Privacy Shield Policy

Commonly asked questions about Forms On Fire®'s international transfers of personal data following the invalidation of Privacy Shield on 16 July 2020.

Forms On Fire is monitoring developments regarding the invalidation of Privacy Shield by the European Court of Justice (ECJ) and continues to make all necessary assessments regarding safeguards for international data transfers.

In compliance with the Privacy Shield Principles, Forms On Fire® commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Forms On Fire® at: 

Security Chief

Forms On Fire, Inc.

10900 NE 4th Street

Suite 2300

Bellevue, WA 98004

security@formsonfire.com

+1 425.214.1920

Forms On Fire® has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU and Switzerland in the context of the employment relationship.

Our clients can remain assured that they can continue to use Forms On Fire® in compliance with European Law. Although Privacy Shield certified, Forms On Fire did not exclusively rely on Privacy Shield for the transfer of personal data from Europe to the US. Forms On Fire Standard Contractual Clauses (which the ECJ confirmed remain valid) in our client contracts, including our Terms of Service. Forms On Fire products, services and operational procedures are designed to incorporate data protection safeguards throughout the entire product lifecycle and system architecture. For these reasons, the invalidation of Privacy Shield does not have any impact on our day to day operations or to data transfers to our international sub-processing entities.

Clients can continue to use Forms On Fire in confidence that they are compliant with European law, including in respect of the high standard of protection the General Data Protection Regulation guarantees.

Do Forms On Fire's template client contracts need to be updated?

No. As detailed above Forms On Fire uses the Standard Contractual Clauses to govern our transfer of personal data to the United States, so no updates are required in that regard: however, we will be updating our public and customer facing documents to remove references to the now invalidated Privacy Shield going forward.

Do we need to remove the sections of our existing contract that refer to Privacy Shield?

No, Forms On Fire does not exclusively rely on Privacy Shield for the international transfer of personal data, and our commitment to adhering to the Standard Contractual Clauses is already built into our approach and system architecture.

Do we need to update our contract to include the Standard Contractual Clauses?

No, as stated above Forms On Fire has incorporated the Standard Contractual Clauses into our data transfer mechanisms and this has been reflected in our agreements as standard. Forms On Fire also continues to make all necessary assessments regarding safeguards for international data transfers (and will be assessing any updated Standard Contractual Clauses should the EU Commission make such available).

How does Forms On Fire handle potential access to customer data from third parties or governments?

Forms On Fire is committed to the security and privacy of the data our clients store in our enterprise cloud services. Forms On Fire believes that our clients should control their data. When government, law enforcement or other third-parties make a lawful request for client data from Forms On Fire, it is our practice to redirect such requests to the client where practical and legally permitted. If we are not able to redirect to the client, Forms On Fire will limit such disclosure to the data specified in the request. We will also notify our clients of any government, law enforcement or third-party request for client data to the extent legally permitted.

How is Forms On Fire approaching assessing certain countries in respect of whether such countries offer adequate data protection?

Forms On Fire monitors developments in each applicable country in which it processes data.

How does Forms On Fire store and process client data?

Forms On Fire does not process client data except where necessary, such as for the purposes of providing technical support, and always strictly in accordance with our agreements with clients.

Please contact us at support@formsonfire.com if you require any additional information.