Business Travel and Immigration Post-Brexit
Ensure your business and workforce are compliant with the new immigration regulations effective 1 January.
- The Information that we Collect
- How the Information we Collect is Used
- CIBT and Newland Chase’s EU GDPR Compliance Statements
- How We Collect Information
- How CIBT and Newland Chase Protects Your Information
- How to Opt out of Further Communication
- How to Contact CIBT and Newland Chase
- Links to Other Websites
- CIBT and Newland Chase’s stance on Collecting Personal Information from Children
In some instances we are engaged directly by corporations or business groups, which results in the processing of employee information at their request. Where we refer to “employer” below, it is in these circumstances where corporations or other business groups have engaged us to act. You may at any time, if you prefer, address any concerns directly to your employer, where applicable.
The Information We Collect
By using our websites and/or our services we may collect and request information from you and/or your employer which includes your name, address, telephone number, date of birth, marital status, passport number, employment history, educational background, tax status, employee number, job title and function, expatriate status, e-mail address and payment and transaction information for billing purposes. Where required for the service, we collect certain personal documents such as passport copies, educational documents, CVs, visa copies, birth certificates, and other documents.
If CIBT and Newland Chase are handling your visa or immigration matter, additional information may be requested by the application forms of the destination country. These additional items can include items such as your personal and family information, educational background, employment history, travel history, and financial records. As required by relevant visa or governmental authorities such additional sensitive information can include ethnicity, race, religion, trade union membership, health related information, biometrics and information about criminal history.
Other information we collect may include marketing information and web interaction information such as:
- Data from marketing opt-in lists, consumer surveys, or publicly available information.
- Unique IDs such as a cookie placed on a computer, mobile or device IDs.
- Internet Protocol address (“IP address”)
- Information about a device such as information contained in HTTP headers or other internet transfer protocol signals, browser or device type and version, operating system, user-agent strings and information about or from the presence or use of “apps” on mobile devices.
- The web search term(s) a consumer used to locate and navigate to a website.
In many instances such as visa extensions, permanent residency, and other cases related to changes in employment, the services we provide require follow-up services. If such follow-up is required, the information we have collected previously is used to provide the additional related services for which we have been engaged.
How Information Is Used
CIBT and Newland Chase may share the personal information with third parties for the following purposes:
- To complete your visa, document legalization, or immigration process request as necessary to provide visa and immigration services to you and your family, including disclosure to government agencies in the form of applications, photographs, and petitions for visa requests and/or immigration benefits. This may include providing sensitive data required for immigration process request to Visa Application Centers, Logistics Companies, Invitation Providers and/or Translators/Solicitors.
- Share data with companies that provide services to assist us with our business activities in visa and immigration request fulfillment.
- To improve our products and services, provide superior customer service, and identify market opportunities
- As required by law in response to requests by public authorities including meeting national security or law enforcement requirements
CIBT and Newland Chase may also use the information to communicate with you directly via survey, e-mail or direct mail, such as to inform you about newsworthy topics and upcoming events that may be of interest to you, or to confer with you regarding your visa or passport request, or immigration case. We may also use your email address to send you reminders of expiring visas, passports, or immigration status. If you would like to discontinue receiving this information see the How to Opt-out of Further Communication section below.
Privacy Statement for California Residents
This Privacy Statement uses certain terms that have the meanings given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”). Consumers with disabilities may access this Statement in an alternative format by sending an email to email@example.com.
Notice of Collection and Use of Personal Information
We may collect and use the following categories of personal information about you as described below.
- Personal Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. We may obtain this information from (1) you, when you use our website and social media platforms or otherwise communicate with us; (2) publicly available databases; (3) joint marketing partners and event sponsors, when they share the information with us; and (4) referral sources. We may share this information with vendors who provide services on our behalf, such as to provide our products and services to you and manage our relationship with you.
- Information necessary to provide our products and services to you such as order information and payment, credit and transaction information for billing purposes. We may obtain this information from you and share it with vendors who provide services on our behalf, such as to provide our products and services to you and manage our relationship with you.
- Commercial information including products or services purchased, obtained or considered; and other purchase histories or tendencies. We may obtain this information from you and share it with vendors who provide services on our behalf, such as to provide our products and services to you and manage our relationship with you.
