemented through the
Information Security procedures and processes. These are periodically reviewed and updated, as the information security landscape
is in a constant state of flux. All new employees are required to sign a written confirmation that they have read and understood
the Information Security Policy and a confidentiality agreement. Employees also have confidentiality obligations in their contracts
of employment with International SOS.
Security of Premises and Other Physical Security Measures
Physical access to all International SOS offices, assistance centres, clinics, medical services sites and other facilities are
security controlled which include locks that are opened by keys and by using security cards and security card readers that record
the identity of employees and visitors entering or leaving the facilities. Registers of visitors are kept and sign-in sheets are used
in locations that require additional security. All employees are given unique ID photo badges which they are required to wear and
clearly display at all times in International SOS facilities.
Information systems containing sensitive information and communications equipment are placed in secure areas and protected by
additional physical security measures that permit access only to the employees who need access, operational processes, environmental controls
and fire detection and suppression systems to safeguard against accidental loss, theft or unauthorized removal, misuse, damage or
Laptops are required to be secured with cables and combination locks.
Security against unauthorised electronic access and viruses
- All gateways to the internet are protected by a firewall and access to both internal and external networks are restricted and controlled.;
- IDS is deployed at key sites.;
- All servers are hardened based on security hardening standards to protect against network threats.;
- Endpoint security is constantly being review to protect the network against unauthorized access, data loss or destruction.;
- Access to computer services and information is on a 'roles and responsibility' basis and is restricted and controlled based on
the business requirements to reduce the risks associated with misuse, such as alteration, destruction and unauthorised dissemination of data.;
- Access to information services is through a secure login process with a unique identifier.;
- Access to and release of voice recordings is subject to review and approval by 3 management levels;
- User access to our main case management system and essential network services are controlled using a user rights management system that utilises
employees' roles in assigning user access rights, especially to the case management system.
- All remote-s access is given on a needs basis and is via a two-factor authentication mechanism.;
- Key personnel laptops have full disk encryption software. The software is configured with a system lock-out feature enabled after
a certain number of incorrect password entries.;
- Mobile devices have password policy controls and remote device hardware reset features enabled to protect against lost or stolen devices.;
- Changes to production systems and network follow a change management process flow to ensure that changes are owner authorized,
assessed for risk and operational impacts, before being approved by the change management board.;
-The security of information assets, including those entrusted to International SOS by third parties, are audited and reviewed
for compliance against company policies and legal requirements. The information security team conducts regular site-level
information security audits.;
- Critical servers are scanned using network and system vulnerability scanners. Web applications are also scanned by automated penetration tools
for application level security vulnerabilities that may be susceptible to hacking.
- External vulnerability scanning on our internet facing sites is performed monthly to ensure that these sites are secure.
These are done via in-house vulnerability scanning tools and third party services.
- Penetration tests are also performed on our key internet applications prior to production or major upgrades.
- International SOS engages external consultants to conduct security review of our environment. These reviews help us to understand the security gaps and ensure that our infrastructure and applications are able to meet and mitigate new network and Internet security threats and risks.
11. How do I Resolve Disputes with International SOS Relating to Personal Data?
If you are unsatisfied with the manner in which your question or concern was addressed, in respect of our online services,
you may contact International SOS at email@example.com.
International SOS Online is a licensee of the TRUSTe Privacy Program. TRUSTe is an independent organization whose mission is to build
users' trust and confidence in the internet by promoting the use of fair information practices. If you do not receive acknowledgment
of your inquiry or your inquiry has not been satisfactorily addressed, you should contact TRUSTe at:;
TRUSTe will serve as a liaison with Intl.SOS to resolve your concerns.
If you do not wish to make a complaint through our online services, you may direct all enquiries, concerns or complaints regarding the collection,
use, storage, correction, deletion, blocking, disclosure or transfer of personal data to the Data Protection Administrator who is also
the International SOS Country General Manager, in the country in which you reside or are receiving services using the contact details
attached to this statement.
If you do not receive a satisfactory response from the Data Protection Administrator you may contact the International SOS
Chief Data Protection Officer, who is also the General Counsel of International SOS using the contact details attached to this statement.
The Chief Data Protection Officer has overall responsibility at International SOS for protecting personal data.
International SOS will investigate all concerns and complaints and will address them expeditiously. An acknowledgement of the identity
of the employee addressing the complaint and the approximate length of time that will be taken to review the complaint will be provided
no later than five (5) business days from the date the complaint is received and understood. Regular updates shall be given to you
on the progress of the review if the review is likely to take longer than seven (7) business days
You have the right at anytime, to raise your issues with a data protection authority or to take your case to a court.
If you receive services from International SOS through an employer or through a relative's employer or through an association or institution,
or an insurance or financial services program and your personal information has been improperly collected, used, stored, disclosed, amended,
destroyed, blocked or transferred as a result of the actions or inactions of the employer, association or institution, insurance company
or financial services company, then you will be directed by International SOS to such employer, association or institution, insurance company
or financial services company. International SOS will not be liable for resolving disputes between you and such companies, associations
12. U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework
International SOS Assistance complies with 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. International SOS Assistance 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
International SOS Assistance’s certification, please visit http://www.export.gov/safeharbor/
13. Changes to this Statement
International SOS reserves the right to change this policy at any time by notifying users through its website of the existence
of a new privacy statement. This statement and the policies outlined herein are not intended to and do not create any contractual
or other legal rights.
Updated: August 2013