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PeopleDoc Sub-Processors

PeopleDoc's Sub-Processors

 

Last Updated: October 2018

 

PeopleDoc uses certain sub-processors, sub-contractors and content delivery networks to assist it in providing the PeopleDoc Services.

 

What is a sub-processor:

A sub-contractor who is processing PeopleDoc's Customers Personal Data for a specific purpose is defined as sub-processor. A sub-processor is a third-party data processor engaged by PeopleDoc, who has or potentially will have access to or process Personal Data of PeopleDoc's Customers. PeopleDoc engages different types of sub-processors to perform various functions as explained on the documents below. PeopleDoc refers to third parties that do not have access to or process Personal Data but who are otherwise used to provide the Services as “sub-contractors” and not sub-processors.

 

PeopleDoc undertakes to use a commercially reasonable selection process by which it evaluates the security, privacy and confidentiality practices of proposed sub-processors that will or may have access to or process PeopleDoc's Customers Personal Data.

 

Contractual Safeguards:

PeopleDoc requires its sub-processors to satisfy the obligations of a sub-processor set forth in PeopleDoc’s Data Processing Agreement (the “DPA”), including but not limited to requirements to:

 

  • process Personal Data based on data controller’s (i.e. PeopleDoc's Customers) instructions;
  • use personnel who are properly background checked, bound to non-disclosure and confidentiality obligations and otherwise contractually binding obligation to observe data privacy and security, to the extent applicable, pursuant to applicable data protection laws;
  • regularly train individuals to whom they grant access to Personal Data in security and data protection;
  • implement and maintain appropriate technical and organizational measures;
  • promptly inform PeopleDoc about any actual or potential security breach; and
  • cooperate with PeopleDoc in order to deal with requests from data controllers, data subjects or data protection authorities, as applicable.

 

PeopleDoc makes available to Customer the current lists of Sub-processors for the Services. Such Sub-processors lists shall include the identities of those Sub-processors and their country of location. Customer may subscribe from this page, and if Customer subscribes, PeopleDoc will provide notification of a new Sub-processor(s) before authorizing any new Sub-processor(s) to Process Personal Data in connection with the provision of the applicable Services.

 

Process to engage new sub-processors and Customer's Right to object:

Customer may object to PeopleDoc’s use of a new Sub-processor by notifying PeopleDoc promptly in writing (including via email) within ten (10) business days after receipt of PeopleDoc’s notice in accordance with the mechanism set out above.


In the event Customer objects to a new Sub-processor, as described above, PeopleDoc will use reasonable efforts to make available to Customer a change in the Services or recommend a commercially reasonable change to Customer’s configuration or use of the Services to avoid Processing of Personal Data by the objected-to new Sub-processor without unreasonably burdening the Customer.

If PeopleDoc is unable to make available such change within a reasonable period of time, which shall not exceed thirty (30) days, Customer may terminate the applicable Contract or Order Form(s) with respect only to those Services which cannot be provided by PeopleDoc without the use of the objected-to new Sub-processor by providing written notice to PeopleDoc, with return receipt requested.

In the event that Customer elects to terminate the Contract or Order Form(s) in accordance with this policy, PeopleDoc will refund Customer any prepaid fees covering the remainder of the term of such Agreement or Order Form(s) following the effective date of termination with respect to such terminated Services, without imposing a penalty for such termination on Customer. PeopleDoc will not be deemed to be in breach of its obligations under the Contract or any applicable Order Form(s).

 

The following are an up-to-date lists of the names and locations of PeopleDoc's sub-processors and content delivery networks:

 

EU Platform - English Version

 

EU Platform - French Version

 

US Platform

 

Our Privacy Team is available at privacy@people-doc.com for further information.

 


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