- Internet and other electronic network and app activity information such as browsing history, search history, and information regarding your interaction with an internet website, application or advertisement. We may obtain this information from you and through the use of website or app cookies and web beacons. We may obtain this information from you and share it with vendors who provide services on our behalf, such as to provide our products and services to you and manage our relationship with you.
- Geolocation information. We may obtain this information from you and your devices through various location technologies (such as GPS) and share this information with vendors who provide services on our behalf, such as to provide products and services to you based on your geographic location.
- Professional, employment-related, and educational information. We may obtain this information from you, employment recruiters and referral sources when you apply for a job with us or become employed by us. We may use and share this information with vendors who provide services on our behalf, such as to manage our human resources activities or perform background checks.
- Inferences drawn from any of the categories of personal information listed above to create a profile about you regarding your preferences, characteristics, psychological trends, predispositions, behavior attitudes, intelligence, abilities and aptitudes. We may develop these inferences internally or obtain this information from vendors who provide services on our behalf, such as to us with our business.
Categories of Personal Information
|Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services.||Personal identifiers; Information necessary to provide our products and services to you; Commercial information; Internet and other electronic network and app activity information; Geolocation information; Professional, employment-related, and educational information, and Inferences.|
|Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance.||Personal identifiers; Information necessary to provide our products and services to you; Commercial information; Internet and other electronic network and app activity information; Geolocation information; Professional, employment-related, and educational information, and Inferences.|
|Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction.||Personal identifiers; Information necessary to provide our products and services to you; Commercial information; Internet and other electronic network and app activity information; Geolocation information; Professional, employment-related, and educational information; and Inferences.|
|Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.||Personal identifiers; Information necessary to provide our products and services to you; Commercial information; Internet and other electronic network and app activity information; Geolocation information; Professional, employment-related, and educational information; and Inferences.|
|Debugging to identify and repair errors that impair existing intended functionality.||Personal identifiers Internet and other electronic network and app activity information; Geolocation information.|
|Undertaking internal research for technological development and demonstration.||Personal identifiers; Information necessary to provide our products and services to you; Commercial information; Internet and other electronic network and app activity information; Geolocation information; Professional, employment-related, and educational information; and Inferences.|
|Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.||Personal contact information; Information necessary to provide our products and services to you; Internet and other electronic network and app activity information; Professional, employment-related, and educational information; Inferences.|
Our Prior Collection, Use and Disclosure of Personal Information
We may have collected and used your personal information, as described in the section above, during the 12-month period prior to the date of this Privacy Statement. For each category of personal information collected during the 12-month period prior to the effective date of this Statement, we also describe above the (1) categories of sources from which we may have obtained the personal information, and (2) categories of third parties with whom we may have shared the information.
During the prior 12-month period, we may have disclosed to third parties for a business purpose each of the categories of personal information listed above.
California Consumer Privacy Rights
You have certain choices regarding your personal information, as described below.
- Access: You may have the right to request, twice in a 12-month period, the personal information we have collected, used, and disclosed within the preceding 12 months.
- Deletion: You may have the right to request that we delete the personal information we have collected from you.
To submit an access or deletion request, please do so by (i) emailing firstname.lastname@example.org or (ii) call us at: 1-800-929-2428.
To help protect your privacy and maintain the security of your personal information, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you request access to your personal information, we may require you to provide any of the following information: contact information, one-time password, information about your interactions with us or information that you have submitted. In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.
If you designate an authorized agent to make a request, we will require your authorized agent to provide us with either (1) your power of attorney authorizing the authorized agent to act on your behalf or (2) your written authorization permitting the authorized agent to request access to your personal information on your behalf. If your authorized agent provides us your written authorization, we also will require you to verify your own identity directly with us.
In connection with your request, you must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized agent.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.
Children’s Personal Information
We do not sell personal information of minors under the age of 16 without affirmative authorization if we have actual knowledge of the individual’s age.
Privacy Rights under California Civil Code Section 1798.83 (“Shine the Light”)
Individual California Users (as defined below) may request information about our disclosures of certain categories of personal information to third parties (i.e., our affiliates) for such third parties’ direct marketing purposes.
As noted above, we may disclose personal Information to affiliates of CIBT and Newland Chase, which may use this information for all purposes outlined in this Privacy Statement. Because separate legal entities are considered “third parties” for purposes of California Civil Code Section 1798.83, and certain communications from our affiliates might be viewed as promoting their services, we are providing the following information for California residents who have provided us with their personal information during the creation of or during the course of an established legal services relationship that is primarily for personal, family, or household purposes (“Individual California Users”).
Individual California Users must submit their requests to us either by email at email@example.com or by mail at the following address:
ATTN: Data Privacy Officer
1600 International Drive
McLean, VA 22102
If you have questions regarding this Privacy Statements, please contact us at:
ATTN: Data Privacy Officer
1600 International Drive
McLean, VA 22102
Email address: firstname.lastname@example.org
Phone number: 800-929-2428
Privacy rights for Nevada residents and users
You have the right to direct us not to sell certain personally identifiable information that we collect about you on our Websites or other online services by emailing us at email@example.com. This information includes: your first name or first initial and last name in combination with your social security number; driver’s license number, driver authorization card number or identification card number; account number, credit card number or debit card number, in combination with any required security code, access code or password that would permit access to your financial account; medical identification number or a health insurance identification number; user name, unique identifier or electronic mail address in combination with a password, access code or security question and answer that would permit access to an online account.
Additionally, you may review and request that we change the personally identifiable information that we collect about you on our websites or other online services by emailing us at firstname.lastname@example.org.
Our service providers and other third parties may collect personally identifiable information about your online activities over time and across different internet websites or online services when you use our Websites or online services.
Please note, however, that we do not sell your personally identifiable information for monetary consideration.
EU Global Data Protection Regulation (GDPR) Compliance statements
Lawful Basis for Collecting Personal Information: CIBT and Newland Chase collect and process personal information in order to fulfill your visa, passport, document legalization, or immigration process request and our contract with you. This information is collected and processed in accordance with local laws including GDPR regulations in the European Union and Switzerland. For those individuals to whom the GDPR applies, general personal information is collected and processed on the basis of the contract formed or to be formed between us but the additional sensitive personal information is collected and processed under the lawful basis of consent. By placing the order and giving your consent, you are giving CIBT and Newland Chase the following rights:
- The right to collect your personal information
- The right to process your personal information
- The right to share your personal information with third party providers and government entities as needed, such as Government Authorities, Visa Application Centers, Logistics Companies, Invitation Providers and/or Translators/Solicitors relevant to your request for services.
You maintain the right to revoke consent at any time.
The Right to Have Your Personal Information Erased: At any time, you have the right to request that CIBT and Newland Chase erase the personal information you have provided to us. CIBT and Newland Chase will erase any data as long as it is legally allowed to according the laws and regulations in the countries in which we operate. You may make this request by emailing email@example.com. The following will then occur:
- CIBT and Newland Chase will acknowledge your request.
- CIBT and Newland Chase will review your specific request and the country of its origin, and determine if we are lawfully allowed to oblige the request.
- CIBT and Newland Chase will then either:
- inform you that your data has been removed from our systems or
- inform you as to the date that CIBT and Newland Chase are legally allowed to remove said data from our systems given the nature of said data and the country of its origin.
The Right to Access Your Personal Information: At any time, you have the right to access your personal information held by CIBT. To make a request for access to your data, a personal appearance is required at a CIBT and Newland Chase location with a government issued ID. After validating the identity of the requestor, CIBT and Newland Chase will provide your personal information in accordance with our policies.
International Transfer of Your Personal Information: Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers. By using our Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.
Some of the non-European Economic Area countries are recognized by the European Commission, the UK and Switzerland as providing an adequate level of data protection according to EEA, the UK or Swiss standards (the full list of these countries is available here). For transfers from the EEA, the UK or Switzerland to countries not considered adequate by the European Commission, the UK or Switzerland, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission or contracts approved by the Swiss Commissioner, to protect your Personal Information.
For data transfers from the EEA, UK or Switzerland to the U.S., CIBT and Newland Chase have put in place adequate measures, such as standard contractual clauses adopted by the European Commission or contracts approved by the Swiss Commissioner, to protect your Personal Information.
Complaint to Supervisory Authority: If you consider that we have breached your rights under GDPR you may complain to the data protection authority in the country in which you reside or to the lead supervisory authority at https://ico.org.uk/concerns/ or by phone at +44 303 123 1113. A listing of the EU Data Protection Authorities (DPAs) is located at: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm. Individuals in Switzerland should contact the Swiss Federal Data Protection and Information Commissioner (the Swiss Commissioner) for resolution. Information regarding the Swiss Commissioner is located at: https://www.edoeb.admin.ch/?lang=en.
Information we share and transfer
We may share some of your personal information with other CIBT and Newland Chase offices to provide you with information that will be relevant to your interests and to connect you with advisors who may be useful to you. For these purposes, your personal information may be processed in, or accessed from, CIBT or Newland Chase offices situated in jurisdictions that do not have equivalent data protection laws to those in your country of residence.
We safeguard your data within the CIBT and Newland Chase group of companies through the use of European Commission-approved standard contractual data protection clauses.
Personal information will be shared with companies providing services under contract to us for the purposes described in this Privacy Notice that may be located in a different country than you. When transferring your personal information, we rely on European Commission-approved standard contractual data protection clauses with service providers or approved binding corporate rules that protect your information.
If you have any questions about our information handling practices or if you wish to access your personal information you should contact our Data Privacy Office at: firstname.lastname@example.org
You may have other rights within the EU, UK, as well as other locations
You have the right to ask us for a copy of your personal information; to correct, delete or restrict processing of your personal information; and to obtain the personal information you provide in a structured, machine readable format. In addition, you can object to the processing of your personal information in some circumstances (in particular, where we do not have to process the data to meet a contractual or other legal requirement). Where we have asked for your consent, you may withdraw consent at any time.
These rights may be limited, for example, if fulfilling your request would reveal personal information about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep. If you have unresolved concerns, you have the right to complain to a data protection authority where you reside, where you work or where you believe there has been an infringement of data protection laws.
We will retain your personal information only for as long as we need it for the purposes described in this Privacy Notice, after which we will take steps to delete your personal information or hold it in a form that no longer identifies you.
How We Collect Information
We may collect information from you in the following ways:
- By Asking: We may collect personal information from you by asking that you provide it to us. CIBT and Newland Chase will only collect information that is needed to help us provide the service you request
- Web Beacons: A web beacon is an electronic file on a web page that allows us to count and recognize users who have visited that page. Among other things, a web beacon can be used in HTML-formatted email to determine responses to our communications and measure their effectiveness. For instance, if you get an email from us and click on a link in that email to go to the Website. You can generally avoid web beacons in email by turning off HTML display and displaying only the text portion of your email.
- Web Server Logs: Web server logs are records of activity created by the computer that delivers the webpages you request to your browser. For example, a web server log may record the search term you entered or the link you clicked to bring you the webpage. The web server log also may record information about your browser, such as your IP address and the cookies set on your web browser by the server.
Protecting Your Information
Protecting personal information we receive from you is of crucial importance to CIBT and Newland Chase. While there is always some risk involved with transmitting information over the internet, we strive to protect against the misuse of any personal information that we receive from you via our website. CIBT and Newland Chase data is protected by Industry endorsed Transport Layer Security (TLS) technology. TLS is the most widely deployed security protocol used today, and is used for Web browsers and other applications that require data to be securely exchanged over a network. This technology ensures the safe transmission of all data, including personal and credit card information. By taking such measures, CIBT and Newland Chase customers can feel secure in the knowledge that their data is protected when using our website.
Deleting Your Information
We will retain and use your information only for as long as is necessary to comply with our legal obligations, government auditing requirements, resolve disputes, and enforce our agreements (including those agreed with our clients). At the end of such period, we may, at our discretion, destroy such personal data without notice to you.
How to Opt-Out of Further Communication
We provide users the opportunity to opt-out of receiving further communications from us at their request. To opt-out of further communications contact us by email at email@example.com.
How to Contact CIBT and Newland Chase
Links to Other Websites
Personal Information from Children
We do not knowingly collect personal information from individuals under 18 years of age. As a parent or legal guardian, please do not to allow your children to submit personal information without your permission.
While every effort is made to provide accurate information, travel visa and passport requirements are constantly changing and there may be a delay before we are advised of such changes. Therefore, we are unable to guarantee complete accuracy at all times. Processing times and charges given are solely for guidance purposes and cannot be guaranteed. Where ‘no’ travel visa is indicated, we recommend this information be confirmed by the carrier and the relevant embassy or consulate. CIBT and Newland Chase recommend that travel visas be obtained before travel. Where information for travel visas upon arrival are given, we always recommend confirmation of this information with the airline and embassy or high commission prior to travel. Travel arrangements should not be confirmed prior to the visa or passport being issued, unless they are a specifically required for that consulate. In such cases, refundable arrangements should be made.
Effective Date: February 19, 2